13 listed banks' "reverse salary claims" total nearly 120 million! Bank of China has pursued over 117.1k yuan in back pay over 3 years, and China Construction Bank's average salary refund per person is 117.1k yuan.

With more and more listed banks releasing their 2025 annual reports, how many “finance workers” had their performance compensation clawed back by the banks in reverse?

As of April 7, 36 listed banks have already released their 2025 annual reports, and all of them mention performance compensation clawback and repayment mechanisms. Among them, 13 disclosed the specific amounts of clawed-back performance compensation in their annual reports, including Bank of China (601988), China Construction Bank, Huaxia Bank (600015), CMB Bank, Bohai Bank, Zhongyuan Bank, RuiFeng Bank, Dongguan Rural Commercial Bank, Harbin Bank, Yuinong Rural Commercial Bank, Jinshang Bank, Gansu Bank, and Yibin Bank. The total “reverse wage-claims” amount is nearly 120 million yuan.

Among them, Bank of China had the highest “reverse wage-claim” amount last year, reaching 47.1782 million yuan. Its three-year cumulative clawback amount exceeded 102 million yuan, involving 9,158 person-times. China Construction Bank (601939) had the highest average amount of pay returned per person, exceeding 117k yuan. The establishment and routine enforcement of performance compensation clawback mechanisms has gradually become an industry consensus.

Bank of China clawed back 102 million yuan in performance pay over three years,

China Construction Bank’s average pay returned was 117.1 thousand yuan

As a core force in China’s banking industry, state-owned banks and joint-stock banks account for the leading shares of performance compensation clawback amounts among the publicly disclosed data.

Among them, Bank of China’s efforts to claw back pay are the most prominent. The 2025 annual report shows that the bank carried out performance compensation clawback against a total of 4,630 person-times, with a total amount of 47.1782 million yuan. Whether measured by number of person-times executed or by the total clawed-back amount, it ranks first among the listed banks whose annual reports have been disclosed. Compared with the 32.5 million yuan clawed back in 2024, the bank’s clawback amount in 2025 increased by 45%, and the number of person-times clawed back was also nearly doubled.

Of note is that Bank of China has disclosed the specific performance compensation clawback amounts for three consecutive years. In 2023, the bank recovered 22.75 million yuan and involved 2,059 person-times; in 2024, it recovered 32.5 million yuan and involved 2,469 person-times. Over the three years combined, the cumulative clawback amount exceeded 102 million yuan, involving 9,158 person-times.

China Construction Bank, meanwhile, disclosed that in 2025 there was no performance compensation clawback for its directors and senior management personnel. For performance compensation clawback, the bank’s head-office management officials and personnel at corresponding levels saw 17 person-times clawed back, involving an amount of 1.99 million yuan, which decreased compared with 26 person-times and 3.74 million yuan in 2024.

For joint-stock banks, in 2025 the scale of clawbacks at multiple institutions declined compared with last year. Bohai Bank clawed back 8.16 hundred person-times of performance compensation totaling 19.58 million yuan. Compared with the 612 person-times and 24.03 million yuan data in 2024, the number of person-times increased but the amount fell slightly. CMB Bank clawed back 970 person-times, with a total amount of 13.6873 million yuan; the clawback amount fell by more than half compared with 2024. In 2025, Huaxia Bank clawed back performance compensation from employees at 577 person-times, totaling 9.8503 million yuan. The bank’s senior management personnel had no performance compensation clawback.

Calculations show that the average “returned pay” amounts for the above five banks all exceeded 10k yuan per person, but they generally fell from last year. For example, Bohai Bank’s average amount clawed back per person fell from 39.3 thousand yuan to 24.0 thousand yuan; Huaxia Bank fell from 29.6 thousand yuan to 17.1 thousand yuan. China Construction Bank’s average “returned pay” amount in 2025 exceeded 117.0 thousand yuan, the highest among the disclosed banks.

In addition, Industrial and Commercial Bank of China specifically mentioned that, as of the disclosure date, its senior management at the head office and employees in positions that have an important impact on head-office risks during 2025 do not involve any circumstances related to suspension of performance compensation and clawback. China Merchants Bank (600036) stated in its annual report that although it has established a performance compensation clawback system, there were no cases in the reporting period involving stopping payment of performance compensation subject to clawback for relevant personnel. Ping An Bank (000001) said that during the reporting period, the performance evaluation and assessment results for its executives were still being confirmed; after confirmation, it will disclose separately.

Agricultural Bank of China, Bank of Communications, and Pudong Development Bank (600000), among others, also clearly stated in their annual reports that the performance compensation clawback and repayment mechanisms have been implemented and executed according to regulations, but they did not disclose specific implementation figures.

Yibin Bank’s performance pay clawback of 2,300 yuan is the lowest disclosed amount,

Jinshang Bank first disclosed specific amounts

Besides state-owned banks and joint-stock banks, eight local banks, including Zhongyuan Bank and RuiFeng Bank, also disclosed performance compensation clawback and repayment situations in detail in their 2025 annual reports.

Among them, Zhongyuan Bank’s performance compensation clawback amount during the reporting period reached 13.5715 million yuan, which is also the bank’s second consecutive year of clawing back over 117k yuan, following the 20.1076 million yuan clawed back in 2024.

Harbin Bank’s 2025 performance compensation clawback exceeded 3.08 million yuan, involving 321 person-times, with an average of about 0.96 thousand yuan; Gansu Bank’s 2025 disciplined and sanctioned personnel for misconduct matters involved 43 person-times, and the performance compensation clawback totaled 1.35 million yuan. Compared with 44 person-times and 606 thousand yuan in 2024, its average returned pay amount doubled.

