COR015 High Earners Report: The PRA’s Annual Remuneration Return

Firms in scope of Chapter 18 of the PRA Rulebook must submit the Remuneration High Earners Report annually. The report is due to the PRA within four months of the firm’s accounting reference date and, under Rules 18.4 and 18.5, covers high earners who mainly undertook their professional activities within the UK; Rule 18.6 reports them in EUR 1 million pay brackets.

COR015 reporting looks deceptively simple. It is one XBRL module, its data content fits on a couple of screens, and the population it describes can be a handful of names. The traps sit around the edges: which legal entity files, at what level of consolidation, in which currency, and against which taxonomy version. Get the scope or the euro conversion wrong and the return is filed but wrong, which is worse than late.

Related reading: COREP Reporting Explained

The legal basis for the COR015 High Earners Report

COR015 sits in the Remuneration Part of the PRA Rulebook. Chapter 18, the High Earners Reporting Requirement, is the operative source: it is a domestic PRA rule, not a directly applicable EU measure, and that distinction matters for anyone still reaching for a CRD article number. The Prudential Regulation Authority, part of the Bank of England, both makes the rule and receives the return.

The requirement has a European ancestry. The data collection began under Article 75(3) of Directive 2013/36/EU, which required competent authorities to collect information on the number of natural persons per institution remunerated one million euro or more per financial year, in pay brackets of one million euro, together with their job responsibilities, the business area involved, and the main elements of salary, bonus, long-term award and pension contribution. The European Banking Authority ran the exercise through its Guidelines on the data collection exercise regarding high earners (EBA/GL/2014/07 of 16 July 2014, which built on a 2012 predecessor). Those EU guidelines were repealed with effect from 31 December 2022 and replaced within the EU by EBA/GL/2022/08.

The point for a UK filer is that the EU repeal did not switch the return off here. When the United Kingdom left the EU, the substance of the collection was retained as a domestic obligation, and it now lives in the PRA Rulebook rather than in a directive or an EBA guideline. The wording tracks the old Article 75(3) collection closely, which is why the data content will look familiar to anyone who filed it before Brexit, but the authority for the return today is the Rulebook. If your policy paper cites CRD Article 75 as the current legal basis for a UK submission, that is the onshoring trap.

COR015 is distinct from COR014, the Remuneration Benchmarking Report under Chapter 17. Chapter 17.1 applies the benchmarking requirement only to firms meeting its GBP 50 billion total-assets test, whereas Chapter 18 governs the High Earners Report. A firm should therefore follow its RegData schedule rather than assume that COR014 and COR015 are both due merely because one is in scope.

Who must report COR015, and at what level of consolidation

The reporting obligation follows the scope of the Remuneration Part. Under Rule 1.1, that Part applies to CRR firms in relation to their UK activities, and to third country CRR firms in relation to activities carried on from an establishment in the UK. In plain terms that captures PRA-authorised banks, building societies and PRA-designated investment firms, plus UK branches of overseas banks that fall within the definition. Rule 18.2 then requires all firms in that scope to submit the high earners information annually.

The consolidation level is where the return either doubles up or does not. Rule 18.4 requires an unconsolidated report where the firm is not, and does not have in its consolidation group, an undertaking responsible for consolidation, covering high earners of the firm who mainly undertook their professional activities within the UK. Rule 18.5 requires an undertaking responsible for consolidation to report on a consolidated basis for high earners of the consolidation-group entities who mainly undertook their professional activities within the UK at the entities and branches specified in Rule 18.5.

Firm size changes the surrounding remuneration regime, and it is worth being precise about what it does and does not change. The Remuneration Part carries a proportionality framework: a small CRR firm, broadly one whose average total assets do not exceed GBP 4 billion, is exempt from a set of the substantive pay rules, and a further band up to GBP 20 billion can qualify on additional conditions. Third country CRR firms are sized on the assets that relate to their UK branch operation. That proportionality principally disapplies structuring requirements such as deferral and payment in instruments. The proportionality framework does not lift the data collection, so a firm that assumes it is small and therefore files nothing should confirm its position against the Rulebook before reading anything across from the pay-rule carve-outs.

