REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on benchmarking of diversity practices under Directive 2013/36/EU
Date: 2016-12-08
Institutions: Directorate-General for Justice and Consumers, European Commission
Subjects: appointment of staff, audit, banking supervision, benchmarking, credit institution, decision-making body (EU), female work, investment company, management audit, right of establishment

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 8.12.2016  COM(2016) 774 final   REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on benchmarking of diversity practices under Directive 2013/36/EU  
 
 
I. 

INTRODUCTION 

It  has  been  widely  acknowledged  that  weaknesses  in  governance  arrangements  and  in  the 
monitoring of  management decisions contributed to  less  prudent risk taking behaviour from 
the part of institutions in the run-up to the financial crisis of 2007-2008.  

To address this, the Capital Requirements Directive1 (CRD) aims to strengthen the ability of 
the  management  bodies2  of  credit  institutions  and  investment  firms  (hereafter  referred  to  as 
‘institutions’)  to  exercise  effective  oversight  and  decision  making  through  a  series  of 
measures,  including  by  ensuring  that  the  composition  of  management  bodies  is  sufficiently 
diverse. 

Article  161(5)  of  the  CRD  requires  the  Commission  to  review  and  report  to  the  European 
Parliament  and  the  Council  on  the  results  achieved  under  the  diversity  benchmarking, 
including the appropriateness of benchmarking diversity practices. This report is prepared in 
view of this requirement. 

II. 

BACKGROUND 

The  requirement  related  to  the  diversity  of  management  bodies  was  introduced  in  order  to 
ensure that a broad set of backgrounds and competences are represented in such bodies. This 
facilitates  independent  opinions  and  constructive  discussion,  and  in  doing  so  counters  the 
‘groupthink’ phenomenon, which is considered to have led to insufficient oversight exercised 
by the management body in the past. 

As  clarified  by  recital  60  of  the  CRD,  management  bodies  should  be  sufficiently  diverse  in 
terms of age, gender, geographical provenance and educational and professional background. 
Employee representation is seen as another positive way of improving diversity, by adding a 
key perspective and genuine knowledge of how a given institution works. 

Under the CRD, Member States or competent authorities must require institutions to take into 
account  a  broad  set  of  qualities  and  competences  when  recruiting  the  members  of  their 
management  bodies,  and  for  this  purpose  to  put  in  place  a  policy  promoting  management 
body diversity.3  

In addition, recognising4 that gender balance ‘is of particular importance to ensure adequate 
representation  of  population’,  the  CRD  requires  ‘significant’5  institutions  to  establish  a 
nomination  committee  which  must  (i)  decide  on  a  target  for  the  representation  of  the 
underrepresented  gender  in  the  management  body,  and  (ii)  prepare  a  policy  on  how  to 

1 Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit 
institutions and the prudential supervision of credit institutions and investment firms. 
2 As per Article 3(1)(7) CRD, ‘management body’ means an institution’s body or bodies, which are appointed in accordance 
with national law, which are empowered to set the institution’s strategy, objectives and overall direction, and which oversee 
and monitor management decision-making, and include the persons who effectively direct the business of the institution. 
3 Article 91(10) CRD. 
4 Recital 60 CRD. 
5 Article 88(2) CRD refers to ‘significance’ in terms of institutions’ size, internal organisation and the nature, scope and 
complexity of their activities. 

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increase the number of the underrepresented gender in the management body in order to meet 
that target.6  

Institutions must publish their diversity policy, its objectives and any relevant targets, as well 
as  the  extent  to  which  these  have  been  met,  as  part  of  the  regular  corporate  governance 
disclosures mandated by Article 435(2)(c) of the Capital Requirements Regulation7 (CRR). 

It is worth noting that the CRD requirements concerning diversity policy are similar to those 
of  Directive  2014/95/EU  on  disclosure  of  non-financial  and  diversity  information,8  which 
requires  listed  undertakings,  including  listed  credit  institutions  and  investment  firms,  to 
report,  on  a  ‘comply  or  explain’  basis,  the  ‘diversity  policy  applied  in  relation  to  the 
undertaking’s administrative, management and supervisory bodies with regard to aspects such 
as,  for instance,  age, gender, or educational and professional  backgrounds, the objectives of 
that diversity policy, how it has been implemented and the results in the reporting period’. 

