2024_7128 Components included in total gross annual earnings used for the calculation of gender pay gap

Question ID: 2024_7128
Legal act: Directive 2013/36/EU (CRD)
Topic: Remuneration
Article: 75
Paragraph: 2
COM Delegated or Implementing Acts/RTS/ITS/GLs/Recommendations: EBA/GL/2021/04 - Guidelines on sound remuneration policies under CRD (repealing EBA/GL/2015/22)
Article/Paragraph: 5.2
Type of submitter: Credit institution
Subject matter: Components included in total gross annual earnings used for the calculation of gender pay gap
Question: Should overtime pay awarded to staff members be included in their total gross annual remuneration for the purposes of calculating the gender pay gap?
Background on the question: As per the Guidelines published on sound remuneration policies (EBA/GL/2021/04) and on benchmarking exercises on remuneration practices, the gender pay gap and approved higher ratios under Directive 2013/36/EU (EBA/GL/2022/06), it is not clear as to whether overtime pay should be taken into account in the total gross annual remuneration.
Submission date: 28/06/2024
Status: Question under review
Answer prepared by: Answer prepared by the EBA.