EBA High Earners Report 2024: What the Data Means for Remuneration Reporting

ByOfficer

Last updated: April 2026

If your institution reported zero high earners for 2024 and you did not document why, that gap is going to stand out. The EBA published its 2024 High Earners Dashboard on 16 April 2026, and the headline number is hard to miss: 2,554 individuals across the EU earned more than EUR 1 million, up 9% from 2,343 in 2023. Credit institutions reported 2,266 high earners (up 6.8%), while investment firms reported 288 (up 30.3%). The variable-to-fixed remuneration ratio for credit institution high earners climbed to 98.5%, and for investment firms it hit 358.7%.

These are not just statistics for the EBA’s dashboards. They are the direct output of the data collection exercise that competent authorities run under Article 75(3) of Directive 2013/36/EU (CRD) and Article 34(4) of Directive (EU) 2019/2034 (IFD). Every credit institution and every Class 2 or Class 3 investment firm in the EU feeds into this pipeline. If you work in remuneration reporting, the 2024 data tells you where the supervisory lens is pointing next.

Related reading: Pillar 3 Disclosure Requirements for Luxembourg Banks

What the EBA High Earners Data Collection Actually Requires

The EBA high earners exercise is not a standalone filing. It feeds into the broader remuneration benchmarking data collection that competent authorities submit to the EBA annually. The legal basis is Article 75(3) CRD for credit institutions, and Article 34(4) IFD for standalone investment firms. Credit institutions may also apply CRD remuneration rules to certain investment firm subsidiaries depending on group structure, per the relevant provisions of Regulation (EU) 2019/2033 (IFR).

The data the EBA collects covers every staff member who earned EUR 1 million or more in total remuneration during the financial year. For each high earner, the institution must report: the business area or function, whether the person is identified staff, the main components of remuneration (fixed salary, variable, long-term awards, pension contributions), and the split between cash and instruments.

Where reporting teams commonly trip up: they assume “high earners” means only senior management. It does not. The EUR 1 million threshold applies regardless of seniority. An investment banker, a portfolio manager, or a senior trader who crosses that threshold enters the dataset. I have seen institutions miss high earners in asset management or corporate functions because the reporting team only checked the management body list. Those are not edge cases.

Identified Staff Ratios and Why They Matter for Your Filing

The 2024 dashboard reports that 89.7% of high earners in credit institutions were classified as identified staff, and 79.5% in investment firms. These ratios are important because competent authorities will scrutinize any institution where a high earner is not classified as identified staff.

The identification exercise is governed by Commission Delegated Regulation (EU) 2021/923 for credit institutions and Commission Delegated Regulation (EU) 2021/2154 for investment firms. These RTS set out quantitative and qualitative criteria: anyone awarded total remuneration of EUR 750,000 or more in the preceding financial year triggers the quantitative threshold under the CRD RTS, regardless of role. There are also criteria based on material business unit size, risk authority, and management body membership.

The real problem starts when an institution reports a high earner (earning above EUR 1 million) who is not flagged as identified staff. That requires an explanation, because the EUR 750,000 quantitative criterion should have caught them already. The 2024 data shows that 10.3% of high earners in credit institutions were not identified staff. In investment firms, 20.5% were not. Some of these have valid reasons: the identified staff RTS allows exclusions for staff whose activities do not have a material impact on the risk profile, provided the institution can justify it. But supervisors notice when the ratio drops sharply year-on-year, and the EBA tracks this trend across Member States.

Luxembourg institutions should pay particular attention here. The CSSF expects documented justification for any high earner exclusion from identified staff status. If you are filing and your identified staff ratio looks off compared to the EU average, make sure the reasoning is in writing before the submission window.

The Variable-to-Fixed Ratio: What the 98.5% Figure Tells You

For credit institutions, the weighted average ratio of variable to fixed remuneration among high earners rose to 98.5% in 2024, up from 87.8% in 2023 and 85.4% in 2022. That number sits just below the 100% bonus cap set by Article 94(1)(g) of the CRD. With shareholder approval, the cap can go to 200%.

