3. General specifications regarding the high-earner data collections

Firms should submit data on high earners for each Member State in which high earners are located and for each payment bracket of EUR 1 million (e.g. EUR 1 million to less than EUR 2 million; EUR 2 million to less than EUR 3 million, etc.). Each high earner should be allocated to the payment bracket based on the staff member’s total remuneration awarded for the financial year.

Firms should submit the required information using financial year-end figures denominated in euro. Amounts should be reported as full amounts, i.e. not as rounded amounts (e.g. EUR 1 234 567.00 instead of EUR 1.2 million).

All staff that received EUR 1 million or more for the financial year should be reported, even if the staff member has left the firm before the end of the financial year or if the amount of EUR 1 million is reached only because of the award of guaranteed variable remuneration or severance payments.

Where high-earners data are reported by firms which disclose financial figures in a currency other than EUR, the exchange rate used by the Commission for financial planning and the budget for December of the reported year should be used for the conversion of the figures to be reported.

The number of high earners should be reported as the number of natural persons (headcount), independently of the number of working hours on which their contract is based. For high earners, the remuneration awarded in euro, elements of remuneration, the Member State, function or business area and responsibility should be reported.

The number of individuals in the row ‘number of individuals in control functions ’ should include all high earners in control functions within the business units and the independent compliance, risk control and internal audit function.

High earners should be classified under the Member State, function or business area and responsibility where they carry out the main part of their business activities. The full amount of remuneration awarded to the relevant high earner within the group or reporting firm should be reported under this Member State, function or business area and responsibility. If two or more areas for a high earner have the same weight, the firm should allocate the high earner and their remuneration taking into account the allocation of other high earners, so that the report best reflects the distribution of high earners within the firm.

Information on the remuneration of high earners and the specific elements of variable remuneration should be provided for all high earners, irrespective of whether the high earner is identified staff or not. The same should apply for high earners included in Annex I who are subject to a specific remuneration framework in accordance with Article 109(4) of Directive 2013/36/EU and are also reported in Annex II, whereby remuneration awarded in ‘ non-cash instruments which reflect the instruments of the portfolios managed ’ or remuneration awarded under ‘approved alternative arrangements’ should be allocated to ‘other instruments’ in Annex I.

High earners who carry out professional activities both within and outside the EU should be classified under a Member State only if they perform the main part of their professional activities within the EU. Otherwise, the staff member should not be reported as a high earner.

The allocation of the remuneration to the fixed and variable part of remuneration should be made, as applicable, according to Section 7 of the EBA Guidelines on sound remuneration policies under Directive 2013/36/EU and Section 7 under the EBA Guidelines on sound remuneration policies under Directive (EU) 2019/2034.

Non-monetary items of remuneration should be reported with their monetary equivalent (e.g. the taxed amount) and be included as ‘ other forms ’ of remuneration.

Severance payments, guaranteed variable remuneration and discretionary pension benefits should be included in the total variable remuneration and should also be provided in the part of the table containing additional information.

For the data-collection exercise for high ear ners, high earners should be reported as ‘identified’ staff if they are treated by firms as ‘identified staff’ at the consolidated level or at the individual level, considering the following:

• a. in Annex I,