One scope point is easy to miss for anyone thinking only in terms of the code staff population. COR015 is about high earners, and Rule 18.1 is explicit that this is not confined to material risk takers. A trader or a control-function head who is not identified as an MRT still counts if total remuneration reaches the one million euro floor. The MRT list and the high earners list can overlap heavily and still diverge at the margin, and the return wants the latter.

What the report contains: high earners in EUR 1 million pay brackets

The unit of the return is a person, counted as one head regardless of role or full-time-equivalent split. Rule 18.6 requires the firm to report, in pay brackets of one million euro, the number of high earners counted as natural persons, together with their job responsibilities, the business area involved, and the elements of their remuneration: salary, bonus, long-term awards and pension contributions. So a single individual paid 2.4 million euro lands in one bracket as one head, with their pay split across the components; the return does not ask for names.

The brackets run upward in steps of one million euro, so the return distributes the high earner population across bands (one to two million euro, two to three million euro, and so on) instead of a single average. That shape is the whole purpose of the collection: it lets the supervisor and, historically, the EBA see how remuneration concentrates at the top of the pay distribution and how the fixed and variable split behaves as pay rises. A firm with three people over the floor produces a very different picture from a dealer with three hundred, and the brackets are what make the two comparable.

The currency convention is counter-intuitive for a UK filer, which is why it repays a close read. Rule 18.7 requires the information to be denominated in euro, determined by reference to the exchange rate used by the European Commission for financial programming and the budget for December of the reported year. A London bank that pays its people in sterling therefore has to convert every relevant remuneration figure into euro at a single prescribed December rate before testing it against the one million euro floor and slotting it into a bracket. Use the wrong rate, or a spot rate on the payment date, and both the population count and the bracket allocation can move. This is the point in the file where a sterling-denominated payroll and a euro-denominated return have to be reconciled, and it deserves a documented control.

Chapter 18 sets the governing reporting requirement. Completion mechanics are supplemented by the PRA’s COR015 completion instructions and the applicable EBA Taxonomy 3.0 technical artefacts used for RegData. Because the PRA’s linked completion PDF is dated March 2016 and retains pre-Brexit EEA wording, current Chapter 18 governs where that legacy wording conflicts with the Rulebook.

Reference dates, frequency and the COR015 remittance deadlines

COR015 is an annual return. Its reference point is the firm’s own accounting reference date, meaning its financial year end, not a fixed regulatory quarter. Rule 18.3 sets the remittance clock at four months from the end of that accounting reference date. The report then covers the remuneration awarded for that financial year.

Because the deadline is pegged to the firm’s year end, there is no single national due date. The operative dates for a given filer are therefore easy to state once the year end is known:

• Reference date: the firm’s accounting reference date (financial year end).
• Frequency: annual, one submission per financial year.
• Remittance: within four months of the accounting reference date (Rule 18.3).
• Worked example: a 31 December year end makes the return due by 30 April; a 31 March year end makes it due by 31 July.

The calendar-quarter assumption is the trap: treating COR015 as if it shared a quarterly remittance with the COREP or FINREP frameworks. It does not. A firm with a non-December year end that copies a 30 April date from a group calendar can file months early or months late without realising the deadline was personal to its own year end. The safer control is to derive the four-month date from the accounting reference date each year and reconcile it against the RegData schedule the firm receives, which itself lists what is due and when.

Submission: RegData, XBRL and EBA Taxonomy 3.0

COR015 is submitted through RegData, the reporting system operated by the Financial Conduct Authority and used for most PRA returns. On the Bank of England’s own guidance, CRD firms submit their High Earners and Remuneration Benchmarking reports via RegData, and firm-specific queries go to the PRA’s remuneration reporting mailbox. This is a deliberate distinction from the returns that travel through BEEDS, the Bank of England Electronic Data Submission portal, which handles Capital+, MREL reporting and stress-test collections. Sending a high earners file to the wrong pipe is a filing failure even when the numbers are right.

