EBA · 2025_7407 Rejected question

EBA Remuneration Diversity Benchmarking - R23.00 - Reporting of not applicable (n/a) gender pay gap

Regulation
Directive 2013/36/EU (CRD)
Article
41
Topic
Supervisory reporting - Supervisory Benchmarking
Submitted by
Consultancy firm
Submitted
2025-04-10

Question

What should be reported in template R23.00 if the gender pay gap cannot be calculated?

Background

As per the final report on the Guidelines on benchmarking of diversity practices, including diversity policies and gender pay gap, under Directive 2013/36/EU and Directive (EU) 2019/2034 "When the gender pay gap between male and female members or the pay gap between male and non-binary members cannot be calculated as the category does not contain both of the respective genders, institutions and investment firms should provide the value ‘n/a’ (not available) instead of calculating the percentage." This is contradictory with the defined metric type (pi935, pi936) because "n/a" cannot be considered as a percentage item, since it is a string. Also, in the template layout, the following is stated: "[4] Or if it cannot be calculated, as the below category does not comprise male and female directors, please indicate not-available (n/a)".
No answer published yet.

Original source: European Banking Authority, Q&A ID 2025_7407

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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