1 min readWarningEBA reporting framework 4.2Updated 10 November 2026

If total remuneration of identified staff benefitting from the above derogation is reported, fixed remuneration must be reported (row 0190, EBA rule v12656_m)

A warning in the remuneration benchmarking, credit institutions return (REM benchmarking), on template R 05.00, derogations from the application of requirements to pay out parts of variable remuneration deferred and in instruments under Directive 2013/36/EU (CRD).

The rule in plain words

If total remuneration of identified staff benefitting from the above derogation is reported, fixed remuneration must be reported.

EBA checks it for two columns: derogations on a firm wide basis under Article 94(3)(a) of the CRD and derogations for identified staff under Article 94(3)(b) of the CRD. That makes two 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.

Derogations on a firm wide basis under Art. 94(3)(a) CRD: If Total remuneration of identified staff benefitting from the above derogation is reported, then Of which: fixed remuneration is reported

What to do if your filing fails it

  1. 01Open the template below and find the cells the rule reads.
  2. 02The check applies only when its first part holds in your file. When it does, the second part must hold too: fix the second part, or correct the first.
  3. 03It runs only when your filing indicators mark R 05.00 as reported.
  4. 04This 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

Derogations from the application of requirements to pay out parts of variable remuneration deferred and in instruments under Directive 2013/36/EU (CRD) (R 05.00)

Rows

  • 0190Total remuneration of identified staff benefitting from the above derogation
  • 0210Of which: fixed remuneration

Columns

  • 0010Derogations on a firm wide basis under Art. 94(3)(a) CRD
  • 0020Derogations for identified staff under Art. 94(3)(b) CRD
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}.

if ((not(empty({R_05.00,r0190,c0010,})))) then ((not(empty({R_05.00,r0210,c0010,})))) else True

The next one:

if ((not(empty({R_05.00,r0190,c0020,})))) then ((not(empty({R_05.00,r0210,c0020,})))) else True

Every REM benchmarking rule, by template

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