1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Number of identified staff, other senior management must equal the sum of its six parts (EBA rule v12567_m)

A warning in the remuneration benchmarking, credit institutions return (REM benchmarking), on templates R 09.00, remuneration awarded for the financial year and R 12.00.b, information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (II).

The rule in plain words

Number of identified staff, other senior management must equal these six added up, all for other senior management:

  • Independent internal control functions
  • Retail banking
  • All other
  • Investment banking
  • Asset management
  • Corporate functions
How the Line4 Check report words itShow

Word for word as the report shows it when the rule fails.

R_09.00: Number of identified staff, Other senior management = R_12.00.B: Of which: other senior management, Independent internal control functions + R_12.00.B: Of which: other senior management, Retail banking + R_12.00.B: Of which: other senior management, All other + R_12.00.B: Of which: other senior management, Investment banking + R_12.00.B: Of which: other senior management, Asset management + R_12.00.B: Of which: other senior management, Corporate functions

What to do if your filing fails it

  1. 01Open the templates below and find the cells the rule reads.
  2. 02Add up the parts in your file and compare the result with the total.
  3. 03If they differ, a part is missing, a value sits in the wrong column, or the total is out of date.
  4. 04EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  5. 05It runs only when your filing indicators mark R 09.00 and R 12.00 as reported.
  6. 06This is a warning. It does not stop the filing on its own, but your authority may ask you to explain it.

The cells it reads

Remuneration awarded for the financial year (R 09.00)

Row

  • 0010Number of identified staff

Column

  • 0030Other senior management

Information on remuneration of staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (II) (R 12.00.b)

Row

  • 0030Of which: other senior management

Columns

  • 0040Investment banking
  • 0050Retail banking
  • 0060Asset management
  • 0070Corporate functions
  • 0080Independent internal control functions
  • 0090All other

A worked example

The first of its checks, with simple numbers.

Illustrative values
other senior management, independent internal control functions1,200
other senior management, retail banking800
other senior management, all other450
other senior management, investment banking300
other senior management, asset management150
other senior management, corporate functions100
Together3,000
What the rule then expects

Number of identified staff, other senior management must then be 3,000.

3,000Passes
3,100Fails

A file that reports 3,000 passes. One that reports 3,100 fails, by 100.

The numbers are illustrative, reported to the unit, so the rounding tolerance does not change the result.

Show the rule as writtenShow

EBA's formula. Cells are written as {template, row, column, sheet}.

{R_09.00,r0010,c0030,} = sum({R_12.00.b,r0030,c0080,},{R_12.00.b,r0030,c0050,},{R_12.00.b,r0030,c0090,},{R_12.00.b,r0030,c0040,},{R_12.00.b,r0030,c0060,},{R_12.00.b,r0030,c0070,})

Every REM benchmarking rule, by template

Checks like this one, run at the point of submission, are the first step to real-time supervision.