Publication of Circulars CSSF 23/836, CSSF 23/837 and CSSF 23/838 adopting the Guidelines on the European Banking Authority’s remuneration data collection exercises for Banks and Investment firms
On 26 May 2023, the CSSF has published the following three Circulars, adopting the Guidelines of the European Banking Authority (“EBA”) on remuneration data collection exercises:
- Circular CSSF 23/836 adopting the EBA Guidelines on the benchmarking exercises on remuneration practices, the gender pay gap and approved higher ratios under Directive 2013/36/EU (“EBA/GL/2022/06”);
- Circular CSSF 23/838 adopting the EBA Guidelines on the benchmarking exercises on remuneration practices and the gender pay gap under Directive (EU) 2019/2034 (“EBA/GL/2022/07”); and
- Circular CSSF 23/837 adopting the EBA Guidelines on the data collection exercises regarding high earners under Directive 2013/36/EU and under Directive (EU) 2019/2034 (“EBA/GL/2022/08”)
These Guidelines organise the remuneration data collection exercises, as mandated by requirements in the CRD and IFD frameworks.
Entities that are in scope of the EBA exercises will be informed by letter in due course.
Additionally, we want to already inform entities that the data collection format will be XBRL rather than Excel, starting from the data collection exercises in 2023 for financial year 2022.
The EBA data collection exercises and frequencies of these exercises are listed in the table below.
Circular CSSF 23/836
| Exercise | Frequency | First data collection |
| Remuneration benchmarking of a sample of CRR institutions | annually | 2023 for financial year 2022 |
| Gender pay gap data collection of a sample of CRR institutions | every three years | 2024 for financial year 2023 |
| Approved higher ratios data collection of all CRR institutions that have approval | every two years | 2023 for financial year 2022 |
Circular CSSF 23/838
| Exercise | Frequency | First data collection |
| Remuneration benchmarking of a sample of non-SNI IFR investment firms | annually | 2023 for financial year 2022 |
| Gender pay gap data collection of a sample of non-SNI IFR investment firms | every three years | 2024 for financial year 2023 |
Circular CSSF 23/837
| Exercise | Frequency | First data collection |
| High earners (earning more than €1m) data collection of CRR institutions | annually | 2023 for financial year 2022 |
| High earners (earning more than €1m) data collection of non-SNI IFR investment firms | annually | 2023 for financial year 2022 |
Finally, we would like to inform you that the CSSF will continue to conduct national data collection exercises including a wider scope of entities, in line with its supervisory role detailed in Articles 38-10 and 38-24 of the Law of 5 April 1993 on the financial sector, as amended.
If you have any questions, please contact us via the following email address: remuneration@cssf.lu.