The EACB welcomes the opportunity to comment on the EBA consultation on the revision of the Guidelines on the remuneration benchmarking exercise under Directive 2013/36/EU.
The proposed updates are clearly meant to implement the amendments to the framework introduced by Capital requirements directive (CRD V). We consider essential that in doing so the revised guidelines do not create administrative requirements that are too onerous and burdensome for banks and overall disproportionate. In this regard, while we understand the EBA’s intention to ensure a benchmarking of the gender pay gap that covers a representative sample of institutions, we believe that extending the scope of institutions in scope for the gender pay gap data collection to those with total assets below € 5 billion would result in a disproportionate burden.
We kindly invite you to look into our position paper for more details.