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.

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

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

So-called “performance-based compensation clawback and recovery,” also known in the industry as “reverse debt collection,” generally refers to cases where, when an employee commits violations of rules and regulations or disciplinary offenses, or when risk losses unusually exposed occur within their scope of duties, the bank—based on relevant regulations—halts payment of the performance-based compensation not yet paid to the corresponding personnel depending on the circumstances’ severity, or recovers part of the compensation that has already been issued.

A reporter from The Daily Economic News (hereinafter “Each Daily reporter”) reviewed and found that as of April 3, A-share listed banks that had released their 2025 annual reports and mainland banks listed in Hong Kong, in their annual reports, almost all mentioned the performance-based compensation clawback and recovery mechanism. This covers state-owned big 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 and recovery amounts—more than 47 million yuan in some cases and as little as only 2,300 yuan in others.

Wang Pengbo, a senior analyst in the financial services industry at Bocomm Consulting, told Each Daily reporter that if the performance-based compensation clawback and recovery mechanism is truly and effectively implemented, it indicates that banks have risk trace-back capability and responsibility-implementation mechanisms. However, at the same time, it is necessary to be alert to formalized or performative implementation.

State-owned big banks lead the scale of clawbacks and recoveries, with Bank of China totaling over 100 million yuan in clawbacks over three years

Based on the 2025 figures disclosed so far, the state-owned big banks’ “reverse debt collection” has a higher absolute scale, while some national joint-stock banks are also by no means less forceful in their efforts.

Taking Bank of China as an example, its 2025 annual report shows that the bank carried out clawback and recovery for 4,630 person-times in total, with an aggregate amount of 47.1782 million yuan. Both figures are currently ranked first among the banks whose annual reports have been disclosed.

What is worth noting is that Bank of China has disclosed its clawback and recovery situation for three consecutive years. In 2023, the bank 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 totaled more than 102 million yuan, involving 9,158 person-times in total.

China Construction Bank also disclosed that in 2025, its board of directors and senior management did not have any performance-based compensation clawback and recovery. However, 17 person-times among head office management officers and personnel 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 carried out performance-based compensation clawback and recovery 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-based compensation clawback and recovery for 577 employees, with a total of 9.8503 million yuan, down sharply from 751 employees and 22.2070 million yuan in 2024.

It is also worth noting that Zhejiang CITIC Bank’s clawback and recovery in 2025 exceeded 10 million yuan. Specifically, the bank clawed back and recovered 970 person-times over the full year, with a total amount of 13.6873 million yuan. Compared with its 2024 recovery data of 1,424 person-times and 30.3378 million yuan, the clawback amount in 2025 fell by more than half, but its absolute scale still remains among the top in the banks whose results have been 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 the relevant systems and executed them, but did not disclose the specific amounts. Ping An Bank stated that the performance appraisal and assessment results of its executives’ fulfillment of duties during the reporting period are still in the confirmation process; once confirmed, it will disclose them separately.

The clawback amounts vary widely among local banks, highlighting differences in risk control and accountability timing

Among local banks, Zhongyuan Bank’s clawback and recovery scale for 2025 is relatively prominent, reaching 13.5715 million yuan. This is also the second consecutive year in which the bank has clawed back more than 10 million yuan after 20.1076 million yuan in 2024.

Some local banks, while their absolute clawback and recovery amounts in 2025 are not large, also disclosed information. For example, RuiFeng Bank clawed back and recovered 3.8221 million yuan; Dongguan Rural Commercial Bank recorded total clawback and penalty amounts of 3.66 million yuan; YuNong Rural Commercial Bank cumulatively clawed back and recovered 2.9093 million yuan; JinShang Bank clawed back and recovered for 30 employees, with a total amount of approximately 1.546 million yuan; and Yibin Bank clawed back and recovered 2,300 yuan.

In addition, the number of people held accountable for the violations that occurred at Gansu Bank in 2025 involved 43 person-times, and the total performance-based compensation clawback and recovery amounted to 135,000 yuan. Compared with 44 person-times and 60,600 yuan in 2024, the per-capita scale increased.

Why do some banks recover tens of millions of yuan, while others recover only a few thousand yuan? In response, Wang Pengbo believes that the distinctly different clawback and recovery data among banks are more the result of the combined effects of differences in scale, historical burdens, and the timing rhythm of internal accountability and enforcement.

