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ING Bank Śląski S.A.
Group
Annual Consolidated Financial Statements
for the year 2025
SELECTED FINANCIAL DATA FROM CONSOLIDATED FINANCIAL STATEMENTS

for the year ended 31 December |  |  |  |
| in PLN million | in EUR million*
2025 | 2024 | 2025 | 2024
Net interest income | 8,871 | 8,725 | 2,094 | 2,027
Net commission income | 2,359 | 2,294 | 557 | 533
Net income on basic activities | 11,805 | 11,246 | 2,786 | 2,613
Gross profit | 5,927 | 5,545 | 1,399 | 1,288
Net profit | 4,633 | 4,369 | 1,093 | 1,015
Weighted average number of ordinary shares (units) | 130,189,835 | 130,143,180 | 130,189,835 | 130,143,180
Earnings per ordinary share (in PLN / in EUR) | 35.59 | 33.57 | 8.40 | 7.80
Net cash flows | -1,051 | 1,320 | -248 | 307

as at 31 December |  |  |  |
| in PLN million | in EUR million**
2025 | 2024 | 2025 | 2024
Liabilities to customers | 282,025 | 260,359 | 66,725 | 60,931
Total assets | 130 | 130 | 31 | 30
Share capital | 21,342 | 17,170 | 5,049 | 4,018
Number of shares (pcs) | 130,100,000 | 130,100,000 | 130,100,000 | 130,100,000
Book value per share (in PLN / in EUR) | 164.04 | 131.98 | 38.81 | 30.89
Total capital ratio | 14.98% | 15.67% | - | -

*) to translate selected data into EUR for items of the Profit and Loss Account and for net cash flows, the exchange rate calculated as the average of the NBP exchange rates prevailing on the last day of each month in the period of 12
months of 2025 (PLN 4.2372) and 12 months of 2024 (PLN 4.3042 ),
**) the average NBP exchange rate valid for 31 December 2025 (PLN 4.2267) and as at 31 December 2024 (PLN 4.2730) was used to convert selected data into EUR for items in the statement of financial position.

1 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

ANNUAL CONSOLIDATED FINANCIAL STATEMENTS FOR THE PERIOD FROM 1 JANUARY 2025 TO 31 DECEMBER 2025
Contents

Consolidated income statement | 2
Consolidated statement of comprehensive income | 3
Consolidated statement of financial position | 4
Consolidated statement of changes in equity | 5
Consolidated cash flow statement | 6
Accounting policy and additional notes | 7
I. Bank and the Group details | 8
1. Key Bank data | 8
2. Scope and duration of operations | 8
3. Share capital | 8
4. Shareholders of ING Bank Śląski S.A. | 8
5. Entity authorised to audit the financial statements | 8
6. Approval of financial statements | 8
7. ING Bank Śląski S.A. Management Board and Supervisory Board composition | 8
8. ING Bank Śląski S.A. Group | 9
II. Statement of compliance with International Financial Reporting Standards | 11
1. Changes in accounting standards | 11
2. Going-concern | 12
3. Financial statements scope and currency | 12
4. Reporting period and comparable data | 12
5. Consolidation rules | 12
III. Significant accounting principles | 12
1. Basis for preparation of consolidated financial statements | 13
2. Professional judgment | 13
3. Accounting estimates | 13
4. Consolidation policies | 20
5. Foreign currency | 20
6. Net interest income | 21
7. Commission income and costs | 21
8. Net income on financial instruments measured at fair value through profit or loss and FX result | 23
9. Net income on the sale of financial assets and dividend income | 23
10. Net (loss)/income on hedge accounting | 23
11. Net (loss)/income on other basic activities | 23
12. Lease contracts and factoring services | 23

13. Financial assets and liabilities | 23
14. Property, plant and equipment and intangible assets | 36
15. Other financial assets | 39
16. Provisions | 39
17. Employee benefits | 40
18. Equity | 40
19. Income tax | 41
IV. Notes to the consolidated financial statements | 42
1. Segment reporting | 42
2. Net interest income | 44
3. Net commission income | 44
4. Net income on financial instruments measured at fair value through profit or loss and FX result | 45
5. Net income on the sale of securities and dividend income | 45
6. Net (loss)/income on hedge accounting | 45
7. Net (loss)/income on other basic activities | 45
8. General and administrative expenses | 46
9. Impairment for expected credit losses | 47
10. Cost of legal risk of FX mortgage loans | 48
11. Tax on certain financial institutions | 48
12. Income tax | 48
13. Earnings and book value per ordinary share | 49
14. Cash and cash equivalents | 49
15. Loans and other receivables to other banks | 49
16. Financial assets measured at fair value through profit or loss | 50
17. Valuation of derivatives | 50
18. Derivative hedging instruments | 51
19. Investment securities | 51
20. Assets securing liabilities | 52
21. Loans and other receivables to customers measured at amortised cost | 53
22. Investments in associates accounted for using the equity method | 54
23. Property, plant and equipment | 55
24. Intangible assets | 58
25. Deferred tax | 59
26. Other assets | 60
27. Liabilities to other banks | 60
28. Financial liabilities measured at fair value through profit or loss | 60
29. Liabilities to customers | 61

30. Liabilities from debt securities issued | 61
31. Subordinated liabilities | 61
32. Provisions | 61
33. Information on initiated administrative proceedings and significant court proceedings | 63
34. Other liabilities | 67
35. Equity | 67
36. Contingent liabilities | 70
37. Fair value | 70
38. Offsetting of financial instruments | 74
39. Supplementary information to the consolidated statement of cash flows | 75
40. Related entities | 78
41. Transactions with the management staff and employees | 79
42. Headcount | 80
43. Significant events after the balance sheet date | 80
Risk and capital management | 81
I. Capital management | 82
1. Introduction | 82
2. Minimum capital requirements | 82
3. Capital adequacy | 83
4. MREL requirements | 85
5. Dividend policy | 85
II. Risk management | 87
1. Introduction | 87
2. Credit risk | 90
3. Market risk | 116
4. Liquidity and funding risk | 130
5. Non-financial risk | 138
6. ESG risk | 140
7. Other risks | 142

2 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Consolidated income statement

for the year ended 31 December |  |  |
| Note | 2025 | 2024
Interest income | 2 | 13,812 | 13,112
calculated using effective interest rate method | 2 | 13,297 | 12,365
other interest income | 2 | 515 | 747
Interest expenses | 2 | -4,941 | -4,387
Net interest income | 2 | 8,871 | 8,725
Commission income | 3 | 2,987 | 2,887
Commission expenses | 3 | -628 | -593
Net commission income | 3 | 2,359 | 2,294
Net income on financial instruments measured at fair value through profit or loss and FX result | 4 | 521 | 198
Net income on the sale of securities measured at amortised cost | 5 | -4 | -6
Net income on the sale of financial assets at fair value through other comprehensive income and dividend income | 5 | 59 | -3
Net (loss)/income on hedge accounting | 6 | -15 | 10
Net (loss)/income on other basic activities | 7 | 14 | 28
Net income on basic activities |  | 11,805 | 11,246
General and administrative expenses | 8 | -4,284 | -3,958
Impairment for expected credit losses | 9 | -782 | -944
including profit on sale of receivables | 2.9.2 | 64 | 80
Cost of legal risk of FX mortgage loans | 10 | -60 | -92
Tax on certain financial institutions | 11 | -801 | -740
Share of profit/(loss) of associates accounted for using the equity method | 22 | 49 | 33
Gross profit |  | 5,927 | 5,545
Income tax | 12 | -1,294 | -1,176
Net profit |  | 4,633 | 4,369
attributable to shareholders of ING Bank Śląski S.A. |  | 4,633 | 4,369

for the year ended 31 December |  |  |
| Note | 2025 | 2024
Net profit attributable to shareholders of ING Bank Śląski S.A. |  | 4,633 | 4,369
Weighted average number of ordinary shares |  | 130,189,835 | 130,143,180
Earnings per ordinary share (in PLN) | 13 | 35.59 | 33.57

The diluted earnings per share are the same as the profit per one ordinary share.
The consolidated income statement should be read in conjunction with the notes to the consolidated financial statements being the integral part thereof.

3 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Consolidated statement of comprehensive income

for the year ended 31 December |  |  |
| Note | 2025 | 2024
Net profit the period: |  | 4,633 | 4,369
Total other comprehensive income, including: | 35.2 | 2,815 | 396
Items which can be reclassified to income statement, including: |  | 2,794 | 384
debt instruments measured at fair value through other comprehensive income - gains on revaluation carried through equity |  | 9 | 55
debt instruments measured at fair value through other comprehensive income - reclassification to financial result due to sale |  | -41 | 9
cash flow hedging - gains on revaluation carried through equity |  | 1,271 | -1,447
cash flow hedging - reclassification to profit or loss |  | 1,555 | 1,767
Items which will not be reclassified to income statement, including: |  | 21 | 12
equity instruments measured at fair value through other comprehensive income - gains on revaluation carried through equity |  | 26 | 15
actuarial gains/losses |  | -5 | -3
Net comprehensive income for the reporting period |  | 7,448 | 4,765
attributable to shareholders of ING Bank Śląski S.A. |  | 7,448 | 4,765

The consolidated statement of comprehensive income should be read in conjunction with the notes to the consolidated financial statements being the integral part thereof.

4 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Consolidated statement of financial position

as at 31 December |  |  |
| Note | 2025 | 2024
Assets |  |  |
Cash and cash equivalents | 14 | 7,310 | 8,361
Loans and other receivables to other banks | 15 | 23,954 | 21,635
Financial assets measured at fair value through profit or loss | 16, 17, 20 | 2,340 | 1,948
Derivative hedge instruments | 18 | 73 | 61
Investment securities | 19 | 65,556 | 58,992
Transferred assets | 20, 16 | - | 179
Loans and other receivables to customers measured at amortised cost | 21 | 180,309 | 166,677
Investments in associates accounted for using the equity method | 22 | 204 | 185
Property, plant and equipment | 23 | 938 | 1,011
Intangible assets | 24 | 551 | 457
Current income tax assets | 12 | 12 | 14
Deferred tax assets | 25 | 621 | 690
Other assets | 26 | 157 | 149
Total assets |  | 282,025 | 260,359

as at 31 December |  |  |
| Note | 2025 | 2024
Liabilities |  |  |
Liabilities to other banks | 27 | 15,042 | 15,468
Financial liabilities measured at fair value through profit or loss | 28, 17 | 916 | 1,400
Derivative hedge instruments | 18 | 77 | 83
Liabilities to customers | 29 | 235,328 | 219,996
Liabilities from debt securities issued | 30 | 1,521 | 509
Subordinated liabilities | 31 | 2,548 | 1,499
Provisions | 32 | 643 | 636
Current income tax liabilities | 12 | 924 | 16
Deferred tax loss | 25 | - | 1
Other liabilities | 34 | 3,684 | 3,581
Total liabilities |  | 260,683 | 243,189
Equity |  |  |
Share capital | 35.1 | 130 | 130
Share premium | 35.3 | 956 | 956
Accumulated other comprehensive income | 35.2 | -1,884 | -4,699
Retained earnings | 35.3 | 22,149 | 20,783
Own shares for the purposes of the incentive program |  | -9 | -
Total equity | 13 | 21,342 | 17,170
attributable to shareholders of ING Bank Śląski S.A. |  | 21,342 | 17,170
Total equity and liabilities |  | 282,025 | 260,359

The consolidated statement of financial position shall be read in conjunction with the notes to consolidated financial statements being the integral part thereof.

5 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Consolidated statement of changes in equity

for the year ended 31 December 2025 |  |  |  |  |  |
Note: 35 | Share capital | Share premium | Accumulated other comprehensive income | Retained earnings | Own shares for the purposes of the incentive program | Total equity
Opening balance of equity | 130 | 956 | -4,699 | 20,783 | - | 17,170
Total comprehensive income, including: | - | - | 2,815 | 4,633 | - | 7,448
Net profit for the current period | - | - | - | 4,633 | - | 4,633
Other net comprehensive income, including: | - | - | 2,815 | - | - | 2,815
financial assets measured at fair value through other comprehensive income - revaluation gains / losses recognized in equity | - | - | 35 | - | - | 35
debt securities measured at fair value through other comprehensive income - reclassification to profit or loss due to sale | - | - | -41 | - | - | -41
cash flow hedge - revaluation gains / losses recognized in equity | - | - | 1,271 | - | - | 1,271
cash flow hedge - reclassification to profit or loss | - | - | 1,555 | - | - | 1,555
actuarial gains/losses | - | - | -5 | - | - | -5
Other changes in equity, including: | - | - | - | -3,267 | -9 | -3,276
dividend payment | - | - | - | -3,276 | - | -3,276
valuation of employee incentive programs | - | - | - | - | - | -
purchase of own shares for the purposes of the employee incentive program | - | - | - | 22 | -22 | -
settlement of the acquisition of own shares and their transfer to employees | - | - | - | -13 | 13 | -
Closing balance of equity | 130 | 956 | -1,884 | 22,149 | -9 | 21,342

for the year ended 31 December 2024 |  |  |  |  |  |
Note: 35 | Share capital | Share premium | Accumulated other comprehensive income | Retained earnings | Own shares for the purposes of the incentive program | Total equity
Opening balance of equity | 130 | 956 | -5,095 | 20,750 | -5 | 16,736
Total comprehensive income, including: | - | - | 396 | 4,369 | - | 4,765
Net profit for the current period | - | - | - | 4,369 | - | 4,369
Other net comprehensive income, including: | - | - | 396 | - | - | 396
financial assets measured at fair value through other comprehensive income - revaluation gains / losses recognized in equity | - | - | 70 | - | - | 70
debt securities measured at fair value through other comprehensive income - reclassification to profit or loss due to sale | - | - | 9 | - | - | 9
cash flow hedge - revaluation gains / losses recognized in equity | - | - | -1,447 | - | - | -1,447
cash flow hedge - reclassification to profit or loss | - | - | 1,767 | - | - | 1,767
actuarial gains/losses | - | - | -3 | - | - | -3
Other changes in equity, including: | - | - | - | -4,336 | 5 | -4,331
dividend payment | - | - | - | -4,339 | - | -4,339
valuation of employee incentive programs | - | - | - | 4 | - | 4
purchase of own shares for the purposes of the employee incentive program | - | - | - | - | -6 | -6
settlement of the acquisition of own shares and their transfer to employees | - | - | - | -1 | 11 | 10
Closing balance of equity | 130 | 956 | -4,699 | 20,783 | - | 17,170

The consolidated statement of changes in equity should be read in conjunction with the notes to the consolidated financial statements being the integral part thereof.

6 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Consolidated cash flow statement

for the year ended 31 December |  |  |
| Note | 2025 | 2024
Net profit |  | 4,633 | 4,369
Adjustments, including: |  | -3,373 | -4,660
Share of net profit (loss) of associates accounted for using the equity method | 22 | -49 | -33
Depreciation and amortisation | 8, 23, 24 | 322 | 340
Interest accrued (from the income statement) | 2 | -8,871 | -8,725
Interest paid |  | -4,482 | -3,817
Interest received |  | 13,383 | 13,067
Dividends received | 5 | -8 | -8
Gains (losses) on investing activities |  | 2 | 1
Income tax (from the income statement) | 12 | 1,294 | 1,176
Income tax paid |  | -1,009 | -975
Change in provisions | 32, 39 | -2 | 91
Change in loans and other receivables to other banks | 15, 39 | -2,332 | -1,999
Change in financial assets measured at fair value through profit or loss | 16, 17, 39 | -368 | 336
Change in hedge derivatives | 18, 39 | 3,477 | 345
Change in investment securities | 19, 39 | -6,114 | -7,762
Change in transferred assets | 20, 16, 39 | 249 | -12
Change in loans and other receivables to customers measured at amortised cost | 21, 39 | -13,574 | -10,229
Change in other assets | 26, 39 | -42 | -58
Change in liabilities to other banks | 27, 39 | -347 | 642
Change in liabilities measured at fair value through profit or loss | 17, 28 | -480 | -448
Change in liabilities to customers | 29, 30 | 15,357 | 14,727
Change in liabilities from debt securities issued | 30, 39 | 12 | 5
Change in subordinated liabilities | 31, 39 | -17 | -27
Change in other liabilities | 34, 39 | 226 | -1,297
Net cash flows from operating activities |  | 1,260 | -291

for the year ended 31 December |  |  |
| Note | 2025 | 2024
Purchase of property, plant and equipment | 23 | -99 | -127
Purchase of intangible assets | 24 | -212 | -134
Purchase of debt securities measured at amortised cost |  | -23,410 | -13,952
Disposal of debt securities measured at amortised cost |  | 23,268 | 19,524
Dividends received | 5, 22 | 38 | 37
Net cash flows from investing activities |  | -415 | 5,348
Long-term loans received | 39 | 2,807 | 3,063
Repayment of long-term loans | 39 | -1,718 | -1,731
Interest payment on long-term loans | 39 | -558 | -701
Proceeds from the issue of debt securities | 30 | 1,000 | 500
Redemption of debt securities | 30 | - | -400
Interests from issued debt securities |  | -32 | -25
Repayment of lease liabilities | 39 | -97 | -98
Purchase of own shares for the purposes of the employee incentive program |  | -22 | -6
Dividends paid | 35.3 | -3,276 | -4,339
Net cash flows from financing activities |  | -1,896 | -3,737
Net increase/(decrease) in cash and cash equivalents |  | -1,051 | 1,320
of which effect of exchange rate changes on cash and cash equivalents |  | -258 | 302
Opening balance of cash and cash equivalents |  | 8,361 | 7,041
Closing balance of cash and cash equivalents | 14, 39 | 7,310 | 8,361

The consolidated cash flow statement should be read in conjunction with the notes to the consolidated financial statements being the integral part thereof.

7 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Accounting policy and additional
notes

I. Bank and the Group details | 8
II. Statement of compliance with International Financial Reporting Standards | 11
III. Significant accounting principles | 12
IV. Notes to the consolidated financial statements | 42

8 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

I. Bank and the Group details
1. Key Bank data
ING Bank Śląski S.A. (”Parent company”, “Parent entity”, “Bank”) with the registered office in Po land, Katowice, ulica
Sokolska 34, zip code 40-086 was entered into the Entrepreneurs Register with the National Court Register
maintained by the Commercial Division of the District Court in Katowice under the number KRS 0000005459.
The Parent company statistical number is REGON 271514909 and the tax identification number is NIP
634-013-54-75.
2. Scope and duration of operations
ING Bank Śląski S.A. offers a broad range of banking services rendered to individual and institutional clients in line
with the scope of services outlined in the Bank’s charter. The Bank runs operations both in the home currency and
in foreign currencies. Additionally, through subsidiaries the Group conducts leasing and factoring activity and
provides other financial services. The duration of business of the Parent company is indefinite.
3. Share capital
The share capital of ING Bank Śląski S.A. amounts to PLN 130,100,000.00 and is divided into 130,100,000 ordinary
bearer shares with a nominal value of PLN 1.00 each. The Bank’s shares are listed on the Warsaw Stock Exchange
(banking sector).
4. Shareholders of ING Bank Śląski S.A.
ING Bank Śląski S.A. is a subsidiary of ING Bank N.V., which as at 31 December 2025 held 75% shares in the share
capital of ING Bank Śląski S.A. and 75% shares in the total number of votes at the General Meeting of ING Bank Śląski
S.A. ING Bank N.V. belongs to the Group, identified as ING Group for the purposes of these consolidated financial
statements.
As at 31 December 2025 the following were shareholders with 5 or more percent of votes at the General Meeting
of ING Bank Śląski S.A:

No. | Entity | Number of shares and votes | % of total number of shares
1. | ING Bank N.V. | 97,575,000 | 75.00
2. | Allianz Polska OFE * | 7,890,923 | 6.07
3. | Nationale Nederlanden OFE ** | 7,217,029 | 5.55

*) Based on information on the semi-annual structure of assets of Allianz Polska OFE as at 31 December 2025.
**) Based on information on the semi-annual asset structure of Nationale Nederlanden OFE as at 31 December 2025.
5. Entity authorised to audit the financial statements
The entity authorised to carry out the audit is Forvis Mazars Audyt Sp. z o.o. with its registered office in Warsaw.
6. Approval of financial statements
These annual consolidated financial statements of the ING Bank Śląski S.A. Group for the period from 1 January
2025 to 31 December 2025 were adopted for publication by the Bank’s Management Board on 5 March 2026.
The annual consolidated financial statements of the ING Bank Śląski S.A. Group for the period from 1 January 2024
to 31 December 2024 were approved by the General Meeting of ING Bank Śląski S.A. on 29 April 2025.
7. ING Bank Śląski S.A. Management Board and Supervisory Board composition
Bank's Management Board
The term of office of Mr. Bruno Bartkiewicz as President of the Bank’s Management Board expired on 29 April 2025,
i.e. the day of the General Meeting approving the financial statements for 2024. From that day, on the basis of
a resolution of the Supervisory Board of the Bank of 3 September 2024, Mr. Michał Bolesławski took the position of
the President of the Management Board of the Bank.
On 29 April 2025, the Supervisory Board of the Bank appointed the Bank Management Board for the new term of
office in the following composition:
• Ms Joanna Erdman - VicePresident of the Bank Management Board,
• Mr Marcin Giżycki - Vice-President of the Bank Management Board,
• Ms Bożena Graczyk - Vice-President of the Bank Management Board,
• Mr Marcin Kościński - Vice-President of the Bank Management Board,
• Mr Michał H. Mrożek - Vice-President of the Bank Management Board,
• Mr Maciej Ogórkiewicz - Vice-President of the Bank Management Board,
• Ms Alicja Żyła - Vice-President of the Bank Management Board.
Furthermore, the Supervisory Board adopted a resolution regarding appointment of Ms Ewa Łuniewska for the Bank
Management Board new term of office as of the entry date of an amendment to Article 26.1 of the Charter of ING
Bank Śląski Spółka Akcyjna (regarding the number of Bank Management Board Members) in the Entrepreneurs
Register of the National Court Register, as provided for in Resolution No. 28 of the Ordinary General Meeting of 29
April 2025. On 9 May 2025, the above change was registered in the National Court Register and from that date the
Bank’s Management Board is composed of 9 members.
Ms Joanna Erdman, Mr Marcin Giżycki, Ms Bożena Graczyk, Ms Ewa Łuniewska, Mr Michał H. Mrożek and Ms Alicja
Żyła held functions on the Management Board during the previous term of office.

9 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

On 12 December 2025, the Bank received the resignation of Ms. Ewa Łuniewska from her position as Member of the
Bank’s Management Board as of 31 December 2025. The submitted resignation was the result of arrangements
made between Ms. Ewa Łuniewska and the Supervisory Board, about which the Bank informed in current report
No. 13/2025 of 29 April 2025.
On 12 December 2025, the Supervisory Board appointed Mr. Wojciech Sieńczyk as Vice-President of the Bank’s
Management Board from 1 January 2026.
On 8 January 2026, the Bank received the resignation of Mr. Michał H. Mrożek from the position of Member of the
Bank’s Management Board, with effect at the end of that day. The reason for his resignation was his appointment
to a new position in the ING Group.
As at the date of adoption of these annual consolidated financial statements for publication, the composition of the
Bank’s Management Board was as follows:
• Mr. Michał Bolesławski - President of the Bank Management Board,
• Ms. Joanna Erdman - Vice-President of the Bank Management Board,
• Mr. Marcin Giżycki – Vice-President of the Bank Management Board,
• Ms. Bożena Graczyk - Vice-President of the Bank Management Board,
• Ms. Marcin Kościński - Vice-President of the Bank Management Board,
• Mr. Maciej Ogórkiewicz - Vice-President of the Bank Management Board,
• Mr. Wojciech Sieńczyk - Vice-President of the Bank Management Board,
• Ms. Alicja Żyła - Vice-President of the Bank Management Board.
Bank's Supervisory Board
On 27 June 2025, the Bank has received from Mr Stephen Creese a letter of resignation from the capacity
as Member of the Bank Supervisory Board, with effect from 31 August 2025. The reason for resignation is his plans
to leave ING Group.
On 24 September 2025, the Bank has received from Ms Anety Hryckiewicz-Gontarczyk a letter of resignation from
the capacity as Member of the Bank Supervisory Board, effective as at 24 September 2025. The reason for
resignation were personal reasons.
At the end of 2025, the composition of the Bank’s Supervisory Board was as follows:
• Ms. Monika Marcinkowska – Chairman of the Supervisory Board, Independent Member,
• Ms. Małgorzata Kołakowska – 1st Vice-Chairman of the Supervisory Board,
• Mr. Michał Szczurek – Vice-Chairman of the Supervisory Board,
• Mr. Dorota Dobija – Independent Member of the Supervisory Board,
• Ms. Arkadiusz Krasowski – Independent Member of the Supervisory Board,
• Ms. Hans De Munck - Member of the Supervisory Board,
• Mr. Serge Offers - Member of the Supervisory Board.
8. ING Bank Śląski S.A. Group
ING Bank Śląski S.A. is the parent entity of the ING Bank Śląski S.A. Group ("Capital Group", "Group"). The composition
of the Group is as follows:

No. | name | type of activity | registered office | % of the Group's share in the share capital registered and votes office on the General Meeting | nature of the capital relationship | recognition in the Group consolidated financial statements
as at 31 Dec 2025 | as at 31 Dec 2024
1 | ING Investment Holding (Polska) S.A., which holds shares in the following subsidiaries and associates: | financial holding | Katowice | 100% | 100% | subsidiary | full consolidation
| 1.1. ING Commercial Finance S.A. | factoring services | Warszawa | 100% | 100% | subsidiary | full consolidation
| 1.2. ING Lease (Polska) Sp. z o.o.* | leasing services | Warszawa | 100% | 100% | subsidiary | full consolidation
| 1.3. Paymento Financial S.A. | financial services and IT solutions for the financial sector | Tychy | 100% | 100% | subsidiary | full consolidation
| 1.4. Goldman Sachs TFI S.A. | investment funds | Warszawa | 45% | 45% | associate | consolidation with the equity method
2 | ING Bank Hipoteczny S.A. | banking services | Katowice | 100% | 100% | subsidiary | full consolidation
3 | ING Usługi dla Biznesu S.A. | accounting, HR and payroll services related to access to information about the account | Katowice | 100% | 100% | subsidiary | full consolidation
4 | Nowe Usługi S.A. | education and promotion for the financial market and TURBO Certificates | Katowice | 100% | 100% | subsidiary | full consolidation
5 | SAIO Spółka Akcyjna | software sales, robotization of processes | Katowice | 100% | 100% | subsidiary | full consolidation
6 | Dom Data IDS Sp. z o.o. | IT services | Poznań | 40% | 40% | associate | consolidation with the equity method

10 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

*) In the ING Lease (Poland) Sp. z o.o. Group there are 5 special purpose vehicles in which ING Lease (Poland)
Sp. z o.o. holds 100% of the shares. These are: ING Aktywa Spółka z o.o., ING Finance Spółka z o.o., Rel Fokstrot
Spółka z o.o., Rel Jota Spółka z o.o. and Rel Project 1 Spółka z o.o.
Execution of agreements aiming at taking control of Goldman Sachs TFI S.A.
On 18 November 2025, the Bank a preliminary share purchase agreement (“Share Purchase Agreement”) with
Goldman Sachs Asset Management International Holdings B.V. (“Seller”), where under the Bank undertook to
purchase 115,500 shares of Goldman Sachs TFI S.A. (“GS TFI”), or a 55%-stake in GS TFI share capital and 55% of the
total number of votes at the General Meeting of GS TFI (“Transaction”). The price for 55% of shares of GS TFI share
capital was set at PLN 396 million (in words: PLN three hundred ninety six million). The final purchase price can be
adjusted with the forecasted dividend equivalent for the period from 1 January 2026 to the month preceding the
transaction closure. Additionally, Bank and the Seller agreed that the dividend from 2025 net profit will be paid out
before the Transaction closing date. The final purchase price can be adjusted as per the Share Purchase Agreement
terms and conditions.
At present, ING Investment Holding (Polska) S.A., a wholly owned subsidiary of the Bank, holds 94,500 of shares
in the GS TFI share capital, or a 45%-stake in GS TFI share capital and 45% of the total number of votes at the
General Meeting of GS TFI. After the Transaction closure, the ING Bank Śląski S.A. Group will hold 100% of the GS TFI
share capital and will be entitled to 100% of the total number of votes at the General Meeting of GS TFI, while the
Bank will become the direct parent entity for GS TFI.
The Transaction will be closed provided the conditions precedent have materialised. Key conditions are the
following:
• decision of the Polish Financial Supervision Authority on the absence of grounds for objection against acquisition
of the GS TFI shares by the Bank in the amount beyond 50% share in the share capital and the total number of
votes at the General Meeting of GS TFI and
• the decision of the European Commission on the absence of objection against the reported concentration and its
recognition as compliant with the internal market rules (the decision expressing the Bank’s unconditional consent
to the acquisition of exclusive control over GS TFI was issued on 17 February 2026).
The Bank expects the Transaction to be closed in H1 2026.
GS TFI’s line of business is the establishment and management of investment funds, including intermediation in the
sale and repurchase of participation units.
Subject of activity of the Capital Group subsidiaries
ING Investment Holding (Polska) S.A.
ING Investment Holding (Polska) S.A. is a holding company. Through it, the Bank holds shares in three subsidiaries:
ING Lease (Polska) Sp. z o.o. (100%), ING Commercial Finance S.A. (100%), Paymento Financial S.A. (100%) and
in one associate company - Goldman Sachs TFI S.A. (45%).
ING Commercial Finance S.A.
The company’s core business is factoring, i.e. receivables financing and servicing services. The company offers
factoring with and without recourse. Comprehensive debt management includes monitoring of recipients,
preparation of current reports, mediation of debt insurance and debt collection.
ING Lease (Polska) Sp. z o.o.
The company offers all basic types of leasing which allow financing both movables (in the form of cars, vans, heavy
transport vehicles, machinery and equipment, construction, medical, equipment and IT equipment) and real estate.
The company services are targeted at all market segments: large, medium and small enterprises as well as micro
clients (entrepreneurs).
Paymento Financial S.A.
The Company is a regulated entity authorised by the Polish Financial Supervision Authority to provide payment
services as a National Payment Institution. The company provides professional financial services and IT solutions for
the financial sector. Its services are addressed to financial market participants and e-commerce.
ING Bank Hipoteczny S.A.
The purpose of the company is to acquire and then increase the share of long-term financing in the Group’s
balance sheet by issuing long-term mortgage bonds based on mortgage-backed credit claims acquired from ING
Bank Śląski or other banks.
ING Usługi dla Biznesu S.A.
The company conducts operations in the following business areas: running an online database of companies and
an online B2B commerce and business platform (ALEO), running a platform for invoicing and payment
management, accounting, HR and payroll services - accounting, HR and payroll services for entrepreneurs
(ING Accounting) and runs and develops the Firmove.pl service, which supports entrepreneurs at every stage
of business development and raises awareness in the ESG area.
Nowe Usługi S.A.
The company conducts educational and marketing activities. Provides a portal on investing and the stock market,
where investment-related materials are published and a knowledge base is available (edukacjagieldowa.pl).

11 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The company is also involved in the popularisation of ING Turbo certificates on the Polish market. The instruments
are issued by ING Bank N.V. Amsterdam and quoted at the Warsaw Stock Exchange The main activities of the
company are the organisation of marketing campaigns, ING Turbo helpline service or technical support while
running the ingturbo.pl website.
SAIO S.A.
The business of the company is the sublicensing of SAIO robotization software and the implementation
of robotization of business processes at clients as part of its own activities and the partner network being built.
The company also provides robotisation services to ING Bank Śląski and selected ING Group entities around the
world.
II. Statement of compliance with International Financial Reporting Standards
These annual consolidated financial statements of the ING Bank Śląski S.A. Group for the period from 1 January
2025 to 31 December 2025 have been prepared in accordance with the International Financial Reporting Standards
("IFRS") approved by the European Union. The consolidated financial statements take into account the
requirements of EU approved standards and interpretations.
Consolidated income statement, consolidated statement of comprehensive income, consolidated statement of
changes in equity and consolidated cash flow statement for the period from 1 January 2025 to 31 December 2025
and consolidated statement of financial position as at 31 December 2025, together with comparable data were
prepared according to the same principles of accounting for each period.
1. Changes in accounting standards
In these annual consolidated financial statements, the Group included the following changes to the standards,
approved by the European Union and effective for annual periods beginning on or after 1 January 2025 :

Change | Influence on the Group’s consolidated financial statements
IAS 21 Effects of changes in currency exchange rates: currency forfeiture | The implementation of the change did not have a significant impact on the Group’s consolidated financial statements.

Published standards and interpretations, which were issued by 31 December 2025 and approved by the European
Union, but were not applied by the Group earlier:

Change (EU effective date provided for in the parentheses) | Influence on the Group’s consolidated financial statements
IFRS 9 Financial instruments and IFRS 7 Financial instruments: disclosures Classification and measurement of financial instruments (financial year beginning on 1 January 2026) | The introduced changes are the result of conclusions from the post- implementation review of the guidelines of both standards. The amendments are of a more precise nature with respect to the classification of financial assets (i.e.: resulting from agreements containing ESG or similar clauses) and the derecognition of financial instruments from the balance sheet that are settled via electronic payment systems. The implementation of these changes will not exert a material impact on the Group’s consolidated financial statements.
Changes resulting from the annual update of the standards (volume 11) (financial year beginning on 1 January 2026) | The amendments to IFRS F1, IFRS 7, IFRS 9, IFRS 10 and IAS 7 are editorial in nature. According to the Group’s analyses, the application of the amendments will not have an impact on the Group’s consolidated financial statements.
IFRS 9 Financial instruments and IFRS 7 Financial instruments: disclosures Renewable electricity contracts (financial year beginning on 1 January 2026) | The amendments are intended to better reflect contracts relating to electricity from renewable sources with physical or virtual supply in the financial statements. The changes focus on requirements for purchasing energy for own use, hedge accounting and disclosures. The Group’s analyses show that applying the changes, from the perspective of the current economic situation, will not have an impact on the Group’s consolidated financial statements.

12 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Published standards and interpretations that were issued by 31 December 2025, but were not approved
by the European Union as at 31 December 2025 and were not previously adopted by the Group:

Change (expected IASB effective date provided for in the parentheses) | Influence on the Group’s consolidated financial statements
IFRS 18 Presentation and disclosures in financial statements (financial year beginning on 1 January 2027) | The new standard published in April 2024, which will replace IAS 1. The implementation of the new guidelines aims to improve the comparability and transparency of the financial statements of the entities. The Group’s analyses show that the application of the standard will have an impact on the presentation and scope of disclosures in the Group’s consolidated financial statements.
IFRS 19 Subsidiaries without public liability: disclosures (financial year beginning on 1 January 2027) | The new standard published in May 2024 will be voluntarily applied by entities that do not have the status of an entity with public responsibility and that are dependent on entities preparing publicly available consolidated financial statements. According to the Group’s analyses, application of the standard will not have an impact on the Group’s consolidated financial statements.
Amendments to IAS 21 Effects of changes in currency exchange rates: Conversion to presentation currency in hyperinflation (financial year beginning on 1 January 2027) | The Group’s analyses show that the implementation of the change will not have a significant impact on the Group’s consolidated financial statements.
Amendments to IFRS 19 (published on 21 August 2025) Subsidiaries without public liability: disclosures (financial year beginning on 1 January 2027) | Amendments to the new standard to take into account published amendments to IFRSs in the scope of disclosures published after the issuance of IFRS 19 (in May 2024) and whose first application date falls in the financial year beginning on 1 January 2027. The Group’s analyses show that applying these amendments to the standard will not have an impact on the Group’s consolidated financial statements.

