2025-08-19 | NBB_2025_10

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Diversity - Summary of Belgian results for the EBA’s benchmarking exercise on diversity practices and the gender pay gap

The National Bank of Belgium reports that female representation among executive directors and CEOs in Belgian financial institutions increased slightly to 19% and 13% respectively, while the gender pay gap for executive directors widened to approximately 12%. The communication confirms that prudential expectations regarding diversity established in previous guidance remain in force for credit institutions and stockbroking firms. It further notes that the observed pay disparities indicate non-compliance with the principle of equal treatment under Belgian law.

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Public NBB_2025_10 – 19 August 2025 Communication – Page1/6 Boulevard de Berlaimont 14 – 1000 Brussels +32 2 221 38 12 Company number: 0203.201.340 Brussels RLE www.nbb.be Communication Public Brussels, 19 August 2025 Reference: NBB_2025_10 Your contact: Nicolas Strypstein +32 2 221 44 74 Nicolas.Strypstein@nbb.be Diversity - Summary of Belgian results for the EBA’s benchmarking exercise on diversity practices and the gender pay gap Scope

  • Credit institutions incorporated under Belgian law
  • Stockbroking firms incorporated under Belgian law
  • Belgian branches of credit institutions and stockbroking firms incorporated under the law of non-EEA countries Summary/Objectives By means of this communication, the National Bank of Belgium shares the results at Belgian level of the latest benchmarking exercise on diversity practices and the gender pay gap carried out by the European Banking Authority. Dear Sir or Madam, The promotion of diversity within the management bodies of credit institutions and stockbroking firms, with a particular focus on gender diversity, is embedded in the CRD1 and the IFD/MiFID II2 3 as well as in the supervisory legislation transposing these European directives into national law.4 In this context, the European Banking Authority (EBA) conducts a benchmarking exercise on diversity practices and the gender pay gap every three years. The most recent analysis was carried out this year (based on data for the period 2022 to 2024). 1 The Capital Requirements Directive (CRD) is Directive 2013/36/EU of the European Parliament and of the Council of 26 June 2013 on access to the activity of credit institutions and the prudential supervision of credit institutions and investment firms, amending Directive 2002/87/EC and repealing Directives 2006/48/EC and 2006/49/EC, amended by Directive (EU) 2019/878 of the European Parliament and of the Council of 20 May 2019 amending Directive 2013/36/EU as regards exempted entities, financial holding companies, mixed financial holding companies, remuneration, supervisory measures and powers and capital conservation measures. 2 The Investment Funds Directive (IFD) is Directive (EU) 2019/2034 of the European Parliament and of the Council of 27 November 2019 on the prudential supervision of investment firms and amending Directives 2002/87/EC, 2009/65/EC, 2011/61/EU, 2013/36/EU, 2014/59/EU and 2014/65/EU. 3 The Markets in Financial Instruments Directive II (MiFID II) is Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Directive 2002/92/EC and Directive 2011/61/EU. 4 The Act of 25 April 2014 on the legal status and supervision of credit institutions and the Act of 20 July 2022 on the legal status and supervision of stockbroking firms. BanqueNationale Jank DE BELGIQUE VAN BELGIË Eurosystem BanqueNationale Jank DE BELGIQUE VAN BELGIË Eurosystem

Public NBB_2025_10 – 19 August 2025 Communication – Page 2/6 The Bank participated in this exercise and, in this context, collected information from a sample of 25 financial institutions (20 credit institutions and five stockbroking firms incorporated under Belgian law), in accordance with the EBA’s instructions. 5 This communication is therefore a follow-up to communication NBB_2023_04 and is limited to the results of the exercise 2025 at the Belgian level. The prudential expectations regarding diversity set out in Communication NBB_2023_04 (Communication NBB_2023_04 / Diversity - EBA and NBB benchmarking exercises and prudential expectations | National Bank of Belgium) continue to apply and reference is made to it. The main findings of the results 2025 at Belgian level can be summarised as follows:

