FIA EPTA members welcome the opportunity to respond to the EBA CP on Draft Guidelines on the benchmarking of diversity practices including diversity policies and gender pay gap under Directive 2013/36/EU and under Directive (EU) 2019/2034. Although FIA EPTA members agree that transparency in general, and more specifically benchmarking, will contribute to achieving these objectives, we are of the opinion that especially the level of detail of the questions regarding the diversity policies are not appropriate in the light of these objectives and/ or need further clarifications.
We note, generally, a few particular concerns, including firstly that we think some of the data requested may be more difficult to provide in light of GDPR implementation in various member states and limitations on some of the data that firms collect.