As at the date of adoption of this report for publication, taking into account the ongoing process of introducing IFRS
standards in the EU and the Group's operations, with respect to the accounting principles applied by the Group
there are no differences between the IFRS standards that have entered into force and the IFRS standards endorsed
by the EU.
2. Going-concern
Consolidated financial statements of the ING Bank Śląski S.A. Capital Group for the period from 1 January 2025
to 31 December 2025 has been prepared on the assumption that the Group will continue as a going concern for
a period of at least 12 months from the date of acceptance for publication i.e. from 5 March 2026. As at the date
of signing the consolidated financial statements, the Management Board of the Bank does not find any facts
or circumstances that would indicate any threat to the Group's ability to continue as a going concern within 12
months from the date of publication as a result of intentional or forced discontinuation or significant limitation
of the Group's current operations.
3. Financial statements scope and currency
These annual consolidated financial statements of the ING Bank Śląski S.A. Group for the period from 1 January
2025 to 31 December 2025 contain data of the Bank and its subsidiaries and associates (together referred to as the
"Group").
These annual consolidated financial statements have been prepared in Polish zlotys ("PLN"). All values, unless
otherwise indicated, are rounded to the nearest million zlotys. There may therefore be mathematical
inconsistencies in the totals or between the notes.
4. Reporting period and comparable data
Annual consolidated financial statements of the ING Bank Śląski S.A. Capital Group covers the period from
1 January 2025 to 31 December 2025 and includes comparative data:
• for the consolidated statement of financial position as at 31 December 2024,
• for items from the consolidated income statement, consolidated statement of comprehensive income,
consolidated statement of changes in equity and consolidated statement of cash flows for the period from
1 January 2024 to 31 December 2024.
5. Consolidation rules
The consolidated financial statements comprise the financial statements of the Bank as well as the financial
statements of its subsidiaries. The documents were developed for the term of 12 months ended 31 December
2025.
After being adjusted for IFRS compliance, the financial statements of subsidiaries are developed for the same
reporting period as the financial statements of the Parent entity, with the use of uniform accounting principles for
similar transactions and business events. Adjustments are made to eliminate any discrepancies in the accounting
principles applied.
All significant balances and transactions between Group members, including income and costs, unrealised profits
as well as gains and losses under intragroup transactions were eliminated in full. Unrealised losses are eliminated,
unless proving impairment occurrence.
III. Significant accounting principles
The requirements of IFRS result in specific options for choosing the accounting policy. The key areas where IFRS
allow the entity to select the policy and which refer to the Group Accounting Policy include:
• selection of accounting policy to continue to apply the hedge accounting requirements of IAS 39,

13 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• selection of accounting policy for valuation of buildings and land at revalued amount, being its fair value at the
balance sheet date.
The Group Accounting Policy complies with IFRS and the Group's decisions as to the admissible policy selection are
presented below.
1. Basis for preparation of consolidated financial statements
The financial statements are prepared in Polish zlotys rounded to one million (unless otherwise stated). The concept
of fair value has been applied in the statements for own real property as well as financial assets and liabilities
measured at fair value, including derivative instruments, and financial assets classified as measured at fair value
through other comprehensive income. Other items of financial assets (including loans and advances) are presented
at amortised cost less impairment or at purchase price less impairment. Recognized financial assets that were
designated as hedged items in the fair value hedge strategy, and which, in the absence of such designation, would
be measured at amortized cost, are measured at amortized cost, taking into account the hedged risk valuation
adjustment. Non-current assets held for sale are recognised at the lower of their carrying amount and the fair value
less sales costs.
2. Professional judgment
In the process of accounting principles application to the matters discussed below, besides the accounting
estimates, professional judgment of the management staff was of key significance.
2.1. Deferred tax assets
The Group recognizes deferred tax assets based on the assumption that it is probable that taxable income sufficient
to fully realize the deferred tax asset would be achieved.
2.2. Classification of leases
When acting as a lessor, the Group classifies leases as operating or financial. The classification is based on the
assessment to what extent the risks and rewards of ownership of the subject of the lease and in relation to the
lease of the assets resulting from the lease are attributable to the lessor and to which the lessee. The substance
of each transaction is used to make the said assessment.
2.3. Classification of financial assets
The Group classifies financial assets on the basis of both the business model for holding the financial assets and
assessment whether under the contractual terms require solely payments of principal and interest on the principal
amount outstanding. The detailed information about assumptions in this regard is presented in item
13.2. Classification of financial assets.
3. Accounting estimates
Estimates and assumptions applied to the presentation of the value of assets, liabilities, income and costs are made
on the basis of historical data available and other factors considered to be relevant in given circumstances.
The assumptions applied for the future and available data sources are the base for making estimates regarding
the carrying amount of assets and liabilities, which cannot be determined explicitly on the basis of other sources.
The estimates reflect the reasons for/ sources of uncertainties as at the balance sheet date. The actual results may
differ from estimates.
The estimates and assumptions are reviewed on an on-going basis. Adjustments to estimates are recognised in the
period when the estimate was changed provided that the adjustment applies to this period alone or in the period
when the estimate was changed and in the following periods, should the adjustment impact both the current and
future periods.
Below are the most significant booking estimates made by the Group.
3.1. Estimation of expected credit losses for financial assets
The Group applies IFRS 9 requirements regarding impairment in order to recognize and measure the impairment for
expected credit losses on debt financial assets that are measured at amortised cost or at fair value through other
comprehensive income.
The expected loss in the portfolio of individually insignificant exposures is calculated collectively as a probability-
weighted average from three macroeconomic scenarios with different probabilities of occurrence. The final level of
the provisions results from the sum of the expected credit losses estimated each year in the future till the maturity
date for Stage 2 and Stage 3 assets and in 12-month horizon for Stage 1 assets, including discount.
To determine impairment (or reverse it) in the ISFA (Individually Significant Financial Assets) portfolio, the present
value of expected future cash flows has to be calculated. The amount of the future cash flows is determined among
others taking account information about the current and forecasted economic standing of the borrower, the
forecast value of the recovery amount from collateral of the credit exposure and the macroeconomic factors.
The methodology and assumptions used to estimate both the amount and the time of future cash flows are
regularly reviewed and adjusted as needed.
Macroeconomic factors
Credit risk models for the purposes of IFRS 9 were built on the basis of historical relations between changes
in economic parameters (i.e. GDP or interest rates) and their subsequent effect on changes in the level of credit risk
(PD/LGD). By the end of 2019, changes in macroeconomic forecasts were relatively slow, moving smoothly from
one phase of the cycle to another, without drastic and shocking events changing the macroeconomic situation.

14 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

After sharp increases in interest rates and inflation, caused, among others, by the war in Ukraine, the situation has
now stabilised.
As at 31 December 2025, the Group revised its macroeconomic indicators forecasts. The macroeconomic
assumptions used to determine the expected credit losses are based on forecasts prepared by the Bank’s
Macroeconomic Analysis Office, supplemented by management adjustments where, in the opinion of the
management, recent economic events have not been fully captured. The effect of changes in macroeconomic
assumptions reduced the level of provisions for expected credit losses at the end of 2025 by PLN 22 million
compared to the end of 2024.
Management adjustments and recalibration of models
In times of heightened volatility and uncertainty, where portfolio quality and the economic environment are
changing rapidly, models are undermined in their ability to accurately predict losses. To mitigate model risk,
additional adjustments can be made to address data quality issues, methodology issues or expert opinions. They
also include adjustments resulting from overestimation or underestimation of allowances for expected credit losses
by IFRS 9 models.
Due to the growing impact of climate risk on credit risk, the Group decided to create a management adjustment
increasing the value of provisions for expected credit losses, the purpose of which is to measure potential financial
losses resulting from the indirect or direct impact of clients’ adjustment to low-emission requirements or to an
economy based on sustainable development. The adjustment covered the portfolio of corporate clients, including
strategic ones.
In Q4 2024, the Group implemented the uLDP (ultra low default portfolio) model, which includes previously used
reserve models for strategic customers within the corporate portfolio. Simultaneously with the implementation, the
second stage of work on the uLDP model began, which was to cover a wider pool of models and reconstruction of
capital models. The Group has decided to apply a management adjustment increasing the value of provisions for
expected credit losses until the implementation of the second stage, the purpose of which is to maintain the
adequacy of provisions for the corporate portfolio. At the end of 2025, the progress of work on the second stage
was so great that the Group decided to waive this adjustment.
The potential underestimation of losses incurred in the real estate sector prompted the Group to create a
management adjustment for strategic customers within the corporate portfolio, increasing the value of provisions
for expected credit losses. At the end of 2025, in connection with the stabilisation of the sector, the Group decided
to waive this adjustment. At the same time, the Group has completed the recalibration of the model, which better
reflects the amount of allowances for expected credit losses in the real estate sector. The model is to be
implemented in 2026. Until the implementation, the Group made a decision to introduce an adjustment aimed at
maintaining the adequacy of provisions.
Due to incomplete implementation of new models or a time-based change of models for corporate clients
(including SME MSSF9 model and LEASE LGD), the Group has estimated the impact of the use of new models on the
amount of allowances for clients not yet covered by these models. As a result, at the end of 2025 , the Group
introduced a management adjustment reducing the value of provisions for expected credit losses.
In Q4 2025, the Group, in accordance with the provisions of Recommendation R, periodically recalibrated the retail
customer segment model. The model recalibration will be implemented in the first quarter of 2026. To maintain the
adequacy of the write-offs, the Group decided to implement a management adjustment to reflect the expected
level of write-offs.
Also in Q4 2025, the Group implemented a new capital model for the sub-segment of mortgage loans. At the same
time, work is underway on a new MSSF9 model for this sub-segment, which is to be implemented in 2026. Until that
time, in order to maintain an adequate level of write-offs, the Group made a decision to implement, at the end of
2025, a management adjustment reducing the value of write-offs.
The following table summarizes the management corrections described above:

as at 31 December |  |  |  |  |  |
| 2025 | 2024
Corporate banking | Retail banking | Total | Corporate banking | Retail banking | Total
Management adjustments that do not affect the classification of exposures into Stages: | 3 | - | 3 | 6 | - | 6
impact of climate risk on credit risk | 25 | - | 25 | 30 | - | 30
uLDP model (ultra low default portfolio) | - | - | - | 9 | - | 9
underestimation of credit losses in the real estate sector | - | - | - | 4 | - | 4
recalibration of the model for estimating write-offs for the real estate sector | 11 | - | 11 | - | - | -
incomplete implementation of models (MSSF9 SME and LGD LEASE) | -33 | - | -33 | -37 | - | -37
Management adjustments affecting the classification of exposures into Stages: | - | -3 | -3 | - | - | -
recalibration of the model for the retail customer sub-segment | - | 16 | 16 | - | - | -
New capital model for the mortgage loan sub-segment | - | -19 | -19 | - | - | -
Total | 3 | -3 | - | 6 | - | 6

The division of adjustments into stages is presented in chapter II.2.9.2. Quality of the loan portfolio, in section Risk
and capital management.
Description of the indications for identification of impairment of financial assets, methodology of calculation
of impairment losses and applied accounting principles are described in point 13.11 Expected credit losses.

15 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Thresholds used to identify a significant increase in credit risk
Determining the threshold of a significant increase in credit risk requires judgment and is a significant source
of uncertainty in the estimates of expected losses. Thresholds of PD parameters increase in the lifetime of
exposures in relation to PD at origination which indicate significant increase in credit risk are established for models
based on assumed methodology.
At the end of 2025 and 2024 these triggers were as follows:

| Strategic clients portfolio | Corporate retail portfolio (SME model) | Mortgages (MTG model) | SE&Micro portfolio (SBF model) | Consumer Lending Portfolio (CLN model) | Investment portfolio
Relative threshold | 0.61 | 1 | 0.98 | 0.5 | 0.7 | 0.61
Absolute threshold | 100pb | 250pb | 75pb | 300pb | 350pb | 100pb

Absolute threshold – indicates maximum difference between PD at the reporting date and PD at initial recognition
which triggers classification to Stage 2
Relative threshold – indicates the maximum measure of the relationship between the PD as at the reporting date
and the PD from the initial recognition of the exposure, taking into account the scaling factor determined at the
level of a particular exposure, based on the PD from the initial recognition, beyond which the asset is classified
to Stage 2.
Exceeding at least one of the above thresholds results in classification of a financial asset to Stage 2.
In addition, regardless of the relative and absolute thresholds described above, the Group has an additional
condition for identifying a significant increase in credit risk - a three-fold increase in the PD parameter since the
exposure was granted. Different threshold levels depending on the exposure portfolio result from different
specificities of individual portfolios, including depending on the amount of the average default rate for a given
portfolio.
Sensitivity analysis of expected credit losses on assumed PD threshold
In order to show the sensitivity of expected losses to the level of the adopted PD threshold, the Group estimated
the allowances for expected losses in Stages 1 and 2 with the following assumptions:
• all these financial assets would be below the PD threshold and assigned 12-month expected losses and
• all of these assets would exceed this PD threshold and have lifetime expected losses assigned to them.

as at 31 December |  |  |  |
| 2025 | 2024
Hypothetical change in the level of expected losses for Stage 1 and Stage 2 assets
Assumption that the assets are below the PD threshold and are assigned 12-month expected credit losses | Assumption that the assets have exceeded the PD threshold and are assigned lifetime expected credit losses | Assumption that the assets are below the PD threshold and are assigned 12-month expected credit losses | Assumption that the assets have exceeded the PD threshold and are assigned lifetime expected credit losses
The entire loan portfolio, including: | -240 | 720 | -260 | 670
Corporate portfolio | -150 | 410 | -170 | 390
Retail portfolio | -90 | 310 | -90 | 280

Macroeconomic forecasts and probability weights applied to each of macroeconomic scenarios
Below are presented the macroeconomic forecasts of of key factors adopted as at 31 December 2025 and
31 December 2024 and the deviations of expected losses in the upside, baseline and negative scenarios from the
reported expected losses, weighted by the probability of the scenarios - broken down into corporate, retail and for
the entire loan portfolio. The analysis takes into account changes in the time horizon of expected losses (migrations
between Stages) resulting from the macroeconomic scenarios used in the analysis. The presented deviations from
reported losses do not take into account the impact of management adjustments described earlier.
The macroeconomic assumptions used to determine these deviations for the base scenario are based on forecasts
prepared by the Bank’s Macroeconomic Research Bureau, with the use of forward curves for interest rates at the
end of 2025.
The tables present the results of the analysis of the change of exposure in Stages and the change of allowance
coverage for the entire loan portfolio and separately for the corporate and retail portfolios.
For both the entire loan portfolio and its corporate and retail part, the selective application of a negative scenario
with a weight of 100% increases the level of provisions in all Stages (1/2/3). The average increase of the allowance
for the entire portfolio, on a consolidated basis, is about 4% compared to the average scenario used in the
calculation of allowances at the end of 2025 (for the corporate portfolio, an increase of the impairment loss by 2%
and for the retail portfolio by 7%). The increase of provisions in this scenario is mainly caused by an increase in the
unemployment rate.
If a 100% weight were applied, for the positive scenario there would be a decrease of allowance by approx. 3%
on the entire portfolio (for corporate portfolio by 2% and for retail portfolio by 5%). A positive effect of GDP growth
and stable values of other variables are observed here (unemployment rate: about 2.0%, interest rate: 7.0%).
The application of a weight of 100% for the base scenario remains neutral for the amount of provisions (decrease
by 1% on the retail part of the portfolio).

16 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Total loan portfolio

2025
| 2026 | 2027 | 2028 | Expected losses weighted by probability - deviation from losses reported in % | Change in the share of Stage 2 in relation to the entire portfolio in % | Weight assigned to the scenario to determine the reported expected losses | Reported expected losses (collective assessment in Stage 1, 2 and 3)
Total | by Stages | Total | by Stages
Upside scenario | GDP | 5.4% | 4.6% | 3.8% | -3% | Stage 1 | -4% | -4% | 20% | 2,709 | Stage 1 | 282
Unemployment | 2.6% | 2.4% | 2.1%
Real estate price index | 9.0% | 6.9% | 4.4% | Stage 2 | -9%
3 months’ interest rate | 6.4% | 7.0% | 7.1% | Stage 3 | -1%
Brent oil price (USD/barrel) | 71.58 | 80.07 | 80.74 |  |
Baseline scenario | GDP | 3.7% | 3.2% | 3.0% | 0% | Stage 1 | 0% | 0% | 60%
Unemployment | 3.1% | 3.1% | 3.1%
Real estate price index | 0.2% | 2.1% | 2.2% | Stage 2 | -1% | Stage 2 | 583
3 months’ interest rate | 3.5% | 3.7% | 3.9% | Stage 3 | 0% | Stage 3 | 1,844
Brent oil price (USD/barrel) | 63.62 | 64.67 | 66.00 |  |
Negative scenario | GDP | 1.1% | 0.9% | 2.1% | 4% | Stage 1 | 5% | 11% | 20%
Unemployment | 5.0% | 7.1% | 8.9%
Real estate price index | -11.9% | -3.6% | -5.0% | Stage 2 | 13%
3 months’ interest rate | 1.7% | 1.3% | 1.3% | Stage 3 | 2%
Brent oil price (USD/barrel) | 51.49 | 45.10 | 48.01 |  |

Corporate portfolio

2025
| 2026 | 2027 | 2028 | Expected losses weighted by probability - deviation from losses reported in % | Change in the share of Stage 2 in relation to the entire portfolio in % | Weight assigned to the scenario to determine the reported expected losses | Reported expected losses (collective assessment in Stage 1, 2 and 3)
Total | by Stages | Total | by Stages
Upside scenario | GDP | 5.4% | 4.6% | 3.8% | -2% | Stage 1 | -4% | -2% | 20% | 1,850 | Stage 1 | 168
Unemployment | 2.6% | 2.4% | 2.1%
Real estate price index | 9.0% | 6.9% | 4.4% | Stage 2 | -8%
3 months’ interest rate | 6.4% | 7.0% | 7.1% | Stage 3 | 0%
Brent oil price (USD/barrel) | 71.58 | 80.07 | 80.74 |  |
Baseline scenario | GDP | 3.7% | 3.2% | 3.0% | 0% | Stage 1 | 0% | 0% | 60%
Unemployment | 3.1% | 3.1% | 3.1%
Real estate price index | 0.2% | 2.1% | 2.2% | Stage 2 | 0% | Stage 2 | 412
3 months’ interest rate | 3.5% | 3.7% | 3.9% | Stage 3 | 0% | Stage 3 | 1,270
Brent oil price (USD/barrel) | 63.62 | 64.67 | 66.00 |  |
Negative scenario | GDP | 1.1% | 0.9% | 2.1% | 2% | Stage 1 | 3% | 8% | 20%
Unemployment | 5.0% | 7.1% | 8.9%
Real estate price index | -11.9% | -3.6% | -5.0% | Stage 2 | 10%
3 months’ interest rate | 1.7% | 1.3% | 1.3% | Stage 3 | 1%
Brent oil price (USD/barrel) | 51.49 | 45.10 | 48.01 |  |

Total loan portfolio

2024
| 2025 | 2026 | 2027 | Expected losses weighted by probability - deviation from losses reported in % | Change in the share of Stage 2 in relation to the entire portfolio in % | Weight assigned to the scenario to determine the reported expected losses | Reported expected losses (collective assessment in Stage 1, 2 and 3)
Total | by Stages | Total | by Stages
Upside scenario | GDP | 4.7% | 6.3% | 4.6% | -7% | Stage 1 | -9% | -6% | 20% | 2,553 | Stage 1 | 279
Unemployment | 2.4% | 2.2% | 2.0%
Real estate price index | 9.6% | 6.0% | 6.3% | Stage 2 | -18%
3 months’ interest rate | 7.6% | 7.7% | 7.7% | Stage 3 | -3%
Baseline scenario | GDP | 3.5% | 3.8% | 2.8% | -1% | Stage 1 | -1% | -1% | 60%
Unemployment | 3.0% | 3.0% | 2.9% | Stage 2 | 601
Real estate price index | 6.5% | 4.7% | 3.9% | Stage 2 | -3% | Stage 3 | 1,673
3 months’ interest rate | 4.4% | 4.2% | 4.4% | Stage 3 | 0%
Negative scenario | GDP | 1.7% | -0.3% | 0.2% | 12% | Stage 1 | 2% | 32% | 20%
Unemployment | 4.3% | 5.9% | 7.1%
Real estate price index | 2.0% | 2.7% | 2.6% | Stage 2 | 44%
3 months’ interest rate | 3.6% | 2.7% | 2.3% | Stage 3 | 3%

Corporate portfolio

2024
| 2025 | 2026 | 2027 | Expected losses weighted by probability - deviation from losses reported in % | Change in the share of Stage 2 in relation to the entire portfolio in % | Weight assigned to the scenario to determine the reported expected losses | Reported expected losses (collective assessment in Stage 1, 2 and 3)
Total | by Stages | Total | by Stages
Upside scenario | GDP | 4.7% | 6.3% | 4.6% | -8% | Stage 1 | -12% | -9% | 20% | 1,719 | Stage 1 | 170
Unemployment | 2.4% | 2.2% | 2.0%
Real estate price index | 9.6% | 6.0% | 6.3% | Stage 2 | -22%
3 months’ interest rate | 7.6% | 7.7% | 7.7% | Stage 3 | -2%
Baseline scenario | GDP | 3.5% | 3.8% | 2.8% | -1% | Stage 1 | -2% | -2% | 60%
Unemployment | 3.0% | 3.0% | 2.9% | Stage 2 | 426
Real estate price index | 6.5% | 4.7% | 3.9% | Stage 2 | -4% | Stage 3 | 1,123
3 months’ interest rate | 4.4% | 4.2% | 4.4% | Stage 3 | 0%
Negative scenario | GDP | 1.7% | -0.3% | 0.2% | 15% | Stage 1 | 0% | 56% | 20%
Unemployment | 4.3% | 5.9% | 7.1%
Real estate price index | 2.0% | 2.7% | 2.6% | Stage 2 | 57%
3 months’ interest rate | 3.6% | 2.7% | 2.3% | Stage 3 | 2%

17 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Retail portfolio

2025
| 2026 | 2027 | 2028 | Expected losses weighted by probability - deviation from losses reported in % | Change in the share of Stage 2 in relation to the entire portfolio in % | Weight assigned to the scenario to determine the reported expected losses | Reported expected losses (collective assessment in Stage 1, 2 and 3)
Total | by Stages | Total | by Stages
Upside scenario | GDP | 5.4% | 4.6% | 3.8% | -5% | Stage 1 | -5% | -9% | 20% | 859 | Stage 1 | 114
Unemployment | 2.6% | 2.4% | 2.1%
Real estate price index | 9.0% | 6.9% | 4.4% | Stage 2 | -11%
3 months’ interest rate | 6.4% | 7.0% | 7.1% | Stage 3 | -3%
Baseline scenario | GDP | 3.7% | 3.2% | 3.0% | -1% | Stage 1 | -1% | -1% | 60%
Unemployment | 3.1% | 3.1% | 3.1% | Stage 2 | 171
Real estate price index | 0.2% | 2.1% | 2.2% | Stage 2 | -2% | Stage 3 | 574
3 months’ interest rate | 3.5% | 3.7% | 3.9% | Stage 3 | 0%
Negative scenario | GDP | 1.1% | 0.9% | 2.1% | 7% | Stage 1 | 7% | 18% | 20%
Unemployment | 5.0% | 7.1% | 8.9%
Real estate price index | -11.9% | -3.6% | -5.0% | Stage 2 | 19%
3 months’ interest rate | 1.7% | 1.3% | 1.3% | Stage 3 | 4%

Retail portfolio

2024
| 2025 | 2026 | 2027 | Expected losses weighted by probability - deviation from losses reported in % | Change in the share of Stage 2 in relation to the entire portfolio in % | Weight assigned to the scenario to determine the reported expected losses | Reported expected losses (collective assessment in Stage 1, 2 and 3)
Total | by Stages | Total | by Stages
Upside scenario | GDP | 4.7% | 6.3% | 4.6% | -5% | Stage 1 | -5% | -1% | 20% | 834 | Stage 1 | 109
Unemployment | 2.4% | 2.2% | 2.0%
Real estate price index | 9.6% | 6.0% | 6.3% | Stage 2 | -11%
3 months’ interest rate | 7.6% | 7.7% | 7.7% | Stage 3 | -3%
Baseline scenario | GDP | 3.5% | 3.8% | 2.8% | 0% | Stage 1 | 0% | 0% | 60%
Unemployment | 3.0% | 3.0% | 2.9% | Stage 2 | 176
Real estate price index | 6.5% | 4.7% | 3.9% | Stage 2 | -1% | Stage 3 | 549
3 months’ interest rate | 4.4% | 4.2% | 4.4% | Stage 3 | 0%
Negative scenario | GDP | 1.7% | -0.3% | 0.2% | 6% | Stage 1 | 5% | 2% | 20%
Unemployment | 4.3% | 5.9% | 7.1%
Real estate price index | 2.0% | 2.7% | 2.6% | Stage 2 | 15%
3 months’ interest rate | 3.6% | 2.7% | 2.3% | Stage 3 | 3%

18 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

3.2. Measurement of financial instruments not quoted in active markets
The fair value of financial instruments not quoted in active markets is measured using valuation models. For non-
option derivatives, the models based on discounted cash flows apply. Options are measured using appropriate
option valuation models. Valuation models used by the Group are verified prior to their usage.
As a rule, in models the Bank uses observable data from active markets. However, in certain circumstances,
to choose the right valuation parameter, the Bank makes an estimate by comparing a given instrument to another
one present in another market but having similar or identical features. Application of the prudence principle
requiring to choose the lower value of assets and the higher value of liabilities as being more probable – especially
in the conditions of lower liquidity or/and volatility in financial markets – is fundamental in the valuation made
under this approach. Change of assumptions concerning these factors may impact valuation of some financial
instruments.
Sensitivity analysis of the valuation of financial instruments not listed on active markets is presented in note 37. Fair
value.
3.3. Legal risk related to the portfolio of mortgage loans indexed to the Swiss franc exchange rate
The Group holds receivables due to CHF indexed retail mortgage loans. The table below presents the individual
elements that make up the gross and net balance sheet value of these receivables.

as at 31 December |  |
| 2025 | 2024
number of contracts (in pieces) | 1,816 | 2,416
capital balance | 348 | 484
the amount of the adjustment to the gross carrying amount | -294 | -387
other elements of the gross carrying amount (interest, ESP) | 5 | 5
gross carrying amount | 59 | 102
impairment for expected credit losses | -5 | -6
Net carrying amount of CHF-indexed mortgage loans | 54 | 96
Provision for legal risk of CHF-indexed mortgage loans | 208 | 253

The next table presents the change in 2025 and 2024 :
• in gross carrying amount adjustments for CHF-indexed mortgage loans recognised in the statement of financial
position, and
• in provision for legal risk of CHF-indexed mortgage loans.

| 2025 | 2024
an adjustment to the gross carrying amount for loans recognized in the statement of financial position | provision for legal risk of CHF-indexed mortgage loans | an adjustment to the gross carrying amount for loans recognized in the statement of financial position | provision for legal risk of CHF-indexed mortgage loans
Balance at the beginning of the period | 387 | 253 | 510 | 128
Changes in the period, including: | -93 | -45 | -123 | 125
provisions recognised/ reversed | 47 | 10 | -12 | 102
transfer between provisions* | 2 | -2 | -34 | 38
utilisation, including from settlements | -142 | -53 | -61 | -15
FX differences | - | - | -16 | -
Balance at the end of the period | 294 | 208 | 387 | 253

Provision for legal risk of CHF-indexed mortgage loans is presented in liabilities under Provisions and applies to:
• mortgage loans indexed to CHF removed from the statement of financial position,
• parts of CHF-indexed mortgage loans recognised in the statement of financial position, for which the estimated
loss value exceeds the sum of gross exposures,
• costs resulting from court proceedings with respect to CHF-indexed loans recognised in the statement of financial
position.
As at 31 December 2025, the number of CHF-indexed mortgage loan agreements removed from the statement
of financial position, excluding closed as a result of cancellation of the agreement by the court or as a result
of entering into a settlement (for more details, see the settlement programme in explanatory note 32.Provisions),
amounted to 2,428 (2,543 as at 31 December 2024) and the corresponding disbursement amount was PLN 342
million (PLN 358 million as at 31 December 2024).
Detailed information on the legal environment related to the legal risk of the portfolio of CHF-indexed mortgage
loans and information on court cases in connection with concluded CHF-indexed mortgage loan agreements are
presented later in the report in note 32. Provisions.
Changes in the period regarding the estimation of the adjustment / provision for legal risk, both in relation to loans
in the Bank’s portfolio and in relation to repaid loans, the Group presents in the statement of profit or loss in the
item Cost of legal risk of FX mortgage loans (note 10).
The amount of the gross balance sheet value adjustment / provision for legal risk for the portfolio of CHF-indexed
mortgage loans presented in the statement of financial position and already removed from the statement
of financial position depends primarily on the expected number of future litigation cases and the scale of
settlements with borrowers.

19 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

As at 31 December 2025, a portfolio approach was used to estimate the adjustment to the gross carrying amount /
legal risk provision for the CHF-indexed mortgage loan portfolio recognised in the statement of financial position
and already removed from the statement of financial position.
The adjustment to the gross carrying amount of the CHF portfolio is aimed at reflecting the actual and expected
changed cash flows resulting from the agreement (this approach results from the fact that the legal risk related
to the portfolio of CHF-indexed mortgage loans changes the estimation of payments on these assets, and the
introduction of a correction to the gross carrying amount allows the presentation of the gross carrying amount
at a value that will reflect the actual and expected changed cash flows resulting from the agreement).
For financial assets that have already been removed from the statement of financial position, the creation
of provisions for legal risk on a portfolio basis results from the assessment of the probability of a cash outflow.
As at 31 December 2025, potential losses due to legal risk are estimated as probability-weighted average of three
scenarios - base, positive and negative - taking into account the estimated probability of occurrence. The scenarios
on which the estimation is based are diversified in terms of the expected number of court cases, as well as the scale
of settlements with customers expected by the Bank.
As at 31 December 2025, for the portfolio of CHF-indexed mortgage loans recognised in the statement of financial
position, the Bank assumes in each scenario that for a specific part of the portfolio there may be:
• cancellation of the loan agreement after the end of the final court proceedings or
• concluding a settlement with the customer.
The calculation of losses in the event of cancellation of the loan agreement is based on the assumption that the
Bank will refund instalments to the customer and return the principal of the loan granted to the Bank by the
customer. This solution, depending on the scenario, covers from 32% to 43% of the portfolio of CHF-indexed
mortgage loans included in the statement of financial position, which are not subject to legal proceedings. For CHF-
indexed mortgage loans recognised in the statement of financial position being the subject of litigation, the Bank
recognised the full loss resulting from the annulment. The positive, baseline and negative scenarios differ in their
assumptions regarding the number of contentious cases and the weights of the individual scenarios are equal.
The calculation of losses in the case of a settlement covers approximately 10% of the CHF-indexed mortgage
portfolio recognised in the statement of financial position.
As at 31 December 2025, for financial assets already removed from the statement of financial position, the Bank
adopts in each scenario, similarly to the portfolio included in the statement of financial position, i.e. that for
a specific part of the portfolio there may be:
• cancellation of the loan agreement after the end of the final court proceedings or
• concluding a settlement with the customer.
The calculation of losses in the event of cancellation of a loan agreement is analogous to the CHF-indexed
mortgage portfolio recognised in the statement of financial position. This solution, depending on the scenario,
covers 16% to 28% of financial assets already removed from the statement of financial position, which are not
subject to legal proceedings. For mortgage loans already removed from the statement of financial position being
the subject of litigation, the Bank recognised the full loss resulting from the annulment. The positive, baseline and
negative scenarios differ in their assumptions about the number of contentious cases, and the weights of the
individual scenarios are equal.
The calculation of losses in the case of settlements covers approximately 7% of the portfolio of mortgage loans
already removed from the statement of financial position.
As at 2025 the approach to costs related to penal interest and court costs and the estimate of the expected
number of litigation cases were updated in the provision estimate, which affected the calculation of losses in the
event of cancellation of the agreement.
The change in the estimate due to the adjustment to the gross carrying amount / provisions for legal risks
of mortgage loans indexed to CHF recognised in the statement of financial position and already removed from the
statement of financial position in 2025 compared to their balance as at 31 December 2024 resulted from the
periodic review of the main assumptions of the calculation, taking into account the expected number of new
litigation cases, assumptions for settlements concluded with customers and other parameters of the model.
The main sources of uncertainty for the above estimates are the number of litigation cases and the propensity
of clients to conclude settlements.
As at 31 December 2025:
• a change in the share of the portfolio of loans affected by cancellation of the loan agreement by +/-5 p.p. at the
expense of the share of the portfolio of loans not affected by loss would result in a change in the level of gross
carrying amount adjustment for CHF-indexed mortgage loans recognised in the statement of financial position
by +/- PLN 7 million (compared to +/- PLN 12 million as at 31 December 2024),
• a change in the share of loans removed from the financial statements affected by the cancellation of the loan
agreement at the expense of the share of loans removed from the financial statements not affected by loss by
+/-5 p.p. would result in a change in the provision for legal risk for mortgage loans indexed to CHF already
removed from the statement of financial position by +/- PLN 8 million (compared to +/- PLN 10 million
as at 31 December 2024).

20 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

3.4. Deferred income tax
As at 31 December 2025, amendments to tax regulations were adopted, introducing new corporate income tax
(CIT) rates in force from 1 January 2026. CIT rate for of domestic banks is to be 30% for 2026, 26% for 2027 and
23% starting from 2028. In accordance with IAS 12 Income tax, deferred tax assets and liabilities should be
measured at the tax rates that will apply at the time of realisation of assets or settlement of liabilities.The Group
analysed the settlement dates of all temporary differences in future periods, i.e. in the years in which the amended
CIT rates will apply (30%, 26% and 23%, respectively). On the basis of the results of this analysis, the value of
deferred tax assets / liabilities was revalued using CIT rates appropriate for the moment of realisation of individual
temporary differences. In most cases, the expected period of reversal of temporary differences results directly from
contractual terms relating to financial assets and liabilities. In situations where the implementation period does not
result from such conditions, the Group estimated the dates for reversal of temporary differences, based primarily
on available historical data and observed trends. As a result of the revaluation due to a change in tax rates,
deferred tax assets as at 31 December 2025 increased by PLN 41 million (PLN +67 million related to items
recognised in profit or loss and PLN -26 million related to items recognised in other comprehensive income).
4. Consolidation policies
4.1. Subsidiaries
Subsidiaries are those entities that are controlled by the Bank. Control exists when the Bank has an exposure to
variable returns from its involvement with the investee and has the ability to direct the activities that significantly
affect those returns through its power over the investee.
Conditions proving the exercise of control shall not be deemed to be fulfilled if the existing rights are of a purely
protective nature, i.e.: they are defined as rights securing the Bank’s interests resulting from a given commitment.
The control reassessment is done each time if the facts and circumstances indicate a change to the terms and
conditions being the basis for the analysis of a specific involvement, however at least once a year.
The financial statements of subsidiaries are included in the consolidated financial statements from the date
of acquisition until the date on which the Parent company ceases to control the subsidiary, if applicable.
If the control ceases, the Bank:
• no longer recognises the assets and liabilities of the unit that formerly was a subsidiary in the consolidated
financial statements,
• recognises any gains or losses associated with the loss of control events attributable to the former controlling
interest.
Retained investments are recognised at fair value as at the control loss date, which is the date of initial recognition
of the investment in the Bank’s books, depending on the conditions, as:
• interest in joint arrangements, or
• interest in associates or
• financial assets classified and measured based on the purpose of holding thereof.
4.2. Associates
Associates are all entities over which the Bank has significant influence but not control in financial or operational
terms, generally accompanying a share of between 20% and 50% of the voting rights. The consolidated financial
statements include the Group share in profits or losses of associates according to its share in net assets
of associates, from the date of obtaining significant influence until the date the significant influence ceases.
Investments in associates are initially recognised at purchase price and then accounted for using the equity
method. The share of the Group in the profits (losses) since the date of acquisition is recognised in the statement
of profit or loss, whereas its share in changes in other capital since the date of acquisition – in other capital.
The carrying amount of the investment is adjusted by the total changes of different items of equity after the date
of their acquisition.
When the share of the Group in the losses of the investment becomes greater than the share of the Group in that
investment, the Group discontinues the recognition of any further losses or creates provisions only to such amount
it has assumed obligations or has settled payments on behalf of the respective investment.
Unrealised gains on transactions between the Group and such entities are eliminated pro rata to the Group's
interest in those entities. Unrealised losses are also eliminated, unless there is evidence of impairment of the asset
transferred.
4.3. Transactions eliminated in consolidation process
Intragroup balances and gains and losses or income and expenses arising from intra-group transactions are
excluded from the consolidated financial statements.
4.4. Assumption of control over an entity other than an ING Group member
The acquisition approach is applied when settling the purchase of entities from non-associated parties. At the
acquisition date, the Bank recognizes, separately from goodwill, purchased identifiable assets and taken over
identifiable liabilities, taking into account recognition criteria and all non-controlling interests in the acquired entity.
5. Foreign currency
5.1. The functional currency and the presentation currency
These consolidated financial statements are presented in Polish Zloty, which is the functional currency and the
presentation currency of the Bank.

21 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

5.2. Transactions in foreign currency
Transactions expressed in foreign currencies are translated at FX rate prevailing at the transaction date.
The financial assets and liabilities, being result of the said transactions and denominated in foreign currencies are
translated at the FX rate prevailing on a given day. The foreign exchange differences resulting from the settlements
of the said transactions and the balance sheet valuation of the financial assets and liabilities denominated
in foreign currency are recognised in the statement of profit or loss in the specific item FX result, which
is an element of Net income on financial instruments measured at fair value through profit or loss and FX result.
Foreign exchange differences under changes to the fair value of debt financial instruments classified as financial
assets at fair value through other comprehensive income are recognised in accumulated comprehensive income
relating to financial assets classified to this financial category.
6. Net interest income
Interest income and expense for all financial instruments are recognised in the income statement.
Revenue from interest on financial assets measured at amortised cost and measured at fair value through other
comprehensive income is recognised in the income statement at amortised cost using the effective interest rate
or effective interest rate adjusted for credit risk.
The effective interest rate is the rate that discounts the estimated future cash inflows or payments made in the
expected period until the expiry of the financial instrument, and in justified cases in the shorter period, to the net
carrying amount of the asset or financial liability.
When calculating the effective interest rate, the Group estimates the cash flow, taking into account all the
provisions of the financial instrument contract; however, it does not take into account potential future losses
related to bad loans. The calculation includes all fees and commissions paid and received by the parties to the
contract that form an integral part of the effective interest rate, transaction costs and all other bonuses and
discounts.
Potential future credit losses are only taken into account for financial assets that are impaired due to credit risk
at the time of initial recognition. The above is aimed at calculating the effective interest rate adjusted for credit risk.
Interest income includes interest and commissions (received or due) included in the calculation of the effective
interest rate on: loans with repayment schedules, interbank deposits and securities.
In the case of financial assets or a group of similar financial assets classified under Stage 3, interest income
is accrued from the net carrying amount of the receivable (i.e. value reduced by an impairment loss) using the
interest rate used to discount future cash flows for the purpose of estimating impairment losses.
Interest income/expense on derivatives designated as hedging instruments in cash flow hedge accounting including
interest income/expense from settlements of the price alignment amount resulting from the service in accordance
with the settled-to-market approach are presented in Net interest income as other interest income.
7. Commission income and costs
Commission income arises from providing financial services by the Group and comprises i.a. fees for extending
a loan, the Group’s commitment to extend a loan, cards issue, cash management services, brokerage services,
insurance products-related services and asset management services. Commission income comprises also margins
on FX derivatives transactions.
Fees and commissions (both income and expenses) directly attributed to origination of financial assets with
repayment schedule are recognised in the statement of profit or loss as effective interest rate component and are
part of the interest income.
The Group recognizes the following effective interest rate-adjusting commissions:
• commissions for application review and credit commitment letter issue,
• commissions for limit/overdraft granted,
• commissions for granting loan or limit/overdraft,
• commission for restructured loan processing,
• commission for amending the credit agreement as to the amount, currency or schedule of repayments,
• costs of credit and cash loan agency commissions.
Other commissions attributed to origination of financial assets without the repayment schedule are settled using
a straight-line method throughout the agreement term.
The Group recognizes the following commissions as the ones cleared on a straight-line basis:
• the commissions described as the commissions adjusting the effective interest rate for the loans for whose
commissions no cash flows can be estimated (first of all, current account overdrafts, working capital loans and
revolving loans),
• commissions for issuing, confirming or prolonging the time and increasing the amount of guarantees or letters
of credit,
• commissions for multi-facility agreements,
• commissions for the loan or limit/overdraft granted to start another lending year.

