Capital adequacy

Bank Pekao S.A. Group and Bank Pekao S.A.

Capital ratios are the basic measure applied for the measurement of capital adequacy according to Regulation of the European Parliament and of the Council (EU) No 575/2013 of June 26, 2013 on prudential requirements for credit institutions and amending Regulation (EU) No 648/2012, which entered into force since January 1, 2014 together with further amendments, as well as Commission Implementing Regulations or Delegated Regulations (EU) (CRR Regulation).

Capital ratios, capital requirements and own funds have been calculated in accordance with the above mentioned CRR Regulation using national options defined in article 171a of The Banking Act, Act of 5 August 2015 on macro-prudential supervision over financial system and crisis management in financial system (Act on macro-prudential supervision), as well as regulations of minister in charge of the finance institutions.

According to law, Bank Pekao S.A. Group and Bank Pekao S.A. are required to maintain minimal values of capital ratios resulting from Pillar I level (CRR Regulation), capital requirement of Pillar II resulting from The Banking Act and combined buffer requirement resulting from Act on macro-prudential supervision.

Minimal value of capital ratios on Pillar I level are:

Total capital ratio (TCR) in amount of 8%,
Tier I capital ratio (T1) in amount of 6%,
Common Equity Tier I capital ratio (CET 1) in amount of 4.5%.

Combined buffer requirement as at 31 December 2025 consists of:

Capital conservation buffer in amount of 2.50%,
Countercyclical capital buffer in amount of 1.00%¹ for Bank Pekao S.A. and Bank Pekao S.A. Group,
Other systemically important institution buffer in amount of 1.00%,
Systemic risk buffer in amount of 0.00%².

On Pillar II, Bank Pekao S.A. and Bank Pekao S.A. Group have no additional capital requirement (P2R).

^1. Countercyclical capital buffer was calculated as of December 31, 2025 at the level 0,9960% for Bank Pekao S.A. and 0, 9963% for Bank Pekao S.A. Group, due to the fact that on 18 September 2024, the Minister of Finance issued a regulation according to which countercyclical capital buffer ratio is equal to 1% of the total risk exposure amount for credit exposures in the territory of the Republic of Poland.
^2. According to the Regulation of the Minister of Finance, the systemic risk buffer was abolished on March 19, 2020. The buffer value applicable until that date was 3% of the total risk exposure amount for all exposures located only in the territory of the Republic of Poland.

Together, Bank Pekao S.A. and Bank Pekao S.A. Group are obliged to maintain:

Total capital ratio (TCR) in amount of 12.50%,

Capital ratio Tier I (T1) in amount of 10.50%,

Common Equity Tier (CET 1) in amount of 9.00%.

The capital ratios of Bank Pekao S.A. Group and Bank Pekao S.A. were significantly above the minimum required by the law.

Bank Pekao S.A. Group

As of December 31, 2025 Bank Pekao S.A. Group total capital ratio amounted to 16.4% and common equity Tier I ratio amounted to 15.0%.

The table below presents the basic information concerning Bank Pekao S.A. Group capital adequacy as of 31 December, 2025 and 31 December, 2024.

CAPITAL REQUIREMENT (PLN mln)	31.12.2025	31.12.2024*
Credit Risk	12 088	11 064
Market Risk	105	93
Counterparty credit risk including CVA	224	150
Operational risk	1 753	2 049
Total capital requirement	14 170	13 356
OWN FUNDS (PLN mln)
Common Equity Tier I Capital	26 642	25 889
Tier II Capital	2 464	2 074
Own funds for total capital ratio	29 106	27 963
Common Equity Tier I Capital ratio (%)	15.0%	15.5%
Total capital ratio TCR (%)	16.4%	16.8%

*Data for December 31, 2024 have been recalculated taking into account the retrospective recognition of part of the profit for 2024 (after confirmation of the financial results by the General Shareholders Meeting), in accordance with the EBA position expressed in Q&A 2018_3822 and Q&A 2018_4085.

Common equity Tier I Capital Ratio of Pekao S.A. Group as at the end of December 2025 was lower by 0.5 p.p. compared to the end of December 2024, mainly due to the increase of total capital requirement by 6.1% despite higher Common Equity Tier I Capital by 4.1%. Total Capital Ratio of Bank Pekao S.A. Group as at the end of December 2025 was lower by 0.4 p.p. compared to the end of December 2024.

Increase of Tier II Capital at the end of December 2025 compared to the end of December 2024 results from issuance of subordinated bonds E series in the amount of 750 mln, partially compensated by amortization of subordinated bonds A series and B series (during final 5 years of maturity of the instrument).

Bank Pekao S.A.

As of December 31, 2025 Bank Pekao S.A. total capital ratio amounted to 18.7% and common equity Tier I ratio amounted to 17.2%.

The table below presents the basic information concerning Bank Pekao S.A. capital adequacy as of 31 December, 2025 and 31 December, 2024.

CAPITAL REQUIREMENT (PLN mln)	31.12.2025	31.12.2024*
Credit Risk	10 594	9 611
Market Risk	99	93
Counterparty credit risk including CVA	224	150
Operational risk	1 667	1 887
Total capital requirement	12 584	11 741
OWN FUNDS (PLN mln)
Common Equity Tier I Capital	27 000	26 295
Tier II Capital	2 464	2 074
Own funds for total capital ratio	29 464	28 369
Common Equity Tier I Capital ratio (%)	17.2%	17.9%
Total capital ratio TCR (%)	18.7%	19.3%

* Data for December 31, 2024 have been recalculated taking into account the retrospective recognition of part of the profit for 2024 (after confirmation of the financial results by the General Shareholders Meeting), in accordance with the EBA position expressed in Q&A 2018_3822 and Q&A 2018_4085.

Common equity Tier I Capital Ratio of Pekao S.A. as at the end of December 2025 was lower by 0.7 p.p. compared to the end of December 2024, mainly due to the increase of total capital requirement by 7.2% despite higher Common Equity Tier I Capital by 3.9%. Total Capital Ratio of Bank Pekao S.A. as at the end of December 2025 was lower by 0.6 p.p. compared to the end of December 2024.