By way of circular dated November 4, 2019, RBI has replaced the existing guidelines and issued revised guidelines on ‘Compensation of Whole-Time Directors /Chief Executive Officers / Material Risk Takers and Control Function Staff’ applicable to all private sector banks (including local area banks, small finance banks and payments banks) and foreign banks operating in India and for pay cycles with effect from April 1, 2020. The following key changes have been proposed under the new guidelines: (i) at least 50% of the compensation has to be variable, (ii) inclusion of share-linked instruments such as employee stock options as a component of variable pay, (iii) capping of variable pay component at 300% of the fixed pay component, (iv) a minimum of 50% of the variable pay if the variable pay is up to 200% of the fixed pay, or 67% if the variable pay is more than 200% of the fixed pay, is to be paid via non-cash component, (v) for senior executives, a compulsory deferral mechanism for variable pay, regardless of the quantum of variable pay, has been introduced, (vi) mandatory imposition of claw-back arrangements in case of deferred compensation, and (vii) qualitative and quantitative criteria for identification of material risk takers. Banks are also now mandated to make disclosures on remuneration of the specified officers on an annual basis at the minimum, forming part of their annual financial statements.