COR015 is an XBRL return submitted through RegData. The PRA’s 15 December 2021 guidance states that COR015 moved to XBRL using the remuneration module implemented in EBA Taxonomy 3.0 for year-ends on or after 1 January 2022, under policy statements PS17/21 and PS22/21; current PRA and FCA reporting pages continue to direct CRR reporting to EBA Taxonomy 3.0. The module code itself is a reminder of how recently this became an XBRL return: COR015 replaced the older REP005 XML template, just as COR014 replaced REP004 for benchmarking. A firm with high earners that has not filed since the XML era should put an XBRL production route in place; the PRA asks firms with high earners to acquire an XBRL licence. For a nil return, the FCA provides an XBRL nil-return route, while the PRA states that it may also accept an emailed nil confirmation where a firm with no high earners has not yet purchased XBRL.

COR015 file construction follows the EBA validation and filing rules implemented in RegData, together with the FCA’s RegData technical material and entry-point mapping. Firms should use the EBA Taxonomy 3.0 entry point mapped to COR015 and should not implement a subsequent EBA taxonomy unless the PRA indicates that change through its reporting-change process.

Validation rules and the common causes of a COR015 rejection

For COR015, RegData applies the EBA validation and filing rules implemented for the applicable CRR taxonomy. The FCA states that EBA blocking rules are treated as ERROR and reject the file, non-blocking rules are treated as WARNING and can be accepted, and deactivated rules are ignored.

The FCA’s available COR015 technical material does not publish a COR015-specific narrative list of rejection causes, so it would be wrong to present a fixed top-five here. What can be stated from the framework is the shape of the failures a small XBRL return like this tends to produce. A rejection should therefore be traced to the applicable EBA validation or filing rule and the COR015 entry point rather than attributed to generic examples that have not been verified against the COR015 rule set. Currency and units are a recurring source of quiet error: because the return is euro-denominated, a file that carries sterling figures or the wrong unit will validate arithmetically while being substantively wrong. A related failure mode is the right euro total reached with the wrong December Commission rate, which shifts who crosses the floor and which bracket they land in while the file passes structural validation.

The Bank’s Banking-taxonomy known-issues logs relate to that separate taxonomy stream and should not be treated as the COR015 technical reference. For COR015, first use the FCA RegData technical material and the applicable EBA validation and filing rules, and escalate unresolved remuneration-reporting issues through the PRA’s published contact channels.

Caveats and interactions with the wider remuneration regime

COR014 and COR015 are separate returns and should not be treated as a single population. Where COR014 applies, its instructions collect information on all staff as well as identified staff, while COR015 captures high earners within the Chapter 18 scope. Both use RegData, but their application conditions and data populations differ.

The euro denomination is the caveat that can survive into a filed return unnoticed. A reviewer should test first whether the one million euro floor was applied in euro at the prescribed December Commission rate; a management rate or a spot rate can misstate both who crossed the floor and which bracket they landed in.

There is also a supervisory split to keep straight. RegData is the FCA’s system, and remuneration is a jointly supervised area, but COR015 as described in the PRA Rulebook is the return the PRA collects from the firms it prudentially regulates. Firms authorised and prudentially supervised only by the FCA sit under a different remuneration and reporting framework, so a group with both PRA-regulated and FCA-solo-regulated entities should not assume a single high earners return covers everything. The Senior Managers and Certification Regime sits alongside the remuneration regime to support individual accountability; the PRA’s remuneration rules and SS2/17, rather than SM&CR itself, govern remuneration requirements including malus and clawback.

