No one, not even the managers themselves, would dispute that misaligned remuneration systems for bank managers at least played a role in worsening the financial crisis.4 The G20 countries therefore adopted the FSB Principles for Sound Compensation Practices as early as September 2009 and, on this basis, specific implementation standards.5 The Basel Committee has since incorporated the disclosure requirements specified in these standards into Pillar 3.6 Germany was one of the first countries to implement the standards.
The Regulation Governing Remuneration at Institutions, or Instituts-Vergütungsverordnung, came into force in Germany on 13 October 2010. This regulation takes account of both the international regulations and the subsequent EU provisions. 2  BCBS: Global systemically important banks: Assessment methodology and additional loss absorbency requirement, July 2011. 3  See FSB, Framework for Strengthening Adherence to International Standards, January 2010.