Section 13 - Resource account disclosure

What is disclosure?

13.1.1 Disclosure is the publication in the Remuneration Report of the salary, bonus, pension and compensation details of your senior management, and of summary data on your use of exit packages.  The Remuneration Report should also include details of your remuneration policy and the nature of contracts of those covered by the Report. Further information about the preparation of Remuneration Reports is contained in Section 5 of the Financial Reporting Manual (FReM).

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Who is subject to disclosure?

13.1.2 The senior management team will normally be your Management Board or a similar group of very senior officials. You should find out who is included because each department or agency or Non Departmental Public Body is responsible for deciding which posts are covered by the disclosure requirements. The notice in Annex 13D must be sent to all staff covered by the disclosure requirements.

13.1.3 You must disclose salary and pension information on all departmental ministers and members of the senior management team. You must also disclose any compensation payments paid to members of the senior management team on loss of office, although you must tell them in advance of your intention to disclose, invite them to see what you intend to publish, and tell them that they can object under Article 21 of the General Data Protection Regulation (GDPR). Ministers are paid severance payments under statute. You do not disclose compensation paid to Ministers.

Important Reminder

Non-disclosure is possible unless you can demonstrate, under the GDPR, compelling legitimate grounds for the disclosure which override the interests, rights and freedoms of the member or for the establishment, exercise or defence of legal claims. If a member does not agree to disclosure, you must consider whether to accept it. You are strongly advised to take legal advice in such a case, because if you decide not to publish this may be challenged under the Freedom of Information Act. Where non-disclosure is agreed, the fact that certain disclosure has been omitted should be disclosed.

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What disclosure is required?

13.1.4   You should disclose the following information in a Remuneration Report:

• Salary for 2022-23 & 2021-22
   
  You should include as salary: gross salary; overtime; London weighting or allowances; recruitment and retention allowances; private office allowances; ex-gratia payments; and any other taxable allowances or payments.
  
  The payment of legitimate expenses is not part of the salary.
  
  Figures regarding Ministers’ salaries are already available to the public and you should disclose them to the nearest £1. 
  
  For senior management these figures are not generally available to the public and you should disclose them in bands of £5,000.
• Bonuses for 2022-23 & 2021-22
  
  Bonuses for senior management should be included in bands of £5,000, and should relate to performance in the year in which they become payable to the individual.
• Benefits in kind for 2022-23 & 2021-22
   
  You should include as “benefits in kind” any taxable benefits that are not given to the individual as cash. The most common taxable benefit is the provision of an allocated car.
  
  Most civil servants do not receive benefits in kind.
  
  The payment of legitimate expenses is not a benefit in kind. 
  
  You should disclose these figures to the nearest £100.
• Value of pension benefits for single total figure of remuneration for 2022-23 & 2021-22.
   
  You should disclose the total value of pension, calculated as the real increase in pension multiplied by 20, plus the real increase in any lump sum, less contributions made by the member.
  
  The real increases exclude increases due to inflation or any increase or decrease due to a transfer of pension rights.
• Ratio of top to median staff pay for 2022-23 & 2021-22.
   
  You should include the median remuneration of your staff and the ratio between this and the mid-point of the banded remuneration of your highest paid director (whether or not this is the Accounting Officer or Chief Executive).
  
  The calculation is based on the full-time equivalent staff at 31/03/23 on an annualised basis.
• Accrued pension and lump sum (if applicable to dual members with classic or classic plus linked benefits) as at 31/03/23.
   
  You should disclose the pension that the individual would receive if 31/03/23 were their last day in service. 
  
  The pension and lump sum (if applicable to dual members with classic or classic plus linked benefits) includes any benefits that have accrued from the individual buying added years, added pension, or transferring in benefits from another scheme.
  
  If a member has a preserved award from a previous Civil Service employment that they have not opted to aggregate (or link) with the pension from their current service, you should not record this.
  
  Where a member has opted out of the pension arrangements for the whole of the year, no pension figures should be reported and a footnote should be included saying “xxxxx chose not to be covered by the Civil Service pension arrangements during the reporting year” (if someone opts out or opts in during the year, they should be treated in the same way as a leaver or joiner).
  
  If the member’s pension included a deduction for Scheme Pays, you should record the gross pension before the scheme pays has been applied.
  
  Where a member has taken partial retirement in the year being reported, they will generally be reported as having a mix of active and pensioner benefits, but the treatment will vary depending on the particular item being reported on. 
  
