The European Banking Authority (EBA) has today published final guidelines on sound remuneration policies.
Firms should note that the implementation date for the Guidelines is now 1 January 2017 and the rules will first apply to the 2017 performance year. Firms will not need to change their existing pay practices for the 2016 performance year.
Key changes since the consultation version of the Guidelines include:
- The restatement of the proportionality principle under Article 92(2) CRD except in relation to the bonus cap
- Changes to the guidelines on long term incentive plans, with valuation of LTIPs at award rather than at vesting
- Clarifications as to how the guidelines apply to carried interest payments
As with all ESA guidelines, there are implementation processes for competent authorities to which we will respond in due course. The FCA, in conjunction with the PRA and HMT, will review the changes proposed by the Guidelines and their application to the UK market, and will consult on any necessary changes to our domestic rules and guidance.
The EBA also published an Opinion to the European Commission on proposals to amend CRD IV to clarify the scope of the proportionality principle.