On 21 January 2022, the European Banking Authority (EBA) launched a consultation on updates to its guidelines on the data collection exercise on high earners, which were originally published in 2012 and revised in 2014.

The review of the data collection exercises reflect the amended remuneration framework laid down in the Capital Requirements Directive (CRD V), 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 establishment of two distinct regulatory frameworks require a separation of the data collection on high earners in credit institutions and investment firms. The templates and instructions have been updated accordingly and specific templates for investment firms have been provided.

The consultation runs until 21 March 2022.

A public hearing on the draft guidelines on the data collection exercise on high earners as well as on the draft guidelines on the remuneration and gender pay benchmarking exercises (which are being consulted on in parallel) will take place via conference call on 17 February 2022 from 14:00 to 15:30 CET.

The new reporting format will apply for the collection of data in 2023 for the financial year 2022.