Validation rule eba_v09286_m

Relating the data entered in the upper part of template R04, the purpose of the v09286_m control is to verify that the total variable remuneration of all high earners is less than or equal to twice the total fixed remuneration by country and by pay bracket. The equation of the control is {r0100} <= 2 * {r0060}. However, the control does not take into account some points, including the following: -    The variable remuneration of {r0100} may include amounts awarded to high earners that are not identified staff; -    The severance payments included in the total variable remuneration of {r0100} amount may not be subject to the bonus cap mentioned above. Indeed, it is specified in the R04 template that the amounts relating additional information requested in the lower part of the report ({r0181} to {r0270}) should also be included in the total variable remuneration or in the total fixed remuneration of the upper part of the same template ({r0100} and {r0060} respectively). In that respect, variable and fixed remuneration of high earners that are not identified staff from {r0260} and {r0270} are included in {r0100} and {r0060} respectively, and severance payments from {r0200} awarded to high earners who are identified or not identified staff are included in {r0100}. As a consequence the equation {r0100} <= 2 * {r0060} may not be respected. Should the v09286_m control be disabled ?

Our question follows a question we received from our national competent authority.