The CRD9 also requires competent authorities to collect the diversity information disclosed by 
institutions  and  to  use  it  to  benchmark  diversity  practices.  Competent  authorities  must  also 
provide  this  information  to  the  European  Banking  Authority  (EBA),  who  must  use  it  to 
benchmark diversity practices at EU level. 

Article  161(5)  of  the  CRD,  on  the  basis  of  which  this  report  is  presented,  requires  the 
Commission to review and report by 31 December 2016 to the European Parliament and the 
Council  on  the  results  achieved  under  Article  91(11)  of  the  CRD,  including  the 
appropriateness of benchmarking diversity practices and taking into account all relevant EU 
and  international  developments.  Article  161(5)  of  the  CRD  also  mentions  the  possibility  of 
submitting the report together with a legislative proposal, if appropriate. 

In  carrying  out  this  review,  the  Commission  drew  on  the  findings  of  the  first  diversity 
benchmarking  report10  issued  by  EBA.  The  report,  compiled  on  the  basis  of  information 
collected from Member States in 2015, was published on 8 July 2016. 

In  line  with  the  legal  requirement,  this  report  takes  stock  of  relevant  international 
developments (part III), reviews the results of the first diversity benchmarking exercise (part 
IV), and assesses the appropriateness of the benchmarking process (part V). Based on this, it 
then draws conclusions on ways of improving the effectiveness of the benchmarking exercise 
and on its usefulness as a tool for the continuous monitoring of diversity developments in the 
EU (part VI). 

III. 

INTERNATIONAL CONTEXT 

The  different  initiatives  that  address  the  diversity  of  management  bodies  concern  mainly 
listed  companies  from  various  business  sectors,  therefore  this  section  does  not  refer 
specifically to credit institutions and investment firms. 

6 Article 88(2)(a) CRD. 
7 Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements 
for credit institutions and investment firms. 
8 The transposition deadline for this directive is 6 December 2016. 
9 Article 91(11) CRD. 
10 Report on the benchmarking of diversity practices at European Union level, available at http://www.eba.europa.eu/-/eba-
publishes-a-report-on-the-benchmarking-of-diversity-practices-at-european-union-level. 

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Most  of  the  diversity-focused  initiatives  concern  gender  diversity.  A  significant  number  of 
studies  suggest  that  women’s  presence  on  boards  is  beneficial  in  terms  of  improving 
companies’  performance11  and  a  growing  number  of  policy  initiatives  aim  to  promote 
increased gender diversity in companies’ top decision-making bodies. 

For instance, in 2013 the Organisation for Economic Cooperation and Development (OECD) 
sent  a  strong  signal  by  recommending  that  member  countries  increase  the  representation  of 
women  on  the  boards  and  senior  management  of  listed  companies.  Countries  are  using 
various  policy  measures  to  achieve  the  goal  of  increased  women  representation  on  boards, 
ranging from legislative quotas and voluntary targets to diversity disclosure requirements and 
government initiatives for state-owned companies.  

Some  countries  have  opted  for  mandatory  minimum  female  representation  percentages  and 
reach  relatively  high  representation  levels  (e.g.  Iceland  and  Norway  require  40 %  female 
representation  on  boards;  France  requires  40 %  female  representation  among  non-executive 
directors  in  large  listed  and  non-listed  companies  by  2017;  Italy  required  33 %  female 
representation  among  executive  and  non-executive  directors  in  listed  companies  and  state-
owned companies by 2015). A number of other countries have shown promising, albeit lower 
results related to gender diversity without having mandatory quotas. In Australia, for instance, 
women  represent  nearly  22 %  of  board  members  of  listed  companies,12  while  in  the  US 
women  represent  19 %  of  all  directors  at  S&P  500  companies.13  At  the  other  end  of  the 
spectrum there are countries, for example in the Asia Pacific region, where the proportion of 
women on the boards of listed companies remains very low, at around 3 %.14 

Other  diversity  dimensions  captured  in  the  EU15  by  the  requirements  under  the  CRD  (age, 
geographical provenance, educational and professional background) were less identifiable in 
international policies and practices relating to the diversity of management bodies. 

