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29th March 2017

Reminder: High Earners Reporting

The Financial Conduct Authority’s Regulatory Round-up Newsletter for March reminds relevant firms of the requirement to submit a High Earners Report in GABRIEL within 4 months of their Account Reporting Date. For those firms that operate their accounts to the calendar year ending 31st December, this means you will need to submit a High Earners Report (REP005) within GABRIEL by the end of the next month.

What is the REP005 Return?

Last year was the first year that the High Earners Report was able to be submitted within the GABRIEL reporting system. The reporting code given to the report is REP005.

REP005 relates to remuneration reporting, a data collecting requirement under CRD IV. Specifically this report relates to ‘High Earners’ – all those individuals within firms that have received total remuneration of €1 Million or more in a financial year. Data is submitted on an anonymised and aggregated basis.

Firms that have to report are those within the scope of SUP 16.17.4R, such as credit institutions (Banks, building societies) and investment firms, and 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.

More information on the High Earners Reporting Requirements can be found within the FCA’s Supervision rulebook.

REP005 Common Mis-reporting Errors

The FCA advises that common mis-reporting errors they have seen so far for the High Earners Report (REP005) within GABRIEL include:

• The REP005 report must be submitted in XML format
• Nil returns are required to be submitted, so you will not be able to submit the return without answering a ‘Yes’ or ‘No’ in the Nil declaration section of the form.
• Firms completing the submission must enter a ‘Version Copy No’ on the form. For uploading the initial submission a ‘1’ should be entered, however should you need to upload a subsequent submission, then ‘2’ should be entered and so on and so on for any subsequent submissions. You will not be able to submit the return without entering a version number.
• In addition, in a number of cases it may only be the firm’s Principal User within GABRIEL that has permission to upload an XML submission.

Help with REP005 Report Submission:

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 like any help with this report or any other regulatory reporting requirements within GABRIEL, please contact our experience Regulatory Reporting Consultants who would be happy to assist.

Common Mis-Reporting on High Earners Report (REP005)