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.

The reporter at 每经｜Zhang Yi    The editor at 每经｜Wei Wenyi

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

So-called “performance compensation recovery and clawback,” which is what the industry commonly calls “reverse wage recovery,” usually refers to situations where an employee commits violations or breaches of discipline, or where risk losses in the scope of their responsibilities are exposed to an unusually high degree. In such cases, banks, in accordance with relevant regulations, will either stop payment of the performance compensation that has not yet been paid to the corresponding personnel based on the severity of the circumstances, or will reclaim some of the compensation that has already been paid out.

A reporter from the Daily Economic News (hereinafter, “the 每经 reporter”) has 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, nearly all mentioned the performance compensation recovery and clawback mechanism in their annual reports. This covers 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 recovery and clawback amounts—up to more than RMB 47 million at the high end, and as little as RMB 2,300 at the low end.

Wang Pengbo, a senior analyst covering the financial industry at BOCOM/博通 (Consulting), told the 每经 reporter that if the performance compensation recovery and clawback mechanism is truly and effectively implemented, it indicates that the bank has risk-retrospection capabilities and a responsibility-implementation mechanism. However, one must also be wary of formalized operations.

State-owned large banks lead in recovery scale; Bank of China recovers over RMB 154.6k cumulatively over three years

Based on the 2025 figures disclosed so far, the state-owned large banks’ “reverse wage recovery” absolute scale is higher, while some national joint-stock banks are by no means less forceful in this regard.

Taking Bank of China as an example, its 2025 annual report shows that the bank carried out performance compensation recovery and clawback against 4,630 people-times in total, with a total amount of RMB 47.1782 million. Both figures are currently the highest among the annual-report banks that have disclosed their data.

Of note, Bank of China has disclosed its clawback situation for three consecutive years. In 2023, the bank reclaimed RMB 22.75 million involving 2,059 people-times; in 2024, it reclaimed RMB 32.5 million involving 2,469 people-times. Over the three years, the cumulative recovered performance compensation exceeded RMB 102 million, with a total of 9,158 people-times involved.

Construction Bank, meanwhile, disclosed that in 2025, its directors and senior management personnel had no performance compensation recovery and clawback; however, 17 people-times among head-office management cadres and personnel at a comparable level were subject to recovery, involving an amount of RMB 1.99 million, which was lower than 26 people-times and RMB 3.74 million in 2024.

In 2025, Bohai Bank carried out performance compensation clawback against 816 people-times totaling RMB 19.58 million, down from 612 people-times and RMB 24.03 million in 2024. In 2025, Huaxia Bank carried out performance compensation recovery and clawback for 577 employees, with a total amount of RMB 9.8503 million, down sharply from 751 people and RMB 22.2070 million in 2024.

It is worth noting that Zhejiang TIN/浙商 Bank saw recovery and clawback exceeding RMB 135k in 2025. Specifically, across the full year, it carried out recovery and clawback against 970 people-times with a total amount of RMB 13.6873 million. Compared with its 2024 data of 1,424 people-times and RMB 30.3378 million, the clawback amount in 2025 fell by more than half, yet the absolute scale remains among the top in the banks that have disclosed their results.

In addition, Industrial and Commercial Bank of China, China Merchants Bank, Minsheng Bank, and others also 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 said that the performance evaluation and assessment results of its executives’ job performance during the reporting period are still in the confirmation process; once confirmed, it will disclose separately.

Vast differences in clawback amounts among local banks; disparities in risk control and accountability cadence stand out

Among local banks, Ping An Bank? (Central Plains Bank, 中原银行) had a relatively prominent recovery and clawback scale in 2025, reaching RMB 13.5715 million. This was also the second consecutive year for the bank to claw back more than RMB 60.6k, after RMB 20.1076 million in 2024.

Some local banks, although their absolute recovery and clawback amounts in 2025 were not large, also disclosed them. For example, Rural? (Feng? 瑞丰银行) disclosed recovery and clawback of RMB 3.8221 million; Dongguan Rural Commercial Bank disclosed a total amount clawed back or penalized of RMB 3.66 million; Yu? (Jiangsu? 渝农商行) cumulative recovery and clawback totaled RMB 2.9093 million; Shanxi Merchants Bank clawed back for 30 employee people-times with a total amount of about RMB 154.6k; Yibin Bank recovered and clawed back RMB 2,300.

In addition, the number of people subject to accountability for violations that occurred at Gansu Bank in 2025 involved 43 people-times, with total performance compensation recovery and clawback of RMB 135k. Compared with 44 people-times and RMB 60.6k in 2024, per-capita scale increased.

Why did some banks claw back several tens of millions while others clawed back only several thousand yuan? Wang Pengbo said that the recovery and clawback data with clear differences among banks are more the result of the combined effects of scale, historical burdens, and the internal accountability-implementation cadence.

