2023_6900 Validation rule eba_v09286_m | European Banking Authority Skip to main content
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  3. 2023_6900 Validation rule eba_v09286_m
Question ID
2023_6900
Legal act
Directive 2013/36/EU (CRD)
Topic
Remuneration
Article
EBA VR Taxo v3.2, Validation rule v09286_m
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Not applicable
Article/Paragraph
Not applicable
Type of submitter
Credit institution
Subject matter
Validation rule eba_v09286_m
Question

Relating the data entered in the upper part of template R04, the purpose of the v09286_m control is to verify that the total variable remuneration of all high earners is less than or equal to twice the total fixed remuneration by country and by pay bracket. The equation of the control is {r0100} <= 2 * {r0060}.

However, the control does not take into account some points, including the following:
-    The variable remuneration of {r0100} may include amounts awarded to high earners that are not identified staff;
-    The severance payments included in the total variable remuneration of {r0100} amount may not be subject to the bonus cap mentioned above.

Indeed, it is specified in the R04 template that the amounts relating additional information requested in the lower part of the report ({r0181} to {r0270}) should also be included in the total variable remuneration or in the total fixed remuneration of the upper part of the same template ({r0100} and {r0060} respectively). In that respect, variable and fixed remuneration of high earners that are not identified staff from {r0260} and {r0270} are included in {r0100} and {r0060} respectively, and severance payments from {r0200} awarded to high earners who are identified or not identified staff are included in {r0100}.

As a consequence the equation {r0100} <= 2 * {r0060} may not be respected. Should the v09286_m control be disabled ?

Background on the question

Our question follows a question we received from our national competent authority.

Submission date
29/09/2023
Rejected publishing date
16/10/2023
Rationale for rejection

 

This question has been rejected because the matter it refers to has already been identified and will be considered for a forthcoming release of the respective validation rules.

Status
Rejected question

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