On 26 November 2025, the European Banking Authority (EBA) published a report setting out its findings of a peer review which assessed how Member State competent authorities (NCAs) supervise and implement gender diversity within the management bodies of financial institutions, specifically credit institutions (CIs).

Background

The Peer Review follows up on the EBA report on the benchmarking of diversity practices and the gender pay gap | Global Regulation Tomorrow (the EBA Report) published on 7 March 2023. The EBA Report found that despite the legal requirements under the Capital Requirements Regulation (CRR) and Capital Requirements Directive IV (CRD IV) to incorporate diversity, a significant proportion of institutions had still not adopted a diversity policy and found more generally that further improvements of gender balance and diversity were needed at the management body level.

The EBA therefore decided to carry out a peer review in this area to assess the supervisory practices of NCAs. The report sets out the findings of the peer review, undertaken by the Peer Review Committee (PRC), on the supervision by six NCAs of diversity policies and the implementation of gender diversity at the level of the management body of institutions under their remit. The NCAs assessed were Austria, Czech Republic, Germany, Greece, Finland and the European Central Bank. The report focuses on the application of the respective requirements in CRD IV and EBA Guidelines across six major areas referred to as benchmarks:

  1. Effectiveness of integration by NCAs of the requirements on gender diversity policies.
  2. Effectiveness of arrangements by NCAs for supervising and reviewing gender diversity policies and their implementation in CIs.
  3. NCA’s effectiveness of implementation of processes for the collection of information on diversity policies.
  4. NCA’s own benchmarking of diversity policies.
  5. Measures taken by NCAs to follow-up on EBA’s report on the review of gender-neutral remuneration policies and the diversity benchmarking report.
  6. Effective supervision of the requirements on internal governance, aiming at the absence of discrimination, ensuring equal opportunities, reducing the gender-pay gap and improving diversity.

Overview of the peer review

The peer review assessment of the six benchmarks and the application of the underlying requirements by the respective NCAs provided an overall positive outcome. Nonetheless several weaknesses were identified for some NCAs which included not having their own benchmarking of diversity policies and measures to be taken by NCAs to follow up on the EBA’s report on the review of gender-neutral remuneration policies only being partially applied. The report mentions this is due in part to limited national CRD IV implementation by the NCA or disclosed information, thematic reviews and the ECB’s own benchmarking exercises being relied upon.

In addition, the peer review mentioned that 4 of the 6 NCAs assessed should ensure the supervision of robust governance arrangements and from time to time a high-level review of the implementation of measures and the setting up of organisational structures to avoid discrimination and ensure equal opportunities for staff. The report mentions that measures should reflect those outlined in paragraph 101 Final report on Guidelines on internal governance under CRD IV. The report also mentions concerns with larger banking markets on the effectiveness of supervising and reviewing gender diversity policies and their implementation in CIs. As for assessing effective supervision of the requirements of internal governance, the report mentions this was partially applied where the activities of the nomination committee were found to be problematic for two of the assessed NCAs.

Next steps

The EBA will conduct a follow-up peer review of the implementation of the measures included in the peer review report in two years.