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

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

So-called “performance compensation clawback and recovery,” i.e., what industry insiders commonly refer to as “reverse wage collection,” usually means that when an employee commits violations or breaches discipline, or when risk losses within their scope of duties are exposed in an unusually severe way, the bank—based on relevant regulations—may stop payment of the performance compensation that has not yet been paid to the corresponding personnel, depending on the severity of the circumstances, or may recover part of the compensation that has already been paid out.

The reporter from The Daily Economic News (hereinafter “our reporter”) found that, as of April 3, among A-share listed banks that had released their 2025 annual reports and mainland banks listed in Hong Kong, nearly all mentioned the performance compensation clawback and recovery 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 specific clawback and recovery amounts—more than 47 million yuan in some cases, and as little as 2,300 yuan in others.

Wang Pengbo, a senior analyst at Bowei Consulting in the financial industry, told our 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 backward and a mechanism to ensure responsibility is carried out. However, at the same time, it is necessary to be wary of formalized operations.

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

Taking Bank of China as an example, its 2025 annual report shows that the bank carried out performance compensation clawback and recovery for a total of 4,630 person-times, with a total amount of 47.1782 million yuan. Both figures are temporarily the highest among the banks that have released annual reports.

Notably, Bank of China has disclosed recovery information 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 the three years combined, the clawback and recovery exceeded 102 million yuan, involving a total of 9,158 person-times.

China Construction Bank also disclosed that in 2025, its board of directors and senior management personnel had no performance compensation clawback and recovery. However, 17 person-times of the bank’s head-office management personnel and people at a corresponding level were subject to clawback, involving an amount of 1.99 million yuan, which was lower than 26 person-times and 3.74 million yuan in 2024.

In 2025, Bohai Bank clawed back and recovered performance compensation for 816 person-times, totaling 19.58 million yuan, which declined compared with 612 person-times and 24.03 million yuan in 2024. In 2025, Huaxia Bank carried out performance compensation clawback and recovery for 577 employees, with a total of 9.8503 million yuan, representing a significant decrease compared with 751 employees and 22.2070 million yuan in 2024.

It is worth noting that in 2025, Zhejiang Commercial Bank’s performance compensation clawback and recovery exceeded 135k yuan. Specifically, over the whole year, it clawed back and recovered 970 person-times, with a total amount of 13.6873 million yuan. Compared with its 2024 figures of 1,424 person-times and 30.3378 million yuan, the 2025 recovered amount fell by more than half, but in absolute scale it still ranks among the top among the banks that have disclosed information.

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 specific amounts. Ping An Bank said that the performance evaluation and assessment results for its executives’履職 during the reporting period are still under confirmation; once confirmed, it will disclose separately.

Among local banks, Zhongyuan Bank stood out in terms of its 2025 clawback and recovery scale, reaching 13.5715 million yuan. This is also the second consecutive year that the bank’s clawback and recovery amount has exceeded 60.6k yuan, following 20.1076 million yuan in 2024.

Some local banks, although their absolute clawback and recovery amounts in 2025 were not large, also disclosed them. For example, RuiFeng Bank clawed back and recovered 3.8221 million yuan; Dongguan Rural Commercial Bank’s performance compensation clawback and recovery and penalties totaled 3.66 million yuan; Yu Nong Rural Commercial Bank cumulatively recovered 2.9093 million yuan; Jin Shan Bank recovered performance compensation involving 30 employee person-times, with a total amount of about 0.1546 million yuan; and Yibin Bank recovered 2,300 yuan.

In addition, Gansu Bank reported 43 person-times of employees being held accountable for compliance violations that occurred in 2025, and the performance compensation clawback and recovery totaled 135k yuan. Compared with 44 person-times and 60.6k yuan in 2024, the per-capita scale increased.

Why did some banks recover several tens of millions of yuan, while others only recovered several thousand yuan? Wang Pengbo believes that the clawback and recovery data with clearly different scales across banks is more the result of the combined effect of scale, historical burdens, and the internal implementation timetable for accountability.

“Like state-owned large banks: their asset base is bigger, their business cycles are longer, and on top of that, regulatory requirements for tracing responsibility have clearly strengthened in recent years—so it’s not surprising to see large-scale clawback and recovery. Meanwhile, for some city commercial banks, smaller clawback and recovery amounts do not necessarily mean they manage risk better; it may simply be that problems have not been fully exposed, or that their accountability mechanism is still being improved step by step.” Wang Pengbo emphasized that you cannot judge which bank’s risk control is stronger based only on the size of clawback and recovery numbers; you also need to look at more substantive indicators such as the non-performing loan ratio and provision coverage ratio.

