Performance-based salary recovery! Multiple listed banks reveal their 2025 "reverse salary collection" ledger, with one bank recovering over 47 million yuan in a year.

Everyday Economic News reporter | Zhang Yi     Everyday Economic News editor | Wei Wenyi

In 2025 listed bank annual reports, “performance-based compensation clawback” has become a high-frequency term.

So-called “performance-based compensation clawback,” which is what industry insiders commonly call “reverse wage-claiming,” typically refers to situations where an employee commits violations or breaches discipline, or where extraordinary risk losses occur within their scope of responsibility. In such cases, banks, according to relevant regulations, will either stop payment of the performance-based compensation not yet paid to the corresponding personnel depending on the severity of the circumstances, or recover part of the compensation that has already been paid.

A reporter from the Daily Economic News (hereinafter “the Daily Economic News reporter”) has sorted through and found that as of April 3, among A-share listed banks that have released their 2025 annual reports and Mainland banks listed in Hong Kong, almost all mentioned the performance-based compensation clawback mechanism in their annual reports. The mechanism covers state-owned banks, national joint-stock banks, as well as city commercial banks and rural commercial banks. Among them, more than 10 banks disclosed specific clawback amounts; the largest exceeds 47 million yuan, while the smallest is only 2,300 yuan.

Wang Pengbo, a senior analyst at Broad Group Consulting who follows the financial industry, told the Daily Economic News reporter that if the performance-based compensation clawback mechanism is genuinely and effectively implemented, it indicates that the bank has the ability to trace risks after the fact and has a responsibility-fulfillment mechanism in place. At the same time, it is also necessary to be wary of formalized operations.

State-owned major banks lead in clawback scale; Bank of China recovers more than 135k yuan over three years

Based on the 2025 data disclosed so far, the state-owned major banks’ “reverse wage-claiming” absolute scale is higher, while some national joint-stock banks are not any less in terms of力度.

Taking Bank of China as an example, its 2025 annual report shows that the bank carried out clawbacks against 4,630 person-times, totaling 47.17 million yuan. Both figures are currently the top among the banks whose annual reports have been disclosed.

What is worth noting is that Bank of China has disclosed clawback information for three consecutive years. In 2023, it recovered 22.75 million yuan, involving 2,059 person-times; in 2024, it recovered 32.50 million yuan, involving 2,469 person-times. Over the three years, total clawbacks exceeded 102 million yuan, involving 9,158 person-times.

Construction Bank also disclosed that in 2025, its directors and senior management personnel had no performance-based compensation clawback cases. However, 17 person-times of clawback were imposed on management cadres of the head office and personnel at a comparable level, involving an amount of 1.99 million yuan, which decreased from 26 person-times and 3.74 million yuan in 2024.

In 2025, Bohai Bank clawed back performance-based compensation 816 person-times totaling 19.58 million yuan, which declined from 612 person-times and 24.03 million yuan in 2024. In 2025, Huaxia Bank executed performance-based compensation clawbacks against 577 employees, with a total of 9.8503 million yuan, down sharply from 751 employees and 22.2070 million yuan in 2024.

It is worth noting that in 2025, Zhejiang Guangfa Bank’s clawback exceeded 60.6k yuan. Specifically, the bank clawed back 970 person-times over the full year, with a total amount of 13.6873 million yuan. Compared with its 2024追回 data of 1,424 person-times and 30.3378 million yuan, the 2025 clawback amount fell by more than half, but the absolute scale still ranks toward the front among the banks that have disclosed information.

In addition, Industrial and Commercial Bank of China, China Merchants Bank, Minsheng Bank, and others also stated clearly in their 2025 annual reports that they have established relevant systems and implemented them, but they did not disclose specific amounts. Ping An Bank said that its executives’ duty fulfillment evaluation and appraisal results during the reporting period are still being confirmed; once confirmed, it will disclose separately.

Clawback amounts vary widely among local banks; differences in risk control and accountability pacing are evident

Among local banks, Zhongyuan Bank’s 2025 clawback scale stands out, reaching 13.5715 million yuan. This is also the second consecutive year the bank has clawed back more than 10 million yuan, after clawing back 20.1076 million yuan in 2024.

Some local banks, although their 2025 clawback absolute amounts are not large, also disclosed them. For example, RuiFeng Bank clawed back 3.8221 million yuan; Dongguan Rural Commercial Bank’s clawback and penalties totaled 3.66 million yuan; YüNong Rural Commercial Bank’s cumulative clawback was 2.9093 million yuan; Shanxi Merchants Bank clawed back performance-based compensation from 30 employees, with a total amount of about 0.1546 million yuan; and Yibin Bank clawed back 2,300 yuan.

In addition, for 2025, Gansu Bank’s accountable-for violations involved 43 person-times, and total performance-based compensation clawbacks were 1.35 million yuan. Compared with 44 person-times and 0.606 million yuan in 2024, its per-capita scale increased.

Why do some banks recover tens of millions of yuan, while others recover only several thousand yuan? Wang Pengbo believes that the clearly different clawback data among various banks is more the result of the joint effect of scale, historical burdens, and the pacing of internal accountability implementation.