For investment firms under the IFD, the bonus cap does not apply (it was removed for IFD firms from 2021). Their average ratio jumped to 358.7%, up from 304.8% in 2023. IFD firms are still required to set an appropriate ratio in their remuneration policies, but they have no hard ceiling.

The data does flag a reporting nuance that teams frequently get wrong. The EBA notes that some credit institution averages exceed 200%, which seems impossible under the bonus cap. The explanation: severance payments and sign-on bonuses that are included in the variable remuneration total for the EBA data collection are not always subject to the bonus cap limitation under Article 94(1)(g) CRD. The cap applies to “the variable component” of identified staff remuneration, but certain payments (retention awards under specific conditions, guaranteed variable for the first year of employment) may sit outside the cap calculation while still counting in the EBA dataset. This is where teams most often misclassify. The EBA data collection instructions count these payments as variable remuneration. The bonus cap rules may not.

If your institution’s variable-to-fixed ratio looks unusually high relative to your peers, check whether severance or guaranteed variable awards are inflating the number. The data is correct. The classification for bonus cap compliance and the classification for the EBA data collection are two different things, and confusing them creates audit findings.

Gender Data and the Supervisory Focus on Diversity

The 2024 dashboard shows 89.1% of high earners in credit institutions are male, and 96.9% in investment firms are male. Both figures reflect a persistent and significant gender imbalance among EU high earners. For credit institutions, the male share has decreased slightly over recent reporting cycles. For investment firms, the concentration remains above 95%. This gender data feeds into the EBA’s separate benchmarking report on diversity practices and the gender pay gap under Article 75(1) CRD.

For reporting teams, the operational point is simple: the gender field in your high earners submission must be accurate and complete. The dashboard continues to capture an “other genders” category, and the 2024 data shows zero entries in that field for credit institutions. Whether that reflects actual demographics or incomplete data collection is a question supervisors may ask.

This is not a soft reporting requirement. The CRD gender diversity provisions under Article 91(10) and the EBA guidelines on diversity benchmarking (EBA/GL/2023/08) mean that high earner gender data flows directly into the supervisory assessment of your institution’s diversity policies. If the data is wrong or incomplete at the high earners submission, it will contradict whatever your institution reports in its Pillar 3 remuneration disclosures or its internal diversity assessments.

Where the Numbers Come From: The Data Pipeline

Institutions do not submit high earner data directly to the EBA. They submit to their national competent authority (in Luxembourg, the CSSF for credit institutions and the CSSF for most investment firms). The competent authority then aggregates and submits to the EBA.

The timeline matters. The EBA publishes its guidelines on the data collection exercise, which set the reporting template and instructions. The data reference date is end of the financial year (31 December for most institutions). Competent authorities collect the data in the first half of the following year, and the EBA typically publishes the dashboard in Q2 (the 2024 data dashboard was published 16 April 2026).

The EBA itself flagged a problem in the press release: data quality issues currently prevent the publication of the benchmarking report closer to the reference date. The EBA stated it will review the relevant regulatory products to simplify data templates, adjust data collection and publication frequencies, and reduce data quality issues. Reporting teams should watch for updated EBA guidelines on the data collection exercise in the coming months, because the templates may change.

This is where teams often get wrong about timing: the high earners data is not tied to your COREP/FINREP submission cycle. It runs on its own schedule, set by the competent authority. In Luxembourg, the CSSF typically issues a separate circular or communication specifying the submission deadline and template. If your team treats the high earners collection as a “side task” that happens after the regular prudential submissions, you risk missing the deadline or submitting with the wrong template version.

EBA High Earners Report 2024: Business Area Breakdown

The 2024 data breaks down high earners by business area for both credit institutions and investment firms. For credit institutions, investment banking is the single largest business area by number of high earners, followed by the management body management function and retail banking. Asset management and corporate functions also account for a meaningful share, which is why reporting teams should not limit their high earner identification process to front-office roles.

For investment firms, the picture is more concentrated. Dealing on own account, underwriting, and placing of instruments is the largest category, followed by investment advice and order execution, and then portfolio management.