22 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Fees on commitment to extend a cash loan, which is likely to be taken, are deferred and as at the date of financial
assets origination are settled as the component of effective interest rate or using straight-line method based on the
above mentioned criterion.
Other fees and commissions relating to the financial services offered by the Group – like cash management
services, brokerage services and asset management services – are recognised in the income statement including
the five steps approach:
1) identify the contract with a customer,
2) identify individual performance obligations in the contract,
3) determine the transaction price,
4) allocate the transaction price to individual performance obligations,
5) recognise income when (or as) each performance obligation is satisfied.
Based on the performed analysis, the Group recognised commission and fee income:
• once the service has been delivered (also for upfront fees) i.e. at transfer of the control over the goods or services,
• over time, if the service delivery is over time,
• at point-in-time, when the Group performs a key operation,
• when there is an actual benefit from the perspective of the customer.
After (or during) satisfaction of the performance obligations, the Group recognises as income the amount which
equals the transaction price, that was allocated to this individual performance obligation.
Commission income that was accrued and is due but was not paid on time is derecognised from the Group’s
financial result upon the lapse of 90 days.
Income and costs under bancassurance commission
Fees and commission related to insurance products are recognised in the income statement according to their
economic content and classified as:
• commissions being part and parcel of a fee under a financial instrument wherewith the insurance product
is linked,
• fee for agency service, and
• fee for additional services after the insurance product sale.
Prior to implementation of the insurance product, in order to recognise it properly in the statement of profit or loss,
the Group analyses features of the insurance product and also the link between the insurance product and the
banking product. In this analysis, the Group takes account of the prevalence of the economic content over the legal
form. The factors analysed by the Group include but are not limited to:
• manner in which an insurance product is offered, option of purchasing a banking product without the insurance
product as well as option of purchasing only the insurance product at the Group,
• pricing conditions of the two products sold together and separately,
• profitability of the insurance and banking products sold together and separately,
• sales target of combined products versus sales target of the same banking products sold without insurance,
• option of concluding an insurance agreement outside the Group,
• number of resignations and the value of refunded insurance premiums,
• settlement cycle with a client,
• scope of activities performed by the Group for the insurer and their duration.
Insurance products offered with loans are treated by the Group as linked to lending products, mainly because
of lack of the possibility to purchase at the Group an insurance product without a loan or a cash loan.
For the absolute majority of insurance products linked with lending products functioning at the Group, the income
on insurance products is earned based on monthly settlements with both the insurer and the client. Since the client
may resign at any time from the insurance coverage for the following month, the Group treats such insurance
as renewed each month and settled for each month separately.
Therefore, the income on insurance products settled monthly is recognised in the income statement also
on a monthly basis. The Group recognises the income on such insurance in the commission income on insurance
products. The Group analogically presents the costs directly related to these insurance products. Such an approach
ensures compliance with the matching principle.
The Group applies an analogical approach to real property insurance with mortgage loans. Taking account of the
materiality principle, the Group presents full income on this insurance in the net commission income.
Most insurance products linked with the Group’s deposit products (current accounts and savings accounts) use the
monthly-settlement structure. Therefore, the income on insurance products settled monthly is recognised in the
income statement also on a monthly basis. The Group recognises the income on such insurance in the commission
income on insurance products.
Commissions under insurance products not linked to banking products are recognised in the income statement:

23 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• on a straight-line basis during the insurance policy term – if the Group, apart from other sales operations, also
provides additional services during the insurance term,
• on a one-off basis – if the Group does not provide any additional services during the insurance policy term.
Should there be a risk of refund of the fee under the insurance product, the Group decreases its income by the
amounts of estimated provisions. The provisions for refunds are established based on the historical data on actual
refunds made in the past and based on projections as to the amount of refunds in the future.
8. Net income on financial instruments measured at fair value through profit or loss and FX result
Net income on financial instruments measured at fair value through profit or loss and FX result includes gains and
losses arising from disposal and change of fair value of assets and liabilities measured at fair value through profit or
loss at initial recognition excluding interest rate derivatives designated as hedging instruments in strategies based
on cash flow hedge accounting principles.
Net income on financial instruments measured at fair value through profit or loss and FX result also includes fair
value adjustments for pre-settlement credit risk and analogous risk generated by the Group (bilateral value
adjustment).
9. Net income on the sale of financial assets and dividend income
Net income on the sale of financial assets measured at fair value through other comprehensive income consists
of realised gains and losses arising from the sale of debt securities measured at fair value through other
comprehensive income and dividend income.
Revenue from dividends is recognised in the income statement on the date of determining the shareholders' rights
to receive them.
The result on the sale of securities measured at amortized cost consists of the realized profits and losses arising
from the sale of debt securities measured at amortized cost.
10. Net (loss)/income on hedge accounting
This item includes the measurement of hedged and hedging transactions in fair value hedging accounting and the
net income on measurement of hedging instruments in the ineffective part of hedge relationship of cash flows
hedge accounting.
11. Net (loss)/income on other basic activities
Net income on other basic activities includes cost and income not attributed directly to Group’s banking and
brokerage activity. These include in particular: net income due to sale of assets (non-current assets and intangible
assets), income on sales of other services, income due to recovered bad debts, received and paid damages,
penalties and fines.
12. Lease contracts and factoring services
12.1. The Group as lessor
The Group is a party to lease contracts, on the basis of which it transfers for payable usufruct non-current assets for
an agreed period. Lease contracts are classified by the Group based on the extent whereto the risk and benefits due
to holding of leased asset are attributable to lessor and lessee.
The lease contract shall be concluded for the term ranging from five to ten years, including transfer of the legal title
to the beneficiary (lessee) after lease contract expiry. The ownership of leased asset is the collateral for the
liabilities arising from lease contracts.
There are no contingent lease payments within the Group. There are no unguaranteed residual values attributable
to the lessor within the Group.
In case of lease contracts, which result in transferring substantially all the risks and rewards following holding of the
leased asset (financial lease), the subject of such lease contract is derecognised from the statement of financial
position. A receivable amount is recognised in an amount equal to the present value of minimum lease payments.
Lease payments are divided into financial income and reduction of the balance of receivables in such a way
as to achieve reaching a fixed rate of return from the outstanding receivables.
Interest on financial leases is presented in Interest income in the item Interest on loans and other receivables
to customers.
Lease payments for contracts which do not fulfil requirements of a finance lease are recognised as income in the
income statement, using the straight-line method, throughout the period of the lease.
12.2. Factoring services
The Group provides factoring services in local and international trade. Handling and financing receivables as well
as risk management are their essence. In addition, as part of factoring activities, the Group provides additional
services, in the field of financial limits for debtors, debt collection and taking over commercial risk. Domestic
factoring without taking over risk (with recourse) is the dominant form of factoring activity of the Group.
Interest income and commissions included in the calculation of the effective interest rate are recognized in the
income statement under Net interest income, and other commission income under Net commission income.
13. Financial assets and liabilities
13.1. Initial recognition
The Group recognizes a financial asset or liability in the statement of financial position when it becomes bound
by the provisions of the contract of this instrument.

24 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Purchase and sale transactions of financial assets measured at amortised cost, measured at fair value through
other comprehensive income and measured at fair value through profit or loss are recognised in accordance with
the accounting method adopted for all such operations on the transaction settlement date – the date on which the
asset is delivered to the unit or delivered by the unit. Financial assets are recognised upon disbursement of funds to
the borrower.
Upon initial recognition, a financial asset or financial liability is measured at fair value, increased in the case
of a financial asset or liability not classified as measured at fair value through profit or loss, by significant
transaction costs that can be directly attributed to the acquisition or issue of the financial asset or financial liability.
13.2. Classification of financial assets
The Group classifies financial assets into one of the following categories:
• measured at amortised cost,
• measured at fair value through other comprehensive income,
• measured at fair value through profit or loss.
Financial assets measured at amortised cost
Financial assets shall be measured at amortised cost if both of the following conditions are met and is not
designated to be measured at fair value through profit or loss:
• the financial asset is held within a business model whose objective is to hold financial assets in order to collect
contractual cash flows and
• the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments
of principal and interest on the principal amount outstanding.
Debt financial assets measured at fair value through other comprehensive income
Financial asset shall be measured at fair value through other comprehensive income if both of the following
conditions are met and it is not designated for measurement measured at fair value through profit or loss:
• the financial asset is held within a business model whose objective is to hold financial assets in order to collect
contractual cash flows and sell financial assets and
• the contractual terms of the financial asset give rise on specified dates to cash flows that are solely payments
of principal and interest on the principal amount outstanding.
Equity instruments measured at fair value through other comprehensive income
Equity instruments are measured at fair value through other comprehensive income in a situation where, upon
initial recognition in the Bank’s books, an irrevocable decision has been made to designate a specific investment
to be measured at fair value through other comprehensive income.
Financial assets measured at fair value through profit or loss
All financial assets that do not meet the criteria for classification to financial assets measured at amortised cost
or financial assets measured at fair value through other comprehensive income are classified as financial assets
measured at fair value through profit or loss.
Business model assessment
The Group assesses the objectives of the business model at the level of the Group’s unit that manages financial
assets and is a so-called business owner of the particular financial assets portfolio. The following business models
are identified for managing the financial assets i.e. in order to:
• collect contractual cash flows,
• collect contractual cash flows and sell financial assets,
• other (e.g.: in order to maximize profits on sales).
The business models are established at the level which is the best reflection of the Group approach to management
of financial assets in order to fulfil business objectives and generate cash flows.
During assessment, the Group verifies all areas of Group’s units activities identified as business owners
of a particular portfolio of financial assets and which may have influence on the decisions taken with regard
to holding assets in the Group’s portfolio, including but not limited to:
• assumptions of the product offer,
• organisational chart of a Bank’s unit,
• assumptions of assessment of the performance of the particular assets portfolio (e.g.: approach to planning,
management information assumptions, key assessment indicators),
• approach to compensation of the key managers in relation to portfolio performance or cash flows generated
on the portfolio,
• the risk generated by the assets portfolio and approach to management of those risks,
• assessment of sales activities from assets portfolio (frequency, volume and reasons for the sales), and
• assessment of expectations regarding sales activities in the future.

25 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The Group permits the sales of financial assets held to collect contractual cash flows, due to the following reasons:
• increase of credit risk,
• sales close to maturity,
• infrequent sales,
• sales insignificant in value.
The Group took the following assumptions:
• sales close to maturity means the sales of financial assets whose:
• original maturity is more than 1 year and sales occurs less than 6 months before maturity date,
• original maturity is less than 1 year and sales occurs less than 3 months before maturity date,
• infrequent sales means that the number of sales compared to the average number of items in the business
model is less than 10%,
• insignificant in value means for which both the value of the sales compared to the total value of the business
model and the net gains from the sales compared to the total net interest income of the business model is less
than 10%.
Assessment of cash flow characteristics
In order to assess the cash flow characteristics the Group formulated the following definitions:
• principal – means fair value of the financial asset at initial recognition in the Group’s books,
• interest – means the payment including consideration for:
• time value of money,
• credit risk resulting from principal amount outstanding within a specified period,
• other basic lending risks and costs (e.g. liquidity risk and administrative costs), and
• profit margin.
The assessment is to confirm that the realised cash flows are solely repayment of principal and interest on the
principal amount outstanding. The Group verifies the contractual terms, which have influence on the timing
of realised cash flows and the amount of the cash flow realised on particular financial asset.
In particular the Group verifies the following conditions:
• contingent events which have influence on the timing and the amount of cash
• leverage,
• prepayment or funding extension conditions,
• non-recourse conditions for the realised cash flows,
• terms that modified the consideration for time value of money.
The assessment of the conditions that modified the time value of money is conducted based on qualitative
or quantitative analysis.
In case the qualitative assessment does not provide the conclusions as to the realised cash flow characteristics,
the Group performs a quantitative assessment. The quantitative assessment is based on comparison of the
difference between:
• undiscounted contractual cash flows and
• undiscounted cash flows that would arise at benchmark asset that not include the conditions modifying
consideration for time value of money.
If the difference between assessed cash flows is significant, then the verified asset will be obligatorily classified
to measurement measured at fair value through profit or loss, as the realised cash flows are not solely repayments
of principal and interest on principal amount outstanding.
13.3. Classification of financial liabilities
The Group classifies financial liabilities into one of the following categories:
• measured at fair value through profit or loss,
• measured at amortised cost,
• financial guarantees.
Financial liabilities measured at fair value through profit or loss
Derivatives that are liabilities and financial liabilities recognised as a result of the short sale of securities are
measured after initial recognition measured at fair value through profit or loss.
Financial liabilities measured at amortised cost
Financial liabilities being a contractual obligation to deliver cash or other financial asset to another entity not
measured at fair value through profit or loss, being a deposit or loan received or a financial liability recognised in the
result on financial asset sales transaction that cannot be derecognised from the statement of financial position.

26 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Financial guarantees
A financial guarantee is a contract under which the issuer undertakes to make specified payments to the
beneficiary to compensate the beneficiary for losses caused by the failure of a specified debtor to make
repayments under the original or modified terms of a debt instrument contract.
13.4. Derecognition
The Group derecognizes a financial asset when, and only when: the contractual rights to the cash flows from the
financial asset expire or the Group transfers the financial asset and the transfer qualifies for derecognition.
The Group transfers a financial asset if and only if it:
• transfers the contractual rights to receive cash flows, or
• retains contractual rights to receive cash flows but assumes a contractual obligation to remit the cash flows.
In a situation where the Group retains contractual rights to cash flows but assumes a contractual obligation
to transfer these cash flows to a third party, the Group treats such a transaction as a transfer of a financial asset
only if all of the following three conditions are met:
• the Group is not required to pay the final recipients until it receives the corresponding amounts resulting from the
original asset,
• under the transfer agreement, the Group may not sell or pledge the original asset other than a security for the
obligation to transfer cash flows established for the benefit of final recipients,
• the Group is required to remit all the cash flows received from the original asset without material delay.
When transferring a financial asset, the Group assesses the extent to which it retains the risks and rewards
of ownership of the financial asset. Accordingly, where the Group:
• transfers substantially all the risks and rewards of ownership of the financial asset, it derecognizes the financial
asset,
• retains substantially all the risks and rewards of ownership of the financial asset, it continues to recognize the
financial asset,
• neither transfers nor retains substantially all the risks and rewards of ownership of the financial asset, then the
Group determines whether it has retained control of the financial asset. In this case if the Group has retained
control, it continues to recognize the financial asset, and if the Group has not retained control, it derecognizes the
financial asset to the extent of its continuing involvement in the financial asset.
The Group derecognizes a financial liability (or part of a financial liability) from its balance sheet when, and only
when the obligation specified in the contract is satisfied or cancelled or expires.
The Group derecognizes financial assets or their part, if the rights pertaining to the financial assets expire, the Group
waives such rights, sells those receivables, they are cancelled or as a result of significant modification of the loan
or cash loan contractual terms.
The Group reduce the gross carrying amount of a financial asset when the Bank has no reasonable expectations
of recovering a financial asset in its entirety or a portion thereof. This principle is applied, among others, to accrued
penalty interest, also when the principal amount of the related financial assets is still recognized in the statement
of financial position.
The amounts of receivables written down as loss and recovered thereafter reduce the value of impairment loss
in the income statement.
The derecognition of financial assets measured at amortised cost in connection with their sale is settled taking into
account the previously created allowance for expected credit losses. Therefore, gains and losses resulting from
derecognition of financial assets measured at amortised cost were presented in the statement of profit or loss
in the item Impairment for expected credit losses - profit on sale of receivables and Net income on the sale of
securities measured at amortised cost.
13.5. Modification of contractual cash flows
When the terms of the loan and cash loan agreements are renegotiated and contractual cash flows of a financial
asset are modified, the Group assesses if such modification was significant and should result in the extinguishment
of that financial asset and recognition of a new financial asset. A financial asset is extinguished if either the
qualitative or the quantitative criteria are met.
Qualitative criteria
The Group assumes that such significant modification of the terms of the agreement will take place in case of a:
• change of the debtor with the consent of the Group, or
• change of the legal form/type of the financial instrument or
• change of loan currency unless it was included in contractual terms, or
• the modified financial asset does not meet the SPPI test, i.e. the cash flows from the financial asset do not
represent, on specified dates, solely payments of principal and interest on the principal amount outstanding, or
• change in interest rate from fixed to floating or vice versa for financial assets that are not credit-impaired, or
• change of the financial instruments from revolving to non-revolving or vice versa for financial assets that are not
credit-impaired, or

27 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• increase of the exposure amount of 50% or an extension of the tenor of the facility/instrument by 50%, if the
present value of cash flows under the modified terms, discounted at the original effective interest rate, is at least
10% different from the discounted present value of the remaining cash flows of the original agreement,
discounted using the original effective interest rate.
Quantitative trigger
A financial asset is deemed to be extinguished when the present value of cash flows under the modified loan terms,
discounted at the original effective interest rate, is at least 10% different from the discounted present value of the
remaining cash flows of the original agreement, discounted using the original effective interest rate.
For modifications that do not lead to a derecognition of the financial asset, the net present value difference (using
the original effective interest rate) between the cash flows of the asset before and after modification is recognised
in the statement of profit and loss.
13.6. Measurement
After initial recognition, the Group measures financial assets, including derivatives that are assets, at their fair
values, except for the financial assets measured at amortised cost using the effective interest method.
After initial recognition, all financial liabilities are measured at amortised cost using the effective interest method,
except for:
• financial liabilities measured at fair value through profit or loss. Such liabilities, including derivatives that are
liabilities, are measured at fair value, in particular a derivative liability that is linked to and must be settled by
delivery of an unquoted equity instrument,
• financial liabilities resulting from the transfer of a financial asset which do not qualify for derecognition or which
are recognised on a continuing involvement basis,
• commitments to provide a loan at a below-market interest rate which it shall subsequently measure it at the
higher of:
• the amount of impairment for expected credit losses, and
• the amount initially recognised less, when appropriate, the cumulative amount of income recognised
in accordance with principles of IFRS 15,
• contingent consideration recognised by the Group acting as an acquirer in a business combination to which IFRS
3 applies, which it shall subsequently be measured at fair value through profit or loss.
If the estimates of payments or inflows change (excluding insignificant modifications and changes in estimates
of expected credit losses), the Group adjusts the gross carrying amount of the asset or the amortised cost of the
financial liability (or group of financial instruments). For this purpose, the Group translates the gross carrying
amount of a financial asset or the amortised cost of a financial liability as the present value of estimated future
contractual cash flows that are discounted at the original effective interest rate of the financial instrument (or the
credit-adjusted effective interest rate for purchased or credit-impaired financial assets created) or, where
applicable, the revised effective interest rate.
In particular, the Group adjusts the gross carrying amount of the portfolio of mortgage loans denominated
in foreign currencies, taking into account the changed estimated cash flows from these agreements resulting from
the legal risk of this portfolio. The adjustment is recorded as a separate line in the income statement Cost of legal
risk of FX mortgage loans.
Granted financial guarantees are measured at the higher of:
• the amount of the loss allowance determined in accordance with the impairment requirements and,
• the amount initially recognised less, where appropriate the cumulative amount of income recognised in
accordance with the revenue recognition principles.
13.7. Gains and losses resulting from subsequent measurement
A gain or loss arising from a change in the fair value of a financial asset or financial liability that is not part
of a hedging relationship is recognised as follows:
• a gain or loss on a financial asset or financial liability classified as measured at fair value through profit or loss
is recognised in the income statement,
• a gain or loss on an asset measured at fair value through other comprehensive income is recognised directly
in equity through statement of changes in equity.
Interest income is calculated using the effective interest rate method. The relevant value is computed by applying
the effective interest rate method to the gross carrying amount of the financial asset, except for:
• purchased or originated credit-impaired financial assets. The Group applies the credit risk adjusted effective
interest rate to the value of amortised cost of a financial asset as of the initial recognition, and
• financial assets that are not purchased or originated credit-impaired financial assets which subsequently became
credit-impaired financial assets (Stage 3).
For those financial assets the Group applies the effective interest rate to the value of amortised cost (net)
of a financial asset in subsequent reporting periods.
Dividends on an equity instrument are recognised in the income statement when the entity’s right to receive
payment is established.

28 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Foreign exchange gains and losses arising from a change in the fair value of a financial asset measured at fair value
through other comprehensive income denominated in foreign currency are recognised directly in equity only for
non-monetary assets. Foreign exchange gains and losses arising from monetary financial assets (e.g. debt
securities) denominated in foreign currency are recognised directly in the income statement.
At the moment of derecognition of financial assets from the balance sheet, cumulated gains and losses recognised
previously in equity:
• regarding debt financial assets are recognised in the income statement,
• regarding equity instruments are recognised in equity.
The fair value of financial assets and liabilities quoted in an active market (including securities) is determined on the
basis of the bid price for long position and offer price for short position. Should there be no active market for a given
instrument or for the securities not quoted on an active market, the Group establishes the fair value with the use
of valuation techniques that include using recent arm’s length market transactions, discounted cash flow analysis
and option pricing models and other techniques commonly used by market players.
Market activity is assessed on the basis of frequency and the volume of effected transactions as well as access
to information about quoted prices which by and large should be delivered on a continuous basis.
The main market and the most beneficial one at the same time is the market the Group can access and on which
in normal conditions it would enter into sale/purchase transactions for the item of assets or transfer of a liability.
Based on the employed methods of determining the fair value, financial assets/liabilities are classified to the
following categories:
• level 1: financial assets/liabilities measured directly on the basis of prices quoted in the active market,
• level 2: financial assets/liabilities measured on the basis of measurement techniques based on assumptions using
data from an active market or market observations,
• level 3: financial assets/liabilities measured on the basis of measurement techniques commonly used by the
market players, the assumptions of which are not based on data from an active market.
The Group verifies on a monthly basis whether any changes occurred to the quality of the input data used for
individual measurement techniques and determines the reasons there for and their impact on the fair value
calculation for the financial assets/liabilities item. Each identified case is reviewed individually. Following detailed
analyses, the Group takes a decision whether its identification entails any changes to the approach for fair value
measurement or not.
In justified circumstances, the Group decides to make changes to the fair value measurement methodology and
their effective date construed as the circumstances change date. Then, it assesses the impact of changes on the
classification to the individual categories of the fair value measurement hierarchy. Any amendments to the
measurement methodology and their rationale are subject to detailed disclosures in a separate note to the
financial statements.
13.8. Derivative instruments and hedge accounting
Derivative instruments are measured at fair value without cost of transactions, which are to be incurred. The base
of initial fair value valuation of derivatives is the transaction price, i.e. fair value of received or paid amount.
Settlements exchanged for Interest Rate derivatives cleared via a central counterparty that are subject to settled
to market contracts reduce the derivative’s carrying value.
The credit risk component is included in the fair value measurement for derivative instruments through credit
valuation adjustments. Valuation adjustments are estimated per counterparty considering the expected pre-
settlement exposure credit risk and the same risk generated by the Group. This approach provides for the possibility
of occurrence of risk of bilateral value adjustments. The adjustment is made using the expected positive exposure
estimated through numerous simulations (the results from the scenarios leading to a negative outcome are
eliminated) and the present market value (or its estimation through referencing to comparable data) of credit
default swaps (CDS). Own risk of the Group and the risk of materialisation of a scenario of concurrent client and
Group insolvency are calculated by analogy.
In addition, for receivables resulting from matured or terminated but unsettled derivatives, the Group establishes
impairment losses using the methodology applied to assessing the risk of impaired credit receivables.
The two adjustments as mentioned above were differently reflected in the financial statements. Fair value
adjustments due to risk for non-matured transactions were presented in the item Net income on financial
instruments measured at fair value through profit or loss and FX result, whereas the impairments losses for matured
transactions in the item I mpairment for expected credit losses.
If a transaction whose fair value was adjusted in the previous reporting period in the item Net income on financial
instruments measured at fair value through profit or loss and FX result becomes mature or subject to restructuring,
then the amount of the previous fair value adjustment is moved to the item Impairment for expected credit losses
and the added part of the impairment loss for such already matured transaction is presented in the statement
of financial position in the item Impairment for expected credit losses. Therefore the financial result is impacted only
by the amount of surplus of the current impairment loss (or write-down) for a mature transaction above the
amount of the fair value adjustment made before the transaction has matured.
The Group uses derivative instruments in order to hedge against FX and interest rate risk, arising from activity of the
Group. Those derivatives, which were not designated as hedge instruments pursuant to the principles of hedge
accounting, are classified as instruments measured at fair value through financial result.

29 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

13.8.1. Hedge accounting
The Group applies the hedge accounting requirements of IAS 39.
Hedge accounting presents the offsetting effects of fair value changes of both hedging instruments and hedged
items which impact the income statement.
The Group designates certain derivative instruments as fair value hedging instrument or cash flow hedging
instrument.
Fair value hedge
The Group applies the fair value hedge accounting in order to hedge changes in fair value of fixed-rate debt
instruments classified to the portfolio of assets measured at fair value through other comprehensive income and
fixed-rate debt instruments classified to the portfolio of assets at amortised cost against the risk resulting from
interest rate changes.
Cash flow hedge
The Group applies cash flow hedge accounting in order to hedge the amount of future cash flows of certain
portfolios of assets/liabilities of the Group or the portfolio of highly probable planned transactions against the
interest rate risk and the highly probable planned transactions against the FX risk.
13.8.2. Derivative instruments not qualifying as hedging instruments
Changes in fair value of derivatives that do not fulfil the criteria of hedge accounting are disclosed in the statement
of profit or loss for the current period. Changes in the fair value of interest rate derivatives resulting from the current
calculation of an interest coupon and the remaining part of the change in the fair value of interest rate derivatives
are presented in the item Net income on financial instruments measured at fair value through profit or loss and FX
result.
Changes in the fair value of FX derivatives are presented under Net income on financial instruments measured at fair
value through profit or loss and FX result.
13.9. Offsetting financial instruments
The Group offsets financial assets and financial liabilities and presents them in a net amount in the statement
of financial position when and only when there is a legally enforceable right to offset the recognised amounts and
there is an intention to settle on a net basis, or realise the asset and settle the liability simultaneously.
In order to mitigate credit risk, the Group concludes master agreements with contracting parties, with which the
Bank concludes transactions. These master agreements provide for offsetting financial assets and liabilities in case
of a breach of the master agreement. Due to the conditional nature of these contractual provisions, there
is no netting in the financial statements and the effects of conditional netting are presented in note 38 . Offsetting
of financial instruments.
13.10. Repo / reverse repo transactions
The Group presents the financial assets sold with the repurchase clauses (repo, sell–buy–back transactions) in its
statement of financial position, simultaneously recognising a financial liability under a repurchase clause.
This is done in order to reflect the risks and benefits arising on this asset item that are retained by the Group after
the transfer.
For the securities purchased with a reverse repurchase clause (reverse repo, buy–sell–back), the financial assets
held are presented as receivables arising from repurchase clause, hedged with securities.
13.11. Expected credit losses
Estimation of the impairment loss is based on the expected credit loss. This approach shall be applied to debt
financial assets measured at amortised cost and financial assets measured at fair value through other
comprehensive income, lease receivables, contract assets, irrevocable loan commitments and financial guarantees,
except for investment in equity securities.
At each reporting date, the Group measures the impairment for expected credit losses for a financial asset
at an amount equal to the lifetime expected credit losses if the credit risk on that financial asset has increased
significantly since initial recognition. If at the reporting date, the credit risk on the financial asset has not increased
significantly since initial recognition, the Group measures the impairment for expected credit losses for that
financial asset at an amount equal to 12-month expected credit losses.
The Group estimates expected credit losses in a way that takes account of:
• an unbiased and probability-weighted amount that is determined by evaluating a range of possible outcomes,
• the time value of money, and
• reasonable and supportable information that is available without undue cost or effort at the reporting date about
past events, current conditions and forecasts of future economic conditions.
The Group applies the definition of exposures in default status, impaired exposures and non-performing exposures
in accordance with regulatory requirements. A debtor or an exposure is assessed as default is also identified
as an impaired and non-performing exposure.
Three stage approach
In the process of creating credit provisions, the change in the credit quality of the exposure since its initial
recognition is described in the Group in three stages with different method of measurement of expected credit
losses:

30 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• Stage 1 includes performing exposures that have not had a significant increase in credit risk since initial
recognition. Expected credit loss shall be measured based on 12-month expected credit losses (or till maturity
date if such exposures will expire in less than 12 months).
• Stage 2 includes performing exposures that have had a significant increase in credit risk since initial recognition.
Expected credit loss is calculated on the basis of anticipated losses throughout the lifetime, or from the reporting
date until the remaining maturity.
• Stage 3 – impaired exposures, which means non-performing loans. Expected credit loss shall be measured based
on lifetime expected credit losses and the probability of default (PD) = 100%.
The Group qualifies the financial exposures to Stage 1, 2 or 3 using a cascade approach in the following order:
1. Identification of impaired exposures and classification thereof to Stage 3,
2. Allocation to Stage 2 based on triggers for significant increase of credit risk,
3. Allocation of other exposures to Stage 1.
Significant increase in credit risk
The Group determines the significant increase in credit risk, which results in classification to Stage 2, based on one
of the following triggers (where the first one is the leading one:
• significant increase in the lifetime PD at reporting date comparing to the lifetime PD at initial recognition
occurring over the period from the reporting date till maturity date,
• customer/Watch List presence (watch list),
• a three-fold increase in PD parameter since granting the exposure,
• the asset has an internal rating of 18 or 19
• customer service by a corporate restructuring unit,
• the fact of granting a facility (forbearance) to the customer,
• deterioration of the risk profile of the portfolio to which the exposure belongs (collective),
• deterioration of the exposure/customer risk profile (individual),
• more than 30 days past due.
Thresholds of significant increase in PD parameters in the lifetime of exposure comparing to PD at initial recognition,
indicating significant increase in credit risk, are established for models according to assumed methodology as:
• absolute threshold – indicates maximum difference between PD at the reporting date and PD at initial recognition
which triggers classification to Stage 2,
• relative threshold – indicates the maximum measure of the relationship between the PD as at the reporting date
and the PD from the initial recognition of the exposure, taking into account the scaling factor determined at the
level of a particular exposure, based on the PD from the initial recognition, beyond which the asset is classified
to Stage 2.
Exceeding at least one of the above thresholds results in classification of a financial asset to Stage 2.
The methodology of establishing PD thresholds to indicate significant increase in credit risk is based on performing
an appropriate segmentation followed by statistical indication of the threshold to classify exposures to Stage 2
which maximizes discriminatory power of classification to stages, under certain assumptions, among others,
minimization of classification errors.
Evidence and triggers for classification of assets at amortised costs to the Stage 3
At each balance sheet date, the Group assesses whether a financial assets item or a group of financial assets
is impaired. A financial asset item or a group of financial assets is impaired if and only if, there is evidence
of impairment as a result of one or more events that occurred after the initial recognition of the asset item (a ‘loss
event’) and that loss event (or events) has (have) an impact on the expected future cash flows of the financial asset
item or a group of financial assets that can be reliably estimated. The Group recognizes the expected credit losses
based on reasonable and supportable information that is available without undue cost or effort at the reporting
date about past events, current conditions and forecasts of future economic conditions.
Evidence of impairment
The evidence of impairment is:
• identification of objective evidence of impairment (in the case of corporate and retail credit exposures), or
• a delay in repayment above 90 days and at the same time exceeding the absolute and relative materiality
threshold by the amount of the arrears in repayment.
Objective evidence of impairment does not require expert judgment – identification of the occurrence of such
evidence causes the credit exposure to be considered defaulted and, at the same time, impaired without further
analysis. Objective impairment evidence of corporate or retail credit exposures cover the occurrence of minimum
one of the following situations:
• restructuring of the credit exposure for non-commercial reasons related to significant financial difficulties of the
client, resulting in a change to the existing terms of the contract, full or partial refinancing of the exposure at risk,
which would not have taken place if the client had not experienced financial difficulties (including forbearance),

31 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

resulting in a loss of more than 1% of the present value of discounted future cash flows; for retail credit exposures
– non-performing restructuring,
• write-down or write-off by the Group in the process of restructuring of a significant amount of corporate client
receivables resulting in a reduction in cash flows from a given financial asset,
• filing by the Group, the client's counterparty or another bank for the client's bankruptcy or the initiation of
proceedings under the restructuring law,
• declaration of bankruptcy; in the case of corporate credit exposures, the client was put into liquidation, ceased
operations,
• the credit exposure becomes due to the termination of the credit agreement by the Group,
• sale by the Group of a credit receivable (or its part) with a loss greater than 5% of the balance sheet exposure
amount, if the sale was caused by the deteriorating credit quality of the exposure,
• the occurrence of an overdue exceeding 30 days or granting another forbearance on a credit exposure classified
initially as forbearance non-performing, and then healed and in the forbearance performing status during the
trial period,
• interest-free status (interest stoppage) for a credit exposure,
• for retail credit exposure, over 3-month arrears in repayment of due liabilities under the loan with a one-off
repayment of the entire mobilised capital at the end of the loan period,
• for corporate credit exposures – making a decision to recover debts as part of the debt collection strategy,
• questioning the balance sheet credit exposure by the client in court proceedings,
• delay in repayment of more than 90 days for exposures representing at least 20% of the total balance of all on-
balance sheet exposures of a given client - for the remaining exposures of the client.
Impairment triggers
Impairment triggers require an individual expert assessment of the debtor's situation and a decision as to whether
the classification to default as an impaired exposure is justified.
The triggers for impairment for corporate credit exposures (excluding exposures to entrepreneurs) include:
• granting by a natural person in default of obligations, a surety at the Bank for significant obligations
of a company belonging to it or when a natural person is a debtor of the Bank and the company belonging
to it is in default,
• over 3-month arrears in repayment (including all interest, principal and commissions) under the loan with a one-
off repayment of all disbursed capital at the end of the loan period (not applicable if the repayment frequency
exceeds one month),
• the customer belongs to the same economic or legal group as the defaulting debtor,
• disappearance of the possibility of refinancing,
• for exposures resulting from transactions concluded on the financial market – disappearance of an active market
(e.g. suspension of quotations on the WSE) for a given financial asset (shares, bonds, other securities) held by the
Group due to financial difficulties of the issuer / client, which may have a negative effect on the future cash flows
of a given financial asset,
• the customer ceases to repay principal, interest or commission and the delay in repayment or the oldest
unauthorised overdraft continues for more than 45 calendar days,
• bankruptcy threat, submission of an application to initiate proceedings under restructuring law or other financial
reorganization, which may result in non-repayment of a financial asset or its delay,
• the customer’s cessation of repayment of a due and payable liability in the amount exceeding EUR 10 thousand
and late repayment or illegal debit persist for more than 1 working day for banks and 5 working days for financial
institutions, but with a 14-day explanatory period to determine whether the default was due to non-operational
reasons,
• no intention or possibility of repayment by the debtor due to the existing financial problems; in particular, the
following events may indicate significant financial difficulties (the events described in points "1" to "5" are not
triggers for impairment if they were assumed in the client's financial plans at the time of granting the
involvement and the Group accepted such plans:
1. negative equity at the end of the annual accounting period,
2. negative cash flows from operating activities in three consecutive annual accounting periods (from the cash
flow statement, and if it is not prepared, then from the simplified cash flow statement),
3. revenues from core activities decrease significantly (over 50% year on year based on the results of annual
accounting periods) or revenues from core activities decrease (over 30% year on year based on the results
of annual accounting periods) and, at the same time, the ratio of debt to EBITDA (earnings before interest,
taxes, depreciation and amortization, profit before deduction of interest on interest-bearing liabilities, taxes
and depreciation) is greater than 4 or EBITDA is less than 0 (if the contract contains a different definition
of the trigger, the event is a trigger for impairment, if it is exceeded level 4 as defined in the contract. If the
contract indicates the level of the ratio> 4, then we identify the triggers for impairment when exceeding the
level specified in the contract),

