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 Economic Daily reporter | Zhang Yi Economic Daily editor | Wei Wenyi

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

So-called “performance compensation clawback,” which is what the industry commonly refers to as “reverse backpay,” usually means that when employees commit violations or breaches of discipline, or when risk losses within their scope of responsibilities are exposed in an unusually severe manner, the bank—based on relevant regulations—will stop payment of the performance compensation that has not yet been paid to the corresponding individuals, depending on the severity of the circumstances, or will recover the portion that has already been paid.

A reporter from The Economic Daily (hereinafter “Economic Daily reporter”) reviewed and found that as of April 3, among A-share listed banks that had published their 2025 annual reports and Mainland banks listed in Hong Kong, nearly all mentioned the performance compensation clawback mechanism in their annual reports. This covers state-owned mega 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—more than 47 million yuan in some cases, and as little as 2,300 yuan in others.

Wang Pengbo, a senior analyst covering the financial industry at Bocom (BoTong) Consultancy, told Economic Daily reporter that if the performance compensation clawback mechanism is truly implemented effectively, it indicates that banks have risk traceability capabilities and a responsibility-fulfillment mechanism. However, it is also necessary to be wary of formalistic implementation.

State-owned mega banks lead in clawback scale; BOC’s cumulative backpay recovery over three years exceeds 154.6k yuan

Based on the 2025 data disclosed so far, the absolute scale of “reverse backpay” by state-owned mega banks is higher, while some national joint-stock banks are not inferior in terms of力度.

Take Bank of China as an example. Its 2025 annual report shows that the bank implemented clawbacks against 4,630 person-times, with the total amount reaching 47.1782 million yuan. Both figures are temporarily the highest among the annual-report banks that have disclosed information.

Of note is that Bank of China has disclosed clawback situations 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 three years, cumulative clawbacks exceeded 102 million yuan, involving a total of 9,158 person-times.

China Construction Bank also disclosed that in 2025, there were no performance compensation clawbacks involving its directors and senior management personnel. However, 17 person-times among its head-office management cadres and personnel at an equivalent level were subject to clawbacks, involving an amount of 1.99 million yuan, which is lower than 26 person-times and 3.74 million yuan in 2024.

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

It is worth noting that in 2025, Zhejiang Commercial Bank’s performance compensation clawbacks exceeded 135k yuan. Specifically, it clawed back for 970 person-times during the full year, with a total amount of 13.6873 million yuan. Compared with its 2024 clawback figures 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 near the top among the banks that have disclosed.

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 the specific amounts. Ping An Bank stated that the evaluation and assessment results of its executives’履职 during the reporting period are still being confirmed; once confirmed, they will disclose separately.

Clawback amounts vary widely among local banks; differences in risk control and accountability timelines stand out

Among local banks, Zhongyuan Bank’s 2025 clawback scale is relatively prominent, reaching 13.5715 million yuan. This is also the second consecutive year that the bank has clawed back more than 60.6k yuan, following 20.1076 million yuan in 2024.

Some local banks may not have large absolute clawback amounts in 2025, but they 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; Yushan Rural Commercial Bank cumulatively clawed back 2.9093 million yuan; Shanxi Merchants Bank clawed back performance compensation for 30 employees, with a total amount of approximately 1.546 million yuan; and Yibin Bank clawed back 2,300 yuan.

In addition, for the violations that occurred at Gansu Bank in 2025, the number of people held accountable involved 43 person-times, and performance compensation clawbacks totaled 1.35 million yuan. Compared with 44 person-times and 0.606 million yuan in 2024, the per-capita scale increased.

Why did some banks claw back several tens of millions of yuan, while others only clawed back a few thousand yuan? In this regard, Wang Pengbo believes that the clawback data—where each bank differs markedly—is more the result of combined factors including scale, historical burdens, and the pace of internal accountability implementation.

“Like state-owned mega banks, they have large asset bases and long business cycles. Combined with the past few years’ clearly strengthened regulatory requirements for responsibility traceability, it’s not surprising to see clawbacks at a larger scale. Meanwhile, when some city commercial banks have smaller clawback amounts, it doesn’t necessarily mean they control risk better; it could simply be that the problems have not been fully exposed yet, or that their accountability mechanisms are still being gradually improved,” Wang Pengbo emphasized. He added that you cannot judge which bank has stronger risk control just by the size of clawback figures; you also need to look together with more substantial indicators such as the non-performing loan ratio and the loan loss reserve coverage ratio.

