The European Banking Authority (EBA) today published its final updated Guidelines on the data collection exercise on high earners, which were originally released in 2012 and revised in 2014. The update of the data collection exercises reflects the amended remuneration framework laid down in the Capital Requirements Directive (CRD), including the introduction of derogations to pay out a part of the variable remuneration in instruments and under deferral arrangements. In addition, the need to update these Guidelines stems from the specific remuneration regime that has been introduced for investment firms and is laid down in the Investment Firms Directive (IFD) and Investment Firms Regulation (IFR).
The CRD and the IFD require competent authorities to collect information on the number of natural persons, per institution and investment firm respectively, who are remunerated EUR 1 million or more per financial year, in pay brackets of EUR 1 million. The information should also include details on their job responsibilities, the business area and the main elements of the salary, bonus, long-term award, and pension contribution. Guidance is provided to ensure that the data is of the appropriate quality for deriving reliable and consistent information. Institutions, investment firms and competent authorities should check the accuracy and consistency of data before submission.
Legal basis and next steps
The EBA has developed these Guidelines in accordance with Article 75 (3) of Directive (EU) 2013/36 and Article 34(4) of Directive (EU) 2019/2034 that provide specific mandates to the EBA to issue Guidelines for the collection of data o high earners. The EBA Guidelines on the data collection exercise regarding high earners (EBA/GL/2014/07) from 16 July 2014 are repealed with effect from 31 December 2022.
The annual collection of data regarding high earners under the updated Guidelines should start in 2023 for the financial year that ends in 2022. The EBA will continue to annually publish high-earners data on an aggregate home Member State basis in a common format.