“Like state-owned big banks, with large asset pools and long business cycles, along with the fact that regulatory requirements for accountability tracing have clearly strengthened in recent years, it’s not surprising that clawbacks on a larger scale occur. Meanwhile, when some city commercial banks have smaller clawback amounts, it does not necessarily mean their risk control is better; it could simply be that the issues have not been fully exposed yet, or that their accountability mechanisms are still being improved step by step,” Wang Pengbo emphasized. He added that you cannot judge which bank has stronger risk control by looking only at the size of the clawback numbers; you also need to look together with more substantive indicators such as the non-performing loan ratio and allowance coverage ratio.

Each Daily reporter noted that although some listed banks had performance-based compensation clawback and recovery situations in 2025, their asset quality did not decline; instead, it improved.

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

In addition, in 2025, the non-performing loan ratios of Zhejiang Bank, Bohai Bank, Huaxia Bank, Dongguan Rural Commercial Bank, and YuNong Rural Commercial Bank were 1.36%, 1.76%, 1.55%, 1.79%, and 1.08%, respectively, all down 0.02 percentage points, 0.02 percentage points, 0.05 percentage points, 0.05 percentage points, and 0.1 percentage point year over year, respectively.

Comprehensive implementation of the compensation clawback mechanism, moving from policy requirements to industry norm

In practice, the performance-based compensation clawback and recovery mechanism is not a new thing. Its policy origins can be traced back to the “Guidelines on Sound Compensation Regulation for Commercial Banks” issued by the former China Banking Regulatory Commission in 2010. The guidance first clarified that commercial banks should formulate rules for deferred payment and clawback of performance-based compensation.

In January 2021, the former China Banking and Insurance Regulatory Commission’s General Office issued the “Guiding Opinions on Establishing and Improving Performance-Based Compensation Clawback and Recovery Mechanisms for Banking and Insurance Institutions,” clarifying that banking and insurance institutions should establish and improve performance-based compensation clawback and recovery mechanisms in accordance with regulations, including the applicable scenarios for performance-based compensation clawback and recovery, clawback and recovery ratios, work procedures, responsible departments, dispute handling, internal supervision, and accountability, and that it applies to employees who have left the company as well as 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 emphasizing that banking and insurance institutions should establish this system.

In August 2022, the Ministry of Finance clarified that if an employee fails to diligently perform their duties within their own responsibilities, resulting in a major illegal violation or major risk loss by a financial enterprise, the financial enterprise should be held accountable for pursuing compensation and pursuing clawbacks.

From the germination of the system in 2010 to today’s active execution and disclosure by various banks, the performance-based compensation clawback and recovery mechanism has taken 15 years to complete the transition from “policy advocacy” to “industry standard.”

In the 2025 annual reports, many banks introduced their mechanisms for deferred payment of performance-based compensation and clawback and recovery.

For example, Bank of China clearly stated that for senior management and personnel in key positions, more than 40% of their performance-based compensation is subject to deferred payment, and the deferral period generally is not less than 3 years. If an unusual exposure of risk losses occurs within their duties during their employment, the bank may partially or fully recover the performance-based compensation issued within the corresponding period, and will halt payment of the portion not yet issued that is subject to deferral.

Agricultural Bank of China stipulates that if senior management and personnel in key positions commit illegal, non-compliant, or disciplinary acts, or have unusual risk exposure within their scope of duties, then depending on the severity, the relevant period’s performance-based compensation and deferred payment compensation will be reduced, recovered, and payment halted.

RuiFeng Bank stated 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 clawback and recovery of the performance-based compensation that has already been issued and halt payment of the portion that has not been paid.

Yibin Bank sets the proportions in segments. The proportions for deferred payment of pay for its chairman, president, chairman of the board of supervisors, and the secretary of the Commission for Discipline Inspection are 50% of the performance-based compensation for that year; for other personnel, the proportion for deferred payment of performance-based compensation is 40% of the performance-based compensation for that year. The deferral period for performance-based compensation is generally 3 years. It uses the method of equal payments over 3 years to release payment year by year starting from the following year.

Regarding the implementation of this mechanism, Wang Pengbo stated that performance-based compensation clawback and recovery should be viewed as an observation window for assessing the maturity of a bank’s risk management and corporate governance, rather than merely a negative signal. He believes that if the mechanism is truly and effectively implemented, it shows that banks have risk trace-back capabilities and responsibility-implementation mechanisms. However, it is necessary to be wary of formalized operations. Attention should be paid to whether the clawback is linked to specific risk events, whether it covers key positions, and whether it continues to be disclosed.

In Wang Pengbo’s view, if “reverse debt collection” becomes normalized, frontline account managers and approvers will care more about the long-term risk performance of projects, rather than only focusing on boosting scale in the current period. In the long run, this is beneficial for 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—unwilling to extend loans that should be extended—and the next step will still need 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. Operate at your own risk.

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