Multiple listed banks reveal their 2025 "reverse salary recovery" accounts, with one bank recovering over 47 million yuan in a year

By Daily Economic News Reporter｜Zhang Yi｜Daily Economic News Editor｜Wei Wenyi

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

The so-called “performance compensation recovery and clawbacks”—what the industry commonly calls “reverse wage recovery”—usually refers to situations where an employee commits violations or breaches discipline, or where, within the scope of their duties, risk losses are exposed to an abnormal extent. In such cases, banks, according to relevant regulations, may stop payment of the performance compensation that has not yet been paid to the corresponding personnel depending on the severity, or may recover part of the compensation already paid.

Reporters from the Daily Economic News (hereinafter “Daily Economic News reporter”) reviewed and found that as of April 3, among A-share listed banks and Mainland banks listed in Hong Kong that have released their 2025 annual reports, almost all have mentioned the performance compensation recovery and clawback mechanism in their annual reports. This includes state-owned large banks, nationwide joint-stock banks, as well as city commercial banks and rural commercial banks. Among them, more than 10 banks disclosed the specific amounts recovered and clawed back; the amounts are as high as over 47 million yuan, and as low as only 2,300 yuan.

Wang Pengbo, a senior analyst in the financial industry at Bocom Consulting, told Daily Economic News reporters in an analysis that if the performance compensation recovery and clawback mechanism is truly and effectively implemented, it shows that the bank has the ability to trace risks back and a responsibility-implementation mechanism. However, it is also necessary to be alert to formalized operations.

State-owned large banks have higher recovery scales

Based on the 2025 data disclosed so far, the absolute scale of state-owned large banks’ “reverse wage recovery” is higher, while some nationwide joint-stock banks are by no means weaker in terms of力度.

For example, in the Bank of China case, its 2025 annual report shows that the bank carried out performance compensation recovery and clawbacks for 4,630 person-times, with a total amount of 47.17 million yuan. Both figures are temporarily the highest among the banks whose annual reports have been disclosed.

Worth noting is that the Bank of China has disclosed recovery information 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. Across the three years, cumulative recoveries and clawbacks exceeded 102 million yuan, involving a total of 9,158 person-times.

China Construction Bank, on the other hand, disclosed that in 2025, there were no cases of performance compensation recovery and clawbacks for its directors and senior management. But 17 person-times of its management cadres and personnel at a corresponding level were subject to recovery, involving an amount of 1.99 million yuan, which is lower than 26 person-times and 3.74 million yuan in 2024.

In 2025, Bohai Bank recovered performance compensation for 816 person-times, totaling 19.58 million yuan. In amount terms, it decreased compared with 612 person-times and 24.03 million yuan in 2024.

In 2025, Huaxia Bank executed performance compensation recovery and clawbacks for 577 employees, with a total amount of 9.8503 million yuan, down from 751 person-times and 22.21M yuan in 2024.

It is worth noting that in 2025, Zhejiang Commercial Bank’s recovered and clawed back amounts exceeded 135k yuan. Specifically, the bank recovered and clawed back for 970 person-times throughout the year, with a total amount of 13.6873 million yuan. Compared with 1,424 person-times and 30.3378 million yuan in 2024, the recovery amount in 2025 fell by more than half, but the absolute scale still remains among the top group among the disclosed banks.

In addition, Industrial and Commercial Bank of China, China Merchants Bank, Minsheng Bank, and others also stated clearly in their 2025 annual reports that relevant systems have been established and implemented, but they did not disclose the specific amounts.

Ping An Bank said that the performance evaluation and assessment results for its executives’履職 during the reporting period are still being confirmed; after confirmation, they will be disclosed separately.

Local banks’ clawback amounts vary widely

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

Some local banks, although their absolute recovery and clawback amounts in 2025 were not large, also disclosed them. For example, RuiFeng Bank recovered and clawed back 3.8221 million yuan; Dongguan Rural Commercial Bank’s total recovery and clawback amount was 3.66 million yuan; Yuyang Rural Commercial Bank’s cumulative recovery and clawbacks were 2.9093 million yuan; Shanxi Bank recovered and clawed back 30 employees, with a total amount of about 0.1546 million yuan; and Yibin Bank recovered and clawed back 2,300 yuan.

In addition, in 2025, Gansu Bank had 43 person-times involved in accountability for违规 matters. The performance compensation recovered and clawed back totaled 135k yuan. This compares 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 recovered only several thousand yuan? In response, Wang Pengbo believes that the differences in recovery data among banks are obvious; more often, they result from the combined impact of scale, historical burdens, and the internal accountability execution timeline.