IV.  MAIN RESULTS OF EBA’S FIRST CRD DIVERSITY BENCHMARKING 

Earlier  this  year,  EBA  analysed  the  diversity  practices  of  a  representative  sample16  of  CRD 
institutions,  for  which  data  were  collected  by  national  competent  authorities.  The 
benchmarking covered two aspects: (i) the diversity policies that the CRD requires institutions 
to have in place (including possible targets set as part of those policies), and (ii) the current 
diversity practices of CRD institutions.17 

11 For instance, a recent IMF working paper (‘Gender Diversity in Senior Positions and Firm Performance: Evidence from 
Europe’,  March  2016)  found  that  replacing  one  man  with  one  woman  in  senior  management  or  on  the  corporate  board  is 
associated with between 8 and 13 basis points higher return on assets. 
12 Korn Ferry Diversity Scorecard 2016 — Building Diversity in Asia Pacific Boardrooms. 
13 Edward Kamonjoh, ISS, ‘Boardroom Refreshment. A Review of Trends at U.S. Firms’, 2015. 
14 Korn Ferry Diversity Scorecard 2016 — Building Diversity in Asia Pacific Boardrooms. 
15 Moreover, on an additional strand of diversity policies, the EU and almost all (27) of its Member States are party to the UN 
Convention on the Rights of Persons with Disabilities, which in its article 31 on Statistics and data collection requires the 
collection of information, including statistical and research data, to enable the formulation and implementation of policies. 
16 Covering around 14 % of the total number of CRD institutions in 27 EU Member States and two EEA countries (Iceland 
and Norway) that participated in the data collection exercise. 
17 864 institutions reported information on their diversity policies and 873 institutions on their actual diversity situation. 

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Diversity policies 

Based on data collected in 2015, EBA found that only around 35 % of the institutions in the 
examined sample had adopted a diversity policy. Denmark was the only Member State where 
all sampled institutions had a diversity policy in place. This percentage was 93.3 % in Sweden 
and was above 60 % in only three other Member States: Spain, Ireland and Latvia.18  

In terms of diversity dimensions addressed, three quarters of diversity policies in place cover 
professional  background,  and  around  two  thirds  cover  gender  diversity  and  educational 
background.  Only  half  cover  age  and  40 %  cover  geographical  provenance  (with  the  caveat 
that  the  geographical  dimension  is  relevant  mostly  for  institutions  with  international 
activities). 

Some of the sampled institutions had set specific targets for the diversity of their management 
bodies with regard to one or more of the diversity dimensions.19 The benchmarking revealed 
that  more  than  a  third  of  sampled  institutions  had  set  a  target  for  gender  representation.  In 
around  a  third  of  these,  however,20  this  target  was  set  at  zero  per  cent,  thereby  making  the 
objective irrelevant. In most cases, gender diversity targets have not yet been met,21 and most 
institutions did not indicate a timeline within which they intend to achieve their target.22  

With regard to age  and  geographical  provenance, diversity targets are currently only  met in 
less  than  a third  of  the cases  in  which  they  have  been  set.  For  educational  and  professional 
background,  the  targets  set  are  met  in  around  42 %  and  52 %  of  cases,  respectively.  These 
better  results  could  be  linked  to  the  suitability  requirements  introduced  by  the  CRD,  which 
states that members of management bodies must possess, both individually and collectively, 
adequate knowledge, skills and experience to be able to understand the institution’s activities, 
including the main risks.23  

All  in  all,  the  benchmarking  results  show  that  most  institutions  still  need  to  take  action  to 
comply with the CRD requirement of having a diversity policy in place, and in order to meet 
the targets set with respect to one or more of the diversity dimensions of their management 
bodies. This may in part be attributed to the requirement’s relatively recent entry into force, in 
2014. 

Diversity practices 

The  benchmarking  of  current  diversity  within  the  management  bodies  of  the  sampled 
institutions  showed  a  mixed  picture  and  revealed  that  there  is  room  for  further  action,  to 
different degrees, with regard to all of the diversity dimensions. 

Data revealed that management bodies have insufficient gender diversity, with only 13.63 % 
of executives in the sampled institutions being female. Moreover, more than two thirds of the 
sampled institutions have no female executive directors at all, and only 11 % have a female 

18 Full results per Member State are available on p. 6-7 of the EBA report on the benchmarking of diversity practices. 
19 Of these diversity dimensions, the CRD only requires targets for the representation of the under-represented gender, and 
this only in the case of institutions that are significant in terms of their size, internal organisation and the nature, scope and 
complexity of their activities. 
20 92 of the surveyed institutions. 
21 Only 90 surveyed institutions reported that they already meet their gender diversity targets. 
22 Only 83 surveyed institutions had set a timeline for meeting their gender diversity targets. 
23 Articles 91(1) and 91(7) CRD. 

