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The publication of Circular 576 announces CySEC’s adoption of EBA guidelines concerning the benchmarking exercises on remuneration practices and the gender pay gap (EBA/GL/2022/07), and the data collection exercises regarding high earners (EBA/GL/2022/08), incorporating them into the commission’s supervisory practices and regulatory approach.

CySEC urges CIFs to consider the abovementioned guidelines and, where necessary, to take actions to ensure compliance with their provisions.

Application of the Guidelines:

The aforesaid Guidelines apply to CIFs that fall under sections 9(1), (3) and (4) of the Prudential Supervision of Investment Firms Law of 2021, i.e. with initial capital requirement of €150,000 and €750,000.

New Reporting Obligations:

  1. Guidelines on benchmarking exercises on remuneration practices and gender pay gap

In relation to remuneration data, CIFs should by 15 June of each calendar year, submit to CySEC:

  • information on remuneration of all staff as set out in Annex I of the Guidelines on benchmarking exercises on remuneration practices and gender pay gap,
  • additional information on remuneration for identified staff as set out in Annex II and Annex III of the Guidelines on benchmarking exercises on remuneration practices and gender pay gap, and
  • information on derogations as specified in Annex IV of the Guidelines on benchmarking exercises on remuneration practices and gender pay gap.

In relation to gender pay data, CIFs should by 15 June every three years, starting from 2024, submit to CySEC, with regard to the financial year 2023, the information set out in Annex V of the Guidelines on benchmarking exercises on remuneration practices and gender pay gap.

Data concerning the Financial Year 2022:

The remuneration data, i.e. Annex I to IV of the Guidelines on benchmarking exercises on remuneration practices and gender pay gap, for the financial year ending in 2022, should be submitted by CIFs to CySEC though CySEC’s Xbrl Portal ONLY by Thursday the 31 August 2023.

  1. Guidelines on data collection exercises regarding high earners

CIFs should submit data to CySEC regarding high earners, ie. staff member(s) earning a remuneration of at least EUR 1 million in the reported financial year. Where a CIF does not have high earners to report, it is not necessary to submit this information, unless explicitly required by CySEC.

High-earners data should be submitted to CySEC each year for any given financial year by 15 June of the next calendar year.

Data concerning the Financial Year 2022:

The high-earners data for the financial year ending in 2022 should be submitted by CIFs through CySEC’s Xbrl Portal ONLY by Thursday the 31 August 2023.

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