The present User Guide for Remuneration Reporting, published on 3 July 2023 by the CSSF, specifies three CSSF Circulars that adopt EBA Guidelines on remuneration data collection exercises. These exercises are mandated by the CRD and IFD frameworks and encompass various aspects of remuneration practices.
The Circulars mentioned are:
1. Circular CSSF 23/836, adopting the EBA Guidelines on benchmarking exercises for remuneration practices, gender pay gap, and approved higher ratios under Directive 2013/36/EU.
2. Circular CSSF 23/838, adopting the EBA Guidelines on benchmarking exercises for remuneration practices and gender pay gap under Directive (EU) 2019/2034.
3. Circular CSSF 23/837, adopting the EBA Guidelines on data collection exercises regarding high earners under Directive 2013/36/EU and Directive (EU) 2019/2034.
Entities falling under the scope of these exercises include a sample of CRR institutions and non-SNI IFR investment firms, as well as all CRR institutions and non-SNI IFR investment firms. Additionally, CRR institutions with approved higher ratios according to Article 38-6 (1) (g) (ii) of the LFS must participate.
The reports for the remuneration data collection exercises must be submitted through either a structured file via S3 protocol or an online solution through dedicated eDesk procedures. After submission, an automatic analysis is performed, and warnings, if any, must be justified through the eDesk platform.
All reports must be provided in XBRL-XML format and transmitted via a compressed .zip file containing a single .xbrl file. The CSSF evaluates the submitted ZIP file to ensure compliance based on Formal Verification Rules provided in Annex I of the present guide.
Entities are advised to review and validate their files before submission and must ensure that any errors or rejected reports are corrected and re-submitted. The report status must be reviewed, and any XBRL warnings must be justified and submitted through the eDesk platform.
For technical questions, entities can contact it_division_analyse@cssf.lu, and for other inquiries, they can reach out to remuneration@cssf.lu.
The CSSF also provides an FAQ at the end of the present guide. Finally, Present Report Statuses and XBRL Analysis Statuses are listed in Annex II. XBRL Files and Tables Descriptions are available HERE as an .xlsx file.