The EBA revised Guidelines on sound remuneration policies in order to reflect amendments of relevant provisions of the CRD V and in particular to reflect that those remuneration policies should be gender neutral.
We consider it essential that the revised GL do not create too heavy and burdensome administrative requirements for banks, resulting in a disproportionate bureaucratism.
Employers in the financial services industry are already most heavily regulated in terms of their variable remuneration options. We observe that a number of requirements and expectations which are applicable across all sectors are reinforced and extended by supervisory law in the banking sector or are even implemented exclusively for the banking sector. Therefore, this gold-plating of generally applicable remuneration regulations (such as relating to discrimination, etc.) in the banking supervisory regulations should be avoided. We doubt that it will be helpful for the cause itself to increasingly develop “financial-sector-specific” regulation.