Dual-regulated firms Remuneration Code (SYSC 19D)

Find out how the Remuneration Code (SYSC 19D) applies to dual-regulated firms, comprising banks, building societies and PRA-designated investment firms, including UK branches of non-UK headquartered firms.

Publication of PS23/17: Remuneration: Enhancing proportionality for small firms and updates to FCA Finalised Guidance

On 5 December 2023, the FCA published PS23/17 setting out our joint rule changes with the Prudential Regulation Authority (PRA) to enhance proportionality for dual regulated firms. We also made minor changes to our current rules to address some differences between the FCA Handbook and the PRA Rulebook.

Alongside this, we made a number of consequential amendments to our existing non-Handbook guidance to reflect the rules changes in PS23/17. Specifically:

  • The Dual-regulated firms Remuneration Code (SYSC 19D) – Frequently asked questions on remuneration (FG23/4) to reflect the amendments to the application of proportionality.
  • The General Guidance on Proportionality (FG23/5) which includes amending the description of the three proportionality levels to reflect the new thresholds for application.
  • The General guidance on the application of ex-post risk adjustment to variable remuneration (FG23/6). This includes guidance on both malus and clawback, alongside in-year adjustments to variable remuneration. 

Publication of PS23/15: Remuneration: Ratio between fixed and variable components of total remuneration

On 24 October 2023, the FCA published a policy statement PS23/15 setting out our joint rule changes with the Prudential Regulation Authority (PRA) to remove the existing limits on the ratio between fixed and variable components of total remuneration (‘the bonus cap’). 

Publication of PRA (PS28/21) Remuneration: Identification of material risk takers

On 17 December 2021, the PRA published changes in PS28/21 to the approach dual-regulated firms must take to identify material risk takers. These changes include the revocation of the onshored PRA version of Commission Delegated Regulation (EU) No 604/2014 and insertion of the provisions of the revised Commission Delegated Regulation (EU) 2021/923 (MRT Regulation), as adopted by the European Commission on Wednesday 9 June 2021, into the Remuneration Part of the PRA Rulebook.

We have published guidance to address some of the frequently asked questions we receive from firms. This guidance gives firms some practical guidance to understand how the EBA Guidelines on sound remuneration policies are relevant to them, and gives additional clarification on our remuneration code.

Firms should read this guidance in conjunction with our remuneration code, proportionality guidance, and the EBA Guidelines to help understand how the requirements apply to them.

In Brexit: our approach to EU non-legislative materials, we explain how we expect firms to continue to apply guidelines to the extent that they remain relevant.


The Dual-regulated firms Remuneration Code (SYSC 19D) (the Code) sets out the standards and policies that dual-regulated firms must meet when setting pay and bonuses for their staff.

The extent to which the Code applies depends on whether firms and individuals meet the relevant proportionality thresholds. Our General guidance on proportionality: the Dual-regulated firms Remuneration Code (SYSC 19D) provides more information on this and sets out that a firm should comply with the Code in a way that is appropriate to its size, internal organisation and the nature, the scope and the complexity of its activities.

Ex-post risk adjustment

Firms must make sure that variable remuneration is only paid or allowed to vest where sustainable and justified by performance, subject to clawback. 

Ex-post risk adjustment refers to the reduction, cancellation or recovery of variable remuneration to take account of crystallised risks or adverse performance outcomes, including those relating to misconduct.

This provides a balancing mechanism for firms to reduce, cancel or recover awards to the extent that these awards are no longer justified by performance, once risk and performance outcomes become known. 

We have published General guidance on the application of ex-post risk adjustment to variable remuneration to share the latest good practice and to clarify our expectations on how relevant firms meet the Remuneration Code requirements in this area.

Supervisory approach

For dual-regulated firms, we are responsible for setting and overseeing implementation of remuneration requirements from a conduct perspective. These are set out in our Dual-regulated firms Remuneration Code (SYSC 19D). 

Firms’ remuneration and recognition practices are important drivers of culture. We pay close attention to them as we assess the way firms focus on embedding and maintaining healthy cultures. 

Throughout the year, our supervisory teams assess and review how firms reward staff, and the behaviour this drives, through our approach to supervising firms. 

We coordinate our supervisory activities with the PRA. Although each regulator has its own areas of focus, both regulators must be happy that the approach of each proportionality Level 1 firm to setting its awards is consistent with our requirements. 

In October 2023, we wrote to the Remuneration Committee Chairs of level one firms to highlight some areas for firms to consider when setting their remuneration policies and practices. The letter includes ensuring remuneration policies and practices incentivise a consumer-centred approach that ensures good outcomes for consumers across all products and services.

The linked letters under 'More information and guidance' set out observations and findings from previous annual remuneration rounds.

Self-assessment templates and tables

Dual-regulated firms can use the Remuneration Policy Statement (RPS) templates and tables available on the Bank of England’s website to record remuneration policies, practices and procedures and assess compliance with the Code.

Firms subject to annual review by us, should submit the completed RPS and tables to their usual supervisory contact, noting the requested submission schedule set out in the RPS.


The EBA revised its Guidelines on the data collection exercise on high earners and remuneration benchmarking in 2014. Firms must provide remuneration data annually on high earners and benchmarking.

In Brexit: our approach to EU non-legislative materials, we explain how we expect firms to continue to apply guidelines to the extent that they remain relevant.

Please also see the UK version of Article 450 of the Capital Requirements Regulation (CRR) for the disclosure requirements regarding your firm’s remuneration policy and practices.

Page updates

: Information changed Updated Finalised Guidances
: Publication added CP23/11
: Information added Publication of PRA (CP5/23)
: Editorial amendment page update as part of website refresh
: Document update Dear Remuneration Committee Chair letter for 2022
: Information added following PRA's PS28/21 publication