5 

 
 
 
                                                            
chief executive officer. The trend seems to be positive though: the percentage of new female 
executive directors recruited went up to 19.39 % in 2014, from 15.17 % over 2010-2013. 

With respect to the supervisory function, the percentage of female non-executive directors is 
18.90 %,24 and 39.18 % of the sampled institutions have no female non-executive directors at 
all.  There  is  a  positive  trend  in  the percentage of  new  non-executive  female  recruits,  which 
went up to 22.15 % in 2014, from 18.52 % over 2010-2013. 

All the above figures are overall values for all the countries covered; at Member State level 
the  representation  of  women  in  both  the  executive  and  the  supervisory  function  can  differ 
quite  significantly  (it  ranges  from  2.63 %  to  40.35 %  for  the  executive  function,  and  from 
6.38 % to 28.57 % for the non-executive function). 

Based on the data presented, EBA concluded that it is possible to increase the representation 
of  women  in  management  bodies,  while  noting  that  this  is  not  only  the  responsibility  of 
institutions, but also of Member States to implement a social framework that supports equal 
opportunities for women and men. 

As  regards  the  age  dimension,  the  ‘under  40’  age  category  is  relatively  poorly  represented 
among executive directors, and especially among non-executive directors. Almost  a third of 
non-executive  directors  are  over  the  age  of  60,  and  almost  a  quarter  of  the  sampled 
institutions  had  non-executive  directors  belonging  to  only  one  or  two  age  categories.  There 
are  however  variations  between  Member  States  and  between  different  sizes  and  types  of 
institution  (with  smaller  credit  institutions  and  investment  firms  having  a  higher  number  of 
directors in the lower age categories than larger credit institutions). While recognising that the 
higher representation of the higher age brackets is related to lengthier professional experience, 
EBA concluded that institutions should aim to diversify the age composition of their boards in 
order to ensure the necessary plurality of perspectives and professional experiences. 

As  regards  geographical  provenance,  EBA  noted  that  institutions  that  are  internationally 
active  should  have  geographically  diverse  management  bodies  in  order  to  ensure  sufficient 
knowledge about the culture, market specificities and legal frameworks of the areas in which 
the  institution  is  active.  Nevertheless,  the  benchmarking  reveals  that  the  composition  of  the 
management  bodies  of  most  of  the  larger  credit  institutions  and  investment  firms  analysed 
does not represent all the geographical areas25 in which the institution conducts business. For 
the smaller institutions analysed, over half are reported to cover all their business areas, but in 
a  number  of  cases  this  might  be  due  to  the  fact  that  the  institution  is  active  in  only  one 
geographical area. 

As regards professional background, EBA looked at the number of years of experience and 
the field in which this experience was gained. Unsuprisingly, most executive directors in the 
insitutions included in the sample had experience in the financial sector and in management 
and  most  non-executive  directors  had  experience  in  the  financial  sector  and  in  academia. 
Financial  sector  experience  tends  to  be  lengthy  (more  than  20  years);  this  was  true  for  a 
significant number of executive and non-executive directors. 

in  business 
As  regards  educational  background, 
administration and economics. In most institutions, only one or two educational backgrounds 

the  prevalent  specialisation 

is 

24 However, this total number includes outliers Iceland and Norway, which as per EBA data have a female representation of 
52.38 % and 35 %, respectively. 
25  For  the  purposes  of  the  EBA  benchmarking,  the  following  geographical  areas  were  defined:  EU/EEA,  Europe  non 
EU/EEA, Africa, America, Asia, Australia. 

6 

 
 
                                                            
are  represented  among  executive  directors,  whereas  the  supervisory  function  is  generally 
more diversified. 

The  above  results  need to  be interpreted in  light  of  considerations  related  to  proportionality 
and to the difference in size between the executive and the supervisory function. Thus, as is 
stated  in  the  EBA  report,  smaller  companies  (and  in  particular  certain  types  of  investment 
firms) with a low number of management body members will find it more difficult to reach a 
high level of diversity than medium-sized and large firms will. Moreover, diversity in all its 
aspects can be more easily achieved among non-executive directors, given the usually wider 
composition of the management body in its supervisory function. 

The  results  of  the  first  diversity  benchmarking  exercise  should  also  be  seen  in  light  of  the 
recent entry into force of the CRD diversity rules and the fact that changes in the composition 
of management bodies typically take time to materialise. As more time needs to be allowed in 
order  to  observe  the  effect  of  these  relatively  new  diversity  requirements,  the  Commission 
will  continue  to  closely  monitor  developments  in  this  area  through  regular  EBA 
benchmarking exercises. 