  The objective of the single total figure of remuneration is to show the value of pension benefits accrued during the year. 
  
  In the year of partial retirement, this should therefore include the increase in pension relating to the accrual based on pay and service before partial retirement (whether or not this element of pension was taken on partial retirement), plus the pension accrued since partial retirement. 
  
  Likewise, in the year of partial retirement the "real increase in pension and related lump sum at pension age" in the CETV table should reflect the pension accrued during the year before and after partial retirement. 
  
  The "accrued pension and related lump sum" figure should show the total pension, with details of the amount taken on partial retirement. 
  
  However, the CETV figures should only value the pension accrued but not taken, so a footnote stating that the member took partial retirement in the year should be included to explain any decrease in the CETV. 
  
  In subsequent years the accrued pension and related lump sum figure in the CETV table in the Remuneration Report should continue to show the total pension, with details of the amount taken on partial retirement and an explanation in a footnote.
  
  You should disclose the accrued pension and lump sum in bands of £5,000.

• Real increase in pension and lump sum
  
  This is the increase in the value of the pension over the year after considering the effect of inflation.
  
  Ministers and members in alpha and with dual benefits in premium or nuvos do not automatically receive a lump sum and so you do not disclose one.
  
  Members with dual benefits in classic and classic plus receive an automatic lump sum, which you should disclose.
  
  You should disclose the real increase in pension and lump sum in bands of £2,500.
• Cash Equivalent Transfer Value (CETV) as at 31/03/22 and 31/03/23.
  
  This is the capital value of the pension and is worked out using guidance provided by the scheme actuary. 
  
  It is an assessment of what it costs the scheme to provide these pension benefits. You should disclose these figures to the nearest £1,000.
• Individuals who have been subject to a pension sharing order
  
  The Resource Accounts are meant to show the cost to the Department of employing the individual over the reporting year. 
  
  The cost to the Department does not change because the member has a Pension Sharing Order against their pension benefits. 
  
  Therefore, you should disclose the member's pension without any reduction to reflect the Pension Sharing Order.

• Real increase in CETV
  
  This reflects the increase in CETV that is funded by the employer. 
  
  It does not include the increase in accrued pension due to inflation or contributions paid by the employee (including the value of any benefits transferred from another pension scheme or arrangement). 
  
  If an individual has brought a transfer in during the reporting year, you should add a footnote to the increase in pension to say that it includes a transfer in.
  
  You should disclose these figures to the nearest £1,000.
• Compensation payments
  
  You must disclose compensation paid to senior management unless they can argue for non-disclosure under the General Data Protection Regulation.
  
  You should include a description of the compensation payment and details of the total amounts paid (the cost to be used must include any top-up to compensation provided by the employer to buy out the actuarial reduction on an individual’s pension).
  
  Where you have a compromise agreement with an individual, which contains a confidentiality clause, disclosure may still be required. You should always seek your own legal advice wherever a confidentiality clause in a compromise agreement exists or is under consideration.
  
  The confidentiality clause should expressly state that it does not prevent disclosure of information about the individual’s compensation where this is required by law or any requirements of a Parliamentary Committee, or where inclusion of the details of compensation paid is required in Departmental Resource Accounts pursuant to the provisions of the FReM. 
  
  Where disclosure is required in these circumstances, it does not require the individual’s permission.
  
  You should also disclose severance payments paid to Ministers.
• Ex-gratia payment 
  
  If you make other payments to the individual, such as an ex-gratia payment, then this should be included in the total disclosed for salary.

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Disclosure of exit packages

13.1.5   The use of exit packages for all staff should be reported in a note to the resource accounts. An example of the requirement is included in Annex C. Form of disclosure sources of information

13.1.6   We have included an example of a Remuneration Report at Annex 13C. Where an individual has a non-standard pension arrangement (e.g. accelerated accrual or membership of the Supplementary Scheme), you should disclose this in the report.

13.1.7   You should obtain information on salary, bonuses, benefits in kind, and exit packages from your records.

13.1.8   You should approach RPMI for pension information relating to Ministers using Annex 13B.

13.1.9   You should send the Annex 13A to MyCSP for pension information for civil servants.

Important Reminder

Your pensions administrator will not be able to start calculating the disclosure figures until after the pension system has been updated after the January 2023 payroll. The figures for anyone who started working for you late in the reporting year may be delayed while your pensions administrator obtains the relevant data.

