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High Earners Reporting (REP005)

28th April 2016

Relevant firms within the UK, such as credit institutions or investment firms including IFPRU limited licence and IFPRU limited activity firms, are required to annually report to the regulator with regards to the remuneration of High Earners.

High Earners Remuneration under CRD IV:

CRD IV requires the FCA to collect data from firms in relation to their remuneration practices and in particular the remuneration of those that are considered ‘High Earners’ – those individuals who are paid one million Euros or more per financial year.

This data is then submitted to the European Banking Authority (EBA) who must utilise the disclosed data to benchmark trends and practices related to remuneration and High Earners. Last month the EBA published a report on remuneration that reviewed the period to the end of 2014.   

Which firms have to report on High Earners?

CRD IV requires those types of firm listed below to submit data on all the employees with a total remuneration of 1 million Euros or more in a financial year:

• Banks;
• Building societies;
• IFPRU investment firms (including IFPRU Limited Licence and IFPRU Limited Activity firms); and
• A BIPRU firm, exempt CAD firm, a local and any other firm that is not a credit institution or an investment firm, provided they are included in the scope of consolidation of an institution for which data regarding high earners must be collected.

Reporting must be for all subsidiaries and branches within a group based in the European Economic Area (EEA) or an EEA branch of a firm with its head office outside of the EEA.

High Earners Reporting Requirements

Firms within the UK that are within the scope of the high earners reporting requirements must submit a High Earners Report annually. The High Earners Reporting requirements are housed within the FCA’s Supervision rulebook (SUP 16.7.4R).

The deadline for firms submitting the High Earners Report (REP005) is within four months after a firm’s accounting reference date and for all those with end of reporting periods after 30th June 2015, this report must now be submitted online via the FCA’s GABRIEL system.

High Earners Report REP005

Firms that are subject to the High Earners Report will have noticed the new REP005 report appearing in their GABRIEL systems in the second half of last year. Prior to this, firms were able to submit their High Earners reports by emailing them to the regulator.

The REP005 High Earners Report should list all employees of a firm that have a total annual remuneration of one million Euros or more. As the regulatory requirements specify, the information in the High Earners Report must be denominated in Euros. Thus, firms operating in other currencies will be required to convert to Euros using the European Commission’s exchange rate for December of the reporting period. The European Commission currency converter can be found here.

In addition, a separate High Earners reporting template must be provided for high earners in different payment brackets – where each payment bracket is EUR 1 Million and for each EEA state in which there is a high earner. Reporting must include the business area involved as well as the main elements of salary, bonus, long-term award and pension contribution. Figures for each high earner should only be reported once and the full amounts should be assigned to only one EEA state as well as only one responsibility and business area or function.

The regulator also clarifies that the number of high earners that must be reported upon is the “number of natural person” rather than based upon the number of working hours.

Should your firm be subject to the High Earners Report, yet has no High Earners to report, a Nil Return must still be submitted.

REP005 High Earners Report Template

The electronic version of the Remuneration High Earners Report (REP005) was introduced within GABRIEL on 1st July 2015 ready for firms with end of reporting periods from 30th June 2015 onwards.

Whilst previously the FCA provided blank templates for the High Earners Report – such as an XLS and XML version - the regulator has now advised these templates are no longer being supported by the regulator.

Firms must now find an alternative means of producing their High Earners Report ready to upload for submission within GABRIEL.

REP005 Regulatory Reporting Support Services

If you are required to submit a REP005 High Earners Report within GABRIEL and are unsure of the information that needs to be included or would any support with this report or any other regulatory reporting requirements within GABRIEL, please contact our experience Regulatory Reporting Consultants who would be happy to help.

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