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.

By Daily Economic News reporter | Zhang Yi | Daily Economic News editor | Wei WENYI

In the 2025 annual reports of listed banks, “performance compensation clawback and recovery deductions” has become a high-frequency term.

So-called “performance compensation clawback and recovery deductions,” meaning what industry insiders commonly refer to as “reverse wage claims,” generally refers to when an employee commits violations or breaches discipline, or when, within their scope of duties, risk losses are exposed to an unusually high extent. In such cases, the bank, according to relevant regulations, may halt payment of the performance compensation not yet paid to the corresponding personnel depending on how severe the circumstances are, or may recover part of the compensation already paid out.

A reporter from the Daily Economic News (hereinafter “Daily Economic News reporter”) reviewed 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 mention the performance compensation clawback and recovery mechanism in their annual reports. The coverage includes state-owned large banks, national joint-stock banks, as well as city commercial banks and rural commercial banks. Among them, more than 10 banks disclosed the specific clawback amounts—some are more than 47 million yuan, while others are only 2,300 yuan.

Wang Pengbo, a senior analyst for the financial industry at Bocomom Consulting, told the Daily Economic News reporter that if the performance compensation clawback and recovery mechanism is genuinely and effectively implemented, it indicates that the bank has the ability to trace risks back and a mechanism for accountability. However, at the same time, there is a need to be wary of formalistic practices.

State-owned large banks lead in clawback scale; Bank of China’s cumulative clawback of wages over three years exceeds 100 million yuan

Based on the 2025 data disclosed so far, state-owned large banks’ “reverse wage claims” have a higher absolute scale, while some national joint-stock banks are also not any less in terms of intensity.

Taking Bank of China as an example, its 2025 annual report shows that the bank carried out clawback and recovery deductions against 4,630 instances of personnel, with a total amount of 47.17 million yuan. Both figures temporarily top the list among the banks whose annual reports have been disclosed.

Worth noting is that Bank of China has disclosed clawback information for three consecutive years. In 2023, the bank recovered 22.75 million yuan, involving 2,059 personnel instances; in 2024, it recovered 32.50 million yuan, involving 2,469 personnel instances. Over the three years, the cumulative clawback and recovery deductions exceeded 102 million yuan, involving 9,158 personnel instances in total.

Construction Bank also disclosed that in 2025, its board of directors and senior management personnel had no performance compensation clawback and recovery deductions. However, 17 personnel instances among the bank’s management cadres and people at a corresponding level were subject to clawback and recovery, involving an amount of 1.99 million yuan, which decreased compared with 26 personnel instances and 3.74 million yuan in 2024.

In 2025, Bohai Bank carried out performance compensation clawback and recovery deductions for 816 personnel instances, totaling 19.58 million yuan, down from 612 personnel instances and 24.03 million yuan in 2024. In 2025, Huaxia Bank implemented performance compensation clawback and recovery deductions for 577 employees, with a total amount of 9.8503 million yuan, a significant decrease from 751 employees and 22.207 million yuan in 2024.

It is worth noting that Zhejiang Commercial Bank’s 2025 clawback and recovery deductions exceeded 10 million yuan. Specifically, the bank clawed back and recovered deductions for 970 personnel instances over the full year, with a total amount of 13.6873 million yuan. Compared with its 2024 data of 1,424 personnel instances and 30.3378 million yuan, the 2025 clawback amount fell by more than half, but the absolute scale still remains among the leading ranks among the banks that have disclosed information.

In addition, Industrial and Commercial Bank of China, China Merchants Bank, Minsheng Bank, and others also clearly stated in their 2025 annual reports that they have established relevant systems and implemented them, but they did not disclose the specific amounts. Ping An Bank stated that the bank’s executive personnel’s fulfillment evaluation and appraisal results during the reporting period are still under confirmation, and will be disclosed separately once confirmed.

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

Among local banks, Zhongyuan Bank’s 2025 clawback and recovery deduction scale stands out at 13.5715 million yuan. This is also the bank’s second consecutive year with clawback and recovery deductions exceeding 10 million yuan, following 20.1076 million yuan in 2024.

Some local banks, although their absolute clawback and recovery deduction amounts in 2025 are not large, also made disclosures. For example, RuiFeng Bank’s clawback and recovery deductions were 3.8221 million yuan; Dongguan Rural Commercial Bank’s clawback and recovery penalty amount totaled 3.66 million yuan; Yu Nong Rural Commercial Bank’s cumulative clawback and recovery deductions were 2.9093 million yuan; Jin Shang Bank clawed back for 30 employees and the total amount is about 154,600 yuan; Yibin Bank’s clawback and recovery deductions were 2,300 yuan.

In addition, Gansu Bank’s illegal and noncompliant matters in 2025 involved 43 personnel instances subject to accountability, with total performance compensation clawback and recovery deductions of 135,000 yuan. Compared with 44 personnel instances and 60,600 yuan in 2024, the per-capita scale increased.

Why do some banks claw back several tens of millions of yuan, while others claw back only several thousand yuan? On this point, Wang Pengbo believes that the markedly different clawback and recovery data across banks are more the result of the combined effects of scale, historical burdens, and the pace of internal accountability implementation.

