Firms should consider the impact of the relevant RemCode on their policies. Should any changes to policies and the resulting practices be required, these should be instigated as early as feasible, given the sensitivity of the topic.
The IFPR introduces new remuneration requirements for UK investment firms.
These requirements are divided into basic, standard, and extended remuneration obligations (RemCodes) and will depend on the
investment firm’s classification as either an SNI or non-SNI, and its on-and-off balance sheet. The new RemCode replaces the IFPRU Remuneration Code and BIPRU Remuneration Code.
With regards to remuneration reporting, MIFIDPRU Remuneration Report (MIF008) replaces the existing Remuneration Benchmarking Information Report (REP004) and High Earners Report (REP005).
The new reports should be submitted annually, within four months of a firm’s accounting reference date.
Wheelhouse Advisors’ impact assessments ascertain whether firms will be subject to a more or less complex RemCode and whether they are adequately prepared for the RemCode changes.
- 100% of firms assessed across all categories will find remuneration code (RemCode) requirements more complex.
- 21% will find RemCode requirements significantly more complex.
- When assessed, 91% of BIPRU/CPMI firms were aware of the changes to RemCodes but had no plans in place. Only 9% of firms were in the early stages of implementation planning regarding remuneration.
- When assessing Exempt-CAD firms, our findings showed that 80% of firms in this category would find RemCode changes significantly more complex.
- All Exempt-CAD firms were aware of the changes but none had plans in place to mitigate this.
- The IFPRU firms we assessed were in a similar position, with all firms being aware of the changes to RemCodes but no plans in place.