On 10 August BaFin has issued a draft decree on the amendment of the Remuneration Regulation for Institutions (Institutsvergütungsverordnung – InstitutsVergV) as well as a related interpretation guideline. The BaFin has also provided a clean version of the draft. The amendments are based on an implementation of the EBA-Guidelines.

The most important amendments can be summarised as follows:

• remuneration will only be split into variable and fixed remuneration. Furthermore, there will be a more precise distinction between both compensation types;
• in the future, risk takers have to be identified by all CRR institutions. Non-CRR institutions, unless they are significant, do not have to identify risk takers. The disclosure will be regulated on a more detailed basis. The interpretation guideline includes a template regarding the quantitative information. Regulations with respect to the classification as a significant institution will be more concrete; and
• the new Institutsvergütungsverordnung will come into force on 1 January 2017. There will not be a grace period.