13.1.10   If you have any civil servants who are members of the Civil Service Supplementary (Earnings Cap) scheme, you should advise MyCSP who will combine Supplementary Scheme figures with the main scheme figures.

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Ministers and senior managers who are not in post for the whole reporting year

13.1.11 When you are preparing your Remuneration Report, you may find that you have individuals covered by the report who were appointed during the reporting year. 

You may also have individuals who left during the reporting year. You should disclose the date of appointment, or last day of service as appropriate.

It is essential that the Remuneration Report includes the details of any individual that has retired during the financial year.

13.1.12 You should only disclose the pay, benefits in kind and pension information that relate to the period during which they were in a post subject to disclosure. However, you should also disclose the full year equivalent of the salary. The following example illustrates this point:

A civil servant joins the Board of the department on 1 July 2022.  Between 1 July 2022 and 31 March 2023, they received a salary of £90,000. You should disclose the salary of £90,000 in the Remuneration Report, that this was only for nine months, and that the full year equivalent is £120,000. You should not disclose the salary they received before 1 July 2022.

You should still disclose the CETV for 31 March 2023, which is the end of the reporting period. However, you should disclose the CETV at 30 June 2022 (which is the value immediately before the individual joins the Board) rather than 31 March 2022. 

If the civil servant was subject to disclosure in their previous post then the opening figure in your accounts should match the closing figure in their previous employer’s accounts.

If an individual is new to the Civil Service you will not have a figure for the start date.

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Partnership pension accounts

13.1.13   If a member of the senior management team has opted to have a partnership pension account rather than joining the pension scheme then you should disclose this in the Remuneration Report. 

13.1.14   You should ask your payroll provider to work out the total employer contributions paid to the partnership pension provider in the reporting year. You should disclose this figure in the Remuneration Report to the nearest £100.

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Departmental staff

13.1.15  You should include a note in your departmental resource accounts that contains:

• the contributions you have paid to the PCSPS/Alpha;
• the contributions you have paid to partnership pension providers during the reporting year;
• the contributions you are due to pay to partnership pension providers at the end of the reporting year;
• the contributions you paid to partnership pension providers during the reporting year that you did not need to pay until after the end of the reporting year.

13.1.16   We suggest that you base this note on the following example:

‘The Principal Civil Service Pension Scheme (PCSPS) and the Civil Servant and Other Pension Scheme (CSOPS) – known as “alpha” – are unfunded multi-employer defined benefit schemes but (insert employer’s name) is unable to identify its share of the underlying assets and liabilities. 

The Scheme Actuary valued the PCSPS as at 31 March 2016. You can find details in the resource accounts of the Cabinet Office: Civil Superannuation.

For 2022-23, employers’ contributions of £XXXX were payable to the PCSPS (2021-22 £XXXX) at one of four rates in the range 26.6% to 30.3% of pensionable earnings, based on salary bands. 

The Scheme Actuary reviews employer contributions usually every four years following a full scheme valuation. The contribution rates are set to meet the cost of the benefits accruing during 2022-23 to be paid when the member retires and not the benefits paid during this period to existing pensioners.

Employees can opt to open a partnership pension account, a stakeholder pension with an employer contribution. Employers’ contributions of £XXXX were paid to one or more of the panel of three appointed stakeholder pension providers. Employer contributions are age-related and ranged from 8% to 14.75%. 
Employers also match employee contributions up to 3% of pensionable earnings. In addition, employer contributions of £XXXX, 0.5% of pensionable pay, were payable to the PCSPS to cover the cost of the future provision of lump sum benefits on death in service or ill health retirement of these employees.

Contributions due to the partnership pension providers at the balance sheet date were £XXXX. Contributions prepaid at that date were £XXXX.

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Ill-health retirement

13.1.17   You should disclose details of the number and total additional accrued pension liabilities, payable by the PCSPS/alpha for individuals who retired early on health grounds during the year, in the notes to the departmental resource accounts.

13.1.18   You do not need to report a capitalised figure for the additional accrued pension liabilities. You should request from your pensions administrator, and report, the difference between the pension the member received after retiring on ill-health grounds and the pension they would have received had they resigned on that date.

Your note would then read:

‘XXX individuals retired early on ill-health grounds; the total additional accrued pension liabilities in the year amounted to XXX.’

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