Last year's bank "reverse salary collection" ledger: some recovered nearly 50 million yuan, others doubled

How do regulatory policies ensure fairness in salary recovery through AI oversight?

Salaries that have been paid out can still be reclaimed. “Reverse salary collection,” banks are taking it seriously.

Recently, Southern Metropolis Bay Finance and Society reporters reviewed the 2025 annual reports of listed banks and found that many banks mentioned the recovery and clawback of performance-based compensation from the previous year. Among them, Bank of China had the highest amounts and number of recoveries, totaling 47.1782 million yuan and 4,630 instances, while Zheshang Bank, Bohai Bank, and Zhongyuan Bank also reported recoveries exceeding ten million yuan.

Compared to the previous year, some banks saw a significant increase in the amounts and instances of recovery. For example, Dongguan Rural Commercial Bank and Chongqing Rural Commercial Bank both doubled their recovery amounts.

Some banks recovered over 10.2k yuan

Performance-based compensation recovery refers to the salary management system where financial institutions can suspend or recover unpaid or already paid performance bonuses for senior management, key position personnel, and other responsible staff due to errors in payment, failure to diligently perform duties, illegal activities, or risk losses caused by them.

According to bank annual reports, at least ten banks disclosed data on performance-based compensation recovery from 2025 onward.

Among state-owned banks, Bank of China reported that in 2025, it recovered from 4,630 instances, totaling 47.1782 million yuan. On average, about 10.2k yuan was recovered per instance. In 2024, Bank of China recovered performance bonuses from 2,469 instances totaling 32.5 million yuan. Compared to the previous year, the number of recoveries increased by 87.53%, and the amount by 45.16%.

Other state-owned banks stated in their annual reports that they have established mechanisms for deferred payment and recovery of performance-based compensation but did not disclose specific recovery data.

In joint-stock banks, Zheshang Bank, Bohai Bank, and Huaxia Bank disclosed relevant data. Zheshang Bank recovered performance-based compensation from 970 instances, totaling 13.6873 million yuan, averaging about 14.1k yuan per instance. Compared to 2024, the number of recoveries decreased by 31.88%, and the total amount by 54.88%.

Bohai Bank recovered 14.1k yuan from 816 instances last year, averaging 24k yuan per instance. The number of recoveries increased, but the total amount decreased compared to 2024.

Huaxia Bank recovered performance-based compensation from 577 employees, totaling 9.8503 million yuan, with an average of 17.1k yuan per instance. Both the number of instances and the total amount decreased compared to 2024. Notably, the bank stated that there were no recoveries involving senior management.

Some city and rural commercial banks doubled recovery amounts

Some city and rural commercial banks also disclosed “reverse salary collection” data. Among them, Zhongyuan Bank recovered 13.5715 million yuan, the highest among the listed city and rural banks.

According to data from the Enterprise Warning System, in 2025, Zhongyuan Bank received 32 regulatory penalties, including 10 institutional penalties and 22 individual penalties, with a total confiscation and fines amounting to 4.81 million yuan.

Additionally, Ruifeng Bank recovered 3.8221 million yuan; Dongguan Rural Commercial Bank recovered a total of 3.66 million yuan through responsibility investigations and recoveries; Harbin Bank recovered over 19.58M yuan involving 321 instances; Chongqing Rural Commercial Bank recovered a total of 2.9093 million yuan; Gansu Bank faced accountability for violations involving 43 instances, with recoveries totaling 135k yuan.

Compared to state-owned and joint-stock banks, most city and rural commercial banks reported lower recovery amounts, but the increases compared to 2024 were generally significant. For example, Dongguan Rural Commercial Bank, Chongqing Rural Commercial Bank, and Gansu Bank all saw more than doubling their recovery amounts. Harbin Bank’s recovery amount increased by nearly 50%, with instances rising by 176%, from 116 in 2024 to 321.

Avoid selective enforcement against some senior executives

Southern Metropolis Bay Finance and Society reporters learned that recovery and deferred payment systems complement each other. Due to the lagging risk exposure characteristic of financial operations, using deferred payment can balance current and long-term, benefits and risks, and facilitate enforcement of recoveries.

In February 2020, the former China Banking and Insurance Regulatory Commission issued the “Guidelines for the Regulation of Sound Compensation in Commercial Banks,” which clearly states that senior management and employees in risk-important positions should have at least 40% of their performance-based pay deferred, with a minimum deferral period of three years. For key senior management, the deferred proportion should be above 50%, ideally reaching 60% if conditions permit.

The guidelines also emphasize that commercial banks should establish rules for deferred performance pay and recovery. If within the specified period, senior management or relevant staff cause extraordinary risk losses in their duties, the bank has the right to recover all performance pay already disbursed and suspend all unpaid portions. These rules should also apply to departing staff.

In January 2021, the former China Banking and Insurance Regulatory Commission issued the “Guiding Opinions on Establishing and Improving the Performance Pay Recovery Mechanism of Banking and Insurance Institutions,” which clarified specific circumstances for enforcement. It states that for senior management and key personnel involved in illegal, non-compliant, or disciplinary violations, banks should recover all or part of their performance pay within the relevant period based on severity.

Additionally, four situations require banks to recover all or part of the performance pay of responsible senior management and key personnel within the relevant period: serious underperformance of key regulatory indicators; measures such as takeover by regulators; occurrence of major risk events causing severe market disorder; or other significant damages to the bank’s property or reputation.

According to the “Three-Year Action Plan for Improving Corporate Governance in Banking and Insurance” released by the former China Banking and Insurance Regulatory Commission in March 2023, over 95% of banking and insurance institutions have established and implemented systems for deferred payment and recovery of performance-based compensation.

A staff member from the Beijing Regulatory Bureau of the National Financial Regulatory Administration stated that financial institutions should strengthen enforcement of recovery measures, insisting on regular application. First, they must fairly and impartially enforce relevant systems, avoiding selective enforcement against some senior executives or retirees. Second, they should fully utilize legal means such as labor dispute mediation, arbitration, and civil litigation to pursue compensation from those refusing to return funds, creating a rigid constraint and preventing complacency among some employees. Third, they should link performance pay with prudent risk management, transforming regulatory policies into industry development and institutional self-discipline, fostering a culture of sound operation, and ensuring steady, healthy, and sustainable growth of commercial banks.

Reporting: Liu Lanlan, Southern Metropolis Bay Finance and Society