9. Data quality

Investment firms and competent authorities should check the completeness and plausibility of the benchmarking data reported, taking into account the specifications in Annex VI, before that data is reported to the competent authority and submitted to the EBA respectively.

Where there are strong fluctuations of benchmarking data over time, the investment firm and the competent authorities should be able to provide explanations.

Investment firms and competent authorities should ensure that the sum of sub-positions of the variable and fixed remuneration equals the total amounts.

When checking the plausibility of benchmarking data, competent authorities should take into account the size and number of employees of the investment firm and typical remuneration levels. Identified implausible data should be followed up and corrected before the submission of data.

Where benchmarking data appears to be implausible, but are in fact correct, competent authorities should inform the EBA of the underlying reasons.

Regarding submitted benchmarking data that shows potential data quality issues or is considered to be implausible, the EBA may ask competent authorities to review the data or to provide the information necessary for the correct interpretation of the data.

Competent authorities should provide as necessary corrected data or explanations for any implausible data as soon as possible. Competent authorities should closely cooperate with the EBA to ensure that the dataset for the analysis is stable and of good quality by at the latest 30 September of the year when data has been reported.

When submitting benchmarking data to the EBA in accordance with these Guidelines, competent authorities should ensure that they also comply with EBA/DC/335 of 5 June 2020 on EUCLID ( ‘ EUCLID Decision ’ )⁷ as amended and that they provide investment firms with any technical specification necessary for the submission of benchmarking data in line with that decision.

7 https://www.eba.europa.eu/sites/default/documents/files/document_library/Risk%20Analysis%20and%20Data/Reporting %20by%20Authorities/885459/Decision%20on%20the%20European%20Centralised%20Infrastructure%20of%20Data%20% 28EUCLID%29.pdf

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