Among other local banks that disclosed specific figures, RuiFeng Bank clawed back 3.8221 million yuan, Dongguan Rural Commercial Bank clawed back 3.66 million yuan, Yuinong Rural Commercial Bank cumulatively clawed back 2.9093 million yuan, Jinshang Bank clawed back about 154.6 thousand yuan for 30 person-times, and Yibin Bank’s clawback amount was 2,300 yuan—showing a significant disparity in clawback amounts.

At the same time, Wuxi Bank (600908) and Zhangjiagang Bank (002839) clearly stated that at the end of the reporting period, there were no relevant cases of suspension and clawback of actual compensation for all directors and senior management personnel. Huishang Bank established mechanisms for deferred payment of performance compensation and clawback for senior management and personnel in key positions, and submitted the implementation related to 2024 to the board of directors for deliberation. Tianjin Bank, Jiangxi Bank, and Guizhou Bank stated that for employees punished by disciplinary actions or other handling due to violations, misconduct, or situations where substantial risk losses were exposed unusually, the bank carried out corresponding deductions, suspension of payments, or clawbacks of performance compensation. Weihai Bank said that during the reporting period it conducted performance compensation clawbacks, and about 80% of the bank’s 2025 executable clawback cases were submitted to the board of directors for deliberation.

It is worth noting that RuiFeng Bank, Dongguan Rural Commercial Bank, Harbin Bank, Yuinong Rural Commercial Bank, Gansu Bank, and Yibin Bank have disclosed performance compensation clawback and repayment amounts for three consecutive years. Jinshang Bank disclosed it for the first time this year. Tianjin Bank clawed back 117.1k yuan in 2024 but did not mention the specific amount this year.

Overall, although the clawback amounts for small and mid-sized banks differ from those of large banks, the establishment of performance compensation clawback and repayment mechanisms and routine enforcement have gradually become an industry consensus.

Performance compensation clawback and repayment mechanisms are becoming more完善,

Multiple banks disclose deferred payment amounts

As far as is known, as early as 2010, the former China Banking Regulatory Commission issued the “Guidance on Sound Compensation Regulation for Commercial Banks,” which required commercial banks to formulate rules for performance compensation deferral, clawback, and repayment.

In March 2018, the former China Banking Regulatory Commission issued the “Guidance on Behavior Management for Practitioners of Banking Financial Institutions,” clarifying that banking institutions should formulate deferral and clawback systems for performance compensation linked to the behaviors of senior executives and key-position personnel.

In February 2021, the former China Banking and Insurance Regulatory Commission issued the “Guiding Opinions on Establishing and Improving Performance Compensation Clawback and Repayment Mechanisms for Banking and Insurance Institutions,” clarifying eight circumstances for clawing back compensation for executives and key-position personnel at banking and insurance institutions.

In the same year, the former China Banking and Insurance Regulatory Commission formulated the “Corporate Governance Guidelines for Banking and Insurance Institutions,” again clarifying that banking and insurance institutions should establish systems for deferred payment of performance compensation and performance compensation clawback and repayment.

In August 2022, the Ministry of Finance issued the “Notice on Further Strengthening Financial Management of State-Owned Financial Enterprises,” requiring financial enterprises to establish and improve mechanisms for deferred compensation distribution payments and accountability and clawback.

On March 24, 2023, the former China Banking and Insurance Regulatory Commission issued the “Three-Year Action to Improve Corporate Governance in the Banking and Insurance Industry Achieved Remarkable Results.” The document mentions strengthening systems for deferred payment of compensation and clawback and repayment mechanisms, continuing to carry out on-site inspections and assessments of deferred compensation payments. The data showed that more than 95% of institutions have formulated and implemented systems for deferred compensation payments and performance compensation clawback and repayment.

Based on the 2025 annual report disclosures, performance compensation deferred payment and clawback and repayment mechanisms have become a “standard configuration” for compensation management at listed banks.

Multiple banks clarified the specific deferred payment proportions and deferral periods. Bank of Communications (601328) applies deferred payments of at least 40% of performance salary for senior management and personnel in key positions within the group, with a deferral period of no less than three years. Citic Bank (601998) applies deferred payments of more than 50% of performance compensation for senior and intermediate-level management personnel and more than 40% for key-position personnel, with a period of three years. Bohai Bank and others also implement deferred payment proportions of no less than 40%.

In addition, some banks further specified the circumstances to which clawback and repayment applies and the implementation process. RuiFeng Bank and Weihai Bank, among others, clarified that the clawback and repayment mechanism also applies to employees who have left and retired personnel.

It is also worth noting that multiple banks mentioned in their annual reports the specific amounts of deferred payments for performance compensation. In 2025, Jiangxi Bank has accrued deferred performance amounts not yet paid of 374.73 million yuan, and has paid 114.54 million yuan. Yibin Bank disclosed a deferred payment amount of 206 million yuan. Weihai Bank’s deferred payment amount reached 101.23 million yuan. Dongguan Rural Commercial Bank implemented performance compensation deferred payments totaling 1,425 employees, with an accrued deferred payment amount of 88.18 million yuan. Gansu Bank’s deferred payment amounts for senior management personnel and personnel in risk-critical impact positions were 24.3897 million yuan.

(Editor: Cao Yanyan HA008)

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