The Revised FSA Remuneration Code

December 22, 2010

The UK Financial Services Authority has published an amended Remuneration Code, which implements the revised Capital Requirements Directive rules on financial institutions’ remuneration structures, performance measurement and governance. It has also published new Disclosure Rules which implement certain requirements on disclosure of remuneration policies and practices. Both measures apply to a broad range of UK financial institutions.

The Revised Code will come into force on January 1, 2011. Firms that are not subject to the existing Code may justify not complying with certain of the Revised Code requirements relating to remuneration structures until July 1, 2011. For firms already subject to the existing Code, it may be possible to justify non-compliance with the requirement to pay 50% of variable remuneration in shares or other non-cash instruments until July 1, 2011.

This alert summarizes key aspects of the Revised Code and the Disclosure Rules.