Title II - Requirements regarding the format and frequency of the remuneration benchmarking exercise

Information to be collected and submission to the EBA dates

4.1. Competent authorities should collect the following financial year-end figures denominated in EUR from Institutions included in the exercise annually by 30 June:

• (a) the template provided in Annex 1 containing data regarding the remuneration of all staff;
• (b) the template provided in Annex 2 containing information on the remuneration of staff whose professional activities have a material impact on the institution’s risk profile³ (identified staff);
• (c) the template provided in Annex 3 containing information on identified staff remunerated EUR 1 million or more per financial year as referred to in Article 450(1)(i) of Regulation (EU) No 575/2013.

4.2. Competent authorities may collect additional data for their national benchmarking exercise. 4.3. Competent authorities should submit the data required for the EBA’s benchmarking exercise to the EBA by 31 August each year using the EBA remuneration benchmarking reporting system and following the specifications that the EBA provide for the use of this system.

³ See Regulation (EU) No 604/2014 (http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOL_2014_167_R_0003) based on the EBA’s draft Regulatory Technical Standards.

Reference year of data collected and currency conversion

5.1. Data should comprise fixed and variable remuneration awarded for performance during the performance year preceding the year of submission of the information.

5.2. Remuneration awarded based on multi-year accrual periods that do not revolve on an annual basis, i.e. where institutions do not start a new multi-year period every year, should be fully allocated to the financial year in which the remuneration was awarded, without consideration of the point in time when the variable remuneration is effectively paid. These amounts should be reported separately to allow a further analysis of fluctuations of the variable remuneration awarded and should not be deducted from the amount of variable remuneration reported.

5.3. The information to be provided on ex post adjustments, including clawback and malus , refers to the application of these arrangements for remuneration already awarded. These amounts should be reported separately⁴ and should not be deducted from the amount of variable remuneration reported.

5.4. Only the amounts of variable remuneration awarded in the performance year that have been deferred should be reported as deferred remuneration. Deferred variable remuneration for previous periods that has not vested yet should be reported separately⁵ .

5.5. Data should be submitted using accounting year-end figures in EUR. All amounts should be reported as full amounts, i.e. not rounded amounts, in euro (e.g. EUR 1 234 567 instead of EUR 1.2 million). Where remuneration is disclosed in a currency other than EUR, the exchange rate used by the Commission for financial programming and the budget for December of the reporting year should be used for the conversion of the consolidated figures to be reported⁶ .

5.6. Where numbers should be reported in terms of the headcount, the number of natural persons should be entered, independent of the number of working hours on which their contract is based. Where numbers should be reported in terms of the full-time equivalent, the number should be based on the percentage of time that a staff member is employed compared to a full-time contract (e.g. 0.5 would be reported for a staff member who is working half-time). 5.7. Staff should be classified under the function or business area where they carry out the predominant part of their business activities. The full amount of remuneration awarded to that staff member within the group or institution should be reported under this function or business area.

⁴ These amounts are reported under 'Total amount of explicit ex post performance adjustment applied in year N for previously awarded remuneration'. 5 These amounts are reported under 'Article 450(h)(iii) of Regulation (EU) No 575/2013; total amount of outstanding deferred variable remuneration awarded in previous periods and not in year N'. 6 The EBA provides a link to the information on its website together with these Guidelines; the exchange rate can also be accessed under http://ec.europa.eu/budget/contracts_grants/info_contracts/inforeuro/inforeuro_en.cfm.

Data quality

6.1. Competent authorities should check the completeness and plausibility of the data reported by each institution participating in the exercise.

6.2. To ensure the high quality of data, competent authorities should perform specific additional data quality checks where requested by the EBA.