On 17 April 2025, the Dutch Minister of Finance published a letter addressed to the Dutch Parliament, together with a recent evaluation of the Remuneration Policy (Financial Institutions) Act (Wet beloningsbeleid financiële ondernemingen, the Remuneration Act). The Remuneration Act, incorporated in the Act on the Financial Supervision (Wet op het financieel
Governance & Compliance
EBA publishes benchmarking report on remuneration and the gender pay gap

On 15 April 2025, the European Banking Authority (EBA) published its benchmarking report on remuneration and gender pay gap for institutions and investment firms.
Background
The EBA collects remuneration and gender pay gap data from national competent authorities for benchmarking under the Capital Requirements Directive and the Investment Firms Directive (IFD)…
Failure to prevent fraud: five key steps for regulated financial services firms
The new failure to prevent fraud offence is due to come into force during 2025. In broad terms, in respect of the financial services community, it will mean that regulated firms of a certain size could be at risk in the event that fraud is committed for their benefit or the benefit of their clients…
Patisserie Valerie charges preview impact of new failure to prevent fraud offence
The recent Patisserie Valerie charges against four individuals provide a preview of the type of scenario in which companies could be investigated under the new failure to prevent fraud offence as well as the expanded test for corporate criminal liability. In this blog, we outline the charges brought by the SFO, provide an update…
FCA Consultation Paper 23/11 ‘Remuneration: Enhancing proportionality for dual-regulated firms’

On 12 May 2023, the FCA published Consultation Paper 23/11 ‘Remuneration: Enhancing proportionality for dual-regulated firms’ (CP23/11).
The FCA implemented remuneration provisions for dual-regulated firms in the dual-regulated firms Remuneration Code (SYSC 19D). These requirements are similar to PRA rules in the Remuneration Part of its Rulebook. The FCA has three…
PRA publishes Policy Statement on moving Senior Managers Regime forms from the PRA Rulebook

On 9 May 2023, the Prudential Regulation Authority (PRA) published Policy Statement PS4/23: Moving Senior Managers Regime forms from the PRA Rulebook. PS4/23 provides feedback to responses to Consultation Paper CP2/23 and contains the PRA’s final policy on its proposed changes to the Senior Managers Regime (SMR) forms.
Previous consultation…
FCA and PRA publish joint Discussion Paper on the review of the SMCR

On 30 March 2023, the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (PRA) jointly published Discussion Paper 1/23: Review of the Senior Managers and Certification Regime (DP23/3). DP23/3 follows the Government’s announcement in December 2022, as part of the Edinburgh Reforms, that HM Treasury, the FCA and…
HM Treasury publishes SMCR Call for Evidence

On 30 March 2023, HM Treasury published a Call for Evidence (CfE) on the Senior Managers and Certification Regime (SMCR). The CfE follows the Government’s announcement in December 2022, as part of the Edinburgh Reforms, that HM Treasury, the Financial Conduct Authority (FCA) and the Prudential Regulation Authority (…
PS1/23 – Remuneration: Unvested pay, Material Risk Takers and public appointments
On 10 February 2023, the PRA published Policy Statement 1/23 ‘Remuneration: Unvested pay, Material Risk Takers and public appointments’ (PS1/23).
PS1/23 is relevant to PRA authorised banks, building societies, PRA-designated investment firms, including third country branches, that are subject to the Remuneration Part of the PRA Rulebook. In PS1/23 the PRA provides feedback…
Edinburgh Reforms – SMCR
As part of the Edinburgh Reforms the Chancellor of the Exchequer issued a Ministerial Statement which announced that the Government would launch a review of the Senior Managers and Certification Regime (SMCR) in Q1 2023. The SMCR was introduced by The Financial Services (Banking Reform) Act 2013 (which amended the Financial Services and…







