IFPRU Remuneration Code (SYSC 19A)

Frequently asked questions guidance

FG20/6: IFPRU investment firms Remuneration Code (SYSC 19A): FAQs on remuneration (PDF)

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 Codes, 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.

Proportionality

The IFPRU Remuneration Code (SYSC 19A) (the Code) sets out the standards and policies that solo-regulated IFPRU investment firms, within scope of CRD IV, must meet when setting pay and bonuses for their staff.

We have adopted a proportionate approach to implementing the IFPRU Remuneration Code and Remuneration Disclosure, which implemented the Capital Requirements Directive (CRD) IV and the Capital Requirements Regulation (CRR). This approach is set out in our General guidance on proportionality: The IFPRU​ Remuneration Code (SYSC 19A), which allows a firm to comply with the Code in a way and to the extent that is appropriate to their:

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

Self-assessment templates and tables

Solo-regulated firms can use our Remuneration Policy Statement (RPS) templates to record remuneration policies, practices and procedures and assess compliance with the Code.

Solo-regulated IFPRU firms:

• RPS template (Word file)
• RPS table (Excel file)

Material risk taker exclusions

The UK version of the Commission Delegated Regulation (EU) No 604/2014 and relevant provisions of the Remuneration Codes (SYSC 19) include requirements on the identification of relevant individuals as material risk takers (MRTs), also referred to as Code staff or identified staff.

If you wish to notify or seek prior approval from us to exclude individuals from identification as an MRT, in accordance with the UK version of Article 4 of the Regulation, you can download our 'MRT exclusion' template.

Please email the completed form and any supporting documents to [email protected].

Disclosure

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.

More information and guidance

• General Guidance on Proportionality: the Remuneration Code (SYSC 19A)
• FG20/6: IFPRU investment firms Remuneration Code (SYSC 19A): FAQs on remuneration (PDF)
• EBA Guidelines on Sound Remuneration Policies under Articles 74(3) and 75(2) of CRD IV and disclosures under Article 450 of CRR
• FCA and PRA statement on compliance with the Guidelines on Sound Remuneration Policies
• Brexit: our approach to EU non-legislative materials