“Like state-owned major banks: their asset base is large and their business cycles are long. Combined with the fact that regulatory requirements for responsibility tracing have clearly been strengthened over these years, it is not surprising that clawbacks of a larger scale occur. As for some city commercial banks, small clawback amounts do not necessarily mean they have better risk control; it may only be that the issues have not been fully exposed yet, or that their accountability mechanisms are still being improved step by step,” Wang Pengbo emphasized. He added that you cannot judge which bank has stronger risk control just by looking at the size of clawback figures; you also need to consider more substantial indicators such as the NPL ratio and the coverage ratio for provisions.

Notably, the Daily Economic News reporter observed that although some listed banks had performance-based compensation clawback cases in 2025, their asset quality did not deteriorate and instead improved.

For example, Bank of China, which clawed back over 47 million yuan in 2025, had a non-performing loan (NPL) ratio of 1.23% at end-2025, down 0.02 percentage points year over year. This is lower than Industrial and Commercial Bank of China, Agricultural Bank of China, Construction Bank, and Bank of Communications.

Additionally, in 2025, the NPL ratios of Zhejiang Guangfa Bank, Bohai Bank, Huaxia Bank, Dongguan Rural Commercial Bank, and YüNong Rural Commercial Bank were 1.36%, 1.76%, 1.55%, 1.79%, and 1.08%, respectively, each declining by 0.02 percentage points, 0.02 percentage points, 0.05 percentage points, 0.05 percentage points, and 0.1 percentage point, respectively, year over year.

The performance compensation clawback mechanism is fully implemented; evolving from policy requirements to industry norms

In fact, the performance-based compensation clawback mechanism is not a new concept. Its policy lineage can be traced back to the “Guidelines for Sound Compensation Regulation of Commercial Banks” released in 2010 by the former China Banking Regulatory Commission. For the first time, the guidelines explicitly stated that commercial banks should formulate rules for performance-based compensation deferral and clawback.

In January 2021, the former China Banking and Insurance Regulatory Commission’s Office issued the “Guiding Opinions on Establishing and Improving Performance-Based Compensation Clawback Mechanisms for Banking and Insurance Institutions,” clarifying that banking and insurance institutions should, in accordance with regulations, establish and improve performance-based compensation clawback mechanisms, including the circumstances applicable to such clawbacks, clawback ratios, work procedures, responsible departments, dispute resolution, internal supervision and accountability, and other related contents. It also applies to employees who have left and retirees. In June of the same year, the former China Banking and Insurance Regulatory Commission issued the “Corporate Governance Code for Banking and Insurance Institutions,” again emphasizing that banking and insurance institutions should establish this system.

In August 2022, the Ministry of Finance clarified that when employees fail to perform their duties diligently within their responsibilities, leading to major violations or major risk losses by financial enterprises, the financial enterprise should hold personnel accountable and recover compensation.

From the early emergence of the system in 2010 to today’s active implementation and disclosure by banks, the performance-based compensation clawback mechanism took 15 years to complete the transformation from “policy advocacy” to “industry standard.”

In their 2025 annual reports, multiple banks introduced their performance-based compensation deferral and clawback mechanisms.

For example, Bank of China clearly stated that for senior management and personnel in key positions, more than 40% of performance-based compensation is paid on a deferred basis, with the deferral period generally not less than 3 years. If extraordinary exposure of risk losses within their duties occurs during their employment, the bank may partially or fully recover the performance-based compensation already paid within the corresponding period and stop payment of the unpaid portion.

Agricultural Bank of China stipulates that when senior management and personnel in key positions commit illegal, regulatory, or disciplinary actions, or when extraordinary risk exposure occurs within their scope of responsibilities, the bank will, based on the circumstances, deduct, recover, and stop payment of performance-based compensation for the corresponding period, and also deduct and defer-related performance-based compensation.

RuiFeng Bank said that when circumstances occur such as extraordinary exposure of risk losses within responsibilities, taking responsibility for major risk events, or receiving regulatory penalties, it has the right to claw back already paid performance-based compensation and stop payment of the unpaid portion.

Yibin Bank sets proportions in a segmented way: the proportion for deferred payment of compensation for its chairman, president, chair of the board of supervisors, and secretary of the disciplinary inspection commission is 50% of the performance-based compensation for the year; for other personnel, the proportion for deferred payment of performance-based compensation is 40% of the performance-based compensation for the year. The deferral period for performance-based compensation is generally 3 years, and it adopts a method of equal payments over 3 years, with settlement fulfilled gradually starting from the following year.

Regarding the implementation of this mechanism, Wang Pengbo said that performance-based compensation clawback should be regarded as an observation window into a bank’s risk management and corporate governance maturity level, not merely as a negative signal. He believes that if the mechanism is truly and effectively executed, it indicates that the bank has risk tracing capability and a responsibility-fulfillment mechanism. However, it is necessary to guard against formalized operations. Attention should be paid to whether clawbacks are linked to specific risk events, whether key positions are covered, and whether disclosure is continued.

In Wang Pengbo’s view, if “reverse wage-claiming” becomes normalized, front-line customer managers and approvers will care more about the project’s long-term risk performance rather than only focusing on achieving scale in the current period. In the long run, this helps the banking system remain more robust and reduces the inertia of “heavy deployment, light management.” But he also reminds that this mechanism may cause some institutions to become overly conservative—fearing to extend the loans that should be extended—and that the next step will still require finding a better balance between incentives and constraints.

Disclaimer: The content and data in this article are for reference only and do not constitute investment advice. Please verify before use. Accordingly, you assume all risks arising from your actions.

Cover image source: Daily Economic News Media Asset Library