This page explains the substantive and technical requirements that need to be met in order to comply with the remuneration reporting for credit institutions and investment institutions. Further information will be added to this page on an ongoing basis.

The remuneration reporting required in the Capital Requirements Directive (Directive 2013/36/EU – CRD) and the Investment Firms Directive (Directive (EU) 2019/2034 – IFD) is implemented in Germany in the Banking Act (Kreditwesengesetz – KWG), the Regulation Concerning Reports and the Submission of Documentation under the Banking Act (Anzeigenverordnung – AnzV, or the Reports Regulation) and, in future, the Act Implementing Directive (EU) 2019/2034 on the prudential supervision of investment institutions of 12 May 2021 (Gesetz zur Beaufsichtigung von Wertpapierinstituten – WpIG, or the Investment Institutions Act) as well as the Investment Institutions Reports Regulation (Wertpapierinstituts-Anzeigenverordnung – WpIAnzV). 

Reporting requirements

Remuneration reports filed by credit institutions are governed by the requirements set out in Section 24(1a) numbers 5 and 6 of the Banking Act (KWG) as well as additional reporting obligations under the CRD; those filed by investment institutions are based on Section 66(3) in conjunction with Section 65(2) numbers 2 and 3 of the Investment Institutions Act (WpIG) and the IFD. For credit institutions and their superordinated undertakings, the reporting requirements under Section 9a of the Reports Regulation (AnzV) in the version of 29 December 2023 should be applied to these reports as at the reporting date of 31 December 2024. Large investment institutions must apply the reporting requirements set out in Section 9a of the Reports Regulation (AnzV) accordingly; administrative acts are issued by BaFin for this purpose. For medium-sized investment institutions, BaFin will publish a general administrative act on REM HE reporting. Medium-sized investment institutions that are required to submit reports on remuneration benchmarking (REM BM) pursuant to the IFD will be requested to do so individually by BaFin.

Scope

The following institutions generally fall within the scope of remuneration reporting under the Banking Act (KWG) and the Reports Regulation (AnzV):

1. CRR credit institutions or their superordinated undertakings; 
2. institutions within the meaning of Section 53(1) of the Banking Act (KWG) that conduct deposit business; 
3. 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 small number of institutions. 

Submission deadlines

Starting from the reporting date of 31 December 2023, all of these reports must be submitted by 15 June of the following year. The reports are subject to differing reporting cycles, as shown in the following table.

Information on electronic 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. It is no longer necessary to submit nil reports.

Files in XBRL format are submitted via the ExtraNet filetransfer service using the mailbox “PRISMA – submission of bank and financial supervisory reports (ITS / RTF / BGR / CONTACT)”.

Any necessary initial or secondary registration must therefore be completed in the “Prudential returns” specialised procedure for the function also named “PRISMA – submission of bank and financial supervisory reports (ITS / RTF / BGR / CONTACT)”. 

It is recommended to also register for the function “PRISMA – feedback on banking and financial reporting (ITS / RTF / BGR / CONTACT)” in order to be able to download automated validation reports.