This page explains which substantive and technical requirements need to be met to comply with the new remuneration reporting for credit institutions and investment institutions. We will be adding further information to this page on an ongoing basis.

The remuneration reporting required under the Capital Requirements Directive (Directive 2013/36/EU – CRD) and the Investment Firms Directive (Directive (EU) 2019/2034 – IFD) were comprehensively reworked as at the reporting date of 31 December 2022 to reflect the amendments made to the underlying EBA guidelines.

Reporting requirements

Remuneration reports by credit institutions are governed by the requirements set out in Section 24(1a) numbers 5 and 6 of the Banking Act (Kreditwesengesetz) as well as additional reporting obligations under the CRD; those filed by investment firms are based on Section 66(3) in conjunction with Section 65(2) numbers 2 and 3 of the Investment Institutions Act (Wertpapierinstitutsgesetz) and the IFD. The requirements under Section 9a of the Reports Regulation (Anzeigenverordnung) in the version of 29 November 2022 should not be applied to these reports as at the reporting date of 31 December 2022. The Federal Financial Supervisory Authority (BaFin) or the Bundesbank will be providing details on the arrangements governing reports as at the reporting date of 31 December 2022 in due course. On 8 February 2023, the Federal Financial Supervisory Authority (BaFin) published a draft general administrative act for credit institutions for consultation.

Scope

The following institutions generally fall within the scope of the remuneration reporting under the Banking Act:

• CRR credit institutions or their superordinated enterprises;
• institutions within the meaning of Section 53(1) of the Banking Act that conduct deposit business;
• large investment institutions.

Medium-sized investment institutions generally fall within the scope of remuneration reporting under the Investment Institutions Act.

In a departure from this, there is a distinct scope of application for each type of report. In particular, the report on benchmarking remuneration practices and the gender pay gap concerns only a minority of institutions. BaFin or the Bundesbank will be providing details on the arrangements governing the reporting in due course.

Submission deadlines

A transitional arrangement will be in force for submission deadlines in 2023. Reports in respect of remuneration benchmarking (REM BM), approved higher ratios (REM HR) and high earners (REM HE) as at the reporting date of 31 December 2022 will therefore have to be submitted by 31 August 2023. Starting from the reporting date of 31 December 2023, each of these reports must be submitted by 15 June of the following year.

The gender pay gap (REM GAP) report must be submitted every three years, starting from the reporting date of 31 December 2023 with submission by 15 June 2024 at the latest.

Information on paperless submissions

Credit institutions and investment institutions are expected to submit remuneration reports to the Bundesbank electronically. The Bundesbank will only accept electronic reports submitted via the Bank’s ExtraNet in XBRL (Extensible Business Reporting Language) format, though a special arrangement is in place for medium-sized investment institutions as outlined below. It will no longer be possible to use the VAM templates to declare high earners, nor will it be necessary to submit nil reports in future.

Special arrangement for medium-sized investment institutions declaring high earners (REM HE) as at the reporting date of 31 December 2022

A special arrangement exists for medium-sized investment institutions with management board members, members of the administrative or supervisory board and staff members who each were awarded total remuneration of €1 million or more for the previous financial year (high earners) and whose information is not already contained in a notification submitted on a consolidated basis by a superordinated enterprise. Instead of submitting reports in XBRL format, these investment institutions will be allowed to do so electronically using an Excel file as at the reporting date of 31 December 2022. The Bundesbank will be providing details on the arrangements governing the reporting in due course.

This special arrangement will no longer be available as from the reporting date of 31 December 2023 – starting from that reporting date, these submissions will also have to be made in XBRL format.