“Like state-owned large banks, with big asset portfolios and long business cycles, plus the fact that regulatory requirements for responsibility tracing have clearly been strengthened in recent years, a large-scale recovery and clawback is not surprising. And for some city commercial banks, smaller recovery amounts do not necessarily mean they have better risk control; it could simply be that problems have not been fully exposed yet, or that accountability mechanisms are still being gradually improved,” Wang Pengbo emphasized. He added that one cannot judge which bank’s risk control is stronger just by the size of recovery and clawback figures; it is also necessary to look together with more substantive indicators such as the NPL ratio and the provision coverage ratio.

The 每经 reporter noted that, although some listed banks had performance compensation recovery and clawback situations in 2025, their asset quality did not deteriorate; instead, it improved.

For example, Bank of China, which had performance compensation recovery and clawback exceeding RMB 47 million, had an NPL ratio of 1.23% by the end of 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.

In addition, in 2025, Zhejiang TIN/浙商 Bank, Bohai Bank, Huaxia Bank, Dongguan Rural Commercial Bank, and Yu? (渝农商行) had NPL ratios of 1.36%, 1.76%, 1.55%, 1.79%, and 1.08%, respectively, each down by 0.02 percentage points, 0.02 percentage points, 0.05 percentage points, 0.05 percentage points, and 0.1 percentage points year over year.

The full rollout of performance compensation recovery mechanisms; from policy requirements to industry norms

In practice, the performance compensation recovery and clawback mechanism is not a new development. Its policy lineage can be traced back to the “Guidelines on Sound Performance Compensation Supervision for Commercial Banks” issued by the former China Banking Regulatory Commission in 2010. For the first time, the guideline explicitly stated that commercial banks should formulate rules for deferred performance compensation recovery and clawback, and clawback requirements.

In January 2021, the General Office of the former China Banking and Insurance Regulatory Commission issued the “Guiding Opinions on Establishing and Improving Performance Compensation Recovery and Clawback Mechanisms for Banking and Insurance Institutions.” It clarified that banking and insurance institutions should, in accordance with the rules, establish and improve performance compensation recovery and clawback mechanisms, including the applicable scenarios, clawback ratios, work procedures, responsible departments, dispute resolution, internal supervision and accountability, and so on. It also applies to employees who have left the company and to retirees. In the same year, in June, the former China Banking and Insurance Regulatory Commission issued the “Corporate Governance Guidelines for Banking and Insurance Institutions,” again emphasizing that such institutions should establish this system.

In August 2022, the Ministry of Finance clarified that for financial enterprises in which employees fail to perform their duties diligently within their own responsibilities, leading to major illegal and noncompliant conduct or major risk losses, the financial enterprise should hold people accountable and recover compensation.

From the system’s early emergence in 2010 to the present, as banks actively implement and disclose it, the performance compensation recovery and clawback mechanism has taken 15 years to complete the shift from “policy advocacy” to “industry standard.”

In their 2025 annual reports, several banks described their mechanisms for deferred payment of performance compensation and performance compensation recovery and clawback.

For example, Bank of China stated that for senior management and personnel in key positions, more than 40% of their performance compensation is subject to deferred payment, and the deferment period is generally not less than 3 years. If, during employment, unusually excessive exposure of risk losses within responsibilities occurs, the bank may partially or fully reclaim the performance compensation already paid within the corresponding period, and will stop payment of the portion that has not yet been paid.

Agricultural Bank of China stipulates that if senior management and key-position personnel commit violations, unlawful acts, breaches of discipline, or unusually excessive exposure of risks within their scope of responsibilities, performance compensation and deferred-payment performance compensation for the corresponding period will be reduced, reclaimed, and stopped based on the severity and circumstances.

Rural? (Ruifeng Bank, 瑞丰银行) said that when situations such as unusually excessive exposure of risk losses within responsibilities, being responsible for major risk events, or receiving regulatory penalties arise, it has the right to recover and claw back already paid performance compensation and to stop payment of any unpaid portion.

Yibin Bank sets proportions in stages: the proportion for deferred payment of compensation for its chairman, president (or general manager), chairman of the board of supervisors, and secretary of the disciplinary inspection commission is 50% of that year’s performance compensation; for other personnel, the deferred-payment proportion is 40% of that year’s performance compensation. The deferred-payment period for performance compensation is generally 3 years. It uses a method of equal payments over 3 years, and pays out each year starting from the following year.

Regarding the rollout of this mechanism, Wang Pengbo said that performance compensation recovery and clawback should be viewed as an observational window into a bank’s risk management and corporate governance maturity—not merely a negative signal. He believes that if the mechanism is truly and effectively implemented, it indicates that the bank has risk-retrospection capabilities and a responsibility-implementation mechanism. However, one must be wary of formalized operations and focus on whether the recovery is linked to specific risk events, whether it covers key positions, and whether disclosure is sustained.

In Wang Pengbo’s view, if “reverse wage recovery” becomes normalized, front-line customer managers and approving personnel will pay more attention to the long-term risk performance of projects rather than only watching short-term efforts to boost volume in the current period. In the long run, this is beneficial for a more stable banking system and reduces the inertia of “heavy deployment, light management.” But he also reminds that this mechanism may lead some institutions to become overly conservative—loan approvals may be discouraged—and the industry will still need to find a better balance between incentives and constraints in the future.

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Cover image source: Every day’s media assets database (每经媒资库)