Recent and upcoming changes to COR015 reporting

The most significant recent development is a change to the remuneration regime rather than to the template itself. On 15 October 2025 the PRA and the FCA published their remuneration reform package, PS21/25 from the PRA and PS25/15 from the FCA, with the stated aim of making the regime simpler and more proportionate. Among the changes, all material risk takers become subject to the same four-year minimum deferral period, and the higher 60 per cent deferral for high earners now applies on a marginal basis, with the 40 per cent rate applying to the first GBP 660,000 of a bonus award. The reforms came into force on 16 October 2025 and apply to performance years starting after that date, with some elements available to firms on an optional basis for earlier years.

These reforms reshape how variable pay is structured and deferred, which is the raw material COR015 reports. They do not, on their own, rewrite the Chapter 18 data content or the one million euro bracket structure. The reforms may affect the composition of remuneration reported in COR015 over future performance years, but that is an operational consequence rather than a change to the Chapter 18 reporting fields. Reporting teams should track the reform for its downstream effect on the figures, since the fields themselves stay put for now. In practice, the marginal deferral structure means more of a high earner’s package will sit in the long-term award column, and the four-year uniform deferral changes the timing of awards within the annual reporting cycle; the Rule 18.6 component fields (salary, bonus, long-term award and pension) capture this split as reported, so the template design accommodates the new deferral shape without amendment, but the underlying composition of each field will shift for performance years starting after 16 October 2025.

On the technical side, COR015 remains in the CRR/RegData stream for which the PRA and FCA currently direct firms to EBA Taxonomy 3.0. Bank of England Banking taxonomy versions 3.7.0 and 4.1.1 belong to a separate taxonomy stream and do not provide the COR015 taxonomy. Firms should implement a different EBA taxonomy for COR015 only when the PRA indicates a reporting change through its published consultation and policy statement process; CRR reporting changes are typically consulted before finalisation under a CP, allowing firms time to plan any updates to their XBRL production infrastructure.

Frequently Asked Questions

Is COR015 required from a firm that has no one paid one million euro or more?

A nil return is still required where the firm has no high earners. The FCA provides a COR015 XBRL nil-return file for submission through RegData; the PRA also states that it may accept an emailed nil confirmation where a firm with no high earners has not yet purchased XBRL.

Does the small-firm proportionality that exempts us from deferral rules also exempt us from COR015?

Not automatically. The Remuneration Part’s proportionality thresholds, broadly GBP 4 billion in average total assets with a further band to GBP 20 billion on conditions, principally disapply substantive pay-structuring rules such as deferral and payment in instruments. They are not framed as a general exemption from the high earners data collection, so a small firm should verify its filing position against the Rulebook before reading the pay-rule carve-out across to the return.

We report in sterling internally. Which exchange rate converts pay for COR015?

Rule 18.7 requires the information to be denominated in euro, using the exchange rate the European Commission uses for financial programming and the budget for December of the reported year. That single prescribed rate is applied before testing the one million euro floor and allocating individuals to brackets, so a spot rate or an internal management rate is the wrong input even though it may feel more accurate.

Do material risk takers and high earners produce the same population?

No. Rule 18.1 makes clear the high earners collection is not confined to material risk takers. The two populations can overlap and still diverge at the edges, so an individual who is not on the MRT list still counts for COR015 if their remuneration reaches the euro floor, and an MRT below the floor does not.

Is COR015 filed through BEEDS like our MREL return?

No. The Bank of England directs High Earners and Remuneration Benchmarking reports to RegData, the FCA-operated system, while BEEDS handles collections such as Capital+, MREL and stress-test data. A high earners instance uploaded to BEEDS has gone to the wrong system regardless of whether the figures are correct.

How does COR015 relate to COR014?

COR014 is the Remuneration Benchmarking Report under Chapter 17 and also uses RegData, but Chapter 17.1 has its own GBP 50 billion application threshold. Its instructions cover remuneration information for all staff as well as identified staff. COR015 is the separate Chapter 18 return for high earners within the applicable UK scope.

