Line4

2 min readWarningEBA reporting framework 4.2Updated 10 November 2026

An upper-limit check across special payments to staff whose professional activities have a material impact on institutions’ risk profile (identified staff) and remuneration awarded for the financial year (R 10.00, R 09.00, EBA rule v12576_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 10.00, special payments to staff whose professional activities have a material impact on institutions’ risk profile (identified staff).

Check your file against this ruleWhat to do if it fails

The rule in plain words

Add up these eight:

  • Guaranteed variable remuneration awards - number of identified staff, other identified staff
  • Guaranteed variable remuneration awards - number of identified staff, MB supervisory function
  • Guaranteed variable remuneration awards - number of identified staff, MB management function
  • Guaranteed variable remuneration awards - number of identified staff, other senior management
  • Severance payments awarded during the financial year - number of identified staff, other identified staff
  • Severance payments awarded during the financial year - number of identified staff, MB management function
  • Severance payments awarded during the financial year - number of identified staff, MB supervisory function
  • Severance payments awarded during the financial year - number of identified staff, other senior management

The result cannot be more than these four added up, all for number of identified staff:

  • Other identified staff
  • MB supervisory function
  • MB management function
  • Other senior management

The headline gives only the kind of check and the template, because some of its cells have no name of their own in EBA’s template.

How the Line4 Check report words itShow

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

R_10.00: Guaranteed variable remuneration awards - Number of identified staff, Other identified staff + R_10.00: Guaranteed variable remuneration awards - Number of identified staff, MB Supervisory function + R_10.00: Guaranteed variable remuneration awards - Number of identified staff, MB Management function + R_10.00: Guaranteed variable remuneration awards - Number of identified staff, Other senior management + R_10.00: Severance payments awarded during the financial year - Number of identified staff, Other identified staff + R_10.00: Severance payments awarded during the financial year - Number of identified staff, MB Management function + R_10.00: Severance payments awarded during the financial year - Number of identified staff, MB Supervisory function + R_10.00: Severance payments awarded during the financial year - Number of identified staff, Other senior management <= R_09.00: Number of identified staff, Other identified staff + R_09.00: Number of identified staff, MB Supervisory function + R_09.00: Number of identified staff, MB Management function + R_09.00: Number of identified staff, Other senior management

What to do if your filing fails it

  1. 01Open the templates below and find the cells the rule reads.
  2. 02Compare the values in your file. If the first is bigger than it may be, one of them is wrong: check both before you change either.
  3. 03EBA allows a small rounding difference, worked out from the decimals each value is reported with.
  4. 04It runs only when your filing indicators mark R 09.00 and R 10.00 as reported.
  5. 05This 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

  • 0080Number of identified staff

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0030Other senior management
  • 0040Other identified staff

Special payments to staff whose professional activities have a material impact on institutions’ risk profile (identified staff) (R 10.00)

Rows

  • 0010Guaranteed variable remuneration awards - Number of identified staff
  • 0060Severance payments awarded during the financial year - Number of identified staff

Columns

  • 0010MB Supervisory function
  • 0020MB Management function
  • 0030Other senior management
  • 0040Other identified staff
Show the rule as writtenShow

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

sum({R_10.00,r0010,c0040,},{R_10.00,r0010,c0010,},{R_10.00,r0010,c0020,},{R_10.00,r0010,c0030,}) + sum({R_10.00,r0060,c0040,},{R_10.00,r0060,c0020,},{R_10.00,r0060,c0010,},{R_10.00,r0060,c0030,}) <= sum({R_09.00,r0080,c0040,},{R_09.00,r0080,c0010,},{R_09.00,r0080,c0020,},{R_09.00,r0080,c0030,})

Every REM benchmarking rule, by template

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