32 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

4. negative EBITDA in two consecutive annual financial periods,
5. the implementation of financial projections by the client negatively differs from the range approved by the
Group by at least 20%, which leads to a significant breakdown of financial ratios,
6. the events described in points "1" to "5" occurred during the accounting year, provided that they occurred
in the amounts considered significant and the Group expects that the situation will not improve until the end
of the annual accounting period and this situation may result in failure to repay the financial asset or its
delay, provided that they were not assumed in the customer’s financial plans at the moment of granting the
commitment and the Group accepted such plans,
7. active enforcement to client accounts kept in the Group, if the oldest active enforcement order persists for
more than 90 days and the total amount of active titles exceeds PLN 100 thousand; PLN for customers of the
corporate sales network or PLN 500 thousand for strategic clients,
8. unsettled claims under guarantees granted by the Group (lack of customer funds), if the customer's overdue
liability to the Group due to the payment of the guarantee by the Group persists for more than 45 days from
the date of payment of the guarantee claim,
9. termination of a loan agreement with another bank of significant value,
• a material breach of contractual terms by the customer, which may have a negative impact on future cash flows
from a given financial asset (if there has been a material breach of contractual terms, but the Group, after
identifying and assessing the causes and effects of such breach, accepted them (temporarily or permanently)
or changed, such an event is not treated as a trigger for impairment),
• inability of a financial institution to repay a liability due to financial problems, which may result in the failure
or delay of the repayment of a financial asset,
• unknown whereabouts of the client, resulting in a lack of representation in contacts with the Group and
undisclosed assets of the client,
• crisis of the sector in which the client operates, combined with the borrower's weak position in a given sector,
• restructuring of the loan receivable for non-commercial reasons related to significant financial difficulties of the
client, resulting in a change to the existing terms of the contract, full or partial refinancing of the exposure at risk,
which would not have occurred if the client had not experienced these financial difficulties (including
forbearance) and loss of the net present value of cash flows is equal to or less than 1%,
• credit fraud of the debtor towards the Bank or another ING Group entity,
• the exposure has received a forbearance 2 or more times in the last 5 years,
• a significant deterioration of the client's rating resulting in its reclassification to a risk class of at least 17 with
a simultaneous drop by at least 4 classes.
The Group has also determined the following additional triggers for impairment for leveraged transactions
(i.e. transactions with a high level of debt relative to operating profit):
• a significant breach of an important financial clause or failure to return to the state from before the breach,
especially when the customer simultaneously requests a repayment facility,
• forbearance refinancing of the existing borrower with an increased level of financial leverage (IBD / EBITDA,
i.e. interest bearing debt / earnings before interest, taxes, depreciation and amortization, total liabilities / profit
before deduction of interest on interest-bearing liabilities, taxes and depreciation) compared to leverage levels
at the time of funding or previous refinancing,
• refinancing of the exposure with the repayment of the entire mobilised capital at the end of the loan period
in the event of financial difficulties of the client and with a low probability of refinancing by another bank under
current market conditions,
• the base case and stress case scenarios indicate the lack of sufficient and stable cash flows to service the debt
in accordance with the adopted schedule;
and the following additional triggers for the revenue-generating real estate financing transactions:
• LTV (Loan to Value)> 90% and this is not a temporary situation,
• historical DSCR (debt service cover ratio) ratio <1.0 or ICR (interest coverage ratio) <1.0 (depending on which
indicator is used for transaction risk assessments) for two consecutive annual accounting periods and cash flows
generated by the real estate are, in the opinion of experts, insufficient to repay and service the loan
in accordance with the adopted schedule.
The triggers for impairment for retail credit exposures and credit exposures to entrepreneurs include:
• failure to meet a minimum of three debt repayment arrangements within the current period of arrears,
• a natural person who is responsible for all of his assets for the material liabilities of his company is in default
or a natural person who is the sole owner of the company in default,
• the business client is related to the same group of debtors (legally or economically) in which one of the debtors
is defaulted,
• no intention or possibility of repayment – in the Group's opinion, the debtor does not want to pay off the
obligation or is unable to pay; the inability to repay the liability occurs when the debtor's sources of income are
insufficient to repay the instalments due, e.g.:

33 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• for an individual client: loss of job, termination of social benefits payments, divorce, serious illness, death of the
debtor, obtaining information on untimely servicing of a debt of significant value in another bank (over 90 days
overdue) or commencement of enforcement / debt collection activities by another bank,
• for a business client: (anticipated) cash shortfall, (anticipated) high or sudden increase in leverage, (anticipated)
breach of financial clauses, (anticipated) deterioration in a market where the debtor's position is weak,
• approving a forbearance to the customer that is not able to repay its financial obligations under a loan
agreement with the Group due to existing or anticipated financial difficulties,
• credit fraud of the debtor towards the Group – reasonable suspicion of extortion of a loan, i.e. an obligation
whose credit documentation or the established facts indicate that it was granted as a result of deliberate
misrepresentation of the Group by presenting documents, certificates, and statements that are not factually
correct,
• occurrence of minimum two forbearance instances within 5 years of granting the first forbearance.
In the process of identifying impairment, the Group first assesses whether there is any objective evidence or trigger
for impairment for financial assets.
The entire loan portfolio of retail and corporate clients is subject to the control for impairment of exposure. Credit
exposure is assessed for impairment in relation to the debtor automatically on a daily basis for customers from
retail segments and on a current basis and on the applicable dates of regular and irregular portfolio monitoring
in relation to corporate customers. Objective evidence of impairment requires the client to be reclassified to the
portfolio of non-performing exposures.
Identification of the triggers for impairment of the credit exposure of corporate clients requires an individual expert
assessment of the debtor's situation and a decision whether the classification to default is justified, i.e.:
• assessment of the customer’s potential to repay all credit obligations to the Group in compliance with the
agreement and a documented assessment,
• if no default or impairment is identified, a written justification for leaving the client in the performing portfolio
should be prepared,
• if as a result of the assessment a situation of default or impairment was identified – reclassification of the client
to the portfolio of non-performing exposures.
If, as a result of the assessment, it is concluded that there is no evidence of impairment for a given financial asset,
the asset is included in groups of financial assets with similar credit risk characteristics that indicate the debtor's
ability to repay the entire liability in accordance with the terms of the contract. In the groups designated in this
way, the impairment loss is calculated using the collective method, based on the valuation of expected credit
losses. If there is evidence that an impairment loss has been incurred on an asset measured at amortised cost, the
amount of the impairment loss is the difference between the asset's carrying amount and the present value
of estimated future cash flows discounted using the original effective interest rate of the financial instrument.
In practice, this means that for assets from the Stage 3 portfolio subject to individual assessment (individually
significant financial assets, whose value exceeds the equivalent of EUR 1 million), the impairment is calculated
directly using discounted future cash flows for a given asset, and for assets from the Stage 3 portfolio subject
to collective assessment (financial assets insignificant) –is determined using the collective impairment method with
the use of the expected credit loss over the life of the asset. When estimating future cash flows, the available
information about the debtor is taken into account, in particular, the ability to repay the exposure is assessed, and
in the event that the credit exposure has collateral, the estimation also takes into account the expected future cash
flows from the realization of the collateral, taking into account inter alia time, costs and difficulties in recovering
payments as a result of selling the collateral.
If the existing evidence of impairment of an assets item or financial assets group measured at amortised cost
indicate that there will be no expected future cash flows from the above mentioned financial assets, the
impairment loss of assets equals their carrying amount.
The Group applies a definition of default, in line with:
• the guidelines of the European Banking Authority (EBA) No. EBA/GL/2016/07 of 18 January 2017 on the
application of the definition of default under Article 178 of Regulation (EU) No 575/2013,
• the EBA guidelines on the management of non-performing and restructured exposures EBA/GL/2018/06 of 31
October 2018,
• Regulation of the Minister of Finance, Investment and Development of 3 October 2019 on the materiality level
of a past due credit obligation,
• Regulation (EU) 2018/1845 of the European Central Bank of 21 November 2018 implementing the discretion
under Article 178(2)(d) of Regulation (EU) No 575/2013 as regards the threshold for the materiality assessment
of overdue credit obligations (ECB/2018/26).
Recognition of an allowance for expected credit losses for assets measured at amortised cost
Impairment is presented as reduction of the carrying amount of the component, while the amount of loss
is charged to the profit and loss account of the period.
If in the next period the amount of impairment loss decreases due to an event that occurred after the impairment
(e.g. improvement in the debtor’s creditworthiness assessment), then the previously made impairment loss
is reversed through the profit and loss account. The Group has defined the events that may result in the reversal
of impairment of the credit exposure.

34 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The Group applies the same criteria for the purpose of recovering a client from default and reversing impairment
losses. The process of starting the trial period and then healing, i.e. transition from the non-performing portfolio
(NPE) to the performing portfolio is carried out:
• for customers from the mortgage and consumer loan segment - at the business segment level, unless it applies
to a situation recognised at the debtor level (e.g. bankruptcy),
• for corporate clients - at the debtor level.
If the debtor is in the impaired portfolio and has no exposure as a forbearance (facility), it shall be considered
to be healthy and qualified as a performing (performing) portfolio if all of the following conditions are met in the
following order:
• no evidence of impairment or impairment triggers giving rise to a default or indicating a high probability
of default - are active,
• at least 3 months (trial period) have passed since the date of completion of proof/ indication of impairment and
during this period the customer’s behaviour (intention to repay) and situation (ability to pay) have been positively
assessed, and in the case of a corporate customer, the assessment of financial standing has been documented,
• the customer made regular repayments, i.e. no arrears >30 days during the trial period,
• after the end of the trial period, the customer was considered able to repay the loan liabilities in full, without
using the collateral,
• no arrears exceeding the absolute limit; if there are arrears in excess of the absolute limit, the trial period shall
be extended until the arrears are reduced below that limit.
A client in an impaired portfolio with an exposure with the status of granted facility for repayment (forbearance) -
shall be deemed to be cured and qualified to the working portfolio (performing) if all of the following conditions
are met:
• no evidence of impairment or impairment triggers giving rise to a default or indicating a high probability of
default - are active,
• at least 12 months have passed since the last of the following events (trial period):
• granting the last restructuring measures, i.e. granting a facility for repayment (forbearance),
• the exposure has been given default status,
• end of the grace period specified in the restructuring agreement,
• during the trial period, the customer made significant/regular repayments:
• the customer, as part of his regular payments in accordance with the established restructuring conditions,
repaid the material amount in the amount constituting the earlier overdue (if there were overdue amounts)
or redemption (if there were no overdue amounts),
• the client made regular repayments in accordance with the new schedule taking into account the conditions
of restructuring, i.e. no arrears > 30 days during the trial period,
• at the end of the probationary period, the customer has no past due amounts and has no concerns about the full
repayment of the exposure under the terms of the restructuring agreement.
The Group has established the following additional terms of reversal of impairment / exit from default status
(default) binding for all customers:
• If in the trial period a proof or an indication of impairment is identified as a source of default/ indicating a high
probability of default, the date of the end of the trial period will be re-established and the trial period starts
to count from the beginning from the moment of expiry of the proof/ indication.
• If a DPD event > 30 occurs during the trial period and after the grace period, the trial period end date will be reset
and the trial period will begin to count from the beginning when the DPD has returned to less than 31 days.
• All conditions for reversal of impairment/exit from default should also be met for new exposures to the client,
in particular if previous credit exposures of this client previously in restructuring were disposed of or permanently
written off.
An exception to the principle of lack of active evidence / impairment triggers constituting the source of default
is evidence "classification to Stage 3 / provision" - its persistence does not suspend the start of the trial period
(because it is the effect and not the cause of the default) - classification to Stage 3 and the provision is also
maintained during the trial period.
Indications of classification of a financial asset measured at fair value through other comprehensive income to
Stage 3
At each balance sheet date, the Group assesses whether there is objective evidence of impairment of debt financial
assets classified as at fair value through other comprehensive income. Confirmation of the existence of objective
evidence of impairment is the premise for classification of the asset to stage 3.
Evidence that a financial asset or group of financial assets is impaired permanently may be based on one or more
of the following:
• significant financial difficulties of the issuer (e.g.: significant negative equity, high losses incurred in the current
year exceeding equity, termination of a credit agreement of significant value in another bank),

35 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• failure to meet contractual conditions, including in particular failure to pay or default on maturing liabilities
(e.g. interest or notional amount), interpreted as materialisation of the issuer’s credit risk,
• the granting by its creditors to the issuer of facilities for the repayment of liabilities which it would not otherwise
have received,
• high probability of bankruptcy or other financial reorganisation of the issuer,
• identification of impairment of a financial asset in the previous period,
• disappearance of an active market for a financial asset, which may result from the issuer’s financial difficulties,
• published analyses and forecasts of credit rating agencies or other entities that confirm a specific (high) risk
profile of a financial asset,
• other observable data indicating a determinable decrease in the estimated future cash flows resulting from the
group of financial assets that appeared after the date of their initial recognition in the Group’s books. The data
referred to above may relate to unfavourable changes in the payment situation of a group of issuers, a country
or local economic conditions that are correlated with the lack of repayments from the group of financial assets.
Recognition of an allowance for expected credit losses on debt financial assets measured at fair value through
other comprehensive income
Impairment losses on debt financial assets measured at fair value through other comprehensive income are
recognised in the statement of profit or loss. These losses are excluded from other comprehensive income.
Measurement of expected credit losses
In order to measure the expected credit losses under collective approach, the Group uses the adjusted to IFRS 9
requirements the existing regulatory capital models (PD, LGD, EAD) developed for the Advanced Internal Ratings
Based (AIRB) approach. The models of risk parameters for the purpose of IFRS 9 follow the same structure as the
models for regulatory capital purposes, however the manner of estimating the specified value of PD, LGD and EAD is
adjusted to IFRS 9 requirements, in particular it includes reasonable and supportable information that is available
without undue cost or effort at the reporting date about past events, current conditions and forecast of future
economic conditions. The model’s parameters were calibrated in accordance with the “point-in-time” approach.
EAD parameter includes the repayment schedules in accordance with credit agreements.
The amount of the revaluation charge calculated collectively is based on the history of losses for asset portfolios
with similar credit risk characteristics. For the purposes of determining risk parameters, the Group uses over thirty
models for the needs of which exposures are classified into homogeneous groups with similar characteristics based
on different criteria (mainly product characteristics, e.g. loan duration, form of collateral and purpose of the loan,
and type of client and financing). Exposures from the retail banking segment are divided into mortgage and
consumer. Corporate banking exposures are grouped mainly by customer size (e.g. small and medium-sized
enterprises, corporations), customer type (e.g. financial institutions), loan application (e.g. real estate financing,
project financing) and product.
The Group measures the lifetime expected credit losses LEL (Lifetime Expected Loss) on exposures without
impairment recognised as the discounted sum of partial losses during the life of the exposure, relating to the events
of default in each 12-month period remaining to the maturity date of the exposure, taking into account the weights
of the scenarios
For credit exposures classified to Stage 1, a 12-month expected credit loss is applied.
For credit exposures in default at Stage 3 and for which the collective provision is computed, the Group measured
the lifetime expected credit losses.
The time value of money was reflected in expected credit losses by two discount factors:
• The discount factor between the moment of default and the moment of debt recovery. It is used for the
parameters of the regulatory LGD models.
• Discounting between the reporting date and the moment the exposure becomes in default which is partly taken
into account in calculating the lifetime expected loss LEL. The Group assumes that for each time window of 12
months the event of default occurs on average in the middle of the period 0-12 months.
The Group measures the expected credit losses as the probability weighted average of the few macroeconomic
scenarios (mostly three: a baseline, negative and positive scenario) with different probability to occur. The expected
loss is determined separately for each scenario and the probability weighted average results from the weights
(probabilities) assigned to each scenario (sum of weights = 100%). Such approach fulfils IFRS 9 requirements that
the impairment for expected credit losses should reflect an unbiased and probability-weighted amount that
is determined based on a number of possible outcomes.
Weightings of scenarios result directly from macroeconomic assumptions made. The Group has chosen for the 90th
percentile of macroeconomic factors distribution as a downside scenario because it corresponds the assumptions
of other calculations in the Group related to risk appetite, which use 90% confidence level (e.g. RWA at risk) and
10th percentile for positive scenario as a mirror approach. 90th and 10th percentile of the distribution imply directly
the probabilities of realization of these scenarios – both have statistically a 20% probability of realization.
Consequently, the baseline scenario is a supplement of these extreme scenarios and it has 60% probability
weighting.
The forecast (measurement) of the expected loss is conducted at each point in time in the future depending on the
expected future economic conditions at a given point. Based on the data about past events, the Group determined
the relation between the observable parameters of expected loss (PD, LGD) and macroeconomic factors
as functions, based on which – at predicted macroeconomic factors – Group computes the predicted parameter

36 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

values of expected loss in a given year in the future in accordance with forward looking “point in time” approach.
The impact of macroeconomic factors on expected credit losses is ensured in the Group by including them in the
modelling of particular risk parameters, which enables appropriate selection of factors specific for a given
parameter and portfolio type. Selection of appropriate macroeconomic factors constitutes a part of model building
process and includes several stages, both expert based that guarantee an economically interpretable relation
as well as statistical approach which enables the assessment of their significance and power of relations. The
assessment of the adequacy of the impact of macroeconomic factors is part of the overall assessment of the
models for determining impairment for expected credit losses as part of the model monitoring performed by the
Group.
For the purpose of measurement of the expected credit loss, the Group determines the level of EAD exposures only
for irrevocable loan commitments through the use of CCF conversion factors (the range of utilization of the
undrawn loan commitment during a period from the reporting date till the default event) from regulatory EAD
models (estimated in accordance with “through the cycle” approach). EAD decreases during the time according
to payment schedule of the particular credit exposure.
For exposures with a specified final repayment date, the time to maturity is equal to the final repayment date.
If the final repayment date exceeds 30 years, the expected loss calculation period is limited to 30 years.
For the financial exposures without maturity payment date (e.g.: some revolving credit facilities and credit cards)
the expected lifetime is determined by the statistical behavioural parameter.
The LGD parameter, which is a function of used techniques for mitigation of credit risk and it is expressed
as percentage of EAD, it is estimated on a product and exposure level based on the parameters of the regulatory
LGD models (estimated according to “through the cycle” approach) which were properly calibrated for the purpose
of IFRS 9. Collateral recoveries are an integral part of the construction of LGD models and, as a rule, the criteria for
recognizing collateral are consistent with the CRR requirements. The most important collaterals recognized by the
Group include mortgage collaterals (residential and commercial) as well as guarantees and sureties.
The level of LGD which is used for the estimation of the amount of the impairment loss according to the collective
method for defaulted exposures (PD = 100%), depends on the period during which the exposure was identified
as defaulted. In addition, for corporate clients segment in the field of large and medium-sized companies, the value
of the LGD parameter is 100% after at least 78 months of the exposure being in default. In a similar way, regarding
the retail clients segment and entrepreneurs, the value of the LGD parameter is set to 100% if one of the following
conditions is met;
• the impairment event took place and the objective evidences of the impairment occurs continuously for 47
months from the date of recognition of impairment in relation to entrepreneurs,
• defaulted exposures that belong to the impaired portfolio (POCI),
• the exposures were assessed as credit fraud, i.e. they were registered as a suspicion of credit fraud or reported
as a notification of a suspected crime.
13.12. Purchased or created financial assets impaired due to credit risk
The Group recognises as a separate category financial assets purchased or originated that are credit-impaired
at the moment of initial recognition (Purchased and originated credit-impaired financial assets, POCI).
Such assets may be recognised due to following reasons:
• purchase of credit impaired financial assets,
• significant modification (described in item 13.5.) due to derecognition of original loan or
• origination of new credit exposure for the client for which other exposures were classified to Stage 3.
Those assets are excluded from the three stage approach described in item 13.11.
The change in the cumulated lifetime expected credit losses, both positive and negative, is recognised
as impairment gain or loss in profit or loss.
14. Property, plant and equipment and intangible assets
14.1. Property, plant and equipment
Own property, plant and equipment
Property, plant and equipment consist of controlled non-current assets and costs to construct such assets. Non-
current assets include property, plant and equipment items with an expected period of use above one year,
maintained to be used to serve the Bank’s needs or to be transferred to other entities, based on the lease contract
or for administrative purposes.
Property, plant and equipment, with the exception of land and buildings, are recorded at purchase price
or production cost i.e. after initial recognition they are recorded at historical cost less depreciation and impairment.
The historical costs are made up of the purchase price/production cost and the costs directly related to the
purchase of assets.
Each component part of property, plant and equipment items, whose purchase price or production cost is material
in comparison with the purchase price or production cost of the entire item, is depreciated separately. The Group
allocates the initial value of the property, plant and equipment into its significant parts.
Land and buildings are carried in accordance with the revaluation model, after initial recognition at a revalued
amount, being its fair value at the date of the revaluation less any subsequent accumulated depreciation and
subsequent accumulated impairment losses. Revaluations are made with sufficient regularity to ensure that the

37 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

carrying amount does not differ materially from that which would be determined using fair value at the balance
sheet date.
The revaluation effect is reflected in other comprehensive income in case of the value increase, or carried through
the income statement in case of the balance sheet asset’s value decrease. However, the increase of value
is recognised as income statement insofar as it reverses the decrease of value due to revaluation of the same asset
that was previously recognised as costs of a given period. Similarly, the decrease of the asset’s value resulting from
revaluation shall be set off against the relevant surplus resulting from the previous revaluation of the same asset.
The entire revaluation surplus is carried through retained earnings at the time of withdrawing from use or selling
the asset item.
Fixed assets in leasing
The Group is a party to lease contracts, under which it receives the right to control the use of an identified asset for
a given period in exchange for remuneration. The Group applies IFRS 16 to all lease agreements, except for all lease
agreements for intangible assets and exemptions provided for in the standard and described below.
The Group identifies leasing and non-leasing components in concluded contracts. Non-lease payments under
contracts are recognised as an expense in accordance with relevant IFRS. Lease payments are recorded
in accordance with the rules described below.
At the date of commencement of the lease, the Group recognizes assets due to the right to use the assets. The
initial valuation of the lease liability is determined by the Group at the present value of future lease payments.
Identifying future lease payments requires a lease period to be determined. When determining the lease period,
the Group takes into account the irrevocable lease period together with the periods for which the lease can
be extended and the periods in which the lease can be terminated. In order to make an assessment, the Group
takes into account all relevant facts and circumstances that create an economic incentive to use or not to use
these options. At the start of the lease contract, the Group assesses whether it can be assumed with sufficient
certainty that it will benefit the option to extend the lease, or that it will not use the option to terminate the lease.
The Group reviews the lease period in order to reassess significant events or circumstances that may affect the
estimated length of the lease period. Leasing ceases to be enforceable if both the lessee and the lessor have the
right to terminate the lease without the other party's permission, which results in a slight penalty, at the most. For
lease contracts concluded for an indefinite period, in which there is a two-sided notice and potentially high costs
related to the termination of the contract, the Group estimates the lease period.
To determine the discounted value of lease payments, the Group uses the leasing interest rate, and if the rate is not
easily available, the Group uses the marginal interest rate. The Group determines the leasing interest rate as the
sum of swap interest rate and internal transfer price, taking into account currencies in which lease contracts and
contract maturities are denominated. After the lease commencement date, the carrying amount of the liability:
• increased by accrued leasing interest, which is recognised in the income statement and losses as interest
expenses,
• less lease payments paid,
• updated as a result of reassessment, changes in leasing or changes in essentially fixed leasing fees.
At the commencement date of the lease, the Group recognizes assets due to the right to use equal to the initial
measurement of the lease liability. The cost of an asset due to the right of use also includes:
• fees paid on the date of commencement or before the date of commencement of the lease, less leasing
incentives received,
• initial direct costs incurred by the lessee,
• costs to be borne by the lessee in connection with bringing the asset to its original condition.
The right to use is depreciated over the duration of the lease and is reduced for impairment losses. The value of the
right to use is updated during the lease period as a result of modifications of the lease agreement.
The Group uses the exemption for:
• short-term leases – a contract may be classified as a short-term contract if the duration of the contract does not
exceed 12 months and a purchase option is not provided for the subject of the contract,
• leases in which the subject of the contract has a low value – assets may be classified as low-value assets if the
gross purchase price of the new component does not exceed EUR 5,000 and the subject of the contract is not and
will not be sub-leased.
Lease payments under the above mentioned contracts are recognised by the Group as costs in the income
statement in a systematic manner throughout the duration of the lease.
14.2. Intangible assets
An intangible asset is an identifiable non-monetary asset without physical substance.
Intangible assets are deemed to include assets which fulfil the following requirements:
• they can be separated from an economic entity and sold, transferred, licensed or granted for use for a fee
to third parties, both separately, and together with their accompanying contracts, assets or liabilities,
• arise from contractual titles or other legal titles, irrespective of whether those are transferable or separable from
the business entity or from other rights and obligations.

38 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Goodwill
Goodwill arising on acquisition of an entity is recognised at the acquisition price being the surplus of the aggregate
of:
• provided payment,
• sums of all non-controlling interest in the acquired entity, and
• in the case of combining entities executed measured at fair value as at the day of acquiring interest in the capital
of the acquired entity, previously belonging to the acquiring entity,
over the net amount determined as at the day of acquiring values of the identifiable acquired assets and assumed
liabilities. After the initial recognition, the goodwill is recognised at acquisition price less any accumulated
impairment losses.
Computer software
Purchased computer software licences are capitalised in the amount of costs incurred for the purchase and
adaptation for use of specific computer software.
Expenditures attached to the development or maintenance of computer software are recognised as costs when
incurred.
Other intangible assets
Other intangible assets purchased by the Group, are recognised at purchase price or production cost less
amortization and total amount of impairment losses.
Subsequent costs
Subsequent costs incurred after initial recognition of acquired intangible asset are capitalised only if the following
conditions are met:
• it is likely that the outlays (taking into account the new version of the software) will result in a significant increase
in functionality in relation to the originally assessed performance standard, and
• these costs can be reliably measured and attributed to internally used existing software.
In other cases, costs are recognised in the income statement in the reporting period in which they were incurred.
14.3. Depreciation and amortization charges
The depreciation/amortization charge of property, plant and equipment and intangible assets is applied using the
straight line method, using defined depreciation/amortization rates throughout the period of their useful lives. The
depreciable/amortisable amount is the purchase price or production cost of an asset, less its residual value. The
useful life, depreciation/amortization rates and residual values of property, plant and equipment and intangible
assets are reviewed annually. Conclusions of the review may lead to a change of depreciation/amortization periods
recognised prospectively from the date of application (the effect of this change is in accordance with IAS 8 carried
through income statement).
In case of buildings measured at fair value, the accumulated depreciation balance at the revaluation date
is removed from the carrying amount gross, and the net carrying amount is adjusted to the revalued amount.
Depreciation and amortization charges are recognised in the income statement. At each balance sheet date
goodwill and other intangible assets with indefinite useful life are regularly tested for impairment. The depreciation/
amortization periods are as follows:
• lands and buildings 50 years
• investments in external fixed assets period of rental, lease, leasing, no longer than 10 years
• devices 3 to 7 years
• equipment 5 years
• costs of development of software 3 years
• software licenses 3 years.

39 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

14.4. Impairment of other non-financial assets
For each balance sheet date, the Group assesses the existence of objective triggers for impairment of an asset.
If such a trigger exists, the Group performs an estimation of the recoverable value. If, and only if, the recoverable
amount of an asset is less than its carrying amount, the carrying amount of the asset shall be reduced to its
recoverable amount.
As regards company goodwill, it is tested for impairment as at the balance sheet date regardless of whether or not
there are triggers for impairment in place.
Recognition of impairment loss
If there are triggers for impairment of common property, i.e. the assets which do not generate cash independently
from other assets or groups of assets, and the recoverable amount of the individual asset included among common
property cannot be determined, the Group determines the recoverable amount at the level of the cash-generating
unit, to which the given asset belongs. An impairment loss is recognised if the book value of the asset or cash-
generating unit exceeds its recoverable amount. The goodwill impairment is determined by estimating the
recoverable amount of the cash-generating unit the given goodwill applies to. Should the recoverable amount
of the cash-generating unit be lower than the carrying amount, impairment loss is made.
The impairment loss is recognised in the income statement under General and administrative expenses. Impairment
losses for cash-generating units reduce the goodwill of the cash-generating units (group of units) in the first place
and then reduce proportionally the book value of other assets in the unit (group of units).
Reversing impairment loss
Goodwill impairment loss is not subject to reversal.
An impairment loss of an asset other than goodwill is reversed if, and only if, there has been a change in the
estimates used to determine the asset’s recoverable amount.
An impairment loss can be reversed only up to the amount, at which the book value of impaired asset does not
exceed its book value, which decreased by depreciation/amortization charge, would be established, if any
impairment loss had not been recognised.
15. Other financial assets
Other financial assets include trade receivables and other receivables.
The Group introduced the simplified approach regarding to measurement of the impairment for expected credit
losses and recognise the impairment at an amount equal to lifetime expected credit losses.
In justified cases, and in particular when receivables due to shortages and damages, claims are contested by
debtors and other receivables for which the Group assesses the risk of non-recovery as high, revaluation write-
downs are made immediately after such assessment is confirmed. In other cases, trade receivables are subject
to impairment write-downs after reaching a certain overdue threshold.
If the effect of the time value of money is material, the value of receivable is determined by discounting the
expected future cash flows to the present value, applying the discount rate that reflects the current market
assessments of time value of money.
Budgetary receivables are recognised as part of other financial assets, except for corporate income tax receivables,
which are a separate item in the statement of financial position.
16. Provisions
Provisions, including provisions for off-balance sheet items, are recognised in the statement of financial position
when the Group has a legal or constructive obligation as a result of past events and it is probable that an outflow
of resources will be required to settle the obligation. If the effect is material, the amount of provision is measured
by discounted, expected cash flows using pre-tax rate that reflects current market assessments of the time value
of money and those risks specific to the liability. This is also applicable to the recognition of provisions for risk-
bearing off-balance sheet items including non-financial guarantees, letters of credit and irrevocable unutilised
credit lines.
Provisions for irrevocable unused credit lines for corporate exposures are recognized in the income statement under
the item Impairment for expected credit losses.
The Group establishes provisions for restructuring costs only when the general criteria of recognising provisions
under IAS 37 are met and in particular but not limited to the situation when the Group is in possession of a formal
restructuring plan determining at least the operations or part thereof, basic locations, place of employment, the
functions and estimated number of employees entitled to compensation, the expenditure to be undertaken and
the term of execution. The commencement of restructuring procedure or the public announcement thereof
is a condition indispensable for establishing the provision. The established provisions comprise only the direct and
necessary expenditures to be undertaken due to the restructuring procedure, which are not related to the current
business operations nor cover the future operating costs.
The Group creates provisions for legal risk on an individual or portfolio basis:
• in an individual approach, the Group creates provisions for liabilities resulting from court cases and other legal
claims if the probability of an outflow of resources to settle the obligation is higher than 50%.
• in the case of a larger population of similar court cases or other legal claims, the probability of an outflow
of resources to meet the Group's obligation is measured on a portfolio basis, taking into account the group

40 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

of obligations as a whole, and the provision is estimated using the expected value method as a probability
weighted average of a few scenarios (most often three: baseline, positive and negative) with different
probabilities assigned to each scenario.
The Group applies the above principles to legal claims that do not affect cash flows from financial assets recognised
in the statement of financial position – in this case the Group applies IFRS 9, as described in item 13.6.
If the legal claim relates to a financial asset that has been excluded from the statement of financial position
(e.g.repaid), provision is created on the basis of IAS 37.
17. Employee benefits
17.1. Benefits under the Act on employee pension programmes
Expenses incurred due to a programme of certain contributions are recognised as costs in the income statement.
17.2. Short-term employee benefits
Short-term employee benefits of the Group (other than termination benefits) comprise of remuneration, bonus,
paid annual leave and social security contributions.
The Group recognizes the anticipated, undiscounted value of short-term employee benefits as an expense
of an accounting period when an employee rendered service (regardless of payment date) in correspondence with
other on-balance liabilities.
The amount of short-term employee benefits on the unused holidays to which Group employees are entitled
is calculated as the total of unused holidays to which particular Group employees are entitled.
17.3. Long-term employee benefits
17.3.1. Benefits under the Labour Code regulations
Provisions for retirement benefits granted under benefits due to regulations of the Labour Code are estimated
on the basis of the actuarial valuation. The provision resulting from actuarial valuation is recognised in Accumulated
other comprehensive income and revalued on an annual basis.
Provisions for long-term employee benefits are recognised in the item Provisions in the statement of financial
position in correspondence with salary costs in the statement of profit or loss.
A description of the assumptions of the method of calculating the provision for retirement and disability severance
pays is included in note 32. Provisions.
17.3.2. Variable remuneration programme benefits
Variable remuneration benefits to employees that are to be settled in cash are recognised as an expense during the
performance period with a corresponding entry of a liability towards employees.
The share-based payment components that are to be settled in cash are recognised as an expense and liability
during the performance period (the year for which the employee receives the benefits) based on the benefit’s fair
value. The fair value is remeasured every balance sheet date until the settlement with the employee, with changes
in the fair value recognised as gains or losses in the statement of profit or loss.
The share-based payment components that are to be settled in shares are recognised as an expense during the
performance period based on the fair value. The corresponding entry is in equity. The fair value is remeasured
at grant date and any changes are recognised in equity.
The fair value of the share-based payment components is determined with reference to the share price and the
present value of estimated dividend payments during the deferral period.
18. Equity
Equity includes: share capital, supplementary capital from the sale of shares above their nominal value,
accumulated other comprehensive income, retained earnings and own shares for the purposes of the employee
incentive scheme. All amounts of equity and funds are presented at nominal value.
Share capital
Share capital is presented at nominal value, in accordance with the Articles of Association (the company’s charter)
and entry into the commercial register of the National Court Register.
Dividends
Dividends for the financial year which have been approved by the General Shareholders’ Meeting, but not paid
at the balance sheet date are disclosed under Dividend liabilities in the item Other liabilities.
Share premium
Share premium is formed from agio obtained from the issue of shares reduced by the attributable direct costs
incurred with that issue.
Accumulated other comprehensive income
Accumulated other comprehensive income is created as a result of:
• valuation of financial instruments classified for measurement measured at fair value through other
comprehensive income,
• valuation of derivatives for the element being the effective cash flow hedge,
• valuation of non-current assets measured at fair value,
• actuarial gains and losses.

41 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The deferred tax assets and liabilities resulting from above mentioned valuations are included in the accumulated
other comprehensive income. The accumulated other comprehensive income is not subject to profit distribution.
Retained earnings
Retained earnings are created from profit write-offs and are allocated for purposes specified in the Articles
of Association or other legal regulations. Retained earnings comprise of:
• other supplementary capital,
• other reserve capital,
• general banking risk fund,
• valuation of share-based payments,
• undistributed result from previous years,
• net result attributable to Parent entity.
Other supplementary capital, other reserve capital and general banking risk fund are created from profit write-offs
and are allocated for purposes specified in the Articles of Association or other legal regulations.
General banking risk fund is created in accordance with the Banking Law Act of 29 August 1997 as amended, from
profit after tax.
The net financial result attributable to the Parent entity represents the gross result under the statement of profit
or loss for the current year, adjusted with the corporate income tax and the result attributable to the minority
shares.
Own shares for the purposes of the incentive program
The Group purchases its own shares in order to fulfil the obligations arising from the incentive scheme, variable
remuneration components on the principles described in point 17.3.2. Variable remuneration programme benefits.
19. Income tax
Income tax is recognised as current and deferred tax. Current income tax is recognised in the income statement.
Deferred income tax is recognised in the income statement or equity depending on the type of temporary
differences.
19.1. Income tax
Current tax is a liability calculated based on taxable income at the prevailing tax rate at the balance sheet date
including adjustments of previous years’ tax liability.
19.2. Deferred income tax
The Group creates a provision for deferred tax in respect of a timing difference caused by different moment
of recognising income as generated and costs as incurred in accordance with the accounting regulations corporate
income tax provisions. A positive temporary net difference is recognised in liabilities as Deferred tax provisions.
A negative temporary net difference is recognised under Deferred tax assets.
The deferred tax provision is created by using the balance sheet method for all positive timing differences as at the
balance sheet date arising between tax value of assets and liabilities and their carrying amount disclosed in the
financial statements, except for situations where deferred tax provision arises from:
• initial recognition of goodwill,
• goodwill the amortization of which is not a tax deductible expense,
• initial recognition of an asset or liability under a transaction which does not constitute a business combination
and which on its origination has no impact on the gross financial result or taxable income or loss,
• at the time of the transaction, does not give rise to equal taxable and deductible temporary differences.
Deferred tax assets are recognised with respect to all negative timing differences as at the balance sheet date
between the tax value of assets and liabilities and their carrying amount disclosed in the financial statements and
unused tax losses. Deferred tax assets are recognised in such amount in which taxable income is likely to be earned
allowing to set off negative timing differences, except for the situations when the component of deferred tax assets
arises from the initial recognition of an asset or liability with a transaction which does not constitute a business
combination and on its origination have no impact on the gross financial result or taxable income or loss and at the
time of the transaction does not give rise to equal taxable and deductible temporary differences.
The carrying amount of a deferred tax asset shall be verified for each balance sheet date and reduced if it is no
longer likely to achieve taxable income sufficient for a partial or full realization of the deferred tax assets
component.
Deferred tax assets and deferred tax provisions are estimated with the use of the tax rates which are expected
to be in force when the asset is realised or provision released, assuming the tax rates (and tax provisions) legally
or factually in force as at the balance sheet date.
Income tax pertaining to items directly recognised in equity is recognised in equity.
Deferred tax assets and provisions are recognised by the Group in the statement of financial position after
offsetting at the level of each entity subject to consolidation. The Group offsets deferred tax assets and deferred tax
provisions, where it has legal title to effect such offsetting, and the deferred assets and provisions pertain to the
same taxpayer.