The EBA dashboard provides a full breakdown by business area and function. This article has not independently verified individual cell-level figures from the underlying PDF, so we describe the distribution qualitatively based on the published dashboard structure.

The operational takeaway: if your institution has significant asset management or trading operations, cross-check the identified staff list against the high earners list before submission. The EBA data shows that the gap between “earning over EUR 1 million” and “classified as identified staff” is widest in asset management. That gap requires justification.

What CRD6 Means for Remuneration Governance and Reporting

CRD6 (Directive (EU) 2024/1619, amending Directive 2013/36/EU) entered into force on 9 July 2024 with Member State transposition deadlines running through 2026. CRD6 does not materially change the EUR 1 million high earners threshold or the mechanism by which the EBA collects high earners data. The proportionality waiver for identified staff remuneration rules (under Article 94(3) CRD) was introduced by CRD V (Directive (EU) 2019/878), not by CRD6.

What CRD6 does introduce that is relevant to remuneration governance and reporting falls into three areas. First, gender-neutral remuneration: under the revised Article 74(1)(e) CRD (as replaced by CRD6), institutions’ remuneration policies and practices must be gender neutral and must take into account the institution’s risk appetite in terms of ESG risks. The existing gender pay gap benchmarking mandate under Article 75(1) CRD (unchanged by CRD6) connects directly to the gender data that institutions submit in the high earners collection. Second, diversity policies: the revised Article 91 CRD (as replaced by CRD6) reinforces the requirement for institutions and their nomination committees to “proportionally promote diversity and gender balance in the management body” and to put in place a diversity policy (Article 91(8)), with a draft RTS on the minimum content of the suitability questionnaire, curricula vitae and internal suitability assessment due under Article 91(10) by 10 July 2026. Institutions reporting high earner gender data that is inconsistent with their stated diversity policies will face sharper supervisory questions. Third, ESG risks in remuneration: CRD6 requires institutions to reflect ESG risks in their remuneration policies (Article 74(1)(e)) and requires the risk committee to examine whether incentives take into account ESG-related risks (revised Article 76(4), second subparagraph). While this does not change what institutions report in the high earners data collection itself, it adds a governance layer that remuneration committees and reporting teams need to align.

The practical implication: CRD6 does not change the high earners template, but it changes the supervisory context around that data. Gender data from the high earners submission will be read alongside the CRD6 diversity and gender pay gap benchmarking. Institutions that treat the high earners filing as isolated from their broader ESG and diversity governance will find the two streams harder to reconcile.

What Teams Should Check Next

The 2024 dashboard release is an input, not just an output. Here is what reporting teams should do with it:

First, compare your institution’s numbers against the EU averages. If your identified staff ratio among high earners is significantly below 89.7% (for credit institutions) or 79.5% (for investment firms), document the reasons. Supervisors benchmark.

Second, review your variable-to-fixed ratio calculation. Make sure the components you include in the EBA data collection match the EBA’s guidelines, not just your internal bonus cap compliance calculation. The two definitions are not identical.

Third, check the gender data in your last submission. If it was incomplete or defaulted, fix it before the next cycle. The EBA and competent authorities will use this data for the benchmarking and diversity reports.

Fourth, watch for updated EBA guidelines on the data collection exercise. The EBA said it will review the templates and frequencies. If that consultation launches in 2026, respond. Template changes affect your data extraction, mapping, and validation workflows.

Fifth, monitor the CRD6 ESG-related remuneration governance requirements as they are transposed: gender pay gap benchmarking under Article 75(1), diversity policy targets under Article 91(10), and the requirement to reflect ESG risks in remuneration policies. These will feed into Pillar 3 ESG disclosures and diversity benchmarking, and they interact directly with the gender data your institution submits in the high earners collection. Getting ahead of this alignment now avoids inconsistencies across reporting streams later.

Frequently Asked Questions

Who must report high earners data to the competent authority?