An Economic Daily reporter noted that although some listed banks had performance compensation clawbacks in 2025, their asset quality did not deteriorate; it improved instead.

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

In addition, in 2025, Zhejiang Commercial Bank, Bohai Bank, Huaxia Bank, Dongguan Rural Commercial Bank, and Yushan Rural Commercial Bank had non-performing loan ratios of 1.36%, 1.76%, 1.55%, 1.79%, and 1.08% respectively, with year-over-year decreases of 0.02 percentage points, 0.02 percentage points, 0.05 percentage points, 0.05 percentage points, and 0.1 percentage point, respectively.

The full implementation of performance compensation clawback mechanisms moves from policy requirements to industry norms

In fact, performance compensation clawback mechanisms are not new. Their policy lineage can be traced back to the 2010 “Guidelines on Sound Performance-Based Compensation Regulation for Commercial Banks” issued by the former China Banking Regulatory Commission. This guideline first made it clear that commercial banks should formulate rules for deferred performance-based compensation recovery and clawback.

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 Mechanism for Banking and Insurance Institutions.” It clarified that banking and insurance institutions should, in accordance with regulations, establish and improve performance compensation clawback mechanisms, including the circumstances for applying performance compensation clawbacks, the clawback ratios, working procedures, responsible departments, dispute handling, internal oversight, accountability, and other matters; and that these apply to employees who have left their positions and retired personnel. In the same year in June, 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 specified that where employees fail to act diligently and responsibly within their own duties, resulting in major illegal and违规 behaviors or major risk losses by a financial enterprise, the financial enterprise should pursue accountability and claw back pay.

From the early emergence of the system in 2010 to each bank’s active implementation and disclosure today, performance compensation clawback mechanisms took 15 years to make the transition from “policy advocacy” to “industry standard.”

In their 2025 annual reports, many banks introduced their mechanisms for deferred performance compensation payment and clawbacks.

For example, Bank of China stated that for senior management and key-post personnel, more than 40% of performance compensation is subject to deferred payment, with the deferral period generally not less than 3 years. If during employment there is unusual exposure of risk losses within duties, the bank may partially or fully recover the performance compensation that was paid within the corresponding timeframe, and stop payment for the portion that has not yet been paid.

Agricultural Bank of China stipulates that if senior management and key-post personnel commit illegal,违规, or discipline-violating acts, or there is unusual exposure of risks within their scope of responsibilities, depending on the severity of the circumstances, the bank will deduct, recover, and stop payment of performance compensation and deferred payment performance compensation for the corresponding period.

Ruifeng Bank said that when situations arise such as unusual exposure of risk losses within duties, being responsible for major risk events, or receiving regulatory penalties, it has the right to pursue and claw back performance compensation that has already been paid and stop payment of the unpaid portion.

Yibin Bank sets clawback ratios in stages: the deferral payment ratio for the chairman, president, chairman of the supervisory board, and the party discipline inspection secretary is 50% of that year’s performance compensation; for other personnel, the deferral payment ratio is 40% of that year’s performance compensation. The deferred payment period is generally 3 years, and it uses an approach of equal payments over 3 years,兑现 each year starting from the following year.

On how this mechanism is implemented, Wang Pengbo said that performance compensation clawbacks should be viewed as an observation window into a bank’s maturity in risk management and corporate governance, not merely a negative signal. He believes that if the mechanism is implemented truly and effectively, it shows that the bank has risk traceability capabilities and a responsibility-implementation mechanism. However, it is necessary to guard against formalistic operations—pay attention to 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 backpay” becomes normalized, front-line customer managers and approvers will care more about the long-term risk performance of projects rather than only focusing on achieving scale in the current period. In the long run, this will help the banking system be more stable and reduce the inertia of “heavy investment, light management.” But he also reminds that this mechanism may lead some institutions to become overly conservative—loans that should be granted may not be granted—and that later it will still be necessary to find a better balance between incentives and constraints.

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Cover image source: Economic Daily media resources