“Like state-owned large banks, with large asset portfolios and long business cycles, together with the noticeably strengthened regulatory requirements for responsibility traceability in recent years, it is not surprising to see larger-scale clawbacks; while for some city commercial banks, smaller clawback amounts do not necessarily mean they have better risk control. It may simply be that problems have not been fully exposed yet, or that the accountability mechanism is still being improved step by step.” Wang Pengbo emphasized that you cannot judge which bank has stronger risk control by looking only at the size of the clawback numbers; you also need to consider more substantive indicators such as the NPL ratio and the loan-loss reserve coverage ratio.

Noticed by the Daily Economic News reporter, although some listed banks had performance compensation clawback and recovery deductions in 2025, their asset quality did not deteriorate; instead, it improved.

For example, for Bank of China, whose clawback and recovery deductions exceeded 47 million yuan in 2025, its NPL ratio at the end of 2025 was 1.23%, down 0.02 percentage points year over year, which is lower than those of Industrial and Commercial Bank of China, Agricultural Bank of China, Construction Bank, and Bank of Communications.

In addition, in 2025, Zhejiang Commercial Bank, Bohai Bank, Huaxia Bank, Dongguan Rural Commercial Bank, and Yu Nong Rural Commercial Bank’s NPL ratios were 1.36%, 1.76%, 1.55%, 1.79%, and 1.08%, respectively—down 0.02 percentage points, 0.02 percentage points, 0.05 percentage points, 0.05 percentage points, and 0.1 percentage points year over year, respectively.

Comprehensive implementation of performance compensation clawback mechanisms; moving from policy requirements to industry norms

In fact, the performance compensation clawback and recovery deduction mechanism is not a new development. Its policy lineage can be traced back to the “Guidelines for the Sound Compensation Regulation of Commercial Banks” issued by the former China Banking Regulatory Commission in 2010. This guideline for the first time clarified that commercial banks should formulate rules for deferred performance compensation clawback and recovery and for deductions.

In January 2021, the General Office of the former China Banking and Insurance Regulatory Commission issued the “Guiding Opinions on Establishing and Improving the Performance Compensation Clawback and Recovery Mechanism for Banking and Insurance Institutions,” clarifying that banking and insurance institutions should, as required, establish and improve the performance compensation clawback and recovery mechanism, including the applicable scenarios, clawback and recovery ratios, work procedures, responsible departments, dispute resolution, internal supervision, and accountability, among other contents. It is also applicable to employees who have left or retired. In the same year in June, the former China Banking and Insurance Regulatory Commission issued the “Corporate Governance Code for Banking and Insurance Institutions,” once again emphasizing that banking and insurance institutions should establish this system.

In August 2022, the Ministry of Finance clarified that for employees who fail to perform diligently within their own duties, resulting in major illegal and noncompliant activities or major risk losses by financial enterprises, the financial enterprise should pursue accountability and recover compensation accordingly.

From the initial emergence of the system in 2010, to the active implementation and disclosure by banks today, it has taken 15 years for the performance compensation clawback and recovery mechanism to complete the transformation from “policy advocacy” to “industry standard equipment.”

In their 2025 annual reports, multiple banks introduced their performance compensation deferred payment and clawback and recovery deduction mechanisms.

For example, Bank of China clearly states that it will implement deferred payment for more than 40% of performance compensation for senior management and key positions. The deferral period is generally no less than 3 years. If, during employment, risk losses are exposed to an unusually high degree within the scope of duties, the bank may partially or fully recover the performance compensation issued within the corresponding period, and halt payment of the portion not yet paid.

Agricultural Bank of China stipulates that if senior management and key position personnel commit illegal, noncompliant, or disciplinary acts, or expose risks to an unusually high extent within their scope of duties, depending on the circumstances, the relevant performance compensation and deferred payment performance compensation for the corresponding period will be reduced, recovered, and halted.

RuiFeng Bank stated that when situations such as unusually high exposure of risk losses within one’s duties, being responsible for major risk events, or receiving regulatory penalties occur, it has the right to claw back and recover already issued performance compensation and halt payment of any unpaid portion.

Yibin Bank sets proportions in segments. The deferral payment proportion for compensation for its chairman of the board, president, chairman of the supervisory board, and secretary of the CCDI is 50% of the annual performance compensation; for other personnel, the deferral payment proportion is 40% of the annual performance compensation. The deferral payment period for performance compensation is generally 3 years. It adopts the method of equal installment payments over 3 years, with payouts realized year by year starting from the following year.

On the implementation of this mechanism, Wang Pengbo said that the performance compensation clawback and recovery deduction should be treated as an observation window into a bank’s risk management and corporate governance maturity—not merely a negative signal. He believes that if the mechanism is genuinely and effectively implemented, it indicates that the bank has risk traceability capability and a mechanism for responsibility to be carried out. However, it is necessary to be wary of formalistic operations, and to focus on whether the clawback is linked to specific risk events, whether it covers key positions, and whether it continues to disclose information.

In Wang Pengbo’s view, if “reverse wage claims” becomes normalized, frontline customer managers and approvers will pay more attention to the long-term risk performance of projects rather than focusing only on boosting scale in the current period. In the long run, this is conducive to making the banking system more robust and reducing the inertia of “heavy investment, light management.” But he also reminds that this mechanism may lead some institutions to become overly conservative—discouraging loans that should be made—so in the future it will still be necessary to find a better balance point between incentives and constraints.

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