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Bank, insurer and super fund APRA disclosures shed light on pay practices
13/04/2026
The first APRA required disclosures (to comply with CPS 511) for Significant Financial Institutions (SFIs) have shone a light into some of the differences in pay across the regulated financial services landscape.
This article summarises analyses of executive fixed and total remuneration for specified roles across the 28 Significant Financial Institutions (SFIs).
The data was considered in aggregate and split into 3 categories: Listed companies (LIS), Unlisted For-Profit (UFP), and Other institutions (superannuation and mutual-type entities) as of 1 April 2026.
Key findings:
- Listed companies’ executives receive a pay premium above those in other companies, although the companies in the listed sample were also larger.
- The pay premium is not apparent at the Material Risk Taker (MRT) level.
- When considering the data in aggregate, a consistent 4% median increase was observed in Total Fixed Remuneration (TFR) across all four CPS 511 roles – CEO, Senior Manager (SM), Highly Paid Material Risk-Taker (HPMRT), and Material Risk-Taker (MRT).
- When considering across categories, listed company roles that are likely to be disclosed in remuneration reports (CEOs and Senior Managers) had the lowest fixed pay increases. Large increases were enjoyed by CEOs of Unlisted For-Profits and Other entities.
- Few companies had employees who were paid highly enough to be classified an HPMRT (A HPMRT is defined as material risk-takers whose total fixed remuneration plus actual variable remuneration is equal to or greater than $1 million AUD in a financial year of the entity).
- Not all companies classified employees outside of the senior executive cohort as MRT. It was more likely for larger companies to classify employees as MRTs who were outside the senior executive level.
- The pay mix varies drastically by category; Listed companies favour an “at-risk” model, while “Other” institutions (super funds/mutuals) provide relatively little at risk pay.
Table 1 outlines the average total fixed remuneration summary statistics across key CPS 511 roles.
Table 1: Average total fixed remuneration paid for each role
|
|
CEO |
SM |
HPMRT |
MRT |
|
Company Count |
28 |
28 |
9 |
13 |
|
Average |
$1.49m |
$0.64m |
$0.73m |
$0.41m |
|
25th percentile |
$1.12m |
$0.52m |
$0.56m |
$0.32m |
|
50th percentile |
$1.50m |
$0.62m |
$0.67m |
$0.40m |
|
75th percentile |
$1.72m |
$0.72m |
$0.80m |
$0.45m |
All fixed remuneration is paid in cash. The market rate is consistent for the CEO as the median and average are nearly identical.
Some companies may classify HPMRTs or MRTs within the Senior Manager (SM) category. This is reflected in the disclosure, with only 9 companies providing specific remuneration data for HPMRTs and 13 for MRTs.
This table below displays the year-on-year percentage growth in average total fixed remuneration across each CPS 511 specified role.
Table 2: Average total fixed remuneration percentage increase on previous financial year for each role
|
|
CEO |
SM |
HPMRT |
MRT |
|
Company Count |
18 |
22 |
9 |
11 |
|
Average |
7% |
4% |
3% |
7% |
|
25th percentile |
3% |
3% |
3% |
3% |
|
50th percentile |
4% |
4% |
4% |
4% |
|
75th percentile |
9% |
6% |
5% |
6% |
The 50th percentile shows a synchronised 4% increase across all categories—CEO, SMs, and MRTs alike. In cases where the percentage increase was not provided in the disclosure, there was likely an incumbent change which makes the year-on-year comparison not applicable.
The table below outlines the average total remuneration summary statistics across key CPS 511 roles.
Table 3: Average total remuneration paid for each role
|
|
CEO |
SM |
HPMRT |
MRT |
|
Company Count |
28 |
28 |
9 |
13 |
|
Average |
$4.70m |
$1.50m |
$2.01m |
$0.63m |
|
25th percentile |
$1.71m |
$0.78m |
$1.44m |
$0.47m |
|
50th percentile |
$2.90m |
$1.03m |
$1.52m |
$0.60m |
|
75th percentile |
$5.75m |
$1.74m |
$1.66m |
$0.74m |
The data shows a significant pay premium for CEOs and HPMRTs, whose average total remuneration of $4.70m and $2.01m respectively far exceeds that of SMs and other MRTs.
The table below shows the average total fixed remuneration summary statistics for each role split by sample categories.
Table 4: Average total fixed remuneration paid for each role split by categories
|
Category |
Summary statistics |
CEO |
SM |
HPMRT |
MRT |
|
LIS |
Count |
13 |
13 |
8 |
6 |
|
Average |
$1.75m |
$0.74m |
$0.66m |
$0.42m |
|
|
Median |
$1.72m |
$0.74m |
$0.65m |
$0.37m |
|
|
UFP |
Count |
7 |
7 |
0 |
4 |
|
Average |
$1.14m |
$0.51m |
N/A |
$0.35m |
|
|
Median |
$1.10m |
$0.52m |
N/A |
$0.34m |
|
|
Other |
Count |
8 |
8 |
1 |
3 |
|
Average |
$1.37m |
$0.57m |
N/A |
$0.47m |
|
|
Median |
$1.26m |
$0.61m |
N/A |
$0.45m |
The fixed remuneration paid by Listed (LIS) entities at the median are significantly larger than that of Unlisted For-Profit (UFP) companies.
