Following the issuance of Circular C576 and the implementation of EBA's Guidelines on benchmarking exercises on remuneration practices and gender pay gap and Guidelines on data collection exercises regarding high earners , all CIFs with an initial capital requirement of €150,000.00 and €750,000.00 should note the following deadlines:
Deadline: 31 August 2023
Information on remuneration of all staff as set out in Annex I of the Guidelines
Additional information on remuneration for all identified staff as per Annex II and III of the Guidelines
Information on derogations as specified in Annex IV of the Guidelines
Deadline: 31 August 2023
High-earners data for the financial year ending 2022 should be submitted to CySEC by CIFs
Deadline: Commencing 2024, every three years by 15 June: CIFs should submit the following to CySEC:
Information on remuneration of all staff as set out in Annex I of the Guidelines
Additional information on remuneration for all identified staff as per Annex II and III of the Guidelines
Information on derogations as specified in Annex IV of the Guidelines
CIFs should submit to CySEC the information stipulated in Annex V of the Guidelines regarding the financial year 2023
CIFS should submit data to CySEC regarding high earners (staff members earning over EUR 1 million in remuneration in the reported financial year)
Note: the report should be done at a consolidation level; in the instance of stand-alone investment firms, high-earners data should be reported on an individual basis
*Note the above data must be submitted via CySEC's Xbrl Portal which will be updated accordingly on 30 June 2023*
CIFs are expected to consider both of the above Guidelines in full and take the necessary actions in order to ensure their compliance.
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By Andie Henderson, Legal & Compliance Associate, Financial Associates International (FAI Comply)