Question ID
2025_7407
Legal act
Directive 2013/36/EU (CRD)
Topic
Supervisory reporting - Supervisory Benchmarking
Article
41
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations
Draft ITS on Supervisory Reporting of Institutions (for benchmarking the internal approaches)
Article/Paragraph
41
Type of submitter
Consultancy firm
Subject matter
EBA Remuneration Diversity Benchmarking - R23.00 - Reporting of not applicable (n/a) gender pay gap
Question

What should be reported in template R23.00 if the gender pay gap cannot be calculated?

Background on the question

As per the final report on the Guidelines on benchmarking of diversity practices, including diversity policies and gender pay gap, under Directive 2013/36/EU and Directive (EU) 2019/2034 "When the gender pay gap between male and female members or the pay gap between male and non-binary members cannot be calculated as the category does not contain both of the respective genders, institutions and investment firms should provide the value ‘n/a’ (not available) instead of calculating the percentage."

This is contradictory with the defined metric type (pi935, pi936) because "n/a" cannot be considered as a percentage item, since it is a string.

Also, in the template layout, the following is stated: "[4] Or if it cannot be calculated, as the below category does not comprise male and female directors, please indicate not-available (n/a)".

Submission date
Rejected publishing date
Rationale for rejection

This question has been rejected because the matter it refers to has already been identified and will be considered for a forthcoming version of the Reporting framework / release of the respective validation rules.

Status
Rejected question