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

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

Also in 2025, the non-performing loan ratios of Zhejiang Commercial Bank, Bohai Bank, Huaxia Bank, Dongguan Rural Commercial Bank, and Yu Nong Rural Commercial Bank were 1.36%, 1.76%, 1.55%, 1.79%, and 1.08%, respectively, each down 0.02 percentage points, 0.02 percentage points, 0.05 percentage points, 0.05 percentage points, and 0.1 percentage point year-on-year.

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

In January 2021, the General Office of the former China Banking and Insurance Regulatory Commission issued the “Guidance on Establishing and Improving the Performance Compensation Clawback and Recovery Mechanism for Banking and Insurance Institutions,” specifying that banking and insurance institutions should establish and improve such a mechanism in accordance with regulations, including the applicable scenarios for performance compensation clawback and recovery, the clawback and recovery ratios, work procedures, responsible departments, dispute handling, internal supervision and accountability, and that it applies to employees who have left and to retired personnel. In June of the same year, the former China Banking and Insurance Regulatory Commission issued the “Corporate Governance Guidelines for Banking and Insurance Institutions,” again stressing that banking and insurance institutions should establish this system.

In August 2022, the Ministry of Finance clarified that where employees fail to perform their duties diligently within their own responsibilities, leading to major unlawful or non-compliant conduct or major risk losses by financial enterprises, the financial enterprises should hold people accountable and pursue compensation.

From the budding of the system in 2010 to today’s active implementation and disclosure by various banks, the performance compensation clawback and recovery mechanism has taken 15 years to make the transition from “policy advocacy” to “industry standard equipment.”

In their 2025 annual reports, many banks introduced their mechanisms for deferring performance compensation payments and clawing back and recovering it.

For example, Bank of China clearly stated that for senior management and personnel in key positions, more than 40% of performance compensation is subject to deferred payment, and the deferral period is generally not less than 3 years. If, during employment, there is unusually severe exposure of risk losses within the employee’s responsibilities, the bank may partially or fully recover the performance compensation that has been paid out for the relevant period, and stop payment of the portion that has not yet been paid.

Agricultural Bank of China stipulates that where senior management personnel and key-position personnel commit unlawful, non-compliant, or disciplinary acts, or where risks within their scope of responsibilities are exposed in an unusually severe manner, depending on the severity of the circumstances, the performance compensation for the relevant period and the deferred performance compensation may be deducted, recovered, and stopped in accordance with the situation.

RuiFeng Bank stated that when circumstances arise such as unusually severe exposure of risk losses within duties, taking responsibility for major risk events, or receiving regulatory penalties, it has the right to pursue the clawback and recovery of performance compensation that has already been paid and stop the payment of any unpaid portion.

Yibin Bank sets percentages in segments: the deferred payment ratio for the compensation of its chairman, president, board supervisor chairman, and the secretary of the disciplinary inspection commission is 50% of the performance compensation for the year; the deferred payment ratio for other personnel’s performance compensation is 40% of the performance compensation for the year. The deferred payment period for performance compensation is generally 3 years, and it uses an equal-amount payment method over 3 years to settle it gradually starting from the next year.

Regarding the implementation of this mechanism, Wang Pengbo said it should treat performance compensation clawback and recovery as an observation window for the maturity of bank risk management and corporate governance, not simply as a negative signal. He believes that if the mechanism is truly and effectively executed, it shows that the bank has the ability to trace risks backward and a mechanism to ensure responsibility is fulfilled. But it is necessary to beware of formalized operations; attention should be paid to whether clawback is linked to specific risk events, whether it covers key positions, and whether there is continuous disclosure.

In Wang Pengbo’s view, if “reverse wage collection” becomes normalized, front-line customer managers and approvers will pay more attention to the long-term risk performance of projects rather than only focusing on driving scale in the current period. In the long run, this benefits a more stable banking system and reduces the inertia of “heavy investment, light management.” However, he also reminds that this mechanism may lead some institutions to become overly conservative—making them unwilling to lend what they should. Going forward, it will still be necessary to find a better balance between incentives and constraints.

Disclaimer: The contents and data in this article are for reference only and do not constitute investment advice. Please verify before using. If you act on this information, the risk shall be borne by you.

Cover image source: The Daily Economic News media resource database

Massive information, precise interpretation—right in the Sina Finance app