1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

Guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap cannot be more than guaranteed variable remuneration awards -total amount (EBA rule v12579_m)

A warning in the remuneration benchmarking, credit institutions return (REM benchmarking), on template R 10.00, special payments to staff whose professional activities have a material impact on institutions’ risk profile (identified staff).

The rule in plain words

Guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap cannot be more than guaranteed variable remuneration awards -total amount.

EBA checks it for four columns: MB supervisory function, MB management function, other senior management and other identified staff. That makes four checks. A failure names the one that failed.

How the Line4 Check report words itShow

The first of its checks, word for word as the report shows it when it fails. The others read the same, with their own column, row or sheet.

Other senior management: Of which guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap <= Guaranteed variable remuneration awards -Total amount

What to do if your filing fails it

  1. 01Open the template 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 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

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

Rows

  • 0020Guaranteed variable remuneration awards -Total amount
  • 0030Of which guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap

Columns

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

A worked example

The first of its checks, with simple numbers.

Illustrative values
guaranteed variable remuneration awards paid during the financial year, that are not taken into account in the bonus cap1,200
What the rule then expects

Guaranteed variable remuneration awards -total amount must then be at least 1,200.

1,200Passes
1,100Fails

A file that reports 1,200 passes. One that reports 1,100 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, as written out for the first of its checks. Cells are written as {template, row, column, sheet}.

{R_10.00,r0030,c0030,} <= {R_10.00,r0020,c0030,}

The next three:

{R_10.00,r0030,c0020,} <= {R_10.00,r0020,c0020,}{R_10.00,r0030,c0040,} <= {R_10.00,r0020,c0040,}{R_10.00,r0030,c0010,} <= {R_10.00,r0020,c0010,}

Every REM benchmarking rule, by template

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