All credit institutions subject to Directive 2013/36/EU and all investment firms subject to Directive (EU) 2019/2034 must report data on staff earning EUR 1 million or more per financial year. The institution reports to its national competent authority, which then submits aggregated data to the EBA. Note that nil-return practices (whether institutions with no high earners still submit a nil return) vary by national competent authority. The CSSF approach in Luxembourg may differ from other NCAs, so check with your competent authority directly.

Does the EUR 1 million threshold include all remuneration components?

Yes. The threshold covers total remuneration: fixed salary, variable remuneration (including bonuses, long-term incentive awards), severance payments, and pension contributions for the financial year. It is not limited to cash. Instruments, deferred awards, and benefits count toward the total.

What happens if a high earner is not classified as identified staff?

The institution must be able to justify the exclusion. Under the RTS on identified staff (Commission Delegated Regulation (EU) 2021/923), anyone earning EUR 750,000 or more in total remuneration triggers a quantitative identification criterion. A high earner above EUR 1 million who is not identified staff requires a documented assessment showing their activities do not materially impact the institution’s risk profile. Competent authorities may challenge this.

How does the CRD bonus cap interact with the EBA high earner data?

The bonus cap under Article 94(1)(g) CRD limits the variable component to 100% of fixed (or 200% with shareholder approval) for identified staff in credit institutions. The EBA data collection counts all variable remuneration, including severance and sign-on bonuses that may not be subject to the cap. The two calculations use different scopes, which is why some reported ratios exceed 200%.

Does the IFD bonus cap exemption apply to all investment firms?

Investment firms subject to the IFD (Directive (EU) 2019/2034) are not subject to the CRD bonus cap. They must set an appropriate ratio in their remuneration policies, but there is no regulatory ceiling. This is why the EBA data shows average variable-to-fixed ratios above 300% for investment firms.

Will the EBA change the high earners data template?

The EBA stated in its April 2026 press release that it will review the relevant regulatory products to simplify data templates, adjust data collection and publication frequencies, and reduce data quality issues. No specific consultation timeline has been announced, but reporting teams should monitor the EBA’s guidelines on data collection for updates.

How does the gender data feed into supervisory assessments?

Gender data from the high earners collection feeds into the EBA’s benchmarking report on diversity practices and the gender pay gap under Article 75(1) CRD. Competent authorities use this data alongside Pillar 3 remuneration disclosures to assess whether institutions comply with the CRD diversity requirements under Article 91(10). Incomplete or inaccurate gender data creates inconsistencies across reporting streams.

When is the next high earners data collection cycle?

The data collection follows an annual cycle. Data for financial year 2025 will be collected by competent authorities in the first half of 2026. The CSSF (for Luxembourg institutions) issues a separate communication with the exact deadline and template. The EBA typically publishes the dashboard in Q2 of the following year.

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Key Takeaways

  • The EBA’s 2024 High Earners Dashboard reports 2,554 individuals earning above EUR 1 million across EU credit institutions and investment firms, a 9% increase from 2023.
  • 89.7% of high earners in credit institutions were classified as identified staff. Any institution significantly below this ratio needs documented justification for the exclusions.
  • The variable-to-fixed remuneration ratio for credit institution high earners reached 98.5%. For investment firms (not subject to the CRD bonus cap since 2021), it was 358.7%.
  • The EBA data collection counts severance and sign-on bonuses as variable remuneration, even when those payments are not subject to the CRD bonus cap. The two calculations are scoped differently.
  • Gender imbalance remains stark: 89.1% male in credit institutions, 96.9% male in investment firms. This data feeds directly into EBA diversity benchmarking and supervisory assessments.
  • The EBA plans to simplify data templates and adjust collection frequencies. Reporting teams should monitor for updated guidelines on the data collection exercise.
  • The EBA’s stated plan to simplify data templates interacts with the broader CRR3/CRD6 implementation timeline but does not currently change the EUR 1 million threshold or the reporting scope.
  • The high earners data collection runs on its own timeline, separate from COREP/FINREP. Treat it as a dedicated submission, not an afterthought.

Sources and References

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.

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