42 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

IV. Notes to the consolidated financial statements
1. Segment reporting
Segments of operation
The management of the Group’s activity is conducted within the areas defined in the Group’s business model.
The Group’s business model, above all for the purpose of management reporting, includes division of clients into
two main segments:
• retail banking segment,
• corporate banking segment.
The basis for distinguishing individual segments are entity criteria and - in the case of division into sub-segments -
financial criteria (especially turnover, level of collected assets). The specific rules of assigning clients to respective
segments are governed by the clients segmentation criteria specified in the Group’s internal regulations.
The Group has separated in organisational terms the operations performed by the Centre of Expertise Treasury. The
Centre of Expertise Treasury manages short-term and long-term liquidity risk in line with the effective regulations
and risk appetite internally set at the Group, manages interest rate risk and invests surpluses obtained from
business lines while maintaining the liquidity buffer in the form of liquid assets. The Centre of Expertise Treasury’s
net income on operations is allocated to the business lines considering its support function for the Group’s business
lines.
Retail banking segment
Within the framework of retail banking, the Group provides services to private individuals - the mass client segment
and wealthy clients segment. This activity is analyzed in terms of the main products, including: loan products
(overdraft facilities, card-related loans, installment loans, mortgage loans), deposit products (current accounts,
term deposits, savings accounts), structured, fund participation units, brokerage services and bank cards.
Corporate banking segment
Corporate banking area encompasses as follows
• providing services to institutional clients,
• providing services to individual entrepreneurs,
• financial Markets products.
Services to institutional clients encompass strategic clients, large corporate entities and mid-sized companies.
For corporate activity, the Bank provides reporting broken down by leading products covering i.e. loan products
(working loans, investment loans), deposit products (current accounts, term deposits and negotiated deposits,
savings accounts), financial markets products, trust services, capital market operations conducted by the Parent
company, products related to leasing and factoring services offered by ING Lease (Polska) Sp. z o.o. and
ING Commercial Finance Polska S.A.
The service of individual entrepreneurs includes natural persons conducting business activity and partner
companies that do not keep full accounting in accordance with the provisions of the Act on accounting, civil
partnerships or general partnerships whose partners are only natural persons who do not keep full accounting
in accordance with the provisions of the Accounting Act, and housing communities. The activity of entrepreneurs
is reported in terms of the main products, including credit products (cash loan, credit line, credit card), deposit
products (company account, foreign currency account, account for housing communities), leasing products offered
by ING Lease (Polska) Sp. z o.o., accounting services, terminals and payment gateways.
Financial markets products encompass operations performed in money and capital markets, conducted both on the
proprietary basis as well as for the customers’ benefit. Within the framework of this activity, currency, money and
derivative instrument market products and securities operations (treasury securities, shares and notes) are
specified.
Measurement
The measurement of the segment’s assets and liabilities, segment’s revenue and costs is based on the accounting
standards applied by the Group, included in notes describing applied accounting standards. In particular, both
internal and external interest income and costs for individual segments are determined with the use of the transfer
price system within the Risk Transfer System (RTS). Transfer prices are defined based on the yield curve for a given
currency that is common for assets and liabilities. The transfer price that is determined for the products being
assets and liabilities with the same position on the yield curve is identical. The original transfer price – coming from
the product measurement regarding the yield curve can be modified and the factors adjusting the transfer price
can be the following: a premium for obtaining long-term liquidity, matching of the Group’s position, a hedging cost
for sophisticated products and the pricing policy. Thereafter, based on quotation rates available at news services,
yield curves are developed using mathematical equations. Revenue, costs, results, assets and liabilities for a given
segment account for elements that are directly attributable to the segment in question, as well as element that
may be attributed to that segment based on reasonable premises. The Group presents segment's interest income
reduced by the cost of the interest.
Geographic segments
The Group pursues business within the territory of the Republic of Poland.

43 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Income statement by segments

for the year ended 31 December
| 2025 | 2024
Retail banking | Corporate banking | Total | Retail banking | Corporate banking | Total
Income total | 5,277 | 6,528 | 11,805 | 4,901 | 6,345 | 11,246
net interest income | 4,354 | 4,517 | 8,871 | 4,153 | 4,572 | 8,725
net commission income, including: | 718 | 1,641 | 2,359 | 671 | 1,623 | 2,294
commission income, including: | 1,098 | 1,889 | 2,987 | 1,026 | 1,861 | 2,887
transaction margin on currency exchange | 84 | 630 | 714 | 83 | 634 | 717
transactions account maintenance fees | 111 | 403 | 514 | 113 | 371 | 484
lending commissions | 23 | 478 | 501 | 23 | 479 | 502
payment and credit cards fees | 474 | 196 | 670 | 460 | 187 | 647
participation units distribution fees | 130 | - | 130 | 95 | - | 95
insurance product offering commissions | 223 | 41 | 264 | 205 | 39 | 244
factoring and lease contracts commissions | - | 59 | 59 | - | 61 | 61
other commissions | 53 | 82 | 135 | 47 | 90 | 137
commission expenses | -380 | -248 | -628 | -355 | -238 | -593
other income/expenses | 205 | 370 | 575 | 77 | 150 | 227
General and administrative expenses | -2,178 | -2,106 | -4,284 | -1,978 | -1,980 | -3,958
including depreciation and amortisation | -180 | -142 | -322 | -181 | -159 | -340
Segment operating result | 3,099 | 4,422 | 7,521 | 2,923 | 4,365 | 7,288
impairment for expected credit losses | -105 | -677 | -782 | -29 | -915 | -944
cost of legal risk of FX mortgage loans | -60 | - | -60 | -92 | - | -92
tax on certain financial institutions | -326 | -475 | -801 | -303 | -437 | -740
share of profit/(loss) of associates measured by the equity method | 49 | - | 49 | 33 | - | 33
Gross profit | 2,657 | 3,270 | 5,927 | 2,532 | 3,013 | 5,545
Income tax | - | - | -1,294 | - | - | -1,176
Net profit | - | - | 4,633 | - | - | 4,369
attributable to shareholders of ING Bank Śląski S.A. | - | - | 4,633 | - | - | 4,369

Assets, liabilities, and net cash flow by segments

as at 31 December |  |  |  |  |  |
| 2025 | 2024
Retail banking | Corporate banking | Total | Retail banking | Corporate banking | Total
Assets of the segment | 126,886 | 152,879 | 279,765 | 113,011 | 145,065 | 258,076
Segment investments in associates accounted for using the equity method | 204 | - | 204 | 185 | - | 185
Other assets (not allocated to segments) | - | - | 2,056 | - | - | 2,098
Total Assets | 127,090 | 152,879 | 282,025 | 113,196 | 145,065 | 260,359
Segment liabilities | 145,028 | 110,404 | 255,432 | 133,788 | 105,167 | 238,955
Other liabilities (not allocated to segments) | - | - | 5,251 | - | - | 4,234
Equity | - | - | 21,342 | - | - | 17,170
Total equity and liabilities | 145,028 | 110,404 | 282,025 | 133,788 | 105,167 | 260,359
Capital expenditure | 158 | 153 | 311 | 130 | 131 | 261
Net cash flow from operating activities | 926 | 1,137 | 2,063 | 4,089 | -2,659 | 1,430
Net cash flow from operating activities (not allocated to segments) | - | - | -803 | - | - | -1,721
Net cash flow from operating activities total | 926 | 1,137 | 1,260 | 4,089 | -2,659 | -291
Net cash flows from investing activities | -189 | -226 | -415 | 2,467 | 2,881 | 5,348
Net cash flows from financing activities | -22 | -1,874 | -1,896 | -6 | -3,731 | -3,737

44 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2. Net interest income

for the year ended 31 December |  |
| 2025 | 2024
Interest income, including: | 13,812 | 13,112
interest income calculated using effective interest rate method, including: | 13,297 | 12,365
interest on financial instruments measured at amortised cost | 11,343 | 10,611
interest on cash and cash equivalents | 432 | 453
interest on loans and other receivables to other banks | 530 | 774
interest on loans and other receivables to customers | 9,134 | 8,281
interest on investment securities | 1,247 | 1,103
interest on investment securities measured at fair value through other comprehensive income | 1,954 | 1,754
other interest income, including: | 515 | 747
interest income related to the settlement of valuations of cash flow hedging derivatives | 515 | 746
other interest on loans and other receivables to customers measured at fair value through profit or loss | - | 1
Interest expenses, including: | -4,941 | -4,387
interest on deposits from other banks | -604 | -789
interest on deposits from customers | -3,890 | -3,050
interest on issue of debt securities | -44 | -31
interest on subordinated liabilities | -66 | -80
interest on lease liabilities | -17 | -18
other interest cost related to the settlement of valuations of cash flow hedging derivatives | -320 | -419
Net interest income | 8,871 | 8,725

The interest costs presented in the table relate to financial liabilities measured at amortised cost.
For assets in Stage 3, interest income is calculated based on net exposure amounts, i.e. amounts that include
interest impairment for expected credit losses.
For 2025, interest income on financial assets in Stage 3 amounted to PLN 319 million compared to PLN 304 million
in 2024.
3. Net commission income

for the year ended 31 December |  |
| 2025 | 2024
Commission income | 2,987 | 2,887
transaction margin on currency exchange transactions | 714 | 717
account maintenance fees | 514 | 484
lending commissions | 501 | 502
payment and credit cards fees | 670 | 647
participation units distribution fees | 130 | 95
insurance product offering commissions | 264 | 244
factoring and lease contracts commissions | 59 | 61
brokerage activity fees | 58 | 52
fiduciary and custodian fees* | 6 | 21
agency in financial instruments transactions | 4 | 2
other commission | 67 | 62
related to assets / liabilities not measured at fair value through profit or loss | 3 | 7
other | 64 | 55
Commission expenses | -628 | -593
card fees paid | -357 | -336
commission paid on agency in selling deposit products | -105 | -89
brokerage activity fees | -21 | -19
commission paid on disclosing credit information | -23 | -23
commission paid on cash handling services | -27 | -26
electronic banking services fees | -17 | -18
commission paid on trading in securities | -10 | -12
costs of the National Clearing House (KIR) | -22 | -20
agency in financial instruments transactions | -4 | -7
leasing services | -4 | -4
other commission | -38 | -39
related to assets / liabilities not measured at fair value through profit or loss | -16 | -8
other | -22 | -31
Net commission income | 2,359 | 2,294

*) Fiduciary and custodian fees show the commissions earned on custody services, where the Group keeps
or invests assets for their clients.
In table Net commission income includes the following items relating to financial instruments that are not
measured at fair value through profit or loss and which have not been included in the calculation of the effective
interest rate:
• revenues in the total amount of PLN 563 million from granting loans, factoring and leasing services
(PLN 570 million in 2024),
• costs in the total amount of PLN 148 million for intermediation in the sale of deposit products, providing credit
information and leasing services (PLN 124 million in 2024).

45 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Revenues from contracts with customers within the meaning of IFRS 15 amounted to PLN 2,424 million in 2025
compared to PLN 2,317 million in 2024 and related entirely to commissions settled on a one-off basis.
4. Net income on financial instruments measured at fair value through profit or loss and FX result

for the year ended 31 December |  |
| 2025 | 2024
FX result and net income on interest rate derivatives, including | 410 | 205
FX result | 120 | 145
currency derivatives | 290 | 60
Net income on interest rate derivatives | 69 | -41
Net income on debt instruments held for trading | 32 | 20
Net income on repo transactions | 10 | 14
Total | 521 | 198

The result on derivatives includes the net result on trading and fair value measurement of interest rate instruments
(FRA, IRS/CIRS, cap options) and currency instruments (swaps, options).
The result on debt instruments includes the net result on trading in government securities and the result on the fair
value measurement of these instruments.
The result on repurchase agreements includes the unrealised result on the measurement and accrual of interest
elements of repo, reverse repo, buy-sell-back (BSB) and sell-buy-back (SBB) transactions measured at fair value
through profit or loss.
5. Net income on the sale of securities and dividend income

for the year ended 31 December |  |
| 2025 | 2024
Net income on the sale of securities measured at amortised cost | -4 | -6
Net income on sale of financial assets measured at fair value through other comprehensive income and dividend income, including: | 59 | -3
sale of debt securities | 51 | -11
dividend income | 8 | 8
Total | 55 | -9

Dividend income received in 2025 and 2024 comes from companies whose shares the Group kept as at
31 December 2025 and 31 December 2024, respectively, in its portfolio.
6. Net (loss)/income on hedge accounting

for the year ended 31 December |  |
| 2025 | 2024
Fair value hedge accounting for securities | 45 | 10
valuation of the hedged transaction | 483 | -163
valuation of the hedging transaction | -438 | 173
Cash flow hedge accounting | -60 | -
ineffectiveness under cash flow hedges | -60 | -
Total | -15 | 10

For details of the hedge accounting applied by the Group, refer to the subsequent part of the financial statements,
Risk and capital management section, in chapter II.3.8. Hedge accounting.
7. Net (loss)/income on other basic activities

for the year ended 31 December |  |
| 2025 | 2024
Sale of other services | 20 | 14
Net income on disposal of property, plant and equipment and intangible assets | - | -3
Banking activity-related compensations and losses | -16 | -10
Reversal of provisions for potential customer complaints | - | 10
Other | 10 | 17
Total | 14 | 28

46 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

8. General and administrative expenses

for the year ended 31 December |  |
| 2025 | 2024
Personnel expenses, including: | -2,125 | -2,031
wages and salaries, including: | -1,692 | -1,624
variable remuneration programme, including: | -56 | -45
concerning cash-settled shares | -26 | -21
concerning equity-settled shares | -30 | -24
retirement benefits | -12 | -11
employee benefits | -433 | -407
Cost of marketing and promotion | -220 | -189
Depreciation and amortisation, including: | -322 | -340
on property, plant and equipment | -232 | -235
including depreciation of the right to use | -109 | -119
on intangible assets | -90 | -105
Other general and administrative expenses, including: | -1,617 | -1,398
IT costs | -578 | -493
advisory and legal services, audit costs | -212 | -245
maintenance costs of buildings and real estate valuation to fair value | -148 | -160
obligatory contributions to the BFG for the compulsory restructuring fund | -174 | -151
obligatory contributions to the BFG for the bank guarantee fund | -100 | -
transport and representation costs | -60 | -52
communication costs | -53 | -40
fees to the Polish Financial Supervision Authority | -35 | -29
disputed claims | -33 | -26
costs from short-term leases and low-value leases | -15 | -14
donation | -8 | -10
other | -201 | -178
Total | -4,284 | -3,958

8.1. Employee benefits
Variable Remuneration Programme
Benefits are awarded to the employees covered with the Programme, based on their performance appraisal for
a given year. Variable remuneration programme benefits to persons holding managerial positions having a material
impact on the risk profile of the Group (in accordance with guidelines and Regulation on the risk management
system and internal control system, remuneration policy and a detailed method of capital estimation in banks have
been granted in one of two programmes:
• An equity-settled share-based payment and cash programme, which operates from mid-2022. In this pro-
gramme the benefit is granted in two parts:
• one - payable in a fixed monetary amount (not more than 50%), and
• the second one - granted as the rights to shares of ING Bank.
• A cash-settled share-based payment and cash programme, which operated until mid-2022. In this programme
the benefit is granted in two parts:
• one - payable in a fixed monetary amount (not more than 50%), and
• the second - paid in cash, the amount of which depends on the ING Bank Śląski share price (at least 50%);
payment in the form of shares settled in cash.
The vari able remuneration programme for any given performance year is settled over a period of up to six years
(the deferral period) in tranches. Furthermore, the components that are settled in shares and in cash are subject
to a one-year retention period after settlement.
The significant accounting principles applied to variable remuneration programme benefits are included in chapter
III. Significant accounting principles, in item 17.3.2. Variable Remuneration Programme benefits.
The tables show the instruments granted under share-based payment schemes.

47 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2025 |  |  |  |  |
| Fair value of instruments at the measurement date* (in PLN million) | Number of instruments granted (pcs.) | Number of instruments outstanding at the beginning of the period (pcs.) | Number of instruments exercised during 2025 (pcs.) | Number of instruments granted but not yet exercised as at 31 December 2025 (pcs.)
Equity-settled shares
Programme 2022 | 13 | 41,964 | 17,033 | 3,317 | 13,716
Programme 2023 | 21 | 64,428 | 64,428 | 35,775 | 28,653
Programme 2024 | 23 | 71,422 | 71,422 | - | 71,422
Programme 2025 | 18 | 57,124 | 57,124 | - | 57,124
Total | 75 | 234,938 | 210,007 | 39,092 | 170,915
Cash-settled shares
Programme 2017 | 26 | 67,029 | 401 | 401 | -
Programme 2018 | 28 | 72,137 | 428 | 214 | 214
Programme 2019 | 28 | 72,259 | 10,410 | 9,420 | 990
Programme 2020 | 25 | 63,806 | 17,530 | 8,282 | 9,248
Programme 2021 | 20 | 51,021 | 17,022 | 4,111 | 12,911
Programme 2022 | 15 | 37,577 | 15,265 | 2,967 | 12,298
Programme 2023 | - | 265 | 265 | 161 | 104
Programme 2024 | - | 338 | 338 | - | 338
Programme 2025 | - | 313 | 313 | - | 313
Total | 143 | 364,745 | 61,972 | 25,556 | 36,416

2024 |  |  |  |  |
| Fair value of instruments at the measurement date* (in PLN million) | Number of instruments granted (pcs.) | Number of instruments outstanding at the beginning of the period (pcs.) | Number of instruments exercised during 2024 (pcs.) | Number of instruments granted but not yet exercised as at 31 December 2024 (pcs.)
Equity-settled shares
Programme 2022 | 10 | 41,964 | 41,964 | 24,931 | 17,033
Programme 2023 | 16 | 64,428 | 64,428 | - | 64,428
Programme 2024** | 18 | 71,422 | 71,422 | - | 71,422
Total | 44 | 177,814 | 177,814 | 24,931 | 152,883
Cash-settled shares
Programme 2017 | 19 | 67,029 | 799 | 398 | 401
Programme 2018 | 20 | 72,137 | 9,874 | 9,446 | 428
Programme 2019 | 20 | 72,259 | 19,780 | 9,370 | 10,410
Programme 2020 | 18 | 63,806 | 25,779 | 8,249 | 17,530
Programme 2021 | 14 | 51,021 | 21,109 | 4,087 | 17,022
Programme 2022 | 11 | 37,577 | 37,577 | 22,312 | 15,265
Programme 2023 | - | 265 | 265 | - | 265
Programme 2024 | - | 338 | 338 | - | 338
Total | 102 | 364,432 | 115,521 | 53,862 | 61,659

*) For equities settled in equity instruments: the product of the number of instruments granted and the fair value
of shares calculated using the discounted dividend model. For cash-settled shares: the product of the number
of granted instruments and the median price of ING Bank Śląski S.A. shares from 10 January to 20 February in the
year following the assessment period
**) For the 2024 cash-settled programme, the value was adjusted for changes approved after the publication of the
annual consolidated financial statements for 2024.
9. Impairment for expected credit losses
Net impairment for expected credit losses

for the year ended 31 December |  |
| 2025 | 2024
Investment securities, including: | 1 | 4
measured at fair value through other comprehensive income | -2 | -
measured at amortised cost | 3 | 4
Loans and other receivables to customers measured at amortised cost*, including: | -749 | -959
corporate banking | -643 | -935
corporate and municipal debt securities | 2 | -2
retail banking | -106 | -24
Provisions for off-balance sheet liabilities | -34 | 11
Total | -782 | -944

*) The values presented in the item Loans and other receivables to customers measured at amortised cost include,
among others, the amounts of repayments regarding receivables previously removed from the balance sheet,
which in 2025 amounted to PLN 1 million compared to PLN 2 million in 2024.
Allowances on expected credit losses in the balance sheet

as at 31 December |  |
| 2025 | 2024
Investment securities, including: | 21 | 22
measured at fair value through other comprehensive income* | 14 | 12
measured at amortised cost | 7 | 10
Loans and other receivables to customers measured at amortised cost, including: | 4,154 | 3,955
corporate banking | 3,266 | 3,075
corporate and municipal debt securities | 2 | 4
retail banking | 888 | 880
Provisions for off-balance sheet liabilities | 139 | 105
Total | 4,314 | 4,082

*) In the case of financial assets measured at fair value through other comprehensive income, the carrying amount
is not reduced by the allowance for expected credit losses.

48 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

10. Cost of legal risk of FX mortgage loans

for the year ended 31 December |  |
| 2025 | 2024
Provisions for legal risk of FX indexed mortgage loans, including: |  |
relating to loans in the Bank's portfolio | -48 | -62
relating to repaid loans | -12 | -30
Total | -60 | -92

Detailed information on the legal risk of CHF-indexed mortgage loans is presented later in the report in note 32.
Provisions. Significant assumptions regarding the calculation of legal risk provisions for CHF-indexed mortgage loans
are described in chapter III. Significant accounting principles, in point 3.3. Legal risk related to the portfolio
of mortgage loans indexed to the Swiss franc exchange rate.
11. Tax on certain financial institutions
Under the Act on the Tax on Certain Financial Institutions (hereinafter referred to as the "Act"), banks are charged
a so-called bank tax amounting to 0.0366% of the value of its assets on a monthly basis. The basis for taxation
is the sum of assets after deductions provided for in the Act (i.a. by the value of PLN 4 billion, the value of own
funds, the value of Treasury securities, the value of assets in the form of securities legally covered by the Treasury
guarantee and the value of assets resulting from the repurchase transaction in which Treasury securities are
subject). For 2025 the tax amounted to PLN 801 million (PLN 740 million for 2024).
12. Income tax
Income tax recognised in the income statement

for the year ended 31 December |  |
| 2025 | 2024
Current tax, of which: | 1,256 | 781
current tax for the financial year | 1,254 | 779
tax on dividends | 2 | 2
Deferred tax, including: | 38 | 395
rise and reversal of temporary differences | 37 | -123
settlement of tax losses, including: | 1 | 518
tax losses - Bank | - | 516
tax loss - subsidiaries | 1 | 2
Total | 1,294 | 1,176

The amount presented in the item settlement of tax losses includes the settlement of the tax loss, incurred by the
subsidiary ING Bank Hipoteczny S.A., incurred in 2023.
Current tax for the financial year

for the year ended 31 December |  |
| 2025 | 2024
Current tax for the financial year included in the income statement | 1,254 | 779
Current tax for the financial year included in equity | 662 | 81
Total | 1,916 | 860

The Group has two sources of current tax, a tax calculated on the profit and loss account and a tax calculated
on the unrealised valuation of hedging instruments (IRS), recorded in other comprehensive income and pertaining
to instruments settled in accordance with the STM (settled-to-market) approach.
Current income tax assets / liabilities

as at 31 December |  |
| 2025 | 2024
Current income tax assets | 12 | 14
Current income tax liabilities | 924 | 16

Calculation of the effective tax rate

for the year ended 31 December |  |
| 2025 | 2024
A. Profit before tax | 5,927 | 5,545
B. 19% of profit before tax | 1,126 | 1,054
C. Increases - non-deductible expenses, including: | 277 | 245
tax on certain financial institutions | 152 | 140
prudential fee in favour of BGF | 52 | 29
impairment loss on receivables in a part not covered with the deferred tax | 27 | 38
reduction of deferred tax asset due to a tax adjustment of the CHF loan portfolio | 13 | -
provisions for legal risk related to the CHF loan portfolio and commission returns | 11 | 17
costs of derecognition of credit and non-credit receivables from the balance sheet | 5 | 7
provisions for disputable debt claims and other assets | 4 | 3
State Fund for Rehabilitation of Disabled Persons (PFRON) payments | 2 | 2
representation expenses | 1 | 1
other | 10 | 8
D. Decreases - tax exempt income, including: | 109 | 123
effect of revaluation of deferred tax at new CIT rates * | 68 | -
creation of deferred tax asset due to the forecasted research and development relief for the current year | 28 | 40
valuation using the equity method of subsidiaries | 9 | 7
research and development allowance settled for previous years | 4 | 51
creation of a deferred tax asset due to a tax adjustment of the CHF loan portfolio | - | 22
release of provisions for disputed claims | - | 3
E. Income tax from the income statement (B+C-D) | 1,294 | 1,176
Effective tax rate (E : A) | 21.83% | 21.21%

The Group does not expect the impact of the provisions of the Act of 6 November 2024 on equalisation taxation
of entities of international and domestic groups on tax liabilities in 2026. In 2025-2026, the Bank uses a statutory

49 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

solution for a temporary safe harbour CbCR (Country by Country Reporting) - the simplified effective tax rate
is higher than the simplified minimum tax rate.
The deviation in the effective tax rate above 19% in 2025 was mainly due to:
• increase, including:
• tax on certain financial institutions in the amount of PLN 801 million (PLN 740 million in 2024),
• a fees for the BFG in the amount of PLN 274 million (total contribution to the compulsory restructuring fund
and the bank guarantee fund, compared to PLN 151 million in 2024 (contribution to the resolution fund),
• creation of provisions for legal risk of mortgage loans in foreign currencies in the amount of PLN 57 million
(PLN 92 million in 2024)
• reductions, including:
• creation of a deferred tax asset for the forecasted research and development relief for 2025, based on the
amount of PLN 145 million,
• revaluation of deferred tax assets and liabilities using the new CIT rates, i.e. the 30% rate for temporary
differences that will settle in 2026, 26% rates for temporary differences that will settle in 2027 and 23% rates
for temporary differences that will settle in 2028 and subsequent years (amount 68 million).
13. Earnings and book value per ordinary share
Basic earnings per share
The calculation of basic earnings per share of the Parent Company is based on net profit attributable to the
shareholders of ING Bank Śląski S.A. and the weighted average number of ordinary shares outstanding at the end
of the year.

for the year ended 31 December |  |
| 2025 | 2024
Net profit attributable to shareholders of ING Bank Śląski S.A. | 4,633 | 4,369
Weighted average number of ordinary shares | 130,189,835 | 130,143,180
Earnings per ordinary share (in PLN) | 35.59 | 33.57

Diluted earnings per share
In 2025 as well as in 2024, there were no factors that would dilute the profit per one share. In the described periods,
ING Bank Śląski S.A. issued neither bonds convertible to shares nor options for shares. The share capital comprises
ordinary shares only (no preference shares). Therefore, the diluted earnings per share are the same as the
underlying profit per share.
Book value per share
The calculation of the book value per one share of the Parent Company is based on the amount of equity
attributable to the shareholders of ING Bank Śląski S.A. and the number of shares outstanding at the end of the
year.

as at 31 December |  |
| 2025 | 2024
Book value | 21,342 | 17,170
Number of shares | 130,100,000 | 130,100,000
Book value per share (PLN) | 164.04 | 131.98

14. Cash and cash equivalents

as at 31 December |  |
| 2025 | 2024
Cash in hand | 865 | 774
Balances with the Central Bank | 6,252 | 7,396
Balances on accounts with other banks, including: | 193 | 191
current accounts | 141 | 105
overnight deposits | 30 | 51
call margins posted | 22 | 35
Total | 7,310 | 8,361

R estricted cash and cash equivalents
The Group’s parent entity maintains on the current account with the National Bank of Poland the statutory reserve,
which at the end of 2025 amounted to 3.50% of the value of deposits received (similar to the end of 2024).
The arithmetic mean of the holdings of required reserves, which the Group’s parent entity is obliged to keep
on a current account with the National Bank of Poland, during a given period, was:
• PLN 8,271 million for the period from 8 December 2025 to 11 January 2026,
• PLN 7,602 million for the period from 31 December 2024 to 9 February 2025.
Holdings of statutory reserve funds on an overdraft account with the National Bank of Poland are remunerated
during the reserve period in the amount determined by the Monetary Policy Council. As at 31 December 2025,
the interest rate was 4.00% (5.75% as at 31 December 2024).
15. Loans and other receivables to other banks

as at 31 December |  |
| 2025 | 2024
Reverse repo transactions | 23,101 | 20,779
Loans and advances | 821 | 856
Interbank deposits (excluding overnight deposits) | 32 | -
Total (net) | 23,954 | 21,635

50 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Due to the very good credit quality of loans and other receivables granted to other banks and the related
insignificant level of the allowance for expected credit losses, the gross carrying amount of these assets is equal
to their net carrying amount. Disclosures on the credit quality of loans and other receivables granted to other banks
are presented later in the consolidated financial statements in Risk and capital management section, in chapter
II.2.9.6. Credit quality of other financial assets.
16. Financial assets measured at fair value through profit or loss

as at 31 December |  |  |  |
| 2025 | 2024
Total | Total, including: | transferred debt securities | other finnancial assets measured at fair value through profit or loss
Financial assets held for trading, including: | 2,332 | 2,105 | 179 | 1,926
valuation of derivatives | 818 | 898 | - | 898
other financial assets held for trading, including: | 1,514 | 1,207 | 179 | 1,028
debt securities: | 1,090 | 700 | 179 | 521
Treasury bonds in PLN | 976 | 678 | 179 | 499
Czech Treasury bonds in CZK | 114 | 22 | - | 22
repo transactions | 424 | 507 | - | 507
Financial assets other than those held for trading, measured at fair value through profit or loss, including: | 8 | 22 | - | 22
loans obligatorily measured at fair value through profit or loss | 7 | 21 | - | 21
equity instruments | 1 | 1 | - | 1
Total | 2,340 | 2,127 | 179 | 1,948

Detailed disclosures on the nominal values of derivative instruments and their valuation broken down into individual
types of derivative instruments along with the remaining dates for their implementation are presented in note
17. Valuation of derivatives.
Securities that can be pledged or sold by the collateral recipient are presented as transferred debt securities. These
assets, as required by IFRS 9, are presented separately by the Group in the consolidated statement of financial
position under Transferred assets. As at 31 December 2025, the Group did not hold such securities in the portfolio
of financial assets measured at fair value through profit or loss. For further information on assets pledged
as security for liabilities, see note 20.
17. Valuation of derivatives
The tables below present the nominal values of derivatives whose valuation is presented in financial assets
measured at fair value through profit or loss (positive valuation) and financial liabilities measured at fair value
through profit or loss (negative valuation) of the Group's statement of financial position. Notional amounts of the
same-currency transaction derivatives were presented in the amounts purchased, while two-currency transactions
showed both purchased and sold amounts. The fair value valuation of derivatives includes a valuation adjustment
for counterparty credit risk (CVA) and Group default (DVA).

as at 31 December 2025 |  |  |  |  |
| Fair value |
Assets | Liabilities | up to 1 year | over 1 year | Total
Interest rate derivatives, including: | 424 | 299 | 404,320 | 676,055 | 1,080,375
settled via CCP | 215 | 187 | 403,265 | 661,956 | 1,065,221
contracts for the future FRA interest rate - PLN | 10 | 10 | 137,561 | 16,410 | 153,971
contracts for the future FRA interest rate - CZK | - | - | 358 | - | 358
Interest rate swaps (IRS PLN) fixed - float | 372 | 242 | 237,234 | 595,562 | 832,796
Interest rate swaps (IRS EUR) fixed - float | 28 | 32 | 22,509 | 43,201 | 65,710
Interest rate swaps (IRS USD) fixed - float | - | - | 1,703 | 2,928 | 4,631
Interest rate swaps (IRS CZK) fixed - float | 9 | 9 | 2,708 | 15,212 | 17,920
Interest rate swaps (IRS GBP) fixed - float | - | 1 | 1,694 | 484 | 2,178
Interest rate swaps (IRS HUF) fixed - float | 1 | 1 | - | 55 | 55
CAP options - EUR | 1 | 1 | 553 | 943 | 1,496
CAP options - PLN | 3 | 3 | - | 1,260 | 1,260
Currency derivatives, including: | 393 | 199 | 56,956 | 12,585 | 69,541
currency contracts (swap, forward), including: | 345 | 101 | 51,452 | 3,932 | 55,384
currency contracts (swap, forward) EUR / PLN | 254 | 50 | 26,971 | 3,453 | 30,424
currency contracts (swap, forward) USD / PLN | 71 | 21 | 16,681 | 19 | 16,700
currency contracts (swap, forward) EUR / USD | 2 | 13 | 3,537 | - | 3,537
currency contracts - other currency pairs | 18 | 17 | 4,263 | 460 | 4,723
CIRS, inluding: | 48 | 98 | 5,504 | 8,653 | 14,157
CIRS EUR/PLN (float-float) | 48 | 9 | 5,048 | 6,296 | 11,344
CIRS EUR/PLN (float-fixed) | - | 89 | 456 | 2,357 | 2,813
Current off-balance sheet transactions, including: | 1 | - | 25,564 | - | 25,564
foreign exchange operations | 1 | - | 915 | - | 915
operations in securities | - | - | 24,649 | - | 24,649
Total | 818 | 498 | 486,840 | 688,640 | 1,175,480

51 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December 2024 |  |  |  |  |
| Fair value |
Assets | Liabilities | up to 1 year | over 1 year | Total
Interest rate derivatives, including: | 244 | 431 | 382,059 | 592,220 | 974,279
settled via CCP | 145 | 135 | 380,399 | 581,887 | 962,286
contracts for the future FRA interest rate - PLN | 5 | 6 | 142,772 | 5,406 | 148,178
Interest rate swaps (IRS PLN) fixed - float | 179 | 350 | 202,316 | 526,609 | 728,925
Interest rate swaps (IRS EUR) fixed - float | 49 | 60 | 27,946 | 40,801 | 68,747
Interest rate swaps (IRS USD) fixed - float | 1 | 1 | 4,319 | 3,203 | 7,522
Interest rate swaps (IRS CZK) fixed - float | 1 | 2 | 1,642 | 13,938 | 15,580
Interest rate swaps (IRS GBP) fixed - float | - | 3 | 2,610 | 257 | 2,867
Interest rate swaps (IRS HUF) fixed - float | 1 | 1 | - | 52 | 52
Interest rate swaps (IRS CHF) fixed - float | - | - | 454 | - | 454
CAP options - EUR | 8 | 8 | - | 1,934 | 1,934
CAP options - PLN | - | - | - | 20 | 20
Currency derivatives, including: | 652 | 301 | 66,892 | 7,784 | 76,124
currency contracts (swap, forward), including: | 599 | 215 | 65,444 | 2,216 | 67,660
currency contracts (swap, forward) EUR / PLN | 314 | 81 | 35,031 | 1,338 | 36,369
currency contracts (swap, forward) USD / PLN | 30 | 86 | 13,580 | 43 | 13,623
currency contracts (swap, forward) EUR / USD | 192 | 5 | 9,237 | 398 | 9,635
currency contracts - other currency pairs | 63 | 43 | 7,596 | 437 | 8,033
CIRS, inluding: | 53 | 86 | 1,448 | 5,568 | 8,464
CIRS EUR/PLN (float-float) | 52 | 10 | 1,349 | 3,139 | 4,488
CIRS EUR/PLN (float-fixed) | 1 | 76 | 99 | 2,429 | 2,528
Current off-balance sheet transactions, including: | 2 | 1 | 24,439 | - | 24,439
foreign exchange operations | 2 | 1 | 1,687 | - | 1,687
operations in securities | - | - | 22,752 | - | 22,752
Total | 898 | 733 | 473,390 | 600,004 | 1,074,842

Interest rate derivatives IRS/FRA settled-to-market
IRS/FRA interest rate derivatives submitted for clearing via central counterparties/CCP are settled in accordance with
the "settlement-to-market" approach. Under the terms of the said service, the balance sheet exposure resulting
from the transaction is settled on a daily basis based on the change in the fair value of individual transactions. As a
result, no Variation Margin is placed. The carrying amount of individual transactions includes cash flows realised as
part of the daily settlement of exposures arising therefrom, including cash flows resulting from the settlement of
the price alignment amount, which ensures the economic equivalence of the applied approach to the
"collateralized-to-market" approach.
18. Derivative hedging instruments
In the consolidated financial statements prepared for 2025 (similarly to 2024), the Group applies fair value hedge
accounting and cash flow hedge accounting. The table below presents the valuation of hedging instruments,
broken down into instruments securing the fair value of securities and cash flow hedging instruments. The valuation
of hedging instruments is presented in the item Derivative hedge instruments in assets (positive valuation) and
liabilities (negative valuation) of the consolidated statement of financial position of the Group.

as at 31 December |  |  |  |
| 2025 | 2024
Assets | Liabilities | Assets | Liabilities
Cash flow hedging instruments | 73 | 65 | 61 | 72
Instruments hedging the fair value of securities | - | 12 | - | 11
Total hedging instruments | 73 | 77 | 61 | 83

For details of the hedge accounting applied by the Group, refer to the subsequent part of the financial statements,
Risk and capital management section, in chapter II.3.8. Hedge accounting.
19. Investment securities

as at 31 December |  |
| 2025 | 2024
Measured at fair value through other comprehensive income, including: | 38,507 | 31,939
debt securities, including: | 38,208 | 31,685
Treasury bonds in PLN | 33,156 | 26,371
European Union bonds | 1,947 | 2,064
European Investment Bank bonds | 2,689 | 2,838
Austrian government bonds | 416 | 412
equity instruments | 299 | 254
Measured at amortised cost, including: | 27,049 | 27,053
debt securities, including: | 27,049 | 27,053
Treasury bonds in PLN | 15,822 | 11,859
Treasury bonds in EUR | 1,972 | 2,872
European Investment Bank bonds | 7,111 | 6,654
Bonds of the Polish Development Fund (PFR) | 1,845 | 3,860
Bank Gospodarstwa Krajowego bonds | 199 | 1,808
NBP bills | 100 | -
Total | 65,556 | 58,992

The value presented in the item equity instruments in the category of assets measured at fair value through other
comprehensive income (FVOCI) includes investments in shares issued by entities that are considered to be material
from the perspective of the Group's operations. The approach to the fair value measurement of these instruments
is described in the further part of the report in note 37. Fair value. In 2025, the Group received income in the form
of dividends in the amount of PLN 8 million (PLN 8 million in 2024), which was presented in the statement of profit
or loss under Net income on the sale of financial assets at fair value through other comprehensive income and
dividend income.
Disclosures on the credit quality of investment securities are presented later in the consolidated financial
statements in the section R isk and capital management, in chapter II.2.9.6. Credit quality of other financial assets.

