What Is 'Compensation Actually Paid'?

Two Numbers, One Proxy: Why Your Pay Figure Isn't Singular

You are preparing for a comp committee meeting, and the proxy in front of you lists two different totals for the same executive in the same fiscal year. One is the familiar Summary Compensation Table figure — the number you've used for years to anchor a benchmarking conversation. The other sits in a newer table, tagged in machine-readable format, and moves up or down with the stock price in ways the first number never did. If you've assumed these are two versions of the same fact, you're not alone, and the mismatch matters more than it looks. By the end of this article, you'll know exactly what the second number measures, how it's built, and why it changes what "market pay" means the next time you sit across from a compensation committee.

What Is Compensation Actually Paid, Exactly?

Compensation actually paid, usually shortened to CAP, is a disclosure concept created by the SEC's Pay Versus Performance rules — Item 402(v) of Regulation S-K, adopted August 25, 2022 and effective starting with 2023 proxy statements (per Mintz, 2022). It is not a replacement for the Summary Compensation Table. It is a second, parallel calculation designed to answer a narrower question: what did this executive's equity and pension holdings actually turn out to be worth as the company's stock price and performance moved during the year, rather than what those awards were valued at on the day they were granted.

That distinction is the entire reason compensation actually paid exists. The Summary Compensation Table reports equity awards at their grant-date fair value — a snapshot estimate made the day the grant is approved, using assumptions about volatility, vesting probability, and time. That estimate does not update as the stock rises, falls, or as performance conditions resolve. Compensation actually paid does update. It replaces grant-date fair value with the value of unvested and vested awards as of fiscal year-end (or vesting date), recalculated using the actual stock price and performance outcomes for that year.

How Compensation Actually Paid Differs From the Summary Compensation Table

The mechanical difference comes down to timing and revaluation. The Summary Compensation Table books an equity grant once, at issuance, and never touches that number again regardless of what the stock does afterward. Compensation actually paid, by contrast, follows the award through its life: it marks unvested equity to its year-end fair value, marks vested equity to its vesting-date value, and layers in adjustments for pension value changes tied to service cost and actuarial assumptions. The result is that the two figures for the same executive, in the same year, can diverge meaningfully — CAP will run well above the Summary Compensation Table total in a strong stock-price year and well below it in a down year, even when the executive's target pay opportunity never changed.

This is precisely the confusion a reader flags when comparing compensation actually paid vs Summary Compensation Table totals side by side for the first time: the two numbers are not measuring the same thing, and neither one is "wrong." One is a grant-date estimate of opportunity. The other is a year-end reconstruction of realized value. If you want the full line-by-line mechanics of that comparison, the companion piece on compensation actually paid vs the Summary Compensation Table walks through the adjustment categories directly.

Why the SEC Created This Second Number

Regulators built compensation actually paid to solve a specific transparency gap. Proxy statements have long disclosed the top five most highly paid executive officers in a company's Summary Compensation Table, including the CEO and CFO (per Meridian Compensation Partners, 2025), but that table's equity figures freeze at grant date even though most large-company CEO pay is now delivered through multi-year, performance-contingent equity. Median S&P 500 CEO actual total direct compensation ran near $17 million in 2024, with long-term incentives — chiefly performance equity — remaining the primary driver of that total (per Harvard Law School Forum on Corporate Governance, 2026, FY2024). When the largest slice of pay is an estimate that never gets trued up, investors and boards lose the ability to see whether pay actually tracked performance, which is exactly the accountability question say-on-pay votes are meant to test.

Compensation actually paid closes that gap by forcing a year-end reconciliation. It sits inside the broader pay-versus-performance table required by Item 402(v), which must appear in the proxy or information statement itself — not in the annual report on Form 10-K (per Greenberg Traurig, 2023) — and which must be tagged using Inline XBRL, a structured data format that produces a single document readable by both people and machines (per SEC.gov, 2024). That tagging requirement matters practically: it is what makes compensation actually paid figures extractable at scale rather than something an analyst has to retype by hand out of a PDF.

Reading the Pay Versus Performance Table Where CAP Lives

If you open the pay-versus-performance table itself, you'll typically see compensation actually paid reported for the CEO and, as an average, for the other named executive officers, alongside the company's total shareholder return, a peer-group TSR comparison, net income, and a company-selected financial performance measure. The table is built to let a reader trace, year over year, whether the line for CAP moved in the same direction as the performance lines beside it — the entire diagnostic the rule exists to enable. For a full walkthrough of that table's structure and what each column is proving, see the dedicated guide to the Item 402(v) pay-versus-performance table; for the broader disclosure context it sits inside, the pay-versus-performance disclosure explained piece covers how CAP fits alongside pay ratio and other Dodd-Frank-era requirements. And because compensation actually paid is fundamentally a set of adjustments layered on top of the original table, it helps to be fluent in the base document first — the Summary Compensation Table explained is the right starting point if that table itself is still unfamiliar.

What This Means When You're the One Being Benchmarked

A pay figure that cannot say which table it came from, and whether it's a grant-date estimate or a year-end reconstruction, is not a benchmark — it's a guess dressed up as a number.

For an executive preparing for a renewal, an offer negotiation, or a change-of-control conversation, the practical takeaway is straightforward: know which number you're citing. If a comp committee references compensation actually paid because the stock had a strong year, and you counter with a Summary Compensation Table figure from a down year, you're not comparing apples to apples — and a compensation committee that already tracks both numbers will notice. CEOSalary parses both the Summary Compensation Table and the XBRL-tagged pay-versus-performance disclosures directly from SEC filings, builds a peer set by revenue band and sector, and positions each figure by percentile with its source cited — so the number you bring to the table names exactly which table, and which year, it came from.

To go deeper on reading these two tables side by side, along with the pay ratio disclosure that often appears in the same proxy, the Proxy Disclosure Decoder: Pay Ratio & Pay-Versus-Performance Reader walks through both Item 402(u) and Item 402(v) line by line, using real filed examples.