Authors: Alexandra Beidas, Mirit Ehrenstein

UK CRD V “small firms”: relaxation of some pay and disclosure rules

Following consultations earlier in 2023, the FCA and PRA have introduced new proportionality levels and relaxed some CRD V pay rules for “small firms”. PL3 firms will not be required to apply malus and clawback rules and (for PRA regulated small firms only) the buy-out rules, for performance years starting on or after 8 December 2023. In addition, the Pillar 3 remuneration disclosure requirements have been relaxed for small firms, from 1 January 2024 (so published in 2025). In this briefing we consider the changes and how they apply to groups