The requirements set out in the instructions and tables are completely overshooting the objectives set out in EBA Guidelines on sound remuneration policies under Articles 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU) No 575/2013.
Proposed questions do not require disclosure of “sufficient general information” as set out in mentioned regulation, but require detailed information not necessary to have in such detail in the Remuneration Policy. They require a disclosure of names, mandates, detailed description of performance management linked to variable remuneration, bonus pool guidelines, explanations on internal rules, internal governance, and the entire cycle of HR policies and practices, as mentioned, not only required by the Remuneration Policy.
Proposed tables and templates do not provide a clear distinction between management levels. As credit-institutions internal organization consists of multi-level hierarchies, a clear terminology needs to be used (e.g. instead of “management function”-“management board”, etc.). It is not clear how tables are connected to each other, in order to first of all understand the requirements and finally provide consistent reporting (e.g. some tables have totals, some not).
Throughout all the tables it is not clear whether there is request for Headcount or FTE number, when it comes to the employees. The terminology used will cause misunderstanding of requirements (e.g. guaranteed variable remuneration is not aloud, only in a form of first year sign-on bonus), therefore more to the point and clear terminology would be necessary. Following this terminology, the disclosure tables should be understood as trick questions, and would lead to incorrect reporting. The questionnaires need to take into account that the tables need to be filled in by many entities, therefore very simple, clear terminology is paramount. A clear distinction needs to be made between the number of staff and amount of payment, when it comes to special payments. Preferably changing the structure of the sentence in a way that it is very obvious.
Throughout all the tables it is not clear whether the historical payments are necessary, or the payout year, it needs to be kept in mind when variable remuneration can be paid out for a performance year. The timeline of the requirements needs to be more clearly specified.
In the table: Remuneration awarded for the financial year – the requirements with regards to separation of deferred parts per type, are structured in an unnecessarily complicated way (e.g. instead of asking for a deferral after each type, we would propose – amount of deferral – of which cash, or instruments, etc.)
Template REM 3: Deferred remuneration – is misleading and unclear. It is not clear whether outstanding payments are required from previous years, payout in the reporting year or future payments. The timeline for reporting is completely unclear. We would recommend moving the types of employees to the columns and requirements and types of payments to rows, for more clear understanding of requirements.
Two tables Rem1 and Rem5 have overlapping requirements for MRT’s, but not keeping the consistency of reporting (e.g. what is the point of reporting identified staff per business areas and then in the other table asking to classify them in one column as “other identified staff”, when a simple sum formula can be added to the first table to provide this figure). Overall the amount of information requested in the tables, as well as lack consistency between the tables will overcomplicate the entire process and lead to incorrect reporting.
REM4: Remuneration of 1 million EUR or more per year – again no clarification of what value needs to be entered (Headcount or FTE).
Recommendation: if additional reporting requirements are required, we recommend the use of old tables which would be amended accordingly. The process of disclosure requires a complicated coordination on a group level, instruction and guidance for the consolidated subsidiaries, etc. therefore sticking to “old” (from previous years) templates which would be only supplemented by necessary requirements by new regulation would be more user friendly and would enable institutions to successfully reach the objectives of the disclosure on remuneration policy.
For REM3: deferred remuneration – it would be beneficial and helpful institutions could be provided with an example of what needs to be reported in which column, as the table is hard to read.
Marking remuneration in a graphic (such as one below) and linking to the specific cell in the table, as well as giving an example of years (timeline) would provide much needed clarity.

In order to compose mentioned templates, one must have a detailed understanding of the payroll systems, calculations and administration. Please, refer to the answer above for more details.

No, we do not agree. As already mentioned, the requirements set out in the instructions and tables are overshooting the objectives set out in EBA Guidelines on sound remuneration policies under Articles 74(3) and 75(2) of Directive 2013/36/EU and disclosures under Article 450 of Regulation (EU) No 575/2013.