52 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

20. Assets securing liabilities
Assets securing liabilities that meet the criteria for separate presentation in the statement of financial position
(transferred assets)
The Group presents separately in the consolidated statement of financial position, assets securing liabilities that
can be pledged or resold by the collateral recipient (transferred assets). IFRS 9.3.2.23(a) requires these assets
to be segregated and presented separately from other assets in the statement of financial position.
As at 31 December 2025,the Group did not have assets securing liabilities in its portfolio. As at 31 December 2024),
the Group held assets securing liabilities in the portfolio of financial assets measured at fair value through profit
or loss.

as at 31 December |  |
2025 | 2024 |
Bonds securing liabilities arising from securities sold with a repurchase agreement (sell-buy-back transactions), including: |  |
Treasury bonds in PLN | - | 179
Total | - | 179

Other assets securing liabilities
The carrying amount of other assets securing liabilities that do not meet the criteria of a separate presentation
in the consolidated statement of financial position is presented next to the table.

as at 31 December |  |  |  |  |  |
| 2025 | 2024
portfolio of financial assets measured at fair value through other comprehensive income | portfolio of financial assets measured at amortised cost | Total | portfolio of financial assets measured at fair value through other comprehensive income | portfolio of financial assets measured at amortised cost | Total
Treasury bonds in PLN, including: | 14 | 745 | 759 | 316 | 822 | 1,138
providing security for the benefit of the Bank Guarantee Fund | - | - | - | - | 449 | 449
constituting a block on the obligation to pay a contribution to the guarantee fund of banks | - | 260 | 260 | - | 201 | 201
constituting a blocking of the obligation to pay a contribution to the banks’ compulsory restructuring fund | - | 344 | 344 | 286 | - | 286
constituting the lodging of securities collateral for initial margin | - | - | - | - | 31 | 31
representing the payment of securities collateral for the initial margin for the ATS Market | - | 61 | 61 | - | 61 | 61
constituting collateral for a settlement fund | - | 10 | 10 | - | 10 | 10
appropriate margin for transactions in Alternative Trading Systems (ATS) | - | 70 | 70 | - | 70 | 70
pledged as collateral in the cover register of mortgage bonds | 14 | - | 14 | 30 | - | 30
Treasury bonds in EUR, including: | - | 65 | 65 | - | 66 | 66
constituting the margin for the settlement of EUREX transactions | - | 65 | 65 | - | 66 | 66
European Union bonds in EUR, including: | 22 | - | 22 | - | - | -
securities on the Euroclear account constituting initial margin collateral for bilateral transactions | 22 | - | 22 | - | - | -
European Investment Bank bonds, including: | 262 | 359 | 621 | 200 | 390 | 590
providing security for settlements with LCH | - | 248 | 248 | - | 252 | 252
constituting the margin for the settlement of EUREX transactions | 197 | 111 | 308 | 200 | 113 | 313
securities on the Euroclear account constituting initial margin collateral for bilateral transactions | 65 | - | 65 | - | 25 | 25
Austrian Government bonds securing the settlements made with LCH | 416 | - | 416 | 412 | - | 412
mortgage receivables securing the covered bonds | - | 3,524 | 3,524 | - | 2,565 | 2,565
Total | 714 | 4,693 | 5,407 | 928 | 3,843 | 4,771

53 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The blocking of securities takes place taking into account the conditions resulting from:
• Act on the Bank Guarantee Fund, deposit guarantee system and forced restructuring,
• Regulation of the European Parliament and of the Council (EU) No. 648/2012 of 4 July 2012,
• from concluded contracts,
• liabilities under repo agreements.
The Group has liabilities due to the issue of mortgage bonds which are secured with the above-mentioned
mortgage claims. At the end of 2025 , the nominal value of the issued covered bonds was PLN 1,500 million
(compared to PLN 500 million at the end of 2024). Detailed information on the issued mortgage bonds can be found
in note 30. Liabilities from debt securities issued.
The Group has deposited call-type margins as security for derivative transactions. Receivables in this respect are
presented in note 14. Cash and cash equivalents and in note 21. Loans and other receivables to customers measured
at amortised cost.
Restricted assets, apart from the instruments presented in this note, also include the value of the obligatory reserve
that the Parent company of the Group is required to maintain in its current account with the NBP. More information
on the required reserve is provided in note 14. Cash and cash equivalents.
Securities not constituting Group’s assets accepted as collateral of liabilities under reverse repurchase
transactions
The market value of buy-sell-back / reverse repo securities was PLN 424 million as at 31 December 2025 compared
to PLN 507 million as at 31 December 2024. As at 31 December 2025, securities worth PLN 418 million were further
resold (compared t o PLN 487 million as at 31 December 2024).
21. Loans and other receivables to customers measured at amortised cost

as at 31 December |  |  |  |  |  |
| 2025 | 2024
gross | impairment for expected credit loss | net | gross | impairment for expected credit loss | net
Loan portfolio, of which: | 181,152 | -4,154 | 176,998 | 167,394 | -3,955 | 163,439
Corporate banking | 100,728 | -3,266 | 97,462 | 96,127 | -3,075 | 93,052
loans in the current account | 15,569 | -312 | 15,257 | 14,934 | -218 | 14,716
term loans | 59,849 | -2,455 | 57,394 | 56,318 | -2,462 | 53,856
lease receivables | 13,803 | -131 | 13,672 | 13,444 | -102 | 13,342
factoring receivables | 6,838 | -366 | 6,472 | 6,860 | -289 | 6,571
debt securities (corporate and municipal) | 4,669 | -2 | 4,667 | 4,571 | -4 | 4,567
Retail banking | 80,424 | -888 | 79,536 | 71,267 | -880 | 70,387
mortgages | 69,268 | -172 | 69,096 | 61,295 | -181 | 61,114
loans in the current account | 687 | -69 | 618 | 688 | -64 | 624
other loans and advances | 10,469 | -647 | 9,822 | 9,284 | -635 | 8,649
Other receivables, of which: | 3,311 | - | 3,311 | 3,238 | - | 3,238
repurchase agreements | - | - | - | 1,040 | - | 1,040
call margin posted | 1,788 | - | 1,788 | 759 | - | 759
other | 1,523 | - | 1,523 | 1,439 | - | 1,439
Total | 184,463 | -4,154 | 180,309 | 170,632 | -3,955 | 166,677

Disclosures on the credit quality of the loan portfolio are presented later in the consolidated financial statements
in the section Risk and capital management, in chapter II.2.9.2. Quality of loan portfolio.
Finance lease receivables
As at 31 December 2025 , vehicles accounted for the largest share in the portfolio of leased items (51.8% of the
portfolio value), while compared to the end of 2024 , vehicle financing agreements increased by 5.0%.
Machines and equipment also account for a significant share in the portfolio (35.0% of the portfolio value) with
a simultaneous increase by 2.6% compared to the value of the financed machinery and equipment at the end of
2024, other movables accounted for 9.3% of the portfolio value (an increase of 1.4% compared to the end of 2024).
At the same time, in 2025, the share in the real estate leasing portfolio decreased by 0.4 p.p. to 3.3% (portfolio
value decreased by 7.8% compared to the end of 2024).

54 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The future minimum lease payments that are to be received by the Group under lease contracts are as follows:

as at 31 December |  |
| 2025 | 2024
up to 1 year | 5,373 | 5,020
over 1 year and up to 2 years | 3,551 | 3,654
over 2 years and up to 3 years | 2,446 | 2,413
over 3 years and up to 4 years | 1,340 | 1,360
over 4 years and up to 5 years | 704 | 619
over 5 years | 389 | 378
Total | 13,803 | 13,444

Gross receivables under financial lease that will be received by Group are as follows:

as at 31 December |  |
| 2025 | 2024
up to 1 year | 5,959 | 5,734
over 1 year and up to 2 years | 3,902 | 4,085
over 2 years and up to 3 years | 2,632 | 2,643
over 3 years and up to 4 years | 1,428 | 1,466
over 4 years and up to 5 years | 740 | 662
over 5 years | 418 | 415
Total | 15,079 | 15,005

The present value of minimum lease instalments is as follows:

as at 31 December |  |
| 2025 | 2024
(Gross) receivables under financial lease | 15,079 | 15,005
Undue interest | 1,276 | 1,561
Present value of minimum lease instalments | 13,803 | 13,444

Revenues realised by the Group from financial lease contracts are as follows:

for the year ended 31 December |  |
| 2025 | 2024
Profit from the sale of fixed assets (leasing items) | 5 | 5
Net interest income from leasing investment | 819 | 918
Variable leasing fees (commission fees) | 26 | 22
Total | 850 | 945

In 2025, as in 2024, no cases of significant modifications to finance lease agreements were identified.
How the lessor manages risks related to all rights that it retains with respect to the underlying assets
In finance lease contracts, the lessee retains substantially all the risks and rewards of ownership of the leased asset.
The main collateral for lease contracts are the objects of leasing, this applies to all contracts, due to the design
of the standard lease contract and the fact that ownership of the subject of the leasing remains until the
termination of the contract on the part of the lessor. Leasing items are fully insured by the Group or by the
customer at insurance companies approved by the Group. Before entering into a lease contract, the Group assesses
the customer's creditworthiness and assesses the risk associated with the subject of the lease. In addition, with
a view to limiting the potential loss in the absence of debt service, the Group aims to conclude additional security
agreements. The type and value of collateral required depend on the amount and subject of financing, lease
parameters (e.g. deductible, financing period, residual value). Pursuant to the terms of the lease contracts, if the
lease contract is terminated, the resulting receivables become due. In addition, as part of securing the Group, the
Group takes over the subject of the lease and immediately strives to develop it in the most advantageous manner
(sale, re-leasing).
22. Investments in associates accounted for using the equity method
ING Bank Śląski S.A. holds an indirect share in the share capital of Goldman Sachs TFI S.A. through its subsidiary,
ING Investment Holding (Polska) S.A. In addition, ING Bank Śląski S.A. holds 40% of shares in Dom Data IDS Sp. z o.o.
the Group recognises the above shares as investments in associates and measures using the equity method
in accordance with IAS 28. The carrying amount of the shares was PLN 204 million at the end of 2025, compared
to PLN 185 million at the end of 2024.
Selected data on associates

for the year ended 31 December |  |  |  |
| 2025 | 2024
Goldman Sachs TFI S.A. | DomData IDS Sp. z o.o. | Goldman Sachs TFI S.A. | DomData IDS Sp. z o.o.
Share in the capital of the entity | 45% | 40% | 45% | 40%
Assets, including: | 271 | 13 | 210 | 10
Fixed assets | 10 | - | 14 | -
Current assets | 261 | 13 | 196 | 10
Liabilities and provisions for liabilities, including: | 84 | 4 | 72 | 3
Long-term | 2 | - | 7 | -
Short-term | 82 | 4 | 65 | 3
Net assets | 187 | 9 | 138 | 7
Revenues | 225 | 31 | 177 | 27
Net profit (loss) for the financial year | 112 | 2 | 74 | 6

A reconciliation of the carrying amount of investments in associates for 2025 and 2024 is presented below.

55 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

for the year ended 31 December |  |
| 2025 | 2024
Opening balance | 185 | 181
Valuation using the equity method in the period | 49 | 33
Dividends received | -30 | -29
Closing balance | 204 | 185

23. Property, plant and equipment

as at 31 December |  |
| 2025 | 2024
Right of use assets, including: | 454 | 491
real estate | 426 | 465
means of transport | 28 | 25
other | - | 1
Own real estate | 181 | 185
Investments in non-owned fixed assets | 97 | 99
Computer hardware | 82 | 101
Other property, plant and equipment | 92 | 71
Fixed assets under construction | 32 | 64
Total | 938 | 1,011

There are no legal constraints on property, plant and equipment at the end of 2025 and 2024.
Contractual obligations to purchase property, plant and equipment
In 2025 , the Group concluded agreements with business partners resulting in future increase in the value
of property, plant and equipment in the total amount of PLN 10 million. Due to the framework nature of some
of the contracts, this amount is not targeted - its amount will result from cost estimates calculated during the
implementation. The agreements pertain to real estate (buildings and structures), investments in external fixed
assets, fixed assets under construction and other fixed assets. At the end of 2024, the Group had agreements
(partly framework agreements) on real estate (buildings and structures), investments in external fixed assets, fixed
assets under construction and other fixed assets for the total amount of PLN 58 million.

56 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The tables present changes in gross value and accumulated depreciation for individual groups of property, plant and equipment in 2025 and 2024.

for the year ended 31 December 2025 |  |  |  |  |  |  |  |  |  |
| right of use assets | own real estate | investments in non- owned fixed assets | computer hardware | other property, plant and equipment | fixed assets under construction | Total
real estate | means of transport | other assets | Total
Opening gross value | 987 | 57 | 2 | 1,046 | 390 | 548 | 542 | 432 | 64 | 3,022
Additions, including: | 101 | 16 | - | 117 | 20 | 31 | 36 | 44 | 79 | 327
new contracts for the right of use | 20 | 15 | - | 35 | - | - | - | - | - | 35
adjustment of the asset in connection with the recalculation of the lease liability | 81 | 1 | - | 82 | - | - | - | - | - | 82
purchases | - | - | - | - | - | 20 | - | - | 79 | 99
transfer from investment | - | - | - | - | 20 | 10 | 36 | 44 | - | 110
other | - | - | - | - | - | 1 | - | - |  | 1
Reductions, including: | -69 | -7 | - | -76 | - | - | -2 | -1 | -111 | -190
reduction of the scope and early termination of the contract | -40 | -7 | - | -47 | - | - | - | - | - | -47
adjustment of the asset in connection with the recalculation of the lease | -29 | - | - | -29 | - | - | - | - | - | -29
liability sale and liquidation | - | - | - | - | - | - | -2 | -1 |  | -3
transfer from investment | - | - | - | - | - | - | - | - | -110 | -110
other | - | - | - | - | - | - | - | - | -1 | -1
Fair value change, including: | - | - | - | - | -9 | - | - | - | - | -9
included in income statement* | - | - | - | - | -9 | - | - | - | - | -9
Closing gross value | 1,019 | 66 | 2 | 1,087 | 401 | 579 | 576 | 475 | 32 | 3,150
Opening accumulated depreciation | -522 | -32 | -1 | -555 | -205 | -449 | -441 | -361 | - | -2,011
Changes in the period, including: | -71 | -6 | -1 | -78 | -15 | -33 | -53 | -22 | - | -201
depreciation charges | -96 | -12 | -1 | -109 | -15 | -33 | -53 | -22 | - | -232
reduction in scope and early termination of the contract | 25 | 6 | - | 31 | - | - | - | - | - | 31
Closing accumulated depreciation | -593 | -38 | -2 | -633 | -220 | -482 | -494 | -383 | - | -2,212
Closing net value | 426 | 28 | - | 454 | 181 | 97 | 82 | 92 | 32 | 938

*) in line General and administrative expenses, in detailed item maintenance costs of buildings and real estate valuation to fair value

57 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

for the year ended 31 December 2024 |  |  |  |  |  |  |  |  |  |
| right of use assets | own real estate | investments in non- owned fixed assets | computer hardware | other property, plant and equipment | fixed assets under construction | Total
real estate | means of transport | other assets | Total
Opening gross value | 881 | 50 | 1 | 932 | 406 | 516 | 491 | 412 | 57 | 2,814
Additions, including: | 171 | 17 | 1 | 189 | 9 | 39 | 54 | 21 | 102 | 414
new contracts for the right of use | 48 | 16 | - | 64 | - | - | - | - | - | 64
adjustment of the asset in connection with the recalculation of the lease liability | 123 | 1 | 1 | 125 | - | - | - | - | - | 125
purchases | - | - | - | - | - | 23 | 1 | 1 | 102 | 127
transfer from investment | - | - | - | - | 9 | 10 | 53 | 20 | - | 92
other | - | - | - | - | - | 6 | - | - | - | 6
Reductions, including: | -65 | -10 | - | -75 | -3 | -7 | -3 | -1 | -95 | -184
reduction of the scope and early termination of the contract | -53 | -10 | - | -63 | - | - | - | - | - | -63
adjustment of the asset in connection with the recalculation of the lease | -12 | - | - | -12 | - | - | - | - | - | -12
liability sale and liquidation | - | - | - | - | - | -1 | -3 | - | - | -4
transfer from investment | - | - | - | - | - | - | - | - | -92 | -92
other | - | - | - | - | -3 | -6 | - | -1 | -3 | -13
Fair value change, including: | - | - | - | - | -22 | - | - | - | - | -22
included in income statement* | - | - | - | - | -22 | - | - | - | - | -22
Closing gross value | 987 | 57 | 2 | 1,046 | 390 | 548 | 542 | 432 | 64 | 3,022
Opening accumulated depreciation | -439 | -30 | -1 | -470 | -191 | -418 | -390 | -343 | - | -1,812
Changes in the period, including: | -83 | -2 | - | -85 | -14 | -31 | -51 | -18 | - | -199
depreciation charges | -108 | -11 | - | -119 | -15 | -31 | -51 | -19 | - | -235
reduction in scope and early termination of the contract | 25 | 9 | - | 34 | - | - | - | - | - | 34
other | - | - | - | - | 1 | - | - | 1 | - | 2
Closing accumulated depreciation | -522 | -32 | -1 | -555 | -205 | -449 | -441 | -361 | - | -2,011
Closing net value | 465 | 25 | 1 | 491 | 185 | 99 | 101 | 71 | 64 | 1,011

*) in line General and administrative expenses , in detailed item maintenance costs of buildings and real estate valuation to fair value

58 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

24. Intangible assets

as at 31 December |  |
| 2025 | 2024
Goodwill obtained as a result of a branch of ING Bank NV contributed in kind | 223 | 223
Software | 225 | 166
Outlays for intangible assets | 101 | 66
Other intangible assets | 2 | 2
Total | 551 | 457

Contractual obligations to purchase intangible assets
In 2025, the Group concluded agreements with contractors for the future purchase of intangible assets for a total
amount of PLN 92 million, however, due to the framework nature of some of the agreements, this amount is not
the target amount. These agreements, as in the previous year, concern the purchase of licenses and the
implementation of computer software.
At the end of 2024, the Group had contracts (partly of a framework nature) for the purchase of licenses and
software implementation for a total amount of PLN 175 million.
Changes in 2025 and 2024 in particular groups of intangible assets are presented below.

2025 |  |  |  |  |
| Goodwill | Software | Outlays for intangible assets | Other intangible assets | Total
Opening gross value | 223 | 1,626 | 66 | 22 | 1,937
Additions, including: | - | 150 | 212 | 2 | 364
purchases | - | - | 212 | - | 212
transfer from investment | - | 150 | - | 2 | 152
Reductions, including: | - | -3 | -177 | - | -180
transfer from investment | - | - | -152 | - | -152
other | - | -3 | -25 | - | -28
Closing gross value | 223 | 1,773 | 101 | 24 | 2,121
Opening accumulated depreciation | - | -1,460 | - | -20 | -1,480
Changes in the period, including: | - | -88 | - | -2 | -90
depreciation charges | - | -88 | - | -2 | -90
Closing accumulated depreciation | - | -1,548 | - | -22 | -1,570
Closing net value | 223 | 225 | 101 | 2 | 551

2024 |  |  |  |  |
| Goodwill | Software | Outlays for intangible assets | Other intangible assets | Total
Opening gross value | 223 | 1,588 | 37 | 20 | 1,868
Additions, including: | - | 88 | 130 | 2 | 220
purchases | - | 4 | 130 | - | 134
transfer from investment | - | 84 | - | 2 | 86
Reductions, including: | - | -24 | -101 | - | -125
transfer from investment | - | - | -86 | - | -86
sale and liquidation | - | -23 | - | - | -23
other | - | -1 | -15 | - | -16
Impairment | - | -26 | - | - | -26
Closing gross value | 223 | 1,626 | 66 | 22 | 1,937
Opening accumulated depreciation | - | -1,356 | - | -19 | -1,375
Changes in the period, including: | - | -104 | - | -1 | -105
depreciation charges | - | -104 | - | -1 | -105
Closing accumulated depreciation | - | -1,460 | - | -20 | -1,480
Closing net value | 223 | 166 | 66 | 2 | 457

Impairment test of cash generating units with respective goodwill
The goodwill impairment test is carried out at least once every year, irrespective of identification of any triggers for
impairment.
At the Group, the impairment test covered the goodwill obtained as a result of a branch of ING Bank NV contributed
in kind, which was assigned to the corporate activity of the Group. The smallest identifiable cash-generating units
were determined and goodwill totalling PLN 223 million was assigned thereto. No other additional elements
of intangible value and indefinite useful life were identified that could be assigned to the identified cash-generating
units.
The test input data cover the economic capital, risk-weighted assets and profit before tax per segment and effective
tax rate. The test is performed using the model that calculates and compares the current value of free cash flow
of the unit to the estimated book value of the unit’s funds. The cash flows of the unit are defined as net profits less
capital needed to maintain the solvency ratio at the required level.
At the end of 2025 , a discount rate of 10.44% was used to discount the cash flows, representing the weighted
average cost of capital, estimated on the basis of the risk-free rate (5.17%), the beta factor (0.96) and the equity
risk premium (5.50%). As at 2024 yearend, the discount rate used to discount the flows was 11.56% and was
estimated based on a risk-free rate of 5.89%, a beta factor of 1.03 and a share price risk premium of 5.50%. Other
assumptions include the nominal growth rate after the forecast period (2.5% at the end of 2025 compared to the
3.5% at the end of 2024).
The recoverable value was determined based on the estimation of the useable value of the assets component
taking into account the estimated forecast of expected future cash flows generated during the continued use.

59 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The cash flow forecasts are based on rational assumptions that reflect the most accurate appraisal of the
management regarding all the conditions that will appear during the remaining lifetime of the assets. The cash flow
forecasts are based on mid-term plan approved by the Group and the strategy covering the maximum period of the
next three years. The data regarding the subsequent years come from extrapolation. Extrapolation assumes that
the cash flow generating centre will maintain the gross profit to risk weighted assets ratio at the level from the last
year of the Group’s forecast and its profits will increase by previously determined growth rate. Legitimacy of the
assumptions made is verified periodically, and any divergence between the cash flows estimated based on the
future cash flows and the actual ones is analysed as appropriate.
The test showed the surplus of present value over the net book value of the cash-generating unit thus
no impairment was determined.
As at 31 December 2025, the sensitivity analysis of the goodwill impairment test shows that:
• increasing the discount rate by 1 p.p. would result in a decrease in the surplus of net cash flows over the net book
value of the cash-generating unit by 21% (compared to 20% at the end of 2024),
• reduction of the discount rate by 1 p.p. would result in an increase in the surplus of net cash flows over the net
book value of the cash-generating unit by 27% (compared to 26% at the end of 2024).
The key assumptions described above are subject to change as economic and market conditions change. The Group
estimates that reasonably possible changes to these assumptions would not reduce the recoverable amount of the
cash-generating unit below the carrying amount.
25. Deferred tax
Changes in temporary differences during the year

for the year ended 31 December 2025 |  |  |  |
| opening balance | changes carried through profit or loss | changes carried through other comprehensive income | closing balance
Deferred tax assets |  |  |  |
impairment for expected credit losses | 477 | 140 | - | 617
valuation of operational leasing | 225 | -24 | - | 201
revaluation of financial instruments | 76 | -62 | 113 | 127
employee benefits | 93 | 28 | - | 121
provision for restructuring | 17 | - | - | 17
other provisions | 130 | 52 | - | 182
settlement of the difference between tax and balance sheet depreciation | 42 | 27 | - | 69
finance lease | 8 | 5 | - | 13
tax losses | 1 | -1 | - | -
research and development relief | 40 | -6 | - | 34
tax adjustment for the CHF loan portfolio | 22 | -10 | - | 12
Total | 1,131 | 149 | 113 | 1,393
Deferred tax losses |  |  |  |
revaluation of financial instruments | 127 | - | 144 | 271
accrued interest | 244 | 148 | - | 392
effective interest rate adjustment | 70 | 31 | - | 101
settlement of prepayments/accruals due to depreciation/ amortisation resulting from the investment relief | 1 | - | - | 1
other | - | 7 | - | 7
Total | 442 | 186 | 144 | 772
Deferred tax disclosed in the balance sheet, of which: | 689 | -37 | -31 | 621
Deferred tax assets | 690 | - | - | 621

The amounts of the changes included, among others, the revaluation effect due to the change in tax rates,
in connection with the entry into force of changes in tax regulations introducing, from January 1, 2026, new
corporate income tax rates (30% for 2026, 26% for 2027 and 23% starting from 2028). The total revaluation effect
of the asset items and deferred tax liability due to the change in tax rates amounted to PLN 41 million
as at 31 December 2025 of which PLN 67 million wa s a PLN -26 million related to items recognised in other
comprehensive income. More information on the approach to the estimation of deferred tax asset / liability
is presented in Chapter III. Significant accounting principles, in point 3.4. Deferred income tax.

60 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

for the year ended 31 December 2024 |  |  |  |
| opening balance | changes carried through profit or loss | changes carried through other comprehensive income | closing balance
Deferred tax assets |  |  |  |
impairment for expected credit losses | 429 | 48 | - | 477
valuation of operational leasing | 223 | 2 | - | 225
revaluation of financial instruments | 84 | 26 | -34 | 76
employee benefits | 88 | 5 | - | 93
provision for restructuring | 22 | -5 | - | 17
other provisions | 142 | -12 | - | 130
settlement of the difference between tax and balance sheet depreciation | 26 | 16 | - | 42
finance lease | 7 | 1 | - | 8
tax losses | 519 | -518 | - | 1
research and development relief | - | 40 | - | 40
tax adjustment for the CHF loan portfolio | - | 22 | - | 22
other | 1 | -1 | - | -
Total | 1,541 | -376 | -34 | 1,131
Deferred tax losses |  |  |  |
revaluation of financial instruments | 148 | - | -21 | 127
accrued interest | 232 | 12 | - | 244
effective interest rate adjustment | 63 | 7 | - | 70
settlement of prepayments/accruals due to depreciation/ amortisation resulting from the investment relief | 1 | - | - | 1
Total | 444 | 19 | -21 | 442
Deferred tax disclosed in the balance sheet, of which: | 1,097 | -395 | -13 | 689
Deferred tax assets | 1,097 | - | - | 690
Deferred tax losses | - | - | - | 1

Deferred tax recognised in equity

as at 31 December |  |
| 2025 | 2024
Deferred tax in accumulated other comprehensive income, due to: | 123 | 96
financial assets valued through other comprehensive income - debt instruments | 53 | 50
financial assets valued through other comprehensive income - equity instruments | 63 | 44
cash flow hedges | 18 | 9
actuarial gains/losses | -11 | -7
Deferred tax in retained earnings due to: | 9 | 5
incentive employee programs | 9 | 5
Total | 132 | 101

26. Other assets

as at 31 December |  |
| 2025 | 2024
Prepayments, including: | 125 | 109
accrued income | 55 | 49
due to commissions | 1 | 1
due to general and administrative expenses | 69 | 59
Other assets, including: | 32 | 40
settlements with recipients | 19 | 17
public and legal settlements | 9 | 14
other | 4 | 9
Total | 157 | 149
including financial assets | 32 | 40
Expected settlement period of other assets |  |
up to 1 year | 71 | 76
over 1 year | 86 | 73

Disclosures on the credit quality of other financial assets are presented later in the consolidated financial
statements in the section Risk and capital management, in chapter II.2.9.6. Credit quality of other financial assets.
27. Liabilities to other banks

as at 31 December |  |
| 2025 | 2024
Current accounts | 733 | 826
Interbank deposits | 341 | 330
Loans received* | 13,652 | 13,735
Received call deposits | 314 | 575
Other liabilities | 2 | 2
Total | 15,042 | 15,468

*) The item Loans received includes financing of long-term leasing contracts in EUR (so-called "matched funding")
received by the subsidiary ING Lease Polska Sp. z o.o. from ING Bank NV and other banks not related to the Group.
This item also includes liabilities due to non-preferred senior loans (NPS) received by ING Bank Śląski S.A. from ING
Bank N.V. More information on NPS loans can be found in the Risk and capital management section, in chapter I.4.
MREL requirements.
28. Financial liabilities measured at fair value through profit or loss

as at 31 December |  |
| 2025 | 2024
Financial liabilities held for trading, including: |  |
valuation of derivatives | 498 | 733
other financial liabilities held for trading, including: | 418 | 667
book short position in trading securities | 418 | 487
repo transactions | - | 180
Total | 916 | 1,400

61 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Detailed disclosures on the nominal values of derivative instruments and their valuation broken down into individual
types of derivative instruments along with the remaining dates for their implementation are presented in note
17. Valuation of derivatives.
29. Liabilities to customers

as at 31 December |  |
| 2025 | 2024
Deposits, including: | 233,356 | 218,148
Corporate banking | 97,305 | 92,474
current deposits | 66,135 | 60,947
including O/N deposits | 5,777 | 5,045
saving deposits | 20,941 | 20,010
term deposits | 10,229 | 11,517
Retail banking | 136,051 | 125,674
current deposits | 34,998 | 31,850
saving deposits | 81,942 | 76,338
term deposits | 19,111 | 17,486
Other liabilities, including: | 1,972 | 1,848
liabilities under monetary hedges | 872 | 751
call deposits | 45 | 7
other liabilities | 1,055 | 1,090
Total | 235,328 | 219,996

30. Liabilities from debt securities issued

as at 31 December |  |
| 2025 | 2024
Liabilities under issue of debt securities, including: |  |
covered bonds issued by ING Bank Hipoteczny S.A. | 1,521 | 509
Total | 1,521 | 509

At the end of 2025 and 2024 , the Group had liabilities arising from the issue of covered bonds issued as part of the
ING Bank Hipoteczny S.A. covered bond issue programme established in 2019 (Programme). The purpose
of establishing the Programme was to create a legal infrastructure under which the Group will be able to issue
covered bonds both on the local and foreign market.
In September 2025, as part of the Programme, ING Bank Hipoteczny S.A. issued 2 series of covered bonds with
a total nominal value of PLN 1,000 million (i.e. 2,000 with a nominal value of PLN 500 thousand per 1 piece) and
variable interest coupon in the amount of WIBOR 6M + 0.78%, payable every six months. The maturity date
of covered bonds is 30 September 2029, however it may be extended in accordance with the provisions of the Act
of 29 August 1997 on covered bonds and mortgage banks. On 30 September 2025, the covered bonds were
admitted to trading on the regulated market in Luxembourg and in Warsaw.
In September 2024, as part of the Programme, ING Bank Hipoteczny S.A. issued 2 series of covered bonds with
a total nominal value of PLN 500 million (i.e. 1,000 with a nominal value of PLN 500 thousand per 1 piece) and
variable interest coupon in the amount of WIBOR 6M + 0.55%, payable every six months. The maturity date
of covered bonds is 11 September 2028, however it may be extended in accordance with the provisions of the Act
of 29 August 1997 on covered bonds and mortgage banks. On 11 September 2024, the covered bonds were
admitted to trading on the regulated market in Luxembourg and in Warsaw.
In October 2024, 1 series of covered bonds with a nominal value of PLN 400 million was redeemed.
31. Subordinated liabilities
ING Bank Śląski has in its balance sheet three subordinated loans resulting from agreements with the parent entity,
i.e. with ING Bank N.V. based in Amsterdam. These are:
• the agreement concluded 14 October 2025 in the amount of EUR 250 million,
• the agreement concluded 30 September 2019 in the amount of EUR 250 million,
• the agreement concluded on 30 October 2018 for the amount of EUR 100 million.
All loans were granted for a period of 10 years. The Bank has the right to early repayment of each of them after
5 years, subject to obtaining the relevant consent of the Polish Financial Supervision Authority (KNF). Interest
on both loans is payable quarterly at EURIBOR 3M plus a margin (1.90% for the 2025 loan, 1.66% for the 2019 loan
and 1.22% for the 2018 loan). The financial conditions of the loans do not differ from market conditions. The Bank
obtained KNF’s consent for including loans in the Tier 2 capital, with the consent for the 2025 loan granted
on 12 January 2026.
At the end of 2025 the total carrying amount of subordinated loans was PLN 2,548 million (PLN 1,499 million at the
end of 2024).
32. Provisions

as at 31 December |  |
| 2025 | 2024
Provision for off-balance sheet liabilities | 139 | 105
Provision for legal risk of foreign currency mortgage loans* | 208 | 253
Provision for retirement benefits | 122 | 104
Provision for restructuring | 60 | 91
Provision for litigation | 62 | 46
Other provisions | 52 | 37
Total | 643 | 636

*) In addition to the provision for legal risk of foreign currency mortgage loans, the Group estimates the adjustment
to the gross carrying amount of CHF-indexed mortgage loans recognised in the statement of financial position and

62 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

recognises it in the consolidated statement of financial position in the item Loans and other receivables
to customers measured at amortised cost. In chapter III. Significant accounting principles, in item 3.3. Legal risk
related to the portfolio of mortgage loans indexed to the Swiss franc exchange are presented the change in 2025 and
2024, as well as assumptions regarding of both provisions and adjustment to the gross carrying amount due to the
legal risk of CHF-indexed mortgages.
The tables below present the movements in the individual provisions in 2025 and 2024.

for the year ended 31 December 2025
| Provision for off-balance sheet liabilities | Provision for legal risk | Provision for retirement benefits | Provision for restructurin g | Provision for litigation | Other provisions | Total
Stage 1 | Stage 2 | Stage 3 | Total
Opening balance | 24 | 34 | 47 | 105 | 253 | 104 | 91 | 46 | 37 | 636
provisions recognised/ reversed | 1 | -9 | 42 | 34 | 10 | 9 | -2 | 21 | 4 | 76
transfer within provisions | - | - | - | - | -2 | - | - | - | 11 | 9
utilisation | - | - | - | - | -53 | - | -29 | -5 | - | -87
other | - | - | - | - | - | 9 | - | - | - | 9
Closing balance | 25 | 25 | 89 | 139 | 208 | 122 | 60 | 62 | 52 | 643
Expected provision settlement period: |  |  |  |  |  |  |  |  |  |
up to 1 year |  |  |  | - | - | 8 | 40 | 16 | 8 | 72
over 1 year |  |  |  | 139 | 208 | 114 | 20 | 46 | 44 | 571

for the year ended 31 December 2024
| Provision for off-balance sheet liabilities | Provision for legal risk | Provision for retirement benefits | Provision for restructurin g | Provision for litigation | Other provisions | Total
Stage 1 | Stage 2 | Stage 3 | Total
Opening balance | 33 | 24 | 59 | 116 | 128 | 93 | 116 | 39 | 50 | 542
provisions recognised/ reversed | -9 | 10 | -12 | -11 | 102 | 8 | - | 10 | -8 | 101
transfer within provisions | - | - | - | - | 38 | - | - | - | -4 | 34
utilisation | - | - | - | - | -15 | - | -25 | -3 | -1 | -44
actuarial gains/losses | - | - | - | - | - | 3 | - | - | - | 3
Closing balance | 24 | 34 | 47 | 105 | 253 | 104 | 91 | 46 | 37 | 636
Expected provision settlement period: |  |  |  |  |  |  |  |  |  |
up to 1 year |  |  |  | - | - | 7 | 40 | 20 | 5 | 72
over 1 year |  |  |  | 105 | 253 | 97 | 51 | 26 | 32 | 564

Provision for retirement benefits
The Group creates provisions for retirement and disability severance pays in accordance with IAS 19. The provision
for retirement and disability severance pays granted under benefits under the regulations resulting from the
Labour Code is calculated using the actuarial method by an independent actuary as the present value of the
Group’s future, long-term liabilities to employees by headcount and pay as at the date of the update. Provisions
resulting from actuarial valuation are recognised and revalued in annual periods.
The calculation of provisions is based on a number of assumptions, both with regard to discount rates, projected
salary increases and employee turnover, death risk and others.
Assumptions adopted for the valuation:
• discount rate – 5.20% (5.80% at the end of 2024),
• long-term wage growth rate – 5.00%.
The table below includes revision of the balance-sheet liability.

for the year ended 31 December |  |
| 2025 | 2024
Opening balance | 104 | 93
Costs included in the income statement, including: | 12 | 11
regular employment costs | 6 | 6
costs of interest | 6 | 5
Actuarial gains / losses | 9 | 3
Paid benefits | -3 | -3
Closing balance | 122 | 104

The sensitivity of the model to the assumed values of individual assumptions as at 31 December 2025 and
31 December 2024 is presented in the table below. The base variant is the value of pension and disability provisions
recognised in the Group’s books as at 31 December 2025 and 31 December 2024, respectively.

| Provisions for retirement and pension benefit (in PLN million)
2025 | 2024
lower bracket | base variant | upper bracket | lower bracket | base variant | upper bracket
Discount rate (+1% / base variant / -1%) | 111 | 122 | 135 | 95 | 104 | 115
Deviation from the assumed dynamics of changes in salaries (- 0.5% / base variant / +0.5%) | 116 | 122 | 129 | 99 | 104 | 110

Provision for restructuring
In 2023, the Bank’s Management Board decided to continue in 2024-2026 the process initiated in 2016, which
is related to the employment restructuring resulting from the continuation of a long-term project to evolve the
Bank’s organisational structure, including, above all, further optimisation of the number of outlets and development
of digital channels in the retail segment, reconstruction of the organisational structure and processes in the
corporate segment, as well as optimisation and automation of processes in the Bank’s business support units.
The value of the restructuring provision at the end of 2025 was PLN 60 million, compared to PLN 91 million at the
end of 2024.

