Find out how the Remuneration Code (SYSC 19D) applies to dual-regulated firms, comprising banks, building societies and PRA-designated investment firms, including UK branches of non-UK headquartered firms.
Publication of PS25/15: Remuneration reform
On 15 October 2025, the FCA and Prudential Regulation Authority (PRA) published PS25/15[1], setting out changes to the dual-regulated firms’ remuneration regime.
We want to make the regime more effective, simple and proportionate in meeting its aim of ensuring accountability for risk taking, while supporting our secondary objective to facilitate the international competitiveness of the UK economy and its growth.
Alongside this, we made a number of changes to our existing non-Handbook guidance. Specifically:
- We made consequential amendments to general guidance on the application of ex-post risk adjustment to variable remuneration FG23/6 (PDF)[2].
We withdrew the following:
- The Dual-regulated firms Remuneration Code (SYSC 19D) – Frequently asked questions on remuneration FG23/4 (PDF)[3].
- The General Guidance on Proportionality FG23/5 (PDF)[4].
We also withdrew the FCA’s letter to Remuneration Committee Chairs of level one firms. Previous letters can be found under more information and guidance[5].
Publication of PS23/17: Remuneration: Enhancing proportionality for small firms and updates to FCA Finalised Guidance
On 5 December 2023, the FCA published PS23/17[6] setting out our joint rule changes with the Prudential Regulation Authority (PRA) to enhance proportionality for dual-regulated firms.
Publication of PS23/15: Remuneration: Ratio between fixed and variable components of total remuneration
On 24 October 2023, the FCA published a policy statement PS23/15[7] setting out our joint rule changes with the Prudential Regulation Authority (PRA) to remove the existing limits on the ratio between fixed and variable components of total remuneration (‘the bonus cap’).
Publication of PRA (PS28/21) Remuneration: Identification of material risk takers
On 17 December 2021, the PRA published changes in PS28/21[8] to the approach dual-regulated firms must take to identify material risk takers. These changes include the revocation of the onshored PRA version of Commission Delegated Regulation (EU) No 604/2014 and insertion of the provisions of the revised Commission Delegated Regulation (EU) 2021/923 (MRT Regulation), as adopted by the European Commission on Wednesday 9 June 2021, into the Remuneration Part of the PRA Rulebook.
Supervisory approach
For dual-regulated firms, we are responsible for setting and overseeing implementation of remuneration requirements from a conduct perspective. These are set out in our Dual-regulated firms Remuneration Code[10] (SYSC 19D).
Firms’ remuneration and recognition practices are important drivers of culture. We pay close attention to them as we assess the way firms focus on embedding and maintaining healthy cultures.
Throughout the year, our supervisory teams assess and review how firms reward staff, and the behaviour this drives, through our approach to supervising firms.
We coordinate our supervisory activities with the PRA. Although each regulator has its own areas of focus, both regulators must be happy that the approach of each proportionality Level 1 firm to setting its awards is consistent with our requirements.
Self-assessment templates and tables
Dual-regulated firms can use the Remuneration Policy Statement (RPS) templates and tables available on the Bank of England’s website[11] to record remuneration policies, practices and procedures and assess compliance with the Code.
Firms subject to annual review by us, should submit the completed RPS and tables to their usual supervisory contact, noting the requested submission schedule set out in the RPS.
Disclosure
The EBA revised its Guidelines on the data collection exercise on high earners and remuneration benchmarking[12] in 2014. Firms must provide remuneration data annually on high earners and benchmarking.
In Brexit: our approach to EU non-legislative materials[9], we explain how we expect firms to continue to apply guidelines to the extent that they remain relevant.
Please also see the UK version of Article 450 of the Capital Requirements Regulation (CRR) for the disclosure requirements regarding your firm’s remuneration policy and practices.
More information and guidance
- PS20/16: Updating the Dual-regulated firms Remuneration Code to reflect CRD V: feedback to CP20/14 and final rules[13]
- General Guidance on Proportionality: the Dual-regulated firms Remuneration Code (SYSC 19D)[4]
- Dual-regulated firms Remuneration Code (SYSC 19D): FAQs on remuneration[3]
- General guidance on the application of ex-post risk adjustment to variable remuneration[2]
- EBA Guidelines on Sound Remuneration Policies under Articles 74(3) and 75(2) of CRD IV and disclosures under Article 450 of CRR[14]
- FCA and PRA statement on compliance with the Guidelines on Sound Remuneration Policies[15]
- Brexit: our approach to EU non-legislative materials[13]
- 2014 letter to RemCo Chairs on the application of ex-post risk adjustment[15] | 2015 letter to RemCo Chairs[16] | 2016 letter to RemCo Chairs[17] | 2017 letter to RemCo Chairs[18] | 2018 letter to RemCo Chairs[19] | 2019 letter to RemCo Chairs[20] | 2020 letter to Remco Chairs[21] | 2021 letter to Remco Chairs[22] | 2022 letter to Remuneration Committee[23]
