Welcome to these “Countdown to IFPR and the new pay rules” podcasts from the Linklaters Employee Incentives team.

There are now just three months to go before a new prudential regime for investment firms - the IFPR - comes into force in the UK. Stricter new pay rules will apply for performance years from 1 January 2022. These podcasts will look at the new pay rules regime, what the firms need to do to be ready in time, some potential pitfalls and some top tips.

Episode 1 - Three months to go… the pay rules

1 October 2021

A summary of the pay regulations coming in from 1 January 2022 for SNI and Non-SNI investment firms; the MIFIDPRU remuneration code SYSC19G: setting fixed to variable pay ratios, pay out process rules and whether they can be disapplied, governance and malus and clawback.

Episode 2 - Two months to go… some tricky issues with the IFPR pay rules

1 November 2021

How the MIFIDPRU pay code ramps up the requirements, the proportionality threshold for non-SNI firms and some tricky issues with remuneration committees requirements, malus and clawback policies and setting the fixed to variable pay ratio.

Episode 3 - One month to go… more tricky issues with the IFPR pay rules and top tips

1 December 2021

The pay out process rules, some pitfalls with the non-cash instruments, the de minimis exemption and with MRTs; differences between the IFPR and IFD pay rules, and a useful checklist of things to consider and the documents you need to comply with the MIFIDPRU pay rules for performance periods from 1 January 2022.