15.1 Non-deferred and deferred remuneration

Without prejudice to the application of waivers under Article 32(4) of Directive (EU) 2019/2034, investment firms should implement a deferral schedule that appropriately aligns the remuneration of staff with the investment firm’s activities, business cycle and risk profile and the activities of the identified staff members, so that a sufficient part of the variable remuneration can be adjusted for risk outcomes over time through ex post risk adjustments.

A deferral schedule is defined by different components:

• a. the proportion of the variable remuneration that is being deferred (section 15.2);
• b. the length of the deferral period (section 15.2);
• c. the speed at which the deferred remuneration vests, including the time span from the end of the accrual period until the vesting of the first deferred amount (section 15.3).

Investment firms should take into account within the deferral schedule the form in which the deferred variable remuneration is awarded and should, where appropriate, differentiate their deferral schedules by varying these components for different categories of identified staff. The combination of these components should lead to an effective deferral schedule, in which clear incentives for long-term-oriented risk taking are provided by transparent risk alignment procedures.