The table below shows year-on-year percentage growth in average total fixed remuneration summary statistics for each role split by sample categories.
Table 5: Average year-on-year percentage growth in average total fixed remuneration for each role split by categories
|
Category |
Summary statistics |
CEO |
SM |
HPMRT |
MRT |
|
LIS |
Count |
8 |
12 |
8 |
6 |
|
Average |
4% |
3% |
4% |
9% |
|
|
Median |
3% |
3% |
4% |
3% |
|
|
UFP |
Count |
5 |
5 |
0 |
4 |
|
Average |
7% |
5% |
N/A |
4% |
|
|
Median |
8% |
4% |
N/A |
4% |
|
|
Other |
Count |
5 |
5 |
1 |
1 |
|
Average |
12% |
5% |
N/A |
N/A |
|
|
Median |
6% |
5% |
N/A |
N/A |
The data shows listed entities are the most conservative with fixed pay growth (averaging 3% to 4% for most roles) while unlisted companies applied stronger base pay adjustments (averaging 7% for Unlisted For-Profit (UFP) company CEOs and 12% for ‘Other’ company CEOs).
The table below presents the average total remuneration summary statistics for each role split by sample categories.
Table 6: Average total remuneration paid for each role split by categories
|
Category |
Summary statistics |
CEO |
SM |
HPMRT |
MRT |
|
LIS |
Count |
13 |
13 |
8 |
6 |
|
Average |
$7.52m |
$2.28m |
$2.07m |
$0.67m |
|
|
Median |
$5.67m |
$2.05m |
$1.51m |
$0.55m |
|
|
UFP |
Count |
7 |
7 |
0 |
4 |
|
Average |
$2.25m |
$0.92m |
N/A |
$0.50m |
|
|
Median |
$1.80m |
$0.88m |
N/A |
$0.49m |
|
|
Other |
Count |
8 |
8 |
1 |
3 |
|
Average |
$2.27m |
$0.74m |
N/A |
$0.72m |
|
|
Median |
$1.66m |
$0.76m |
N/A |
$0.74m |
Table 4 and 6 confirm a substantial “listed premium”, with CEOs and SMs of Listed (LIS) companies consistently outearning their peers in both fixed remuneration and total remuneration.
Listed company CEOs receive an average fixed remuneration of $1.75m, which is 54% higher than Unlisted For-Profit (UFP) CEOs ($1.14m) and 28% higher than those in the “Other” category ($1.37m). The gap widens dramatically when variable pay is included. Listed company CEOs earn an average total of $7.52m, more than triple the average for both UFP CEOs ($2.25m) and “Other” CEOs ($2.27m).
The table below shows the balance of fixed to variable remuneration. The CPS 511 definition includes service-based incentives as variable remuneration.
Table 7: Mix between total fixed remuneration and total variable remuneration split by category
|
Category |
|
CEO |
SM |
HPMRT |
MRT |
||||
|
|
|
Fixed (%) |
Variable (%) |
Fixed (%) |
Variable (%) |
Fixed (%) |
Variable (%) |
Fixed (%) |
Variable (%) |
|
LIS |
Company Count |
13 |
13 |
13 |
13 |
8 |
8 |
6 |
6 |
|
Average |
33% |
67% |
42% |
58% |
38% |
62% |
64% |
36% |
|
|
Median |
30% |
70% |
40% |
60% |
39% |
61% |
66% |
34% |
|
|
UFP |
Company Count |
7 |
7 |
7 |
7 |
0 |
0 |
4 |
4 |
|
Average |
55% |
45% |
60% |
40% |
N/A |
N/A |
71% |
29% |
|
|
Median |
55% |
45% |
62% |
38% |
N/A |
N/A |
71% |
29% |
|
|
Other |
Company Count |
8 |
8 |
8 |
8 |
1 |
1 |
3 |
3 |
|
Average |
73% |
27% |
78% |
22% |
N/A |
N/A |
67% |
33% |
|
|
Median |
77% |
23% |
77% |
24% |
N/A |
N/A |
62% |
38% |
|
The mix reveals a stark divergence in pay philosophy across the sector: Listed (LIS) institutions operate an “at-risk” model where the average CEO receives 67% of their pay as variable remuneration, whereas institutions in the “Other” category (super funds and mutuals) prioritise guaranteed pay, with 73% of CEO compensation delivered as fixed pay.
One-off payments remain rare across the 28 SFIs:
- Sign-on Awards: Granted to 1 CEO (of 32), 12 Senior Managers (of 375), 6 Highly Paid MRTs (of 214), and 4 Other MRTs (of 222).
- Severance Payments: Received by 0 CEOs (of 32), 37 Senior Managers (of 375), 5 HPMRTs (of 214), and 11 MRTs (of 222).
While downward adjustments are applied by only a small subset of entities, the financial impact increased with seniority.
- CEOs: 5 companies applied adjustments, averaging 128% of TFR.
- SMs: 13 companies applied adjustments, averaging 11% of TFR.
- HPMRTs: 4 companies applied adjustments, averaging 7% of TFR.
- MRTs: 5 companies applied adjustments, averaging 2% of TFR.
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