You should submit the completed questionnaire through the Digital Reporting Portal (DLR, in Dutch: Digitaal Loket Rapportages) using your standard login details. From the 1st of June 2018 onwards DLR will be open to submit the questionnaire. Please complete and submit no later than the 30th of June 2018.
The data to be submitted via the template concern the remuneration of high earners for the performance year 2017. The data should be broken down into pay brackets of one million euro and various categories of high earners’ job responsibilities. If your institution has no high earners, you must also report this to DNB via DLR using the template (a so-called zero report).
DNB will check the data submission and may ask you for further information. Subsequently, DNB will submit the data – in aggregated form – to EBA, which will then draft a report of aggregated findings per country.
EBA has provided instructions for completing the template:
- The “Guidelines on the data collection exercise regarding high earners” should be read in conjunction with the CEBS “Guidelines on remuneration policies and practices” and the EBA “Guidelines on sound remuneration policies”, as appropriate. All definitions provided in those Guidelines and in Directive 2013/36/EU and Regulation (EU) No 575/2013 apply. For the terms “variable remuneration” and “fixed remuneration” the definitions of the EBA “Guidelines on sound remuneration policies” should be used.
- “High earners‟ means all staff earning a total remuneration of at least EUR 1 million per financial year.
- Institutions should provide information at the highest level of consolidation, covering all subsidiaries and branches within a group established in the EEA as well as information for EEA branches of institutions that have their head office in a third (non-EEA) country. Data regarding high earners in third countries should not be collected within this exercise, even if they relate to subsidiaries or branches of EEA groups.
- A separate set of data (i.e. separate templates) should be collected/provided for each EEA 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.).
- The number of high earners should be reported as the number of natural persons (headcount), independent of the number of working hours on which their contract is based. For high earners the remuneration paid in euro, elements of remuneration, the EEA state, function or business area and responsibility should be reported in accordance with Annex I of the Guidelines on the data collection exercise regarding high earners dated 16 July 2014 (EBA/GL/2014/07).
- High earners should be classified under the EEA state, function or business area and responsibility where they carry on the predominant part of their business activities. The full amount of remuneration awarded to the relevant high earner within the group or institution should be reported under this EEA state, function or business area and responsibility. If the predominant areas for one high earner have the same weight, the institution should allocate the high earner and its remuneration taking into account the allocation of other high earners, so that the report best reflects the distribution of high earners within the institution. For each high earner, figures should only be reported once and the full amounts should be assigned to one area and responsibility only.
- High earners who carry out professional activities both within and outside the EEA should be classified under an EEA state only if they undertake the predominant part of their professional activities within the EEA. Otherwise, figures should not be reported.
- 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.
- Institutions should submit the required information using financial year-end figures denominated in euro. All amounts should be reported as full amounts, i.e. not as rounded amounts, in euro (e.g. EURO 123 456 789.00 instead of EUR 1.2 million). Institutions that do not have any high earners in their EEA consolidation scope should provide a response stating this fact without the need to submit additional data.
- Where institutions disclose financial figures in a currency other than euro, the exchange rate used by the European Commission for financial programming and the budget for December for the reported year should be used.
- Please complete the footnote 'staff reported in column "all other" consists of .....' where applicable and in English.
- The format may not be amended. Please state “not applicable” where appropriate; do not delete cells/columns/rows.