On Feb. 14, BEL CB issued circular to comply with EBA guidelines.
BEL CB issued Circular NBB_2024_03 on diversity to compy with EBA guidelines on reporting obligations on diversity practices for credit institutions, stockbroking firms.
Circular for credit institutions governed by Belgian law; stockbroking firms governed by Belgian law; Belgian branches of credit institutions and stockbroking firms governed by the law of non-EEA member state i.e. entities referred to as financial institutions in cir.
The guidelines have benchmarking of diversity practices under CRD and IFD directives.
Establish new reporting requirements for diversity practices, with data to be submitted for first time in Apr. 2025 and every three years thereafter.
New reporting similar to that applied by EBA for comparative analyses since 2015.
Financial entities selected to participate in EBA benchmarking exercise to be informed.
Information provided will enable EBA and competent supervisory authority (BEL CB or ECB) to assess progress made in terms of diversity within firms' management bodies.
Key Aspects
Per guidelines BEL CB must select institutions to participate in benchmarking exercise.
It will be conducted on individual basis, institutions selected will be informed by letter.
Insofar as possible, BEL CB will strive to ensure continuity with the previous selection.
But will add a few institutions where necessary to meet expectations of EBA and ECB.
It will also ensure a certain degree of consistency with the gender pay gap reporting.
I.e. more quantitative reporting required by its Circular NBB_2022_28 of Nov. 2022.
Definition of diversity used covers five aspects: gender, age, educational background, professional background and geographical provenance.
Regarding gender, a new feature, compared to previous exercises, is that individuals can now be assigned to three gender categories: male, female or non-binary.
All data collected as part of exercise covered by legal frameworks of EBA, ECB and BEL CB rules relating to professional secrecy, confidentiality; access granted per guidelines.
At technical level, for Belgium, requested data relate to both executive, non-executive directors members of the management body, specific information is also requested for positions of chief executive officer (CEO) and chairperson of the board of directors.
Reporting template has detailed questions on how entities calculate gender pay gap.
Specific instructions on how to answer these questions are included in the guidelines.
Other Aspects
Initial reporting per new table must be carried out from reference date Dec. 31, 2024.
The data must be submitted to BEL CB for first time by Apr. 30, 2025, at the latest.
Thereafter, diversity benchmarking data will be collected every 3 years per reference date of Dec. and must be submitte by Apr. 30, of the following year.
Even if firm financial year differs from calendar, reference Dec. 31 must be respected.
Gender pay gap should be calculated per total annual remuneration for year end 2024.
Selected institutions are required to submit the completed reporting table, appended to EBA/GL/2023/08, taking into account the requirements set out therein.
Electronic transmission of data in XBRL format will be done using OneGate application.
Test and production environments available 2 months before, on reference date of the first reporting; data will then be communicated by BEL CB to the European authorities.
Effectiveness
First data collection will be conducted in 2025 with a reference date of Dec. 31, 2024.
Please note the circular makes erroneous references to EBA/GL/2023/18 instead.
