Question
Should overtime pay awarded to staff members be included in their total gross annual remuneration for the purposes of calculating the gender pay gap?
Background on the question
As per the Guidelines published on sound remuneration policies (EBA/GL/2021/04) and on benchmarking exercises on remuneration practices, the gender pay gap and approved higher ratios under Directive 2013/36/EU (EBA/GL/2022/06), it is not clear as to whether overtime pay should be taken into account in the total gross annual remuneration.
Answer
For the purpose of calculating the gender pay gap under the EBA Guidelines on the benchmarking exercises on remuneration practices, the gender pay gap and approved higher ratios under Directive 2013/36/EU (EBA/GL/2022/06) payments for overtime should not be taken into account. Paragraph 53 of the EBA/GL/2022/06 specifies the remuneration components and approach for the calculation that should be considered when establishing each staff member’s total gross annual remuneration for each whole financial year, which should equal the remuneration that would have been awarded on a full-time basis. Hence, payments for overtime should not be taken into account for the gender pay gap calculation under EBA/GL/2022/06 as they concern a reward for additional time worked on top of the normal time commitment contractually established.