Insights from the EBA Report on Gender-Neutral Remuneration Policies and the EU Pay Transparency Directive
The Capital Requirements Directive 2013/36/EU and the Investment Firms Directive 2019/34/EU (and relevant EBA sound remuneration Guidelines) require that relevant institutions have gender-neutral remuneration policies. Both Directives require the EBA to report on the application of these policies within two years of the Guidelines, and the EBA has just published its report on this on 16 July 2024. The Report is based on data up to 15 December 2023 on 254 banking firms and 99 investment firms.
Our newsletter highlights key findings of the Report with a focus on the requirements for firms to: (i) appropriately document the value of positions; and to (ii) monitor the gender pay gap over time. Those requirements will resonate with firms preparing for the upcoming EU Pay Transparency Directive (“EUPTD”), which will be in force from 7 June 2026 (see our dedicated webpage). Our newsletter highlights some of the key findings of the Report which overlap with the upcoming obligations for firms under the EUPTD, as well as our experience when advising many firms on those issues.
The key take-way is that with multiple “watchdogs”, addressing the gender pay gap is a more critical priority for the financial sector than ever before. We have extensive sector market expertise to assist clients in their journey; reach out for more details on our service offering.

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