Question
Point 18 of EBA/GL/2022/08 states: “High-earners data should be submitted (…) by: a. institutions referred to in Subsection 1.1, using the template for the data collection specified under: i. Annex I for high earners that are staff of institutions and other entities in the scope of consolidation; ii. Annex II for high earners that are staff in investment firms subject to Article 25 and 34 of Directive (EU) 2019/2034;” We have found that there are several common data points defined between R 04.00 and R.04.01 (in particular columns 0010, 0020 and 0070 of R 04.01) in XBRL taxonomy version 3.2. which technically prevents the possibility to report according to point 18 of EBA/GL/2022/08. For example, supposing an institution has one member of the MB Supervisory function (column 0010) reported in “Number of other staff” (row 0030) in an investment firm (point ii) and four members of the MB Supervisory function (column 0010) reported in “Number of other staff” (row 0030) in the parent institution (point i), it cannot report one person in R 04.01 and four people in R 04.00 due to the common data points between them.
Background on the question
We have found that there are several common data points defined between R 04.00 and R.04.01 (in particular columns 0010, 0020 and 0070 of R 04.01) in XBRL taxonomy version 3.2. which technically prevents the possibility to report according to point 18 of EBA/GL/2022/08.
Answer
This question has been rejected because the issue it raises is beyond the remit of the Q&A process and as such it cannot be addressed via a Q&A.The Single Rule Book Q&A tool has been established to provide explanations and non-binding interpretations on questions relating to the practical application or implementation of the provisions of legislative acts referred to in Article 1(2) of the EBA’s founding Regulation, as well as associated delegated and implementing acts, and guidelines and recommendations, adopted under these legislative acts. The Q&A process cannot, for example, consider issues which would require changes to the regulatory framework.For further information on the purpose of this tool and on how to submit questions, please see “Additional background and guidance for asking questions”.