4. General specifications for the submission of benchmarking data

When submitting benchmarking data in accordance with sections 2 and 3 and the Annexes of these Guidelines, institutions and competent authorities should apply the general specifications set out in this section, the additional specifications set out in sections 5 and 6 and the instructions set out in Annex VII.

Benchmarking data should be submitted using accounting year-end figures in EUR. Where remuneration is disclosed in a currency other than the EUR, the exchange rate used by the European Commission for financial programming and the budget for December of the reported year should be used for the conversion of the consolidated figures to be reported⁴ .

All amounts should be reported as full amounts, i.e. not rounded amounts, in EUR (e.g. EUR 1 234 567 should be reported, instead of EUR 1.2 million).

Benchmarking data for the calendar year in which the financial year ended should be submitted in the following calendar year. For example, with regard to the benchmarking exercise for the financial year ending on any date in the year ‘ 20 yy’ , data will be submitted in the year ‘ 20 yy+1’ .

The allocation of submitted amounts to the fixed and variable components of remuneration should be made in line with Section 7 of the EBA Guidelines on sound remuneration policies under Directive 2013/36/EU.