Diversity Benchmarking National analysis of reports on benchmarking of diversity practices

In 2023, the European Banking Authority (EBA) published guidelines for the benchmarking of diversity practices. On this basis, the Bundesbank examined diversity practices and strategies in the management bodies (management board and administrative or supervisory board) of 158 German CRR credit institutions, medium-sized and large investment firms as at the 31 December 2024 reporting date. Diverse composition of management bodies in terms of age, gender, geographical origin, and educational and professional background can reduce the risk of 'groupthink', strengthen risk control and improve institutions’ overall resilience.

Despite regulatory requirements, 52 out of 158 institutions do not have a diversity strategy, including individual significant institutions. Institutions with a diversity strategy have mostly set targets to support the underrepresented gender (83 %), of which around 70 % use quantitative targets. In many management boards, the target rates for the underrepresented gender were no more than 25 %. By contrast, administrative or supervisory boards set target ratios of over 25 % more frequently and achieved their targets more frequently overall.

Women are significantly underrepresented in the management bodies examined. Only 15.5 % of the members of management boards are female; a significant number of the institutions have no female management board members at all. At 26.8 %, the percentage of women on administrative or supervisory boards was significantly higher than in the management boards. The members of the management bodies are predominantly aged between 51 and 60. In management boards, training and career paths typical of the sector predominate, being degrees in business or economics, banking training and professional experience in the banking sector, whilst administrative or supervisory boards are more heterogeneous.

CRR credit institutions and investment firms must design their remuneration policies and practices in a gender-neutral manner. In practice, however, wage differentials exist across genders: On average, women receive around 5 % less remuneration than men in management boards (excluding chairs); on administrative or supervisory boards (excluding chairs/employee representatives) the average pay gap is smaller. Some institutions have pay gaps of more than 10 %, especially when it comes to management boards.

All CRR credit institutions and investment firms are required by European rules to promote diversity in their management bodies. Institutions without a diversity strategy must develop one in a timely manner and implement the associated measures. Significant CRR credit institutions should define quantitative targets for the presence of the underrepresented gender in their management bodies as part of their diversity strategy, and all other institutions should set at least qualitative targets. Moreover, institutions that already pursue quantitative objectives could make these more ambitious in order to further strengthen the presence of the underrepresented gender. Finally, all institutions must design their remuneration policies and practices in a gender-neutral manner and, where relevant, take appropriate measures to address any deficits.