Commentary on new cases, legislation and regulation affecting executive pay, by Edward Brown KC, author of Executive Remuneration: Law and Practice (Oxford University Press, forthcoming).
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From March 2027, dismissing an employee for refusing a reduction in contractual cash pay will generally be automatically unfair. The Government has confirmed that changes to share schemes will fall outside the protection. But for executive remuneration, the more important dividing line may be between contractual entitlements and separate plan arrangements.
The 2025 reforms cut minimum deferral for material risk takers in dual-regulated firms to four years. The seven-year clawback period did not move, so more of it now falls after pay has vested.
Since 1 September 2026 the conduct rules reach serious bullying, harassment and violence in firms other than banks. The rules say nothing about pay, but they widen the conduct capable of engaging malus and clawback.