- Question ID
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2023_6808
- Legal act
- Regulation (EU) No 575/2013 (CRR)
- Topic
- Transparency and Pillar 3
- Article
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450
- COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
- Regulation (EU) 2021/637 - ITS with regard to disclosures of information referred to in Titles II and III of Part Eight CRR
- Article/Paragraph
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17
- Type of submitter
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Consultancy firm
- Subject matter
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Remuneration policy disclosure regarding Management Bodies of subsidiaries of an EU parent institution
- Question
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We would appreciate the EBA to shed light on the disclosure requirements about remuneration for EU parent institutions for the purpose of the Pillar 3 Disclosure Report and under Annex XXXIV of the Commission Implementing Regulation (EU) 2021/637. Indeed, requirements under the Annex stipulate that information on members of the Management Body disclosed under “Template EU REM1 – Remuneration awarded for the financial year” shall, in accordance with Article 13 CRR, be disclosed on the basis of their consolidated situation. In such case, the disclosure entity will solely reflect, in the columns related to Management Body, information on their own management body while information on the identified staff of the management bodies of subsidiaries shall be disclosed under the relevant business area.
We would kindly ask for detailed explanations on how EU parent institutions shall disclose the Management Body members of their subsidiaries in terms of columns within “Template EU REM1 – Remuneration awarded for the financial year” (i.e., under column a/b, c or d) and “Template EU REM5 – Information of staff whose professional activities have a material impact on institutions’ risk profile (identified staff)”.
- Background on the question
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A common understanding of this disclosure requirement seems not to be shared by all EU parent institutions as we noticed discrepancies in the application of these requirements in practice. For instance, certain EU parents institutions seem only to report information about their own Management Body in columns a & b of “Template EU REM1 – Remuneration awarded for the financial year” but report information on Management Body members of subsidiaries either under columns c or d, whereas others report information on all Management Body members, including members of subsidiaries in columns a & b.
- Submission date
- Rejected publishing date
-
- Rationale for rejection
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This question has been rejected because the issue it deals with is already explained in Article 17 and relevant Annexes to Regulation (EU) 2021/637. In addition, please refer to paragraph 44 of the EBA Guidelines on the benchmarking exercises on remuneration practice, the gender pay gap and approved higher ratios under Directive 2013/36/EU (EBA/GL/2022/06).
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- Status
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Rejected question