  1. With respect to the representation of women on the management bodies of the Belgian financial institutions in the sample, the results show a slight improvement:
  • On average, 21% of executive directors (up from 19% in 2022) and 13% of CEOs (compared with 11% in 2022) of Belgian institutions in the sample are female.
  • Women account for 39% on average of non-executive directors (37% in 2022) and 21% of chairpersons (13% in 2022). 2022 2025 5 More specifically, the sample consisted of eight credit institutions with a total balance sheet of more than €30 billion, two institutions with a total balance sheet of between €10 billion and €30 billion, five institutions with a total balance sheet of between €1 billion and €10 billion, five institutions with a total balance sheet of less than €1 billion and five stockbroking firms. The sample of financial institutions in 2022 included 28 institutions. 89% 81% 11% 19% 0% 50% 100% CEO Executive director M/F Executive directors Male Female Other 87% 63% 13% 37% 0% 0% 0% 50% 100% Chair Non-executive directors M/F Non-executive directors Male Female Other 79% 61% 21% 39% 0% 50% 100% Chair Non-executive director M/F Non-executive directors Male Female 87% 79% 13% 21% 0% 50% 100% CEO Executive director M/F Executive directors Male Female Other

Public NBB_2025_10 – 19 August 2025 Communication – Page 3/6 For directors appointed between 2022 and 2024, 33 of the 41 new executive directors were men and eight were women (compared with 36 men and 11 women in 2022). Of the 62 new non-executive directors, 38 were men and 24 were women (48 men and 31 women in 2022). 2022 2025 2. For the other aspects covered by the prudential definition of diversity, the results can be summarised as follows:

  • Age: slightly less concentration than in 2022 in one age group. 2022 2025 36 11 0 20 40 Male Female Newly appointed executive directors 33 8 0 20 40 Male Female Newly appointed executive directors 48 31 0 20 40 60 Male Female Newly appointed non-executive directors 38 24 0 10 20 30 40 Male Female Newly appointed non-executive directors 0 3 7 37 13 53 7 5 0 20 40 60 CEO Executive director NUMBER BY AGE M+F 30-40 41-50 51-60 61-70

70 0 8 3 19 14 48 6 15 0 1 0 20 40 60 CEO Executive director NUMBER BY AGE M+F 30-40 41-50 51-60 61-70 70

Public NBB_2025_10 – 19 August 2025 Communication – Page 4/6

  • Educational background: the number of executive and non-executive directors with an educational background in ICT remains insufficient. 2022 2025 0% 10% 20% 30% 40% 50% 60% EDUCATIONAL BACKGROUND Non-executive director Executive director 0% 10% 20% 30% 40% 50% 60% EDUCATIONAL BACKGROUND Non-executive director Executive director x 6 X e X -X’ .X x 6 X e X -X’ .X

Public NBB_2025_10 – 19 August 2025 Communication – Page 5/6

  • Professional background: situation equivalent to that of 2022. 2022 2025 0 50 100 150 200 250 PROFESSIONAL BACKGROUND Non-executive director Executive director 0 50 100 150 200 250 PROFESSIONAL BACKGROUND Non-executive director Executive director O6 y X -Î5
    w % % XXX XX \ % ƒ oX VXA Vx %>ƒ Vx XX X \ \ O6 y X -Î5
    w % % XXX XX \ % ƒ oX VXA Vx %>ƒ Vx XX X \ \

Public NBB_2025_10 – 19 August 2025 Communication – Page 6/6

  • Geographical provenance:6 the vast majority of both executive and non-executive directors are from the EU/EEA. 2022 2025
  1. With regard to the gender pay gap within the sample of 25 financial institutions, excluding CEO pay and based on median remuneration, there has been a deterioration in the situation, with male executive directors earning on average +/- 12% more than their female counterparts (up from 7% in 2022). For non￾executive directors, the gender pay gap has narrowed somewhat, from 4% (in 2022) to +/- 2%. These findings indicate non-compliance with the principle of equal treatment enshrined in Belgian law. Yours faithfully, Pierre Wunsch Governor 6 The term geographical provenance refers to the region where a person has gained a cultural, educational or prior professional background. This aspect should be taken into account in particular for institutions operating at international level. 28 6 2 3 1 3 1 28 3 1 0 0 2 0 26 3 2 3 1 2 1 0 5 10 15 20 25 30 Geographical provenance Internationally active institutions At least one executive director with prior international professional background At least one non-executive director with prior international professional background 23 4 1 2 1 3 0 23 5 1 2 2 3 1 23 5 4 5 1 4 0 0 5 10 15 20 25 EU/EEA Europe (Non EU/EEA) Africa North America South America Asia Australia Geographical provenance Internationally active institutions At least one executive director with prior international professional background At least one non￾executive director with prior international professional background