9. Data quality

Firms and competent authorities should have appropriate processes and controls in place to ensure that the high-earners data are aggregated and provided correctly.

Firms and competent authorities should check the completeness and plausibility of the high-earners data provided, taking into account the validation rules in Annex III. Competent authorities should also apply those checks to the aggregated data that are to be submitted to the EBA.

Firms and competent authorities should ensure that the sum of sub-positions of the variable and fixed remuneration equals the total and that the average total remuneration of staff is consistent with the payment bracket selected.

In accordance with the applicable minimum requirements under Directive (EU) 2013/36/EU and Directive (EU) 2019/2034, high-earners data on deferral arrangements and the pay out in instruments should be plausible, after the deduction of amounts awarded to high earners that are identified staff benefitting from derogations and high earners that are not identified staff.

For institutions the ratio between the variable and fixed remuneration for high earners that are identified staff should be below 100% (200% with shareholders ’ approval), after the deduction of amounts awarded as severance pay or guaranteed variable remuneration that have not been taken into account for the calculation of the ratio and amounts awarded to high earners within firms that apply a specific remuneration framework.

When checking the completeness of high-earners data, competent authorities should take into account, in particular, the size and numbers of staff of the firms and the number of high earners provided in the past.

Competent authorities should make plausibility checks to confirm that firms that have to provide high-earners data have indeed provided it in accordance with these Guidelines. In particular, where competent authorities do not receive high-earners data from firms that have previously submitted such data, they should contact the firms to receive confirmation of the fact that no high earners had to be reported. Competent authorities should also follow up on material changes to the number of reported high earners.

Where competent authorities are aware of developments that materially increased or reduced the number of high earners, they should inform the EBA of the underlying reason.

For data submitted that show potential data-quality issues, the EBA may ask competent authorities to review the data and provide the information necessary for the correct interpretation thereof.

Competent authorities should provide corrected data or explanations to 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 30 September.

When submitting high-earners 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 European Centralised Infrastructure for Supervisory Data (EUCLID) ( ‘ EUCLID Decision ’ )¹¹ as amended and that they provide institutions and investment firms with any technical specifications necessary for the continuous compliance with the EUCLID Decision.

¹¹ 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%2 0of%20Data%20%28EUCLID%29.pdf