Implementing the remuneration requirements of CRD V: Key actions for Level 3 firms

Following the effective date of CRD V in December 2020, the new Directive bought in a number of changes to remuneration requirements that are particularly impacting on Level 3 firms. These include:

• Introduction of the fixed to variable remuneration cap for all Material Risk Takers.
• Extension of the requirements around performance adjustment meaning that all variable remuneration awarded to Material Risk Takers should be subject to malus and clawback provisions.
• Changes to the identification of Material Risk Takers
• Application of the PRA’s requirements on buy-outs of unvested variable remuneration for new joiners.
• Changes to the tests for determining your firm’s proportionality status.
• Updating relevant policy documentation to reflect the enhanced CRD V requirements.

As we near the end of the calendar year, we’ve produced the attached document to act as a helpful checklist highlighting key actions that Level 3 firms will want to consider to ensure compliance with CRD V, particularly when determining performance outcomes for the 2021 financial year.