Alternative Investment Managers Remuneration Code (SYSC 19B)

Find out more on Alternative Investment Fund Managers Remuneration Code (SYSC 19B) and how it applies to a full-scope UK Alternative Investment Fund Manager of both UK and non-UK AIFs (full-scope UK AIFMs).


The AIFM Remuneration Code (the Code) sets out the standards and policies that full-scope UK AIFMs must meet when setting pay and bonus awards for their staff.

More details on how full-scope UK AIFMs can comply with the remuneration requirements derived from the AIFMD are set out in the ESMA Guidelines on sound remuneration policies under the AIFMD which continue to apply to the extent they remain relevant. This is consistent with out general approach to guidelines set out in Brexit: our approach to EU non-legislative materials.

We have adopted a proportionate approach to implementing the AIFM Remuneration Code. This approach is set out in General guidance on the AIFM Remuneration Code (SYSC 19B). The guidance explains that the AIFM remuneration proportionality rule in SYSC 19B requires full-scope UK AIFMs to comply with the Code in a way and to the extent that is appropriate to their:

  • size
  • internal organisation, and
  • the nature, scope and complexity of their activities

Our guidance on the AIFM Remuneration Code includes more information on application to partnership structures, payment in units, shares or other instruments, as well as other guidance on remuneration.

Pay-out process rules

Non-cash instruments

There may be circumstances where making awards in non-cash instruments linked to the AIF may be impractical or disproportionate and where non-cash instruments linked to the AIFM may be justified instead.

Where a firm can justify that this is the case, it may use suitable non-cash instruments linked to:

  • the AIFM or its parent company, or
  • to the performance of a weighted average of the AIFs managed by the AIFM

Where the management of AIFs accounts for less than 50% of the total portfolio managed by the AIFM, the requirement to award at least 50% of any variable remuneration in non-cash instruments does not apply.

This means that firms may determine a lower appropriate minimum level for their firm (SYSC19B.1.17R(1)).

For more details on the justifications and types of non-cash instrument that we would consider to be acceptable, please see Section 5 'Remuneration in the form of units, shares or other instruments' of the guidance document.

This doesn't affect our existing guidance, which may allow for the disapplication of certain requirements for a firm that is not significant (see Section 3 of the guidance), or for particular individuals awarded variable remuneration below the thresholds set out in SYSC19B.1.13AG.

Self-assessment template and tables for Alternative Investment Fund Mangers

Use our RPS template for AIFMs to record your remuneration policies, practices and procedures and assess compliance with the Code.

Our RPS table for AIFMs allows you to keep a record of all AIFM Remuneration Code staff identified for the current performance year.

Page updates

: Editorial amendment page update as part of website refresh
: Information changed AIFM Remuneration Code information updated.
: Link changed RPS template and table for AIFMs