V. 

APPROPRIATENESS OF THE BENCHMARKING PROCESS 

A number of observations and recommendations can be made regarding various aspects of the 
process  of  benchmarking  diversity  practices  on  the  basis  of  the  first  exercise  of  this  type 
carried out, with a view to the periodic benchmarking activities to be undertaken in the future. 

Scope of the benchmarking 

As  regards  CRD  institutions  included  in  the  benchmarking  process,  EBA  sought  to  cover  a 
representative  sample  of  entities:  at  least  10 %  of  institutions  in  each  Member  State  were 
covered by the data collection, and the sample was composed of entities of different sizes and 
types. The sample used appears to be appropriate in terms of size and composition. It reflects 
the  balance  that  needs  to  be  found  between,  on  the  one  hand,  the  need  to  ensure  that  the 
sample  is  sufficiently  large  and  representative  to  make  it  possible  to  draw  meaningful 
conclusions and, on the other hand, the concern not to cause excessive burden on the parties 
involved (institutions, competent authorities and EBA).   

With  respect  to  the  diversity  dimensions  analysed,  the  benchmarking  process  covered  the 
main  dimensions  of  a  diverse  management  body  as  specified  by  the  CRD:  gender,  age, 
geographical  provenance,  educational  and  professional  background.  However,  one  aspect 
listed by the CRD as a positive way of improving a management body’s diversity and variety 
of  perspectives  —  employee  representation  —  was  not  covered  by  this  first  benchmarking 
exercise. In order to fully mirror all aspects of diversity as outlined in the CRD, future stock-
takings  should  also  include  data  on  the  extent  to  which  institutions’  management  bodies 
benefit from employee representation, in accordance with the applicable national legislation. 

Data collection process 

According  to  EBA  feedback  following  the  first  CRD  diversity  benchmarking,  a  number  of 
aspects  could  be  improved  in  the  context  of  future  exercises  in  order  to  ensure  better  data 
quality.  EBA  has  identified  the  following  areas  which  could  be  improved  on  the  basis  of 
lessons learnt from this first exercise: 

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  Certain concepts could be clarified and the phrasing of some questions improved in order 
to  facilitate  a  harmonised  understanding  of  the  issues,  for  example  for  the  notion  of 
geographical provenance. 

  Data collection could be made easier through the use of IT tools. 

  Additional  data  quality  checks  could  be  applied  at  all  data  collection  levels  in  order  to 

ensure that the information compiled is complete and consistent. 

The Commission encourages EBA to work on the basis of these first lessons learnt in order to 
streamline future exercises, and invites it to continue to take note of the obstacles and possible 
areas for improvement in future diversity benchmarkings. 

With  a  view  to  advancing  the  harmonisation  of  data  collection  for  diversity  benchmarking 
purposes,  EBA  may  want  to  consider  whether  developing  own-initiative  guidelines  could 
further facilitate the data collection process. 

Presentation of the findings 

While the data and information collected by EBA provide a good picture of the status quo, it 
nevertheless seems that certain presentational aspects could be revised in future benchmarking 
exercises in order to render the data even more informative. 

One recommendation is that EBA reflect more specifically the findings of the benchmarking 
exercise for the subset of ‘significant’ institutions. In particular, it would be valuable if future 
benchmarking  reports  could  assess  to  what  extent  ‘significant’  institutions  comply  with  the 
requirement  to  set  a  gender  representation  target  and  whether  institutions  that  have  set  an 
explicit target for gender representation achieve better results than those that did not have a 
specific target. 

With  regard  to  the  data  on  the  geographical  provenance  of  institutions’  directors,  it  is 
suggested  to  also  include  information  on  the  number  of  geographical  areas  in  which  the 
analysed  institutions  conduct  activities.  In  the  absence  of  such  information,  it  is  difficult  to 
assess  for  instance  how  many  of  the  institutions  covering  all  geographical  areas  do  so  only 
because they are active in only one area. 

The  presentation  of  the  findings  could  also  benefit  from  a  clearer  differentiation  between 
institutions that have diversity policies, diversity targets or both. In all comparable sections, 
the data should be presented under the same categories, including total EU averages, and all 
the indicators and notions used should be clearly defined. 