Related Articles

• COREP Reporting Explained: how the own funds and prudential COREP returns are built and submitted, the calendar-quarter framework COR015 does not share.
• FINREP Reporting Explained: the financial reporting framework and its notification and accounting-reference-date mechanics.
• SMCR Reforms 2026: Strengthening Accountability: the UK senior manager and certification regime that sits alongside remuneration and clawback.
• PRA Pillar 2A Review Phase 1: how PRA reporting and capital add-ons interact for UK banks and building societies.
• MREL Reporting Requirements: a resolution return that travels through BEEDS while COR015 uses RegData, and why the pipe matters.

Key Takeaways

• COR015, the Remuneration High Earners Report, is a PRA Rulebook requirement under Chapter 18 of the Remuneration Part, not a live CRD Article 75 obligation; cite the Rulebook for a UK filing.
• It is annual and due within four months of the firm’s accounting reference date, so a 31 December year end falls due by 30 April, with no fixed national quarter date.
• The return counts natural persons paid one million euro or more per financial year, sorted into pay brackets of one million euro, with salary, bonus, long-term award and pension components.
• Remuneration must be denominated in euro at the European Commission’s December budget exchange rate for the reported year, so a sterling payroll is converted before the floor is tested.
• Scope follows the Remuneration Part: CRR firms and UK establishments of third country CRR firms; Rules 18.4 and 18.5 apply the UK professional-activity condition; small-firm proportionality relaxes the pay rules but does not automatically lift the data collection.
• Submit in XBRL through RegData using the EBA Taxonomy 3.0 entry point for COR015; the return replaced the old REP005 XML template and a firm with high earners needs an XBRL production route.
• For COR015, use the FCA RegData technical material and applicable EBA validation and filing rules; the Bank of England Banking taxonomy known-issues logs relate to a separate stream and are not the COR015 technical reference.
• PS21/25 and FCA PS25/15 (15 October 2025) reshape deferral for high earners; the reforms may affect the reported pay composition over future performance years while the template itself holds.

Sources and References

• PRA Rulebook, Remuneration Part, Chapter 18 (High Earners Reporting Requirement): prarulebook.co.uk
• PRA Rulebook, Remuneration Part, Chapter 1 (Application and Definitions): prarulebook.co.uk
• Bank of England, Regulatory reporting: banks, building societies and investment firms (CRR reporting modules, including COR015 Remuneration High Earners; submission via RegData): bankofengland.co.uk
• PRA, Guidance on changes to banking reporting requirements (15 December 2021 statement on COR015 Remuneration High Earners; XBRL for year-ends on or after 1 January 2022): bankofengland.co.uk
• PRA statement on Remuneration Benchmarking and Remuneration High Earners reporting templates (COR014/COR015 replacing REP004/REP005), April 2021: bankofengland.co.uk
• PRA PS21/25, Remuneration Reform (15 October 2025): bankofengland.co.uk
• FCA PS25/15, Remuneration Reform: fca.org.uk
• EBA Guidelines on the data collection exercise regarding high earners (EBA/GL/2014/07, historical EU basis under Directive 2013/36/EU Article 75(3); repealed in the EU from 31 December 2022): eba.europa.eu
• Directive 2013/36/EU (CRD), Article 75(3) (historical origin of the high earners collection): eur-lex.europa.eu
• FCA, COREP and FINREP reporting via RegData (EBA validation-rule treatment: blocking rules rejected as ERROR, non-blocking rules accepted as WARNING, deactivated rules ignored): fca.org.uk

Filing COR015 without the avoidable errors

The COR015 return rewards a firm that settles four questions before it opens the taxonomy: whose payroll the return draws on and at what level of consolidation, which individuals cross the one million euro floor once converted at the prescribed December euro rate, which taxonomy version the RegData schedule expects, and what date four months from the accounting reference date actually falls on this year. Fix those, validate the instance locally against the published rules, and the submission itself is routine. A team with high earners that has not filed since the XML era should confirm its XBRL production route now. A firm with a nil return should follow the FCA’s COR015 nil-return process and, if it has no XBRL licence, note the PRA’s stated email alternative.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.