On November 1, the FSA published policy statement 12/18 ‘Data collection on remuneration policies’ (PS12/18). PS12/18 sets out the FSA’s rules in line with the requirements in the capital requirements directive CRD3 and the EBA’s guidelines on a Benchmarking Information Report and the High Earners Report to be submitted by firms annually, and follows the FSA’s consultation CP12/18.

The Benchmarking Information Report requires firms to provide certain information in respect of Remuneration Code Staff in their group, including the number of Code Staff in each business division and total remuneration for Code Staff in each business division broken down by fixed and variable remuneration in cash and shares.

The High Earner Report requires firms to submit data on all employees in their group (excluding subsidiaries and branches established outside the EEA) with total annual remuneration of EUR 1 million or more, and the total number of High Earners split between Code Staff and non-Code Staff in each business division.

Both reports apply to banks, building societies and investment firms, but not to BIPRU limited licence and BIPRU limited activity firms (unless these firms are part of a group that does fall in scope). Firms should file two versions of each report by December 31 – one for each of the last two complete financial years. Thereafter firms required to submit a report annually, within four months of their accounting year end.