The updated technical package supports the following amendments to v3.2 Phase 3:
- the new guidelines on remuneration benchmarking and gender pay gap for credit institutions with reference date December 2023
As part of the CRD V, guidelines are provided on remuneration, gender pay gaps, and benchmarking exercises for higher ratios. CRD V changed remuneration and disclosure requirements regarding the application of derogations to the requirement to pay out a part of variable remuneration in instruments and under deferral arrangements, as well as the benchmarking of the gender pay gap.
Competent authorities will be able to monitor the implementation of such measures at different levels of pay and, in particular, the representation of staff of different genders at different levels of pay by benchmarking the gender pay gap.As a result of the guidelines, a representative sample of institutions is selected for benchmarking the gender pay gap.
The requirement to benchmark such practices applies to all institutions.
- the guidelines on remuneration benchmarking and gender pay gap for investment firms with reference date December 2022
Under the Investment Firms Directive (IFD), revised Guidelines have been published on remuneration and gender pay gap benchmarking exercises. The draft guidelines for investment firms follow the same approach as the corresponding guidelines for banks.
- the guidelines on high earners for credit institutions and investment firms with reference date as of December 2022
Under the CRD and IFD, the revised guidelines for collecting high earner data reflect the revised remuneration framework outlined in the CRD V, including introducing derogations for variable remuneration to be paid in instruments and deferred.Furthermore, the IFD and Investment Firms Regulation (IFR) have introduced a specific remuneration regime for investment firms and these guidelines need to be updated accordingly.
Under Directives (EU) 2013/36/EU and 2019/2034, competent authorities are required to collect information about the number of natural persons, per institution and investment firm, who are paid EUR 1 million or more every year, in pay brackets of EUR 1 million, including their job responsibilities, their business area, and the main elements of their salary, bonus, long-term award and pension contribution.
For the fiscal year ending in 2022, high earner data will be collected annually starting in 2023 under the updated guidelines. Data on high-earners will continue to be published annually by the EBA in a common format based on the aggregated home Member States of the high earners.
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RBI Regulatory Advisory
Raiffeisen Bank International AG | Member of RBI Group | Am Stadtpark 9, 1030 Vienna, Austria | Tel: +43 1 71707 - 5923