“Like state-owned large banks, they have large asset portfolios and long business cycles, and combined with the regulator’s higher and clearer requirements for accountability tracing in recent years, it is not surprising to see recoveries on a larger scale. But some city commercial banks have small clawback amounts, which does not necessarily indicate that their risk controls are better; it may also mean that the problems have not been fully exposed yet, or that the accountability mechanism is still being improved step by step,” Wang Pengbo emphasized. He added that you cannot judge which bank has stronger risk control just by looking at the size of recovery figures; you also need to look together with more substantive indicators such as the non-performing loan ratio and the provision coverage ratio.

Daily Economic News reporters noted that although some listed banks had cases of performance compensation recovery and clawbacks in 2025, their asset quality did not deteriorate; it improved instead.

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

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

The compensation recovery mechanism is fully implemented

The performance compensation recovery and clawback mechanism is not a new thing. Its policy lineage can be traced back to the “Guidelines for Sound Compensation Supervision of Commercial Banks” issued by the CBIRC in 2010. The guideline for the first time clarified that commercial banks should formulate rules for deferred performance compensation recovery and clawbacks.

In January 2021, the general office of the CBIRC issued the “Guiding Opinions on Establishing and Improving Performance Compensation Recovery and Clawback Mechanisms for Banking and Insurance Institutions,” which made clear that banking and insurance institutions should, in accordance with regulations, establish and improve performance compensation recovery and clawback mechanisms, including the circumstances under which performance compensation recovery and clawbacks apply, the clawback recovery ratios, work procedures, responsible departments, dispute handling, internal supervision and accountability, and that it applies to both employees who have left and retired personnel.

That same year in June, the CBIRC issued the “Corporate Governance Code 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 employees fail to perform their duties diligently within their own responsibilities, resulting in major illegal and noncompliant behavior by financial enterprises or major risk losses, financial enterprises should pursue responsibility and recover wages.

From the early institutional seeds in 2010 to today’s proactive execution and disclosure by banks, it took 15 years for the performance compensation recovery and clawback mechanism to make the transition from a “policy advocacy” stage to “industry standard equipment.”

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

For example, the Bank of China clearly stated that for senior management personnel 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 abnormal exposure to risk losses within one’s duties occurs during employment, the bank may recover all or part of the performance compensation paid within the corresponding period, and may stop payment of the portion not yet paid.

Agricultural Bank of China stipulates that if senior management personnel and personnel in key positions commit illegal, noncompliant, or disciplinary acts, or experience abnormal exposure to risks within their scope of duties, then depending on circumstances, the bank will deduct, recover, and stop payment of the corresponding-period performance compensation and deferred-payment performance compensation.

RuiFeng Bank stated that when there are circumstances such as abnormal exposure to risk losses within one’s duties, taking responsibility for major risk events, or being subject to regulatory penalties, it has the right to recover and claw back already paid performance compensation and stop payment of unpaid portions.

Yibin Bank sets the proportions in segments. The deferral-payment proportion for compensation of its chairman, president, chairman of the supervisory board, and secretary of the discipline inspection commission is 50% of the performance compensation for that year; for other personnel, the deferral-payment proportion of performance compensation is 40% of the performance compensation for that year. The deferral-payment period for performance compensation is generally 3 years, and it uses a method of equal payments over 3 years to settle it year by year starting from the following year.

Regarding the implementation of this mechanism, Wang Pengbo said that performance compensation recovery and clawbacks should be viewed as an observation window for the maturity of a bank’s risk management and corporate governance, not just as a purely negative signal. He believes that if the mechanism is truly and effectively implemented, it means the bank has the ability to trace risks back and a mechanism for implementing responsibility. However, it is necessary to be alert to formalized operations; attention should be paid to whether recoveries are tied to specific risk events, whether they cover key positions, and whether disclosures are continuous.

In Wang Pengbo’s view, if “reverse wage recovery” becomes normalized, front-line client managers and approving personnel will care more about the long-term risk performance of projects rather than only focusing on the scale-building in the current period. In the long run, this is conducive to a more robust banking system and reduces the inertia of “heavy lending, light management.” But he also reminds that this mechanism may cause some institutions to become overly conservative—being unwilling to extend loans that should be extended. Going forward, the system will still need to find a better balance between incentives and constraints.

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