FINREP template F44.03, F44.04

In template  44.3  Staff expenses by type of benefits  in row 0010 “ Pension and similar expenses” are requested . In template 44.4 Staff expenses by category of remuneration and category of staff in row 0030 “Staff expenses other than remuneration” are requested.  For the whole template the following validation rules applies: v3988_s: {F 44.03} >= 0 (for all rows and with severity level error); v8364_s ({F 44.04} >= 0). This is suggesting Pension and similar expenses  and Staff expenses other than remuneration  can never be a negative amount, which we believe is not always the case (as a result of changes in the fair value of the liability recognised). Can you please amend the Validation rules by excluding row 0010 (44.3 Template), row 0020 ((44.4 Template) from those rules?

The guidance on the Template 44.3  row 0010 Pension and similar expenses” is as follows: Annex V. part 2. Art 311 a)‘Pension and similar expenses’ shall include the amount recognised in the period as staff expenses for any post-employment benefit obligations (both defined contribution plans and defined benefit plans), including post-employment-related contributions to social security funds (pension funds) maintained by the government or social security entities; Pension and similar expenses - 2022 the amount of accumulation has decreased due to a member of     the board of retirement age and several other managers of retirement age who have accumulated quite significant amounts and due to the change of other variables. Staff expenses other than remuneration - after dismissing two board members in 2022 staff costs decreased due to a decrease in accrued vacation reserve and pension accruals. So we think that the validation rules v3988_s  and v8364_s are not correct for the above reasons.