On 13 January 2022, the FCA published a new webpage concerning the MIFIDPRU Remuneration Code which applies to MiFIDPRU investment firms for performance periods starting on or after 1 January 2022. The core requirements in the MIFIDPRU Remuneration Code apply to all small and non-interconnected (SNI) MIFIDPRU investment firms, with the requirements applying in full to non-SNI MIFIDPRU investment firms.
A MIFIDPRU investment firm’s remuneration policy must be appropriate and proportionate to the nature, scale and complexity of the risks that exist in the business model and activities of the firm. The FCA has included guidance in SYSC 19G.2.5G that the content and level of detail of the remuneration policy may depend on many factors including the number of staff the firm employs and different types of roles and activities carried out by the firm.
The web page also refers to performance adjustment and the FCA reminds firms that Finalised Guidance 21/5: General guidance on the application of ex-post risk adjustment to variable remuneration provides further detail regarding its expectations on malus and clawback.
The web page also covers:
- Self-assessment templates and tables. The FCA has published templates for Remuneration Policy Statements.
- Reporting requirements. In particular all firms in scope of the MIFIDPRU Remuneration Code should complete the MIFIDPRU Remuneration Report (MIF008). All returns should be completed using the FCA’s reporting system, RegData, and submitted annually within 4 months of a firm’s accounting reference date.
- This includes that all MIFIDPRU investment firms should disclose qualitative and quantitative information about their remuneration policies, practices and outcomes.