63 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Legal risk of foreign currency mortgage loans
The significant assumptions concerning the calculation of the amount of the gross balance sheet value
adjustment / provision for legal risk for the CHF-indexed mortgage loan portfolio presented in the statement
of financial position and already remo ved from the statement of financial position as at 31 December 2025 are
described in chapter III. Significant accounting principles, in point 3.3. Legal risk related to the portfolio of mortgage
loans indexed to the Swiss franc exchange rate.
To date, the Bank has not received any class action, and neither of the clauses used by the Bank in the agreements
has been entered in the register of prohibited clauses.
As at 31 December 2025, 1,485 court cases were pending against the Bank (1,673 cases at the end of 2024 )
in connection with concluded CHF-indexed loan agreements in PLN. The outstanding principal of the mortgage
loans to which these proceedings related was PLN 241 million as at 31 December 2025 (PLN 284 million at the end
of 2024). By 31 December 2025, 1,234 court cases had ended with a final court judgement (568 cases at the end
of 2024).
As at 31 December 2025, the Bank was also subject to 28 court cases (22 cases at the end of 2024) in connection
with concluded EUR mortgage loan agreements. The outstanding principal of the loans concerned by these
proceedings was below PLN 1 million as at 31 December 2025 (similar to the end of 2024 ). By 31 December 2025,
8 court cases had ended with a final judgement.
The most important findings of the European Court of Justice (CJEU) and the Supreme Court (SC) in recent years
regarding credit agreements indexed or denominated in foreign currencies have been presented in the
consolidated financial statements for previous years. The following are the important arrangements that have been
made since the beginning of 2025.
• By the resolution of seven judges of March 5, 2025, file ref. no. III CZP 37/24, the Supreme Court found that "In the
event of an investigation from the bank of repayment of the benefit provided on the basis of the loan agreement,
which turned out to be non-binding, the bank is not entitled to retention under Article 496 in conjunction with
Article 497 of the Civil Code".
• On 19 June 2025, the CJEU issued a judgement in one of the Polish cases concerning the recovery of capital
by banks after cancellation of a mortgage loan agreement in CHF. The CJEU has questioned the compatibility
with European Union law of the so-called theory of two conditions, which has so far been widely used in Polish
case law. It was based on the assumption that each party to the annulled contract had its own claim. The
consumer has the right to recover all instalments paid to the bank and the bank has the right to pursue the
capital (in two separate civil proceedings). The CJEU stated that such an approach is contrary to EU law. Both
claims should be considered in one proceeding. The bank is only entitled to make a difference between its claim
and the consumer's claim (balance theory). Analyses of the impact of the above-mentioned judgement on the
situation of banks are currently underway, in particular the monitoring of court judgments issued after this
judgement.
• On 22 January 2026, the CJEU issued a judgment confirming the admissibility of the case resolution regarding
a CHF-indexed contract by offsetting in one proceeding. The CJEU stated that banks may raise the objection of
set-off even if the invalidity of the contract is contested. The CJEU pointed out that depriving a bank of the
possibility to raise a charge of set-off against a consumer would constitute a disproportionate violation of its right
to effective judicial protection.
Settlement programme
The Bank offers borrowers with mortgage loans indexed to CHF/EUR the possibility of concluding voluntary
settlements. By the end of 2025, the Bank had concluded 1,090 settlements (840 settlements by the end of 2024),
including 802 settlements before the PFSA Court of Arbitration (777 settlements by the end of 2024).
33. Information on initiated administrative proceedings and significant court proceedings
The value of proceedings concerning liabilities or receivables pending in 2025 did not exceed 10% of the Group’s
equity. In the Group’s opinion, none of the individual proceedings pending in 2025 in front of a court, arbitration
court or public administration authority, or all of them jointly pose a threat to the Group’s financial liquidity.
Detailed information on the legal environment related to the legal risk of the CHF-indexed mortgage portfolio and
information on court cases in connection with concluded CHF-indexed mortgage loan agreements are presented
in note 32. Provisions.
PFSA proceedings
• On 12 October 2018, the Polish Financial Supervision Authority imposed a fine on the Bank in the amount of PLN
0.5 million, pursuant to Art. 232 sec. 1 of the Act on Investment Funds and Alternative Investment Funds
Management, in the wording before the amendment made by the Act of 31 March 2016, in connection with the
breach of depository’s obligations set out in Art. 72 of the Act in connection with the Bank acting as the
depositary of the Inventum Premium SFIO and Inventum Parasol FIO funds with separate sub-funds. In the course
of reconsidering the case, the PFSA confirmed the violations and did not identify any circumstances that would
justify reducing the fine. In connection with the proceedings, a provision in the amount of PLN 0.5 million was
created in December 2018. The Bank paid the imposed fine in the third quarter of 2020. On 1 October 2020, the
Bank appealed against the said decision to the Voivodship Administrative Court. In its judgement of 7 April 2021,
the Voivodship Administrative Court overturned the decision of 12 October 2018 and the decision of the Polish
Financial Supervision Authority of 12 August 2020 maintaining this decision. The Polish Financial Supervision
Authority filed a complaint with the Supreme Administrative Court (NSA) on 27 July 2021. On 25 August 2021,
the Bank submitted a response to the complaint. On 19 March 2025, a hearing was held before the Supreme
Administrative Court. The Supreme Administrative Court overturned the judgement of the Voivodeship
Administrative Court of 7 April 2021 and referred the case for reconsideration. The Supreme Administrative Court

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

assessed that the Voivodeship Administrative Court prematurely found the allegation of a breach of substantive
law by the PFSA. In the Supreme Administrative Court’s opinion, the justification for the PFSA’s decision may lead
to a conclusion as to which legal provision was violated by the Bank, for which an administrative sanction was
imposed, and the PFSA did not have to indicate these violations in the content of the decision itself (which was
argued by the Voivodeship Administrative Court). The Voivodeship Administrative Court, when re-examining the
case, is bound by the findings of the Supreme Administrative Court. On 5 August 2025, the Voivodeship
Administrative Court issued a judgement in which it upheld the decision of the PFSA, i.e. dismissed the Bank’s
complaint. The Voivodeship Administrative Court emphasised that it is bound by the position of the Supreme
Administrative Court. After receiving the justification of the judgement of the Voivodeship Administrative Court,
the Bank lodged a complaint with the Supreme Administrative Court. Until the end of the court proceedings,
the PFSA’s decision remains invalid.
• On 17 June 2020, the Polish Financial Supervision Authority (PFSA, KNF) initiated administrative proceedings
to impose a penalty on ING Bank Śląski S.A, in connection with suspicion of breach of depositary duties defined
in art. 72 of the Act on investment funds and management of alternative investment funds in connection with
the Bank’s function of depositary of specific funds and Article 9(2) of the above mentioned act. The proceedings
ended on 17 December 2021 with the issuance of a Decision under which the PFSA imposed an administrative
penalty of PLN 4.3 million on the Bank. The fine of PLN 4.3 million was paid. On 21 November 2022, the Bank filed
a complaint with the Provincial Administrative Court. Pursuant to the content of the complaint, the Bank
demands that the Decision imposing an administrative penalty be repealed in its entirety. In a judgment of 8
March 2023, the Provincial Administrative Court dismissed the Bank's complaint in its entirety. The justification for
the judgment was received on 21 June 2023, after analyzing it, the Bank decided to file a cassation complaint
with the Supreme Administrative Court. The complaint was prepared and submitted on time. The date of the
hearing before the Supreme Administrative Court has not been set.
• On 22 November 2023, the Polish Financial Supervision Authority initiated an administrative proceeding regarding
the imposition of a fine on ING Bank Śląski S.A. pursuant to Art. 176i sec. 1 point 4 of the Act on Trading
in Financial Instruments. In May 2025, the proceedings were discontinued in their entirety.
Proceedings initiated by the President of the Office of Competition and Consumer Protection (UOKiK)
Proceedings on the application of practices infringing collective consumer interests regarding unauthorized
transactions
On 22 June 2021, the UOKiK opened an investigation against ING concerning the Bank’s replies to customer reports
of unauthorized transactions, including the reimbursement of transaction amounts at D+1. In the course of the
proceedings, the Bank repeatedly provides the explanations and documents required by the Office.
On 22 November 2022, the Bank received a notice from the UOKiK to initiate proceedings for a practice damaging
the collective interests of consumers, together with a request to respond to the following allegations:
• non-reimbursement to consumers within D+1 of the consumer requesting the return of the unauthorized
transaction or restoring the account to the condition that would have existed if the unauthorized payment
transaction had not taken place; the only exceptions, according to the UOKiK, are situations where the Bank
informs the law enforcement authorities of the suspicion of a criminal offense by the consumer or 13 months
have elapsed from the date on which the transaction was debited or the day on which the transaction was
to be executed; UOKiK claims that this may infringe Article 46(1) of the Payment Services Act and compromise
the collective interests of consumers and, and may therefore constitute a practice that would be affected;
• providing misleading information in response to a complaint by suggesting that the use of individual credentials
means correct authentication, which in turn means demonstrating a correct authorization of transactions, which
may mislead consumers regarding the obligations of the trader under Article 46 of the Act and the distribution
of the burden of proof that the payment transaction has been authorized - which, according to the UOKiK, may
constitute an unfair market practice and undermine the collective interests of consumers, and consequently
constitute a practice that infringes the collective interests of consumers;
• providing consumers with misleading, incorrect information about the correct authorization of transactions
in response to a complaint, while pointing out the lack of consent of consumers to carry out a transaction
(i.e. a lack of authorization) by indicating that the customer has led to the transaction as a result of a breach
of one of the obligations referred to in Article 42 of the Act and that the customer is therefore fully liable for the
transaction being advertised, and the recovery is possible as a result of action by the law enforcement authorities
at the request of the injured party, which may constitute an unfair market practice and, consequently, constitute
a practice which infringes the collective interests of consumers.
On 16 January 2023, the Bank sent a letter in the proceedings containing a very comprehensive explanation of its
position rejecting the above-mentioned allegations, indicating both the correct interpretation of the provisions
of the Payment Services Act in the Bank's opinion and the analysis of certain cases described in the order by the
Office of Competition and Consumer Protection. The case is pending. UOKiK has decided to extend the deadline for
completing the proceedings until 30 March 2025.
In connection with the proceedings, as at 31 December 2025 the Group had a provision in the total amount of PLN
38 million (PLN 34 million as at 31 December 2024).
Proceedings on provisions providing for the possibility of changing a standard contract, contract or table of fees
and commissions for important reasons, the so-called modification clauses
On 1 April 2019, the President of the Office of Competition and Consumer Protection (UOKiK) initiated ex officio
proceedings to recognize a standard contract as illegal in terms of contractual provisions that may violate Art. 23a
of the Act on competition and consumer protection. The proceedings concern provisions providing for the possibility
of changing the standard contract, contract or table of fees and commissions for important reasons, the so-called
modification clauses.

65 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

In the opinion of the President of UOKiK, the analysed modification clauses may constitute prohibited contractual
provisions due to:
• the possibility of unilaterally changing the general terms and conditions of the contract as to its essential
provisions, in the scope of contracts enabling the generation of debt on the part of consumers, concluded for
a specified period,
• general, imprecise nature of the premises for a unilateral amendment to the contract, which does not allow
consumers to verify them correctly, and in some provisions there are no time limits as to the scope of changes,
• no provisions regarding the possibility of continuing a contract concluded for a specified period of time regarding
crediting consumer needs under the existing rules in the event of failure to accept unilateral proposed changes
from the bank.
In the letter of 13 May 2021, the Office for Competition and Consumer Protection notified the Bank that the
collection of evidence had been completed. The Office for Competition and Consumer Protection decided to extend
the deadline for the completion of the proceedings until 30 April 2026.
As at 31 December 2025 the Group did not have any provisions in this respect, similarly as at 31 December 2024.
Proceedings on the allegation of practices restricting competition on the market of acquiring services related to
payments with payment cards in Poland
After conducting antitrust proceedings against ING Bank Śląski S.A. and other banks, at the request of the Polish
Trade and Distribution Organization - the Employers' Association (POHiD), the President of the Office of Competition
and Consumer Protection issued a decision on 29 December 2006 stating that the Bank had committed practices
restricting competition. UOKiK found competition-restricting practice consisting in the participation by various Polish
banks, including the Bank, in an agreement limiting competition on the market of acquiring services related to the
settlement of consumer obligations to merchants, for payments for goods and services purchased by consumers,
using payment cards in Poland by jointly determining the interchange fee charged on transactions made with Visa
and MasterCard cards in Poland. In connection with the finding of practices restricting competition, UOKiK imposed
fines, including on the Bank in the amount of PLN 14 million.
The Bank appealed against the Decision to the Court of Competition and Consumer Protection (SOKiK).
By judgement of 12 November 2008, SOKiK amended the UOKiK's decision, in that it did not find any practice
restricting competition. On 22 April 2010, this verdict was overturned by the Court of Appeal, which referred the
case to SOKiK for reconsideration. Another judgement of the Court of Appeal was upheld, which resulted in the
obligation to pay a fine. However, the amount of the fine was refunded to the Bank following the judgement of the
Supreme Court, which overturned the judgement of the Court of Appeal. Currently, as a result of the Appellate
Court’s decision of 23 November 2020, the case is being reconsidered by the SOKiK. Further hearings were held
following an exchange of pleadings between the parties. The court admitted the evidence from the expert opinion.
The opinion was served on the parties who replied to it. The Court ordered a supplementary opinion but has not yet
been served on the Bank’s representative.
Due to the lack of final decisions, the amount of the refunded penalty was not recognized in the profit and loss
account. As at 31 December 2025, the value of the provision was PLN 14 million, similarly as at 31 December 2024.
Litigation concerning loans based on variable interest rate and the rules for determining the WIBOR reference
rate
As at 31 December 2025, the Bank was subject to 304 court proceedings (196 proceedings as at 31 December
2024), in which clients question the basis of the mortgage loan agreement on the variable interest rate structure
and the rules for determining the WIBOR reference rate. The Bank questions the validity of the claims raised
in these cases, as the use of the WIBOR index is compliant with the law. The WIBOR benchmark is set
by an administrator, independent of the bank, and supervised by the Polish Financial Supervision Authority. When
granting such loans, the Bank provides clients with all the information required by law, i.e. the ratio and the risk of
variable interest rate. This is confirmed by the case law to date, which is favourable for the Bank. As at 31 December
2025, 27 cases had already been successfully completed (12 cases as at 31 December 2024).
The Częstochowa Regional Court in a case against one of the banks, in which the plaintiff raises objections
regarding the WIBOR rate, decided to refer the following questions to the Court of Justice of the European Union
by order of 31 May 2024:
1) Does Article 1(2) of Directive 93/13, which excludes from the directive the terms of a contract which reflect, inter
alia, the applicable laws or regulations, permit the examination of variable-rate contractual terms on the basis
of the WIBOR benchmark?
2) If the answer to the first question is in the affirmative, does Article 4(2) of Directive 93/13, which excludes the
assessment of the unfairness of contractual terms relating to the determination of the main subject-matter
of the contract or of the price/remuneration, permit the examination of variable-rate contractual terms on the
basis of the WIBOR benchmark?
3) In the event of a positive answer to the first and second questions, can the provisions of the agreement
on variable interest rates based on the WIBOR reference rate be regarded as contrary to the requirements
of good faith and causing a significant imbalance in the parties’ rights and obligations arising under the
agreement to the detriment of the consumer, due to the consumer’s inadequate information regarding the
exposure to the risk of a variable interest rate, including, in particular, the failure to indicate how the benchmark
on which the variable interest rate is set is determined and what doubts are related to its non-transparency and
the uneven distribution of this risk among the parties to the agreement?
4) If the previous questions are answered positively, is it possible to continue the operation of a contract in which
the interest rate on the amount of the loan principal will be based on the second component determining the

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

interest rate contained in the contract, i.e. the bank’s fixed margin, which will change the interest rate on the
loan from variable to fixed?
On 3 July 2024, the request for a preliminary ruling was formally submitted to the CJEU and the case was given the
case number C-471/24. On 28 October 2024, the Polish Government submitted to the CJEU its position on the
preliminary questions asked in this case, in which it recommends a negative answer to all the above questions. This
position is in line with the banks' arguments.
On 11 June 2025, a hearing was held before the CJEU, during which the judges heard the positions of participants
in the proceedings. Both the representative of the EC and the representative of the Polish and Portuguese
Governments presented a position in line with the position of the banking sector, i.e. that there are no grounds
to examine WIBOR and question its reliability, credibility and legality. It is an objective, market-based indicator and
depends primarily on the monetary policy of the central bank. During the hearing, it was announced that the
Advocate General of the CJEU would prepare an opinion.
On 11 September 2025, the Ombudsman issued an opinion in which he confirmed the correctness of WIBOR
designation. The Ombudsman concluded that the national court could not examine the method of determining the
WIBOR index. The bank should provide information about the name, the administrator and the effects of the
increase in the index on the loan interest rate, which was implemented by the banks. The transparency
requirement of Directive 93/13 does not oblige the creditor to directly provide more detailed information on the
benchmark methodology than required by the BMR. Regulation. The banks have fulfilled these obligations. Even
if the terms were to be considered as non-transparent, this is not yet sufficient to effectively undermine them. For
a term to be considered unfair, the interest rate would have to deviate from market conditions.
On 12 February 2026, the CJEU announced its verdict in which it upheld the position expressed in the Ombudsman’s
opinion. The CJEU judges confirmed that the courts in consumer cases cannot investigate the correctness of the
designation of WIBOR, including the method of its determination. This would be contrary to the BMR. Regulation.
In such proceedings, the courts should examine whether the bank has fulfilled its disclosure obligations under
Directive 2014/17/EU - providing information about the name, administrator and impact of the increase in the
benchmark on the loan interest rate. The CJEU confirmed that banks are not obliged to disclose to consumers the
method of determining the benchmark. However, the CJEU stressed that even a breach of information obligations
regarding variable interest rates is not sufficient to declare the agreement invalid. In order to establish this, the
court must examine the fairness of the clause. Due to the short period of time since the verdict, it is not known at
this moment how it will affect the jurisprudence of Polish courts. However, it should be estimated that the existing
line of jurisprudence in WIBOR cases will be strengthened, according to which no final judgment unfavorable to
banks has been issued so far.
Court proceedings concerning the sanction of free credit
As at 31 December 2025, there were 103 court proceedings against the Bank (75 proceedings as at 31 December
2024) regarding the free loan sanction. As at 31 December 2025, 39 cases were already completed (23 cases
as at 31 December 2024), while none of them had any irregularities in contracts that would have been the basis for
recognising the statement on the sanction of the free loan.
A lawsuit by borrower against one of the banks was brought to the court in Poland for the imposition of a free loan
sanction, i.e. depriving the lender of the right to interest and other fees resulting from the agreement. In the course
of the proceedings, the court raised certain doubts, with which it referred a preliminary ruling to the CJEU.
On 13 February 2025, the CJEU issued a judgement in Case C-472/23, answering the following questions asked
by the Polish court:
1) The fact that the credit agreement refers to an annual percentage rate of charge which is overstated because
certain terms of the agreement were subsequently found to be unfair (i.e. abusive) and therefore not binding
on the consumer does not in itself constitute a breach of the obligation to provide information.
2) The fact that the credit agreement mentions a number of circumstances justifying an increase in the charges
relating to the performance of the contract, without the consumer, who is reasonably well informed and
reasonably observant and circumspect, being able to ascertain whether those charges have occurred or whether
they have had an effect on them, constitutes an infringement of the obligation to provide information, in so far
as that indication is liable to call into question the consumer’s ability to assess the extent of his obligation.
3) Article 23 of Directive 2008/48 does not preclude national legislation which provides, in the event of a breach
of the obligation to provide information imposed on the creditor, for a uniform penalty consisting in depriving the
creditor of his right to interest and charges, irrespective of the individual degree of seriousness of the breach,
in so far as that breach is liable to undermine the consumer’s ability to assess the extent of his obligation.
In this judgement, the CJEU recalled that the law requires a number of detailed information to be provided
in a consumer credit agreement, including the actual interest rate (calculated according to the given mathematical
formula) and the total cost of the credit incurred by the consumer. One of the elements of the dispute in the main
proceedings was that, once the abusive provision has been removed, the APR is lower than that stated in the
contract. However, in the CJEU’s opinion, the situation that the deletion of the contested provision leads
to an overstatement of the APR calculated by the lender according to the aforementioned mathematical formula
does not mean a breach of information obligations. The CJEU pointed out that this does not mean, however, that
the creditor had the right to freely and arbitrarily change the terms of the agreement, including the amount of fees,
in the course of its implementation. Information on loan repayment terms is a key element, including the reasons
for changing these parameters - therefore the agreement should indicate in a transparent manner the reasons and
manner of changes in the amount of fees related to the loan granted.

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The CJEU also addressed whether a civil court verdict may result in a free loan sanction depriving the bank of all its
receivables, or whether it should be proportional to the scale of violations. The CJEU pointed out that according
to the directive, these consequences should be effective, proportionate and dissuasive, so their severity should
be adequate to the gravity of the violation. Therefore, since the lack of correct information restricts the consumer’s
exercise of his rights and makes it difficult to understand his obligations, the CJEU considers that the sanction
of a free loan provided for by national law can be considered disproportionate only if the breach of the information
obligations could not affect the consumer’s ability to assess his obligations. That, in turn, means that national law
may allow a penalty in the form of deprivation of interest and other entitlements to the creditor - but the
assessment of the conditions and circumstances obviously depends on the facts and must therefore be carried out
by the referring court.
Other proceedings
On 23 January 2020, the Bank received a notice from the President of the Office for Personal Data Protection
(President of the DPA) regarding the audit of the compliance of the processing of personal data with personal data
protection regulations, i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016
on the protection of natural persons with regard to the processing of personal data and on the free movement
of such data and repealing Directive 95/46/EC (General Data Protection Regulation) and the Act of 10 May 2018
on personal data protection. On 9 December 2021, the Bank received a notice from the President of UODO on the
initiation of ex officio administrative proceedings in this area. On 28 July 2025, the Bank received the decision
of UODO to impose a fine of PLN 18 million. The Bank created a provision for the amount of the fine and recognized
it in the costs of 2025. The Bank appealed against the decision using the right to lodge a complaint with the
Voivodeship Administrative Court in Warsaw.
34. Other liabilities

as at 31 December |  |
| 2025 | 2024
Accruals, including: | 979 | 1,053
due to employee benefits | 388 | 406
of which variable remuneration programme | 57 | 54
due to commissions | 227 | 210
due to general and administrative expenses | 364 | 437
Other liabilities, including: | 2,705 | 2,528
lease liabilities | 497 | 529
interbank settlements | 1,194 | 1,023
settlements with suppliers | 164 | 163
public and legal settlements | 216 | 196
liability to pay to the BFG guarantee fund | 202 | 172
liability to pay to the BFG resolution fund | 295 | 244
other: | 137 | 201
Total | 3,684 | 3,581
Including financial liabilities | 2,705 | 2,528
Expected settlement period of other liabilities |  |
up to 1 year | 3,053 | 2,705
over 1 year | 631 | 876

35. Equity
35.1. Share capital
The Parent entity's share capital is PLN 130,100,000 and is sub-divided into:
• 92,600,000 A-series ordinary bearer's shares with face value of PLN 1.00 each, and
• 37,500,000 B-series ordinary bearer's shares with face value of PLN 1.00 each.
Each ordinary share entitles its holder to dividend and one vote during the general meeting. All shares are fully
paid.
35.2. Accumulated other comprehensive income
The following table presents the balances of accumulated other comprehensive income as at 31 December 2025
and 31 December 2024, respectively. The tables on next page show the reconciliation of changes in accumulated
other comprehensive income during 2025 and 2024.

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December |  |
| 2025 | 2024
Accumulated other comprehensive income, including: |  |
from financial assets measured through other comprehensive income - debt instruments, including: | -37 | -5
deferred tax | -53 | -50
current tax * | 49 | 51
from financial assets measured through other comprehensive income - equity instruments, including: | 212 | 186
deferred tax | -63 | -44
from cash flow hedges, including: | -2,023 | -4,849
deferred tax | -18 | -9
current tax ** | 487 | 1,147
from actuarial gains / losses, including: | -36 | -31
deferred tax | 11 | 7
Total | -1,884 | -4,699

*) current tax on the valuation of debt instruments - due to the fact that the debt securities included in all portfolios
are jointly owned by one taxpayer of corporate income tax (hereinafter "CIT"), the Bank calculated for all portfolios
jointly, separately for each security and using the FIFO method, tax results on purchase and sale of debt securities.
The method of determining tax results on the purchase/sale of debt securities results in a different distribution
of the results achieved in terms of valuation than for accounting purposes. Accounting unrealised valuation
in accumulated other comprehensive income for CIT purposes becomes a realised valuation, on which the Bank
pays current tax. For this reason the current tax is recorded for the part of the unrealised valuation in accumulated
other comprehensive income that is realised in terms of CIT.
**) current tax on the valuation of hedging derivatives - the Group uses the service “settlement-to-market”,
or “STM”, provided for by the Regulation of the KDPW/LCH/EUREX (CCP) in respect of the approach to the settlement
of IRS and FRA instruments. Even though the effective portion of the derivative hedge instruments resulting from
the measurement of derivative hedging instruments is recognised in other comprehensive income, due to the STM
mechanism it is settled in cash and the amount paid to/ received from CCP represents tax income/ expense for the
purpose of the corporate income tax (CIT). That is why the current tax is recognised in other comprehensive income.
Details on the STM services are presented in note 17. Valuation of derivatives.
Accumulated other comprehensive income - change in balance

for the year ended 31 December 2025 |  |  |  |  |
| changes in the fair value of financial assets measured through other comprehensive income | cash flow hedges | actuarial gains / losses | Total
debt instruments | equity instruments
Balance at the beginning of the period | -5 | 186 | -4,849 | -31 | -4,699
gains/losses on revaluation carried through equity | 9 | 26 | 1,271 | - | 1,306
transfer to financial result in connection with the sale | -41 | - | 1,555 | - | 1,514
actuarial gains/losses | - | - | - | -5 | -5
Balance at end of period | -37 | 212 | -2,023 | -36 | -1,884

for the year ended 31 December 2024 |  |  |  |  |
| changes in the fair value of financial assets measured through other comprehensive income | cash flow hedges | actuarial gains / losses | Total
debt instruments | equity instruments
Balance at the beginning of the period | -69 | 171 | -5,169 | -28 | -5,095
gains/losses on revaluation carried through equity | 55 | 15 | -1,447 | - | -1,377
transfer to financial result in connection with the sale | 9 | - | 1,767 | - | 1,776
actuarial gains/losses | - | - | - | -3 | -3
Balance at end of period | -5 | 186 | -4,849 | -31 | -4,699

In the item financial assets measured at fair value through other comprehensive income – gains/losses on revaluation
carried through equity in relation to debt securities, changes in the fair value of items classified in this category have
been presented, without taking into account the changes resulting from the valuation of the hedged risk, in terms
of items covered by the fair value hedge accounting.
With respect to cash flow hedges:
• in the item gains/losses on revaluation carried through equity - the amount of the effective part of the hedging
relationship in the cash flow hedging strategy of the portfolio of financial assets/liabilities is presented.
• in the item transfer to the financial result - the amortization of the effective part of the hedging relationship of the
cash flow hedging strategy was presented on the dates when the hedged item results in the profit or loss.
The rules relating to the above items are described in detail in chapter III. Significant accounting principles, in item
13.8.1. and in the section Risk and capital management, in chapter II.3.8. Hedge accounting.
35.3. Retained earnings

as at 31 December |  |
| 2025 | 2024
Other supplementary capital | 315 | 315
Reserve capital | 15,931 | 14,803
General risk fund | 1,215 | 1,215
Valuation of share-based payments, including: | 32 | 24
deffered tax | -9 | -5
Retained earnings from previous years | 23 | 57
Result for the current year | 4,633 | 4,369
Total | 22,149 | 20,783

Supplementary capital
Supplementary capital is formed from appropriations from profit after tax, surpluses generated under issue
of shares above their face value and extra contributions paid up by the shareholders to be used for covering
balance-sheet losses. The decision on the use of the supplementary capital is taken at the General Meeting.

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Reserve capital
The reserve capital is created irrespective of the supplementary capital from profit after tax write-offs, in the
amount passed by the General Meeting. The reserve capital may be allocated to cover special costs and expenses,
and also to increase the share capital from the Bank’s funds. The decision on activation of the reserve capital
is taken by the General Meeting.
General Risk Fund
The General Risk Fund is established in accordance with the Banking Law Act from the post-tax profits and is used
for unidentified risk of banking activity. The decision on the use of the Fund is taken by the Management Board.
Dividend payout
The dividend is paid based on the financial result determined in the separate annual financial statements of the
Parent company and the Group companies. Details of the Group’s dividend policy and divided payout constraints
are included in the section Risk and capital management, in item I.5. Dividend Policy.
Retained earnings - change in balance

as at 31 December 2025 |  |  |  |  |  |  |
| Other supplemen- tary capital | Reserve capital | General risk fund | Valuation of share-based payments | Retained earnings from previous years | Result for the current year | Total
Balance at the beginning of the period | 315 | 14,803 | 1,215 | 24 | 4,426 | - | 20,783
net result for the current period | - | - | - | - | - | 4,633 | 4,633
dividend payment* | - | - | - | - | -3,276 | - | -3,276
write-down of profit to reserve capital | - | 1,150 | - | - | -1,150 | - | -
valuation of incentive employee programmes | - | - | - | -14 | 14 | - | -
using the reserve capital created for the implementation of the employee incentive programme | - | -22 | - | 22 | - | - | -
purchase of own shares for the purposes of the employee incentive program | - | - | - | - | 22 | - | 22
settlement of the acquisition and transfer of own shares to employees | - | - | - | - | -13 | - | -13
Balance at end of period | 315 | 15,931 | 1,215 | 32 | 23 | 4,633 | 22,149

*) In 2025, the Bank paid out a dividend from the 2024 profit in the amount of PLN 3.276 million, i.e. PLN 25.18 per
share.

as at 31 December 2024 |  |  |  |  |  |  |
| Other supplemen- tary capital | Reserve capital | General risk fund | Valuation of share-based payments | Retained earnings from previous years | Result for the current year | Total
Balance at the beginning of the period | 315 | 14,699 | 1,215 | 72 | 4,449 | - | 20,750
net result for the current period | - | - | - | - | - | 4,369 | 4,369
dividend payment* | - | - | - | - | -4,339 | - | -4,339
write-down of profit to reserve capital | - | 110 | - | - | -110 | - | -
valuation of incentive employee programmes | - | - | - | -54 | 52 | - | -2
using the reserve capital created for the implementation of the employee incentive programme | - | -6 | - | 6 | - | - | -
purchase of own shares for the purposes of the employee incentive program | - | - | - | - | 6 | - | 6
settlement of the acquisition and transfer of own shares to employees | - | - | - | - | -1 | - | -1
Balance at end of period | 315 | 14,803 | 1,215 | 24 | 57 | 4,369 | 20,783

*) In 2024, the Bank paid out a dividend from the 2023 profit and from the reserve capital allocated for the payment
of dividend in the amount of PLN 4,339 million, i.e. PLN 33.35 per share.

