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

The CSSF has recently released three circulars, namely CSSF 23/836, CSSF 23/837, and CSSF 23/838, which adopt EBA’s guidelines on remuneration data collection exercises for banks and investment firms. These guidelines serve to organize the remuneration data collection exercises in accordance with the CRD and the IFD frameworks.
Circular CSSF 23/836 adopts the EBA guidelines on benchmarking exercises for remuneration practices, gender pay gap, and approved higher ratios under Directive 2013/36/EU (EBA/GL/2022/06). This exercise will be conducted annually, with the first data collection taking place in 2023 for the financial year 2022.
Circular CSSF 23/837 adopts the EBA guidelines on data collection exercises regarding high earners under Directive 2013/36/EU and Directive (EU) 2019/2034 (EBA/GL/2022/08). This exercise will focus on high earners earning more than €1 million and will be conducted annually for both CRR institutions and non-SNI IFR investment firms, with the first data collection set for 2023 for the financial year 2022.
Circular CSSF 23/838 adopts the EBA guidelines on benchmarking exercises for remuneration practices and the gender pay gap under Directive (EU) 2019/2034 (EBA/GL/2022/07). Similarly, this exercise will be conducted annually, with the first data collection scheduled for 2023 for the financial year 2022.
It is worth noting that the data collection format for these exercises will transition from Excel to XBRL, starting from the 2023 data collection exercises for the financial year 2022. Entities within the scope of the EBA exercises will receive notification letters regarding their participation in due course.
In addition to the EBA exercises, the CSSF will continue to carry out national data collection exercises with a broader range of entities as part of its supervisory responsibilities outlined in the Law of 5 April 1993 on the financial sector, as amended.
For further inquiries or questions, interested parties can contact the CSSF via email to remuneration@cssf.lu.