Question ID
2023_6872
Legal act
Directive 2013/36/EU (CRD)
Topic
Remuneration
Article
75
Paragraph
3
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
EBA/GL/2022/08 – Guidelines on the data collection exercises regarding high earners
Article/Paragraph
Point 18
Type of submitter
Competent authority
Subject matter
Data collection regarding high earners that are staff in investment firms subject to Article 25 and 34 of Directive (EU) 2019/2034 when the investment firms are part of a group subject to prudential consolidation.
Question

Point 18 of EBA/GL/2022/08 states:

“High-earners data should be submitted (…) by:

a. institutions referred to in Subsection 1.1, using the template for the data collection specified under:

i. Annex I for high earners that are staff of institutions and other entities in the scope of consolidation;

ii. Annex II for high earners that are staff in investment firms subject to Article 25 and 34 of Directive (EU) 2019/2034;”

We have found that there are several common data points defined between R 04.00 and R.04.01 (in particular columns 0010, 0020 and 0070 of R 04.01) in XBRL taxonomy version 3.2. which technically prevents the possibility to report according to point 18 of EBA/GL/2022/08.

For example, supposing an institution has one member of the MB Supervisory function (column 0010) reported in “Number of other staff” (row 0030) in an investment firm (point ii) and four members of the MB Supervisory function (column 0010) reported in “Number of other staff” (row 0030) in the parent institution (point i), it cannot report one person in R 04.01 and four people in R 04.00 due to the common data points between them.

Background on the question

We have found that there are several common data points defined between R 04.00 and R.04.01 (in particular columns 0010, 0020 and 0070 of R 04.01) in XBRL taxonomy version 3.2. which technically prevents the possibility to report according to point 18 of EBA/GL/2022/08.

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A. 

The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. The Q&A process cannot, for example, consider issues which would require changes to the regulatory framework.

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Status
Rejected question