Timing of the benchmarking 

The  first  benchmarking  report  was  compiled  by  EBA  based  on  information  collected  in  the 
course  of  2015.  However, the  CRD  requirements  on the  diversity  of  management  bodies  of 
institutions were applicable only as of 2014, which means that only a relatively short time had 
elapsed since they entered into force. 

Consequently,  according  to  EBA,  some  institutions  provided  information  on  their  planned, 
not yet adopted, diversity policies, which presents the risk that the policies effectively adopted 
and implemented will differ from what has been reported at this stage. Another consequence 
of this short timespan since the rules were introduced is that it might be too early to observe 
the effects of the CRD diversity provisions. 

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Article 91(11) of the CRD does not explicitly mention with what frequency the benchmarking 
should  be  performed.  In  order  to  continue  monitoring  institutions’  compliance  with  the 
diversity  requirements  and  to  identify  trends  in  their  diversity  practices,  it  is  nevertheless 
important  that  the  benchmarking  exercise  be  performed  regularly.  Such  periodical 
benchmarking,  the  results  of  which  are  made  public,  can  also  play  a  role  in  incentivising 
credit  institutions  and  investment  firms  to  improve  their  diversity  practices,  by  having  a 
certain peer pressure effect. 

In  light  of  the  usual  length  of  mandates  of  management  body  members,  the  Commission 
deems  it  unnecessary  to  conduct  the  benchmarking  exercise  every  year.  It  nevertheless 
considers that the time between future benchmarking exercises should not be longer than three 
years. 

VI.  CONCLUSIONS 

Following the obligation set out in Article 161(5) of the CRD, the Commission has reviewed 
the results achieved under Article 91(11) of the CRD and has assessed the appropriateness of 
the benchmarking of diversity practices. 

The  review  of  the  benchmarking  results  showed  that  there  is  still  considerable  room  for 
improvement  both  with  regard  to  having  diversity  policies  in  place  and  achieving  greater 
diversity  of  the  management  bodies  of  institutions.  As  regards  compliance  with  CRD 
provisions,  the  benchmarking  revealed  that  most  of  the  sampled  institutions  are  not  at  the 
moment compliant with the requirement of putting in place a policy promoting the diversity 
of  their  management  bodies.  The  degree  of  ‘significant’  institutions’  compliance  with  the 
CRD  requirement  to  set  a  gender  representation  target  could  not  be  assessed;  however,  the 
benchmarking revealed that most of the institutions that had set a gender diversity target, be it 
on a voluntary or on a compulsory basis, have not yet met it and/or have not set a timeline for 
doing so. Although these results can be at least partly attributed to the rules being recent, they 
highlight the need for both institutions and supervisors to make further efforts to ensure that 
the required diversity policies are properly put in place. 

The  review  of  the  appropriateness  of  the  benchmarking  process  revealed  some  aspects  that 
could  be  improved  with  a  view  to  future  exercises.  Most  notably,  the  bechmarking  and 
presentation  of  the  findings  should  facilitate  understanding  on  the  level  of  ‘significant’ 
institutions’  compliance  with  the  requirement  to  set  a  female  representation  target;  the 
benchmarking could be extended so as to also cover the employee representation dimension; 
the benchmarking should be conducted at regular intervals and at least every three years.  

All  in  all,  the  Commission  review  showed  that  the  diversity  benchmarking  is  a  valuable 
source  of  information  on  the  degree  of  institutions’  compliance  with  the  CRD  diversity 
requirements.  The  exercise  is  also  a  useful  stock-taking  tool,  providing  a  snapshot  of  the 
diversity situation and policies of CRD institutions at different points in time.   

As  such,  the  benchmarking  of  diversity  practices  constitutes  a  useful  tool  for  assessing  the 
impact and effectiveness of the CRD diversity requirements over time. Regular benchmarking 
exercises  will  make  it  possible  to  continuously  monitor  compliance  with  the  relevant 
provisions and to see future trends in the field of diversity, as more experience is gained with 
these relatively recent requirements. Furthermore, by enhancing transparency on institutions’ 

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diversity  practices,  the  benchmarking  might  also  incentivise  better  industry  practices  by 
having a peer pressure effect. 

Consequently,  the  Commission  is  satisfied  with  the  overall  added  value  of  benchmarking 
diversity practices and considers the tool — with the minor adaptations outlined in this report 
— important in order to identify in future years the effects of the CRD diversity provisions. 
Therefore, at this time the Commission does not consider it useful to envisage putting forward 
a legislative proposal to amend these provisions. 

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