The code of practice, published in February this year, aimed to ensure all employers had risk-focused remuneration policies - covering wages, bonuses, incentive plans, pensions and severance packages - that do not expose them to risk.
But 84% of employers surveyed by law firm Pinsent Masons do not think the code will make a difference to remuneration and 78% are not reviewing their severance arrangements and payout levels.
The findings come as the FSA's consultation on the codes of practice closes, prior to implementation as early as November this year.
Tom Flanagan, employment partner at Pinsent Masons, said: "Since the FSA first commented on bonuses and remuneration last autumn, there has been a greater focus on senior level pay, but in many cases bonuses have continued to be paid even though performance objectives have not been met.
"Whilst this may seem perverse given the current state of the economy and the shareholder unrest it has created, we feel it highlights two fears among businesses; a fear of losing top executives at a time when it could be argued they are needed most, and a fear of tackling the thorny issue of changing contracts.
"Businesses are in a catch-22 situation. They are under pressure to rein in benefits which are now deemed excessive by some stakeholders, but they also need to retain their best talent to help get them through the recession.
"Not paying bonuses could lead to the exit of senior staff, which could explain why discretionary benefits continue to be granted even if the business is not performing well."
Employers dismiss FSA guidelines on executive pay
More than eight out of 10 employers think remuneration and bonus guidelines from the Financial Services Authority (FSA) will have little or no impact on the way executives are rewarded.