Shorter deferral, unchanged clawback
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.
Topic
Malus and clawback
Non-financial misconduct and pay
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.