2015年-EBA欧洲银行管理局_Report_on_Benchmarking_of_Remuneration_and_on_High_Earners_2013_74页_2mb

EBA Report Summary: Benchmarking of Remuneration Practices and Data on High Earners

Core Content

This report by the European Banking Authority (EBA) provides an analysis of remuneration practices across the European Union (EU) and aggregated data on high earners, defined as individuals earning EUR 1 million or more per financial year. The findings are based on data collected for the year 2013, in accordance with updated EBA guidelines, and reflect the impact of the Capital Requirements Directive IV (CRD IV) and its related Regulatory Technical Standards (RTS).

Main Viewpoints

• Remuneration Benchmarking: The EBA benchmarks remuneration trends at the Union level and publishes aggregated data on high earners.
• High Earners: The number of high earners in the EU decreased from 3530 in 2012 to 3178 in 2013, influenced by exchange rate fluctuations and institutional profitability.
• Identified Staff: Identified staff are those with a material impact on an institution’s risk profile. The percentage of high earners who are identified staff increased slightly over time, from 54% in 2012 to 59% in 2013.
• Remuneration Structure: The variable-to-fixed remuneration ratio for identified staff decreased to 104% in 2013, indicating a shift toward more fixed remuneration. This trend is expected to continue under CRD IV, which introduced a bonus cap of 100% (200% if approved by shareholders).
• Data Collection and Analysis: The EBA collects data at the highest level of consolidation, ensuring comprehensive coverage across the EU. The data includes information on the type of remuneration, deferral arrangements, and specific elements like guaranteed variable remuneration and severance payments.
• Regional Variations: The United Kingdom has the largest number of high earners in the EU, with a significantly higher proportion of high earners being identified staff compared to other Member States. The proportion of identified staff among high earners varies by business area, with investment banking and asset management showing lower percentages.

Key Information

1. Benchmarking of Remuneration Practices at Union Level and Data on High Earners

1.1 Background

• CRD IV and CRD III: Both directives introduced requirements for remuneration benchmarking and data collection on high earners.
• EBA Guidelines: Updated in July 2014 to align with CRD IV and CRR disclosure requirements.
• Data Coverage: At least 60% of the EU banking system (by total assets) is covered by data collection in each Member State.
• Voluntary Participation: One EEA Member State participated voluntarily in the benchmarking exercise.
• Data Collection Scope: Excludes staff predominantly active in third countries and includes all staff earning EUR 1 million or more in total remuneration.

1.2 Data Collected for Benchmarking and on High Earners

• High Earners: Defined as individuals earning EUR 1 million or more per financial year.
• Data Aggregation: Includes information on business area, payment brackets, and remuneration components.
• Data Sources: Collected from 140 groups and institutions, with some data collected at the group level.
• Proportionality Considerations: Some institutions waived deferral and pay-out in instruments for certain staff, particularly smaller ones.

1.3 Analysis of Remuneration Data

• Trends: The number of high earners decreased due to exchange rate changes and profitability trends.
• Identified Staff: The proportion of identified staff among high earners increased slightly, but still varied significantly by Member State and business area.
• Remuneration Components: Analysis of variable-to-fixed remuneration ratios, deferred variable remuneration, and other elements like guaranteed variable remuneration and severance payments.
• CRD IV Impact: The bonus cap introduced by CRD IV is expected to further reduce variable remuneration ratios in future reports.

1.4 EBA's Other Work on Remuneration

• Role-Based Allowances: Some institutions introduced allowances that were later classified as variable remuneration.
• Guidelines on Sound Remuneration Policies: A consultation paper was published in March 2015 to clarify remuneration categorisation and ratios.
• Proportionality Principle: The EBA is analyzing how Member States implement the proportionality principle and will provide recommendations for amendments to CRD IV.
• Review of Remuneration Provisions: The EBA is collaborating with the European Commission on reviewing remuneration provisions under Article 161 of the CRD IV, with a review report due by June 2016.

2. Remuneration Practices in the EU

2.1 Remuneration of High Earners

• Definition: High earners are those earning EUR 1 million or more in total remuneration.
• Exchange Rate Impact: The EUR-GBP exchange rate significantly influenced the number of high earners, particularly in the UK.
• Identification Criteria: Under the RTS, staff earning EUR 500,000 or more are generally considered identified staff, unless excluded based on risk impact analysis.

2.2 Remuneration Benchmarking Exercise

• Sample and Trends: Data were collected from 140 groups and institutions, showing trends in remuneration structures.
• Identified Staff: The percentage of identified staff among high earners varied between 52% and 94% across Member States.
• Payment Brackets: Data on high earners are broken down by payment brackets, providing insights into remuneration distribution.

Key Figures

• Figure 1: Shows the development of the number of high earners and EUR-GBP exchange rate.
• Figure 2: Displays the number of high earners by Member State (logarithmic scale).
• Figure 3: Indicates the percentage of high earners relative to total staff by Member State.
• Figure 4: Compares the total number of high earners and identified staff in the EU.
• Figure 5: Breaks down high earners by business area or function.
• Figure 6: Shows the percentage of high earners who are identified staff by Member State.
• Figure 7-8: Compares variable-to-fixed remuneration ratios and deferred variable remuneration ratios.
• Figure 9-10: Displays remuneration by payment bracket and deferral rates.
• Figure 11-13: Covers variable remuneration composition and ex post risk adjustments.
• Figure 14-16: Shows fixed and variable remuneration composition by business area.
• Figure 17-22: Provides insights into the distribution of remuneration elements and their impact on identified staff.

Conclusion

The EBA continues to monitor and report on remuneration practices across the EU, with a focus on high earners and identified staff. The implementation of CRD IV has led to more harmonized remuneration policies, particularly with the introduction of the bonus cap. Future reports will reflect the full impact of these regulations, especially as the RTS on identified staff are applied from 2014 onwards. The EBA is also working on updating its guidelines and providing input to the European Commission on remuneration provisions.