Reports on benchmarking of diversity practices under the Capital Requirements Directive (CRD) and Investment Firms Directive (IFD)

The information on the substantive and technical requirements to be met when reporting on benchmarking of diversity practices for CRR credit institutions and investment institutions will be updated continuously and expanded in line with further developments.

The reporting requirements are derived in detail from the EBA’s Guidelines on benchmarking of diversity practices, including diversity policies and gender pay gap, under Directive 2013/36/EU and Directive (EU) 2019/2034 (EBA/GL/2023/08), which entered into force on 27 June 2024. These Guidelines flesh out the requirements laid down in the Capital Requirements Directive (Directive 2013/36/EU – CRD) and the Investment Firms Directive (Directive (EU) 2019/2034 – IFD) concerning benchmarking of diversity including the gender pay gap (hereinafter referred to as diversity benchmarking). National implementation of the reporting requirements will take place in full through the provisions of the Banking Act (Kreditwesengesetz – KWG), the Regulation Concerning Reports and the Submission of Records under the Banking Act (Anzeigenverordnung – AnzV, or the Reports Regulation), the Investment Institutions Act (Gesetz zur Beaufsichtigung von Wertpapierinstituten – WpIG) as well as the Investment Institutions Reports Regulation (Wertpapierinstituts-Anzeigenverordnung – WpIAnzV).

Scope

The following institutions generally fall within the scope of reports on diversity benchmarking:

  1. CRR credit institutions;
  2. large investment institutions;
  3. medium-sized investment institutions.

Reporting CRR credit institutions and investment institutions forming part of a representative sample that must meet the requirement to report to the European Banking Authority (EBA) will be requested to submit their reports by BaFin or the Deutsche Bundesbank. Submissions must be at the individual institution level.

The sample of institutions is expected to remain broadly stable and is therefore based on the EBA’s previous diversity benchmarking surveys.

Submission

Reports on diversity benchmarking shall be submitted every three years, for the first time as at the reference date of 31 December 2024. The deadline for submission is 30 April 2025.

Information on electronic submissions

Credit institutions and investment institutions are expected to submit remuneration reports to the Bundesbank electronically. The Bundesbank will only accept electronic reports submitted via the Bank’s ExtraNet in XBRL (Extensible Business Reporting Language) format.

Files in XBRL format are submitted via the ExtraNet filetransfer service using the mailbox “PRISMA – submission of bank and financial supervisory reports (ITS / RTF / BGR / CONTACT)”.

Any necessary initial or secondary registration must therefore be completed in the “Prudential returns” specialised procedure for the function also named “PRISMA – submission of bank and financial supervisory reports (ITS / RTF / BGR / CONTACT)”.

It is recommended to also register for the function “PRISMA – feedback on banking and financial reporting (ITS / RTF / BGR / CONTACT)” in order to be able to download automated validation reports.