70 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

36. Contingent liabilities
36.1. Contingent liabilities granted

as at 31 December |  |
| 2025 | 2024*
Undrawn credit facilities | 49,821 | 43,416
Guarantees | 9,273 | 8,014
Credit card limits | 2,108 | 1,896
Undrawn overdrafts in current account | 1,386 | 1,409
Letters of credit | 391 | 393
Reverse transactions | - | 281
Total | 62,979 | 55,409

*) The data as at 31 December 2024 included liabilities due to binding offers in the amount of PLN 904 million, which
in the consolidated financial statements for 2024 were presented as supplementary information under the table.
Currently, these liabilities are presented in individual items of the table, according to the product to which they
relate.
The Group has commitments to grant loans. These obligations include approved loans, credit card limits and
overdrafts in current accounts. The Group issues guarantees and letters of credits to secure fulfilment of obligations
of the Group’s customers to third parties. The value of guarantees and letters of credit disclosed above reflects the
maximum loss that can be incurred and that would be disclosed as at the balance sheet date should the customers
fail to fulfil their obligations in full.
The Group charges commissions for contingent liabilities granted, which are settled in line with the specific nature
of the particular instrument.
Financial guarantee contracts by maturity

as at 31 December |  |
| 2025 | 2024
up to 1 month | 155 | 167
over 1 month and up to 3 months | 786 | 865
over 3 months and up to 1 year | 3,176 | 3,557
over 1 year and up to 5 years | 4,515 | 2,749
over 5 years | 641 | 676
Total | 9,273 | 8,014

36.2. Contingent liabilities received

as at 31 December |  |
| 2025 | 2024
Guarantees received | 23,285 | 24,276
Financing | 4,877 | 1,948
Total | 28,162 | 26,224

Guarantee commitments received consist of collateral values for loans granted by the Bank. Funding commitments
received include the value of deposits and loans that do not meet the criteria for recognition in the statement
of financial position at the time of the financial statements.
37. Fair value
37.1. Financial assets and liabilities measured at fair value in statement of financial position
Based on the methods used to determine fair value, the Group classifies individual financial assets/liabilities into one
of three categories, the so-called level in the fair value measurement hierarchy. The description of particular levels
of the valuation hierarchy is contained in chapter III. Significant accounting principles, in item 13.7.
In 2025, as in 2024, there were no transfers between levels of the valuation hierarchy.
The carrying amounts of financial assets and liabilities measured at fair value are presented below, broken down
by measurement hierarchy levels.

as at 31 December 2025 |  |  |  |
| Level 1 | Level 2 | Level 3 | Total
Financial assets, including: | 39,298 | 1,315 | 307 | 40,920
Financial assets held for trading, including: | 1,090 | 1,242 | - | 2,332
valuation of derivatives | - | 818 | - | 818
other financial assets held for trading, including: | 1,090 | 424 | - | 1,514
debt securities, including: | 1,090 | - | - | 1,090
treasury bonds in PLN | 976 | - | - | 976
Czech Treasury bonds | 114 | - | - | 114
repo transactions | - | 424 | - | 424
Financial assets other than those held for trading, measured at fair value through profit or loss, including: | - | - | 8 | 8
loans are obligatorily measured at fair value through profit or loss | - | - | 7 | 7
equity instruments | - | - | 1 | 1
Derivative hedge instruments | - | 73 | - | 73
Financial assets measured at fair value through other comprehensive income, including: | 38,208 | - | 299 | 38,507
debt securities, including: | 38,208 | - | - | 38,208
treasury bonds in PLN | 33,156 | - | - | 33,156
European Union bonds | 1,947 | - | - | 1,947
European Investment Bank bonds | 2,689 | - | - | 2,689
Austrian government bonds | 416 | - | - | 416
equity instruments | - | - | 299 | 299
Financial liabilities, including: | 418 | 575 | - | 993
Financial liabilities held for trading, including: | 418 | 498 | - | 916
valuation of derivatives | - | 498 | - | 498
book short position in trading securities | 418 | - | - | 418
Derivative hedge instruments | - | 77 | - | 77

71 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December 2024 |  |  |  |
| Level 1 | Level 2 | Level 3 | Total
Financial assets, including: | 32,385 | 1,466 | 276 | 34,127
Financial assets held for trading, including: | 521 | 1,405 | - | 1,926
valuation of derivatives | - | 898 | - | 898
other financial assets held for trading, including: | 521 | 507 | - | 1,028
debt securities, including: | 521 | - | - | 521
treasury bonds in PLN | 499 | - | - | 499
Czech Treasury bonds | 22 | - | - | 22
repo transactions | - | 507 | - | 507
Financial assets other than those held for trading, measured at fair value through profit or loss, including: | - | - | 22 | 22
loans are obligatorily measured at fair value through profit or loss | - | - | 21 | 21
equity instruments | - | - | 1 | 1
Derivative hedge instruments | - | 61 | - | 61
Financial assets measured at fair value through other comprehensive income, including: | 31,685 | - | 254 | 31,939
debt securities, including: | 31,685 | - | - | 31,685
treasury bonds in PLN | 26,371 | - | - | 26,371
European Union bonds | 2,064 | - | - | 2,064
European Investment Bank bonds | 2,838 | - | - | 2,838
Austrian government bonds | 412 | - | - | 412
equity instruments | - | - | 254 | 254
Transferred assets, including: | 179 | - | - | 179
Treasury bonds in PLN from the portfolio of financial assets measured at fair value through profit or loss | 179 | - | - | 179
Financial liabilities, including: | 487 | 996 | - | 1,483
Financial liabilities held for trading, including: | 487 | 913 | - | 1,400
valuation of derivatives | - | 733 | - | 733
book short position in trading securities | 487 | - | - | 487
repo transactions | - | 180 | - | 180
Derivative hedge instruments | - | 83 | - | 83

Valuation of financial instruments classified to level 2 of the valuation hierarchy
The Group classifies derivatives and repo transactions to level 2 of valuation hierarchy.
Derivatives
The following models are applied for non-linear transactions (FX options), depending on the product type:
• the European vanilla option and a European digital option – the Garman-Kohlhagen model,
• Cap/Floor (back-to-back transactions) – the Bachelier model.
The following are the input data for the models:
• the FX rate – obtained by the parties from the National Bank of Poland’s website,
• implied volatilities – obtained from Bloomberg,
• profitability curves similar to those for linear derivatives.
Fair value for linear instruments (other derivatives) is determined based on discounted future cash flows at the
transaction level. The fair value determined in that manner is the PV of those cash flows.
All input data used for the creation of the revaluation curves are observed on the market, and include: deposit
market rates, forward points, FRA rates, IRS rates, OIS rates, FX basis points, basis points among the indexes for
variable rates, and FX rates. The data come from the Reuters system and come mainly from brokers. Market data
quality is controlled during the daily contribution process for revaluation rates.
Derivatives are generally valued according to the concept of OIS curves with the assumption of the existence
of transaction valuation collateral in the form of a deposit bearing interest at the ESTR rate. The exceptions are
transactions in PLN and CZK subject to settlement within central clearing houses (LCH, KDPW, EUREX) and bilateral
transactions concluded on the basis of an ISDA agreement with a CSA annex in the collateral currency of PLN
or without the annex. For these transactions, the NPV is settled in the original currency, which is reflected in the
valuation curves used (discount curve based on IBOR, FRA and IRS quotes).
Repurchase transactions
Fair value for repurchase transactions is determined based on future payment flows discounted according to the
profitability curve for instruments with payment flow (so-called cash instruments).
Valuation of financial instruments classified to level 3 of the valuation hierarchy
The financial assets classified to level 3 of the valuation as at 31 December 2025 and 31 December 2024 include
unlisted equity instruments and loans that did not meet the SPPI criterion according to IFRS 9.
Equity instruments
Fair value measurement of unquoted equity interests in other companies is based on the discounted cash flow,
dividend or economic value added model. Estimates of future cash flows were prepared based on medium-term
profitability forecasts prepared by the Management Boards of these companies. The discount rate is based on the
cost of equity estimated using the CAPM (Capital Asset Pricing Model). At the end of 2025 , it was in the range
of 11.1%-13.1%, depending on the company, compared to 11.7%-13.7% at the end of 2024. Fair value
measurement of unquoted equity interests in other companies as at 31 December 2025 and 31 December 2024
covered the following entities: Biuro Informacji Kredytowej S.A., Krajowa Izba Rozliczeniowa S.A. and Polski Standard
Płatności sp. z o.o.
As at 31 December 2025, the sensitivity analysis of the valuation of equity instruments shows that:
• adoption of the target dividend payment rate by +10p.p. / -10p.p. compared to the base scenario, would result
in a valuation increase/decrease of 9% (by 10% as at 31 December 2024);

72 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• adopting the cost of equity by -0.5p.p. / +0.5p.p. compared to the base scenario, would result in a valuation
increase by 6%/ decrease by 5% (increase by 6%/decrease by 5% as at 31 December 2024);
• a combination of effects from points 1) and 2), would result in respectively an increase of valuation by 16% /
decrease of valuation by 14% (11%/9% as at 31 December 2024).
In 2025, the change in the valuation of equity instruments classified to level 3 of the valuation hierarchy included
in other comprehensive income amounted to PLN 26 million (in 2024: PLN 15 million).
Loans
The fair value methodology of the loan portfolio is based on the discounted cash flow method. Under this method,
for each contract being valued, expected cash flows are estimated, discount factors for particular payment dates
and the value of discounted cash flows is determined as at the valuation date. Valuation models are powered
by business parameters for individual contracts and parameters observable by the market, such as interest rate
curves, liquidity cost and cost of capital. The change in the parameters adopted for the valuation did not have
a significant impact on the valuation value as at 31 December 2025.
The impact of the valuation of loans classified to level 3 of the valuation hierarchy is presented in the statement
of profit or loss in the item Net income on financial instruments measured at fair value through profit or loss and
FX result. It was negligible both in 2025 and in 2024.
Change in financial assets classified to level 3 of the measurement hierarchy

for the year ended 31 December 2025 |  |  |
| loans obligatorily measured at fair value through profit or loss | equity instruments measured at fair value through profit or loss | equity instruments measured at fair value through other comprehensive income
Opening balance | 21 | 1 | 254
Additions, including: | - | - | 45
valuation recognised in accumulated other comprehensive income | - | - | 45
Reductions, including: | -14 | - | -
loan repayments | -14 | - | -
Closing balance | 7 | 1 | 299

for the year ended 31 December 2024 |  |  |
| loans obligatorily measured at fair value through profit or loss | equity instruments measured at fair value through profit or loss | equity instruments measured at fair value through other comprehensive income
Opening balance | 39 | - | 236
Additions, including: | - | 1 | 18
valuation referred to accumulated other comprehensive income | - | - | 18
Reductions, including: | -18 | - | -
loan repayments | -18 | - | -
Closing balance | 21 | 1 | 254

37.2. Non-financial assets measured at fair value in the statement of financial position
Own real property
The Group measures properties held at fair value and classifies them to level 3 of the measurement hierarchy.
At the end of 2025 , their balance sheet value was PLN 181 million, compared to PLN 185 million a the end of 2024.
The change in the balance of own property is presented in this report in note 23. Properyty, plant and equipment.
The valuation of the own property is carried out by an independent valuer using the income method in accordance
with the applicable rules for the valuation of the property. The results of real properties appraisals were presented
in the income statement in the item General and administrative expenses (in note 8 ., in detailed item maintenance
costs of buildings and real estate valuation to fair value).
As at 31 December 2025, the sensitivity analysis of the valuation of own property indicates that, assuming
a capitalisation rate of -0.5p.p. / +0.5p.p. compared to the base scenario, it would result in a valuation increase
of 6.2% (PLN 16 million) / a valuation decrease of 5.5% (PLN 14 million), respectively.
As at 31 December 2024 the sensitivity analysis of the valuation of own property indicates that, assuming
a capitalisation rate of -0.5p.p. / +0.5p.p. compared to the base scenario, it would result in a valuation increase
of 6.1% (PLN 16 million) / a valuation decrease of 5.4% (PLN 14 million), respectively.
37.3. Financial assets and liabilities not measured at fair value in consolidated statement of financial position
The tables present a comparison of the carrying amount with the fair value for investment securities measured
at amortized cost, the loan portfolio and amounts due to customers, liabilities arising from the issue of securities
and subordinated liabilities. For other financial assets and liabilities as well as guarantees and off-balance sheet
liabilities not measured at fair value in the consolidated statement of financial position, the fair value is close to the
carrying amount.
In 2025, the same as in 2024, there were no transfers between levels of the valuation hierarchy.

73 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December 2025 |  |  |  |  |
| Carrying amount | Fair value
Level 1 | Level 2 | Level 3 | Total
Investment securities at amortised cost | 27,049 | 24,534 | 2,042 | - | 26,576
treasury bonds in PLN | 15,822 | 15,680 | - | - | 15,680
treasury bonds in EUR | 1,972 | 1,901 | - | - | 1,901
European Investment Bank bonds | 7,111 | 6,953 | - | - | 6,953
bonds of the Polish Development Fund (PFR) | 1,845 | - | 1,750 | - | 1,750
Bank Gospodarstwa Krajowego bonds | 199 | - | 192 | - | 192
NBP bills | 100 | - | 100 | - | 100
Loans and receivables to customers at amortised cost, including: | 180,309 | - | - | 181,056 | 181,056
Corporate banking segment, including: | 97,462 | - | - | 97,864 | 97,864
loans and advances (in the current account and term ones) | 72,651 | - | - | 73,370 | 73,370
lease receivables | 13,672 | - | - | 13,493 | 13,493
factoring receivables | 6,472 | - | - | 6,472 | 6,472
corporate and municipal debt securities | 4,667 | - | - | 4,529 | 4,529
Retail banking segment, including: | 79,536 | - | - | 79,881 | 79,881
mortgages | 69,096 | - | - | 69,140 | 69,140
other loans and advances | 10,440 | - | - | 10,741 | 10,741
Other receivables | 3,311 | - | - | 3,311 | 3,311
Liabilities to customers | 235,328 | - | - | 235,331 | 235,331
Liabilities from debt securities issued | 1,521 | - | - | 1,555 | 1,555
Subordinated liabilities | 2,548 | - | - | 2,634 | 2,634

as at 31 December 2024 |  |  |  |  |
| Carrying amount | Fair value
Level 1 | Level 2 | Level 3 | Total
Investment securities at amortised cost | 27,053 | 20,459 | 5,384 | - | 25,843
treasury bonds in PLN | 11,859 | 11,317 | - | - | 11,317
treasury bonds in EUR | 2,872 | 2,750 | - | - | 2,750
European Investment Bank bonds | 6,654 | 6,392 | - | - | 6,392
bonds of the Polish Development Fund (PFR) | 3,860 | - | 3,618 | - | 3,618
Bank Gospodarstwa Krajowego bonds | 1,808 | - | 1,766 | - | 1,766
Loans and receivables to customers at amortised cost, including: | 166,677 | - | 1,040 | 165,836 | 166,876
Corporate banking segment, including: | 93,052 | - | - | 93,329 | 93,329
loans and advances (in the current account and term ones) | 68,572 | - | - | 69,213 | 69,213
lease receivables | 13,342 | - | - | 13,134 | 13,134
factoring receivables | 6,571 | - | - | 6,571 | 6,571
corporate and municipal debt securities | 4,567 | - | - | 4,411 | 4,411
Retail banking segment, including: | 70,387 | - | - | 70,309 | 70,309
mortgages | 61,114 | - | - | 60,783 | 60,783
other loans and advances | 9,273 | - | - | 9,526 | 9,526
Other receivables | 3,238 | - | 1,040 | 2,198 | 3,238
Liabilities to customers | 219,996 | - | - | 219,925 | 219,925
Liabilities from debt securities issued | 509 | - | - | 509 | 509
Subordinated liabilities | 1,499 | - | - | 1,610 | 1,610

The Group discloses the data on the fair value of loans and deposits recognised respectively in the groups
of financial assets and financial liabilities carried at amortised cost considering the effective interest rate.
For the purpose of fair value calculation of the PLN mortgage loan portfolio, a yield curve containing transfer prices
is used, which are calculated on the basis of WIBOR 1M, WIBOR 6M and WIRON 1M rates, respectively.
To compute fair value of other assets and deposits measured at amortised cost and financial liabilities measured
at amortised cost considering the effective interest rate the transfer price is applied. The transfer price is calculated
as:
• PLN: BID rates being WIBID overnight, OFFER rates being WIBOR overnight.
• EUR: BID rates being EURIBOR overnight, OFFER rates being EURIBOR overnight.
• USD and CHF: BID rates being LIBOR overnight, OFFER rates being LIBOR overnight.
BID rates are used to compute fair value of financial liabilities measured at amortised cost; in the case of financial
assets measured at amortised cost OFFER rates are applied. All intermediate points on the curves are interpolated
linearly.
Credit loss estimations reflect the credit loss provisioning model in place at the Group in the model of impairment
for expected credit losses.
In certain aspects, the model adopted by the Group is based on the assumptions that do not confirm the prices
of verifiable current market transactions referring to the same instrument – the model does not take into account
restructuring-based changes either.
Loans and other receivables
The credit portfolio including securities classified to financial assets measured at amortised cost is divided into sub-
portfolios according to the product type, client segment and the currency. In the case of those sub-portfolios, the
discounting factor is used for each cash flow.
For loans/securities, the discounting factor is assumed as the total of:
• the market rate based on the yield curve as at the balance sheet date, and
• the average margin based on the portfolio of loans granted in the first and second month of the current quarter.
For that purpose, the following assumptions are adopted:
• use to calculate loans granted in the first and second month of the current quarter,
• division into the abovementioned product groups, and

74 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• the spot at the yield curve on the basis of which the relevant market rate is set is reflected by the revaluation
date for each loan.
As a result for loans and other receivables, the fair value, that arises during calculation, is the total of the net
present value of cash flows of a single loan/ security (in the case of the mortgage portfolio, the fair value is the total
of the net present value of cash flows of the aggregated mortgage portfolio).
In the case of the portfolio of mortgage loans in PLN, the income method is used to measure them at fair value.
Key assumptions:
• for the needs of the valuation, the original schedule of principal and interest repayments is adjusted by taking
into account prepayments, credit risk and adopting a timely structure of interest rates,
• credit risk parameters, i.e. PD lifetime and LGD, discounted for the purposes of the valuation, are included in the
expected cash flows,
• for the purposes of estimating cash flows, prepayments are taken into account, estimated based on the analysis
of historical data on the basis of the prepayment model used,
• the calculation of the discount rate adopted to estimate the value of cash flows takes into account all risks and
costs, excluding the prepayment risk and credit risk costs reflected in the flows,
• prepayment risk is reflected in cash flows,
• application of the calibration margin determined on the basis of the portfolio of mortgage loans granted in the
first and second month of the current quarter, analogous to the measured portfolio.
The fair value of the loan is calculated as the sum of discounted cash flows from principal repayments and interest
payments, taking into account the prepaid capital and the cost of credit risk.
In the case of loans without any repayment schedules and loans from the impaired group, it is assumed that the
fair value for those loans equals their book value.
Investment securities measured at amortised cost
In the case of investment securities measured at amortized cost, the fair value of disclosure securities that are
quoted on an active market is determined based on the price in this market, for other securities in this portfolio the
model described above in Loans and other receivables is used.
38. Offsetting of financial instruments
The following disclosure relates to offsetting financial assets and financial liabilities that are subject to an
enforceable contingent master agreement. ISDA agreements (for derivative transactions) and GMRA (for securities
repo and reverse repo transactions) are the main framework agreements concluded by the Group. Additional
collateral for derivative exposures are security deposits, which the Group makes and receives as part of the so-
called Credit Support Annex (CSA), i.e. attachments to ISDA agreements.
Financial assets

as at 31 December 2025 |  |  |  |  |
| Gross amounts of recognised financial assets | Net amounts of financial assets presented in the statement of financial position | Related amounts not offset in the statement of financial position | Net amount
Financial instruments | Cash collateral received
Derivatives, including: | 1,050 | 891 | -287 | -358 | 246
valuation of derivatives | 872 | 818 | -226 | - | 592
derivative hedge instruments | 178 | 73 | -61 | - | 12
derivatives collateral | - | - | - | -358 | -358
Securities loans with repurchase agreements received, including: | 23,525 | 23,525 | - | -23,773 | -248
transactions classified as loans and other receivables to other banks | 23,101 | 23,101 | - | -23,365 | -264
transactions classified as held for trading financial assets | 424 | 424 | - | -408 | 16
Total |  |  |  |  | -2

Financial Liabilities

as at 31 December 2025 |  |  |  |  |
| Gross amounts of recognised financial liabilities | Net amounts of financial liabilities presented in the statement of financial position | Related amounts not offset in the statement of financial position | Net amount
Financial instruments | Cash collateral pledged
Derivatives, including | 735 | 575 | -287 | -14 | 274
valuation of derivatives | 597 | 498 | -226 | - | 272
derivative hedge instruments | 138 | 77 | -61 | - | 16
derivatives collateral | - | - | - | -14 | -14
Total |  |  |  |  | 274

75 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Financial assets

as at 31 December 2024 |  |  |  |  |
| Gross amounts of recognised financial assets | Net amounts of financial assets presented in the statement of financial position | Related amounts not offset in the statement of financial position | Net amount
Financial instruments | Cash collateral received
Derivatives, including: | 1,139 | 959 | -287 | -580 | 92
valuation of derivatives | 963 | 898 | -226 | - | 672
derivative hedge instruments | 176 | 61 | -61 | - | -
derivatives collateral | - | - | - | -580 | -580
Securities loans with repurchase agreements received, including: | 22,326 | 22,326 | - | -22,177 | 149
transactions classified as loans and other receivables to other banks | 20,779 | 20,779 | - | -20,661 | 118
transactions classified as loans and other receivables granted to customers | 1,040 | 1,040 | - | -494 | 546
transactions classified as held for trading financial assets | 507 | 507 | - | -1,022 | -515
Total |  |  |  |  | 241

Financial Liabilities

as at 31 December 2024 |  |  |  |  |
| Gross amounts of recognised financial liabilities | Net amounts of financial liabilities presented in the statement of financial position | Related amounts not offset in the statement of financial position | Net amount
Financial instruments | Cash collateral pledged
Derivatives, including | 996 | 816 | -287 | -53 | 476
valuation of derivatives | 842 | 733 | -226 | - | 507
derivative hedge instruments | 154 | 83 | -61 | - | 22
derivatives collateral | - | - | - | -53 | -53
Securities loans with repurchase agreements received, including: | 180 | 180 | - | -179 | 1
transactions classified as held for trading financial liabilities | 180 | 180 | - | -179 | 1
Total |  |  |  |  | 477

39. Supplementary information to the consolidated statement of cash flows
Cash and cash equivalents
For the purposes of the consolidated statement of cash flows, the Group accepts as cash and cash equivalents
assets in the form of cash and other cash, cash on accounts with the Central Bank and cash on accounts with other
banks (including balances on current accounts and overnight deposit accounts and balances of call margins
posted). These financial assets are presented in the consolidated statement of financial position in Cash and cash
equivalents and in the note 14.
Explanation of the classification of the Group’s activities into operating, investment and financial activities in
the consolidated cash flow statement
Operating activity includes the core activities of the Group, not classified as investment or financial activities.
Investing activities include the acquisition and sale of property, plant and equipment, intangible assets and debt
securities measured at amortised cost (excluding short-term treasury bills and NBP bills). Inflows from investment
activities also include dividends received on account of the holding of shares in other entities.
Financial activities concern long-term (over 1 year) financial operations carried out with financial entities. Inflows
from financial activities indicate the sources of financing of the Group, obtained e.g. by taking long-term loans and
borrowings from other banks and from financial entities other than banks or by issuing debt securities. Outflows
from financing activities mainly concern repayments of long-term liabilities by the Group (i.a. repayments of loans
and interest received, redemption of issued debt securities and interest payments on them, repayments of lease
liabilities), and also include dividend payments to owners and acquisition of own shares for the purposes of the
employee incentive programme.
Reasons for the differences between the changes in certain items reported in the consolidated statement of
financial position and in the consolidated cash flows statement
Below are presented the differences between the changes in the balance resulting from the consolidated
statement of financial position and the changes reported in the consolidated cash flow statement.

76 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The explanations for the reasons for the differences are as follows

Difference no | Explanation of the reasons for the difference
Difference 1 | Changes in the balance of individual assets and liabilities have been adjusted for interest, which is presented in the item Interest received (from assets) or Interest paid (from liabilities).
Difference 2 | Changes in the valuation of fair value recognized in other comprehensive income are excluded from the changes in the balances of individual assets and liabilities.
Difference 3 | Changes in the balances of Investment Securities exclude changes related to the purchase and sale or redemption of debt securities valued at amortized cost (excluding short-term Treasury bills and NBP money bills). These changes were presented as cash flows from investing activities.
Difference 4 | The change in other assets includes non-monetary - except depreciation - changes in the carrying amount of property, plant and equipment and intangible assets (cash changes related to these items are presented in cash flows from investing activities).
Difference 5 | The amount of lease liabilities repaid was excluded from the change in other liabilities, which was presented in cash flows on financing activities.
Difference 6 | The amounts contracted were excluded from the change in liabilities to other banks and the amounts of repayments of loans for long-term financing, which together with the amount of interest payments on these loans, were presented in cash flows on financing activities, were excluded from the change in liabilities to other banks.
Difference 7 | The amount of the settlement of the acquisition of own shares for the purposes of the incentive scheme, which was recognised in retained earnings, was excluded from the change in other liabilities.
Difference 8 | Changes in liabilities from securities issues and C hanges in subordinated liabilities due to the issue and redemption of debt securities as well as changes resulting from the incurrence of subordinated liabilities are excluded. These changes, together with the amount of interest payments on these instruments, are presented in cash flows on financing activities.

77 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

In the tables below, individual differences are numbered according to the list presented in the table above.

for the year ended 31 December 2025 |  |  |  |  |  |  |  |  |  |  |
| change od balance |  |  |  |  |  |  |  |  |
in consolidated statement of financial position | in consolidated cash flow statement | difference, including: | Difference 1 | Difference 2 | Difference 3 | Difference 4 | Difference 5 | Difference 6 | Difference 7 | Difference 8
change in provisions | 7 | -2 | -9 | - | -9 | - | - | - | - | - | -
change in loans and other receivables to other banks | -2,319 | -2,332 | -13 | -13 | - | - | - | - | - | - | -
change in financial assets measured at fair value through profit or loss | -392 | -368 | 24 | 24 | - | - | - | - | - | - | -
change in hedge derivatives | -18 | 3,477 | 3,495 | - | 3,495 | - | - | - | - | - | -
change in investment securities | -6,564 | -6,114 | 450 | 290 | 18 | 142 | - | - | - | - | -
change in transferred assets | 179 | 249 | 70 | 70 | - | - | - | - | - | - | -
change in loans and other receivables to customers measured at amortised cost | -13,632 | -13,574 | 58 | 58 | - | - | - | - | - | - | -
change in other assets, including: |  | -42 |  |  |  |  |  |  |  |  |
change in ‘other assets’ in the statement of financial position | -8 | -8 | - | - | - | - | - | - | - | - | -
other changes | - | -34 | -34 | - | - | - | -34 | - | - | - | -
change in liabilities to other banks | -426 | -347 | 79 | -3 | - | - | - | - | 82 | - | -
change in financial liabilities measured at fair value through profit or loss | -484 | -480 | 4 | 4 | - | - | - | - | - | - | -
change in liabilities to customers | 15,332 | 15,357 | 25 | 25 | - | - | - | - | - | - | -
change in liabilities from securities issues | 1,012 | 12 | -1,000 | - | - | - | - | - | - | - | -1,000
change in subordinated liabilities | 1,049 | -17 | -1,066 | - | - | - | - | - | - | - | -1,066
change in other liabilities, including: |  | 226 |  | - | - | - | - | - | - | - | -
change in ‘other liabilities’ in the statement of financial position | 103 | 200 | 97 | - | - | - | - | 97 | - | - | -
other changes | - | 26 | 26 | - | 4 | - | - | - | - | 22 | -

for the year ended 31 December 2024 |  |  |  |  |  |  |  |  |  |  |
| change od balance |  |  |  |  |  |  |  |  |
in consolidated statement of financial position | in consolidated cash flow statement | difference, including: | Difference 1 | Difference 2 | Difference 3 | Difference 4 | Difference 5 | Difference 6 | Difference 7 | Difference 8
change in provisions | 94 | 91 | -3 | - | -3 | - | - | - | - | - | -
change in loans and other receivables to other banks | -2,015 | -1,999 | 16 | 16 | - | - | - | - | - | - | -
change in financial assets measured at fair value through profit or loss | 326 | 336 | 10 | 10 | - | - | - | - | - | - | -
change in hedge derivatives | -50 | 345 | 395 | - | 395 | - | - | - | - | - | -
change in investment securities | -2,378 | -7,762 | -5,384 | 90 | 98 | -5,572 | - | - | - | - | -
change in transferred assets | -14 | -12 | 2 | 2 | - | - | - | - | - | - | -
change in loans and other receivables to customers measured at amortised cost | -10,156 | -10,229 | -73 | -73 | - | - | - | - | - | - | -
change in other assets, including: |  | -58 |  |  |  |  |  |  |  |  |
change in ‘other assets’ in the statement of financial position | -5 | -5 | - | - | - | - | - | - | - | - | -
other changes | - | -53 | -53 | - | - | - | -53 | - | - | - | -
change in liabilities to other banks | 1,813 | 642 | -1,171 | -8 | - | - | - | - | -1,163 | - | -
change in financial liabilities measured at fair value through profit or loss | -422 | -448 | -26 | -26 | - | - | - | - | - | - | -
change in liabilities to customers | 14,706 | 14,727 | 21 | 21 | - | - | - | - | - | - | -
change in liabilities from securities issues | 105 | 5 | -100 | - | - | - | - | - | - | - | -100
change in other liabilities, including: |  | -1,297 |  |  |  |  |  |  |  |  |
change in ‘other liabilities’ in the statement of financial position | -1,410 | -1,312 | 98 | - | - | - | - | - | 98 | - | -
other changes |  | 15 | 15 | - | 5 | - | - | - | - | 10 | -

78 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Change in liabilities recognized in the statement of cash flows in financing activities

for the year ended 31 December 2025 |  |  |  |
| long-term loans received | liabilities fram debt securities issued | subordinated liabilities | lease liabilities
Opening balance | 13,735 | 509 | 1,499 | 529
changes from cash flows recognised in financing activities of the consolidated statement of cash flows, of which: | -477 | 968 | 1,008 | -97
incurring liabilities / issue of debt securities | 1,741 | 1,000 | 1,066 | -
repayment of liabilities | -1,718 | - | - | -97
interest payments on liabilities | -500 | -32 | -58 | -
non-cash changes included in operating activities of the consolidated statement of cash flows | 394 | 44 | 41 | 65
including changes due to exchange rate differences | -150 | - | -26 | -2
Closing balance | 13,652 | 1,521 | 2,548 | 497

for the year ended 31 December 2024 |  |  |  |
| long-term loans received | liabilities fram debt securities issued | subordinated liabilities | lease liabilities
Opening balance | 12,535 | 404 | 1,526 | 484
changes from cash flows recognised in financing activities of the consolidated statement of cash flows, of which: | 713 | 75 | -82 | -98
incurring liabilities | 3,063 | 500 | - | -
repayment of liabilities | -1,731 | -400 | - | -98
interest payments on liabilities | -619 | -25 | -82 | -
non-cash changes included in operating activities of the consolidated statement of cash flows | 487 | 30 | 55 | 143
including changes due to exchange rate differences | -224 | - | -26 | -4
Closing balance | 13,735 | 509 | 1,499 | 529

40. Related entities
ING Bank Śląski S.A. is a subsidiary of ING Bank N.V., which as at 31 December 2025 held 75% of the share capital
of ING Bank Śląski and 75% of the total number of votes at the General Meeting of ING Bank Śląski S.A. The ultimate
parent company is ING Groep N.V. with its registered office in the Netherlands.
ING Bank Śląski S.A. conducts transactions with ING Bank N.V. and its subsidiaries on the interbank market. These
are both short-term deposits and loans as well as derivatives operations. The Bank also maintains bank accounts
of ING Group entities and receives and grants guarantees to entities from the ING Group.
ING Lease Sp. z o.o., a subsidiary, received from ING Bank N.V. long-term financing of leasing contracts in EUR (so-
called "matched funding"). In addition, the Bank has three subordinated loans and three non-preferred senior loans
(NPS) in its balance sheet, which result from agreements concluded with ING Bank N.V.
The operating costs incurred by the Bank on behalf of the Parent Entity result primarily from contracts for the
provision of consulting and advisory services, data processing and analysis, providing software licences and
IT support. As regards costs incurred by the Bank on behalf of other related parties, outsourcing agreements
concerning the provision of system resource hosting services for various applications, lease of IT equipment,
monitoring of availability and performance of IT applications and infrastructure, as well as penetration tests and
IT security monitoring play a dominant role.
All the above-mentioned transactions are carried out on market terms.
Costs are presented at net value (excluding VAT).
The tables present figures relating to receivables and liabilities, revenues and costs as well as outlays on fixed
assets, which result from transactions concluded between the Group and its related entities.

79 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December |  |  |  |  |  |
| 2025 | 2024
ING Bank N.V. | Other ING Group entities | Associates | ING Bank N.V. | Other ING Group entities | Associates
Receivables | 23,215 | 3 | - | 20,540 | 1 | -
Nostro accounts | 42 | 2 | - | 5 | 1 | -
Positive valuation of derivatives | 72 | - | - | 181 | - | -
Reverse repo | 23,098 | - | - | 20,351 | - | -
Other receivables | 3 | 1 | - | 3 | - | -
Liabilities | 25,837 | 470 | 57 | 25,276 | 328 | 55
Deposits received | 409 | 280 | 57 | 475 | 239 | 55
Loans received, including: | 13,652 | - | - | 13,735 | - | -
non-preferred senior loans (NPS) | 8,949 | - | - | 9,055 | - | -
Subordinated loan | 2,548 | - | - | 1,499 | - | -
Loro accounts | 88 | 178 | - | 247 | 72 | -
Negative valuation of derivatives | 28 | - | - | 34 | - | -
Other liabilities | 163 | 12 | - | 231 | 17 | -
Off-balance-sheet operations | 12,168 | 455 | - | 16,846 | 192 | -
Off-balance sheet liabilities granted | 808 | 445 | - | 667 | 183 | -
Off-balance sheet liabilities received* | 890 | 10 | - | 973 | 9 | -
FX transactions | 8,999 | - | - | 14,427 | - | -
IRS | 29 | - | - | 188 | - | -
Options | 1,442 | - | - | 591 | - | -

for the year ended 31 December |  |  |  |  |  |
| 2025 | 2024
Income and expenses |  |  |  |  |  |
Income, including: | -465 | 1 | 74 | 284 | 6 | 56
net interest and commission income/expenses | -82 | 6 | 74 | -42 | 5 | 56
net income on financial instruments | -386 | -6 | - | 322 | - | -
net (loss)/income on other basic activities | 3 | 1 | - | 4 | 1 | -
General and administrative expenses | -339 | -63 | - | -350 | -68 | -

41. Transactions with the management staff and employees
Loans to Bank employees and senior management
Employees of the ING Bank Śląski S.A. Group use loans on the same terms as the Bank’s other clients (there are
no preferential loans for employees). Loans to employees are included in the amount of loans to customers and
as at 31 December 2025 amounted to PLN 275 million (excluding loans from the Company Social Benefit Fund).
As at 31 December 2024, their value amounted to PLN 248 million.
Granting a loan, cash loan, bank guarantee and surety for persons in the Bank's management is defined by
a separate procedure and monitoring in accordance with the Regulation of the President of ING Bank Śląski S.A.
The consolidated financial statements for 2025 include bank loans, cash loans, guarantees and sureties granted
to the Bank’s management (within the meaning of Article 79 of the Banking Law) in the amount of PLN 32 million.
As at 31 December 2024, their value was also PLN 32 million.
Company Social Benefit Fund
Employees may take advantage of various forms of social assistance within the framework of Social Benefits
Funds established in entities of the Group. The balance of loans granted from the Company Social Benefit Fund
as at 31 December 2025, was below PLN 1 million, similar as at 31 December 2024. The balance of the Company
Social Benefit Fund as at 31 December 2025 was PLN 38 million, compared to PLN 27 million as at 31 December
2024.
Remuneration of ING Bank Śląski S.A. Management Board Members
The composition of ING Bank Śląski S.A. Management Board as at the end of 2025 was presented in the chapter
I. Bank and the Group detail s in point 7. ING Bank Śląski S.A. Management Board and Supervisory Board composition.
Emoluments of ING Bank Śląski S.A. Management Board Members

| 2025 | 2024
Short-term employee benefits, including: |  |
remuneration | 15.0 | 13.8
benefits | 4.6 | 2.6
Total | 19.6 | 16.4

Short-term employee benefits comprise: base remuneration, insurance, mutual fund contributions, medical care
and other benefits awarded by the Supervisory Board.
Emoluments of ING Bank Śląski S.A. Management Board Members under the Variable Remuneration Programme

| 2025 | 2024
Short-term benefits | Long-term benefits | Short-term benefits | Long-term benefits
Cash payments | 4.3 | 3.1 | 3.8 | 3.1
Own stock | 4.3 | 3.1 | 3.7 | 2.9
Total | 8.6 | 6.2 | 7.5 | 6.0

Short-term benefits comprise the benefits under the Variable Remuneration Programme – the non-deferred part.
Long-term benefits comprise the benefits under the Variable Remuneration Programme – the deferred part.
Emoluments of Members of the ING Bank Śląski S.A. Management Board for 2025 under the Variable Remuneration
Programme have not yet been awarded.

80 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

In accordance with the Bank’s remuneration system, Members of the Bank’s Management Board may be entitled
to a bonus for 2025, part of which will be paid in 2026, and part of which will be deferred for subsequent years
(2027-2033). The maximum possible amount of the bonus for 2025, for which the provision was created,
is PLN 15 million, including PLN 4 million for cash withdrawals in 2026, and PLN 11 million for the deferred part
of the bonus. The final decision regarding the amount of bonus will be made by the Supervisory Board of the Bank.
As at 31 December 2024, the provision for cash payment of the bonus for Members of the Bank’s Management
Board was PLN 14 million. The bonus for 2024 approved by the Supervisory Board in 2025 amounted
to PLN 12 million.
In the year ended 31 December 2025 post-employment benefits in the amount of PLN 2 million were paid
to Management Board Members. In the year ended 31 December 2024, no post-employment benefits were paid
to Management Board Members.
Members of the Management Board have entered into non-competition agreements after they cease to perform
functions in the Bank’s Management Board. In the event of failure to appoint for a new term of office or dismissal,
Management Board Members are entitled to a severance pay. Information on severance pay for Management
Board Members is included in their employment contracts and is due only in the case of termination
of the employment contract by the Bank for reasons other than those entitling it to terminate the employment
contract without notice.
Remuneration of ING Bank Śląski S.A. Supervisory Board Members
The composition of ING Bank Śląski S.A. Supervisory Board as at the end of 2025 was presented in the chapter
I. Bank and the Group details in point 7. ING Bank Śląski S.A. Management Board and Supervisory Board composition.
Emoluments of ING Bank Śląski S.A. Supervisory Board Members

| 2025 | 2024
Short-term employee benefits, including: |  |
remuneration | 1.6 | 1.3
Total | 1.6 | 1.3

The Management Board Members and other persons employed by ING Bank Śląski S.A. do not receive any
remuneration or awards for performing functions in the governing bodies of subsidiaries and affiliated entities of
the ING Bank Śląski S.A. Group.
Volume of ING Bank Śląski shares held by Bank Management Board and Supervisory Board Members
As part of the Incentive Programme addressed to persons having a significant impact on the Bank’s risk profile,
the Bank grants free-of-charge own shares as a component of variable remuneration.
As at 31 December 2025 the Members of the Bank’s Management Board in the new composition appointed
on 29 April 2025 held a total of 19,987 shares, which consisted of:
• non-deferred own shares for the period from 1 July to 31 December 2022 (4,725 shares after taking into account
the sale of 1,328 shares),
• the first part of the deferred shares for the period from 1 July to 31 December 2022 (627 shares after taking into
account the sale of 176 shares) and non-deferred shares for the period from 1 January to 31 December 2023
(5,587 shares after taking into account the sale of 1,635 shares),
• the second part of the deferred shares for the period from 1 July to 31 December 2022 (805 shares), the first part
of the deferred shares for the period from 1 January to 31 December 2023 (1,641 shares) and non-deferred
shares for the period from 1 January to 31 December 2024 (6,602 shares).
As at 31 December 2024, Members of the Bank’s Management Board held a total of 17,498 shares, which consisted
of non-deferred own shares for the period from 1 July to 31 December 2022 (6,835 shares after taking into account
the sale of 937 shares), the first part of deferred shares for the period from 1 July to 31 December 2022 (1,079
shares) and non-deferred shares for the period from 1 January to 31 December 2023 (9,584 shares).
Members of the Bank’s Supervisory Board did not hold any shares in ING Bank Śląski S.A. either as at 31 December
2025 or as at 31 December 2024.
42. Headcount
The headcount in the Group at the end of 2025 and 2024 was, respectively:

as at 31 December |  |
| 2025 | 2024
Individuals | 7,693 | 8,001
FTEs | 7,646.2 | 7,947.0

43. Significant events after the balance sheet date
None.

81 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Risk and capital management

I. Capital management | 82
1. Introduction | 82
2. Minimum capital requirements | 82
3. Capital adequacy | 83
4. MREL requirements | 85
5. Dividend policy | 85
II. Risk management | 87
1. Introduction | 87
2. Credit risk | 90
3. Market risk | 116
4. Liquidity and funding risk | 130
5. Non-financial risk | 138
6. ESG risk | 140
7. Other risks | 142

82 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

I. Capital management
1. Introduction
Capital management at ING Bank Śląski S.A. Capital Group is aimed at enabling and facilitating the Group’s
development in accordance with the adopted strategy and business model. In addition, it allows you to actively
manage capital, taking into account the size and dynamics of changes, both now and in the future (including
in a stressful situation). Capital management takes place in three perspectives: normative/regulatory perspective,
economic capital perspective and stress perspective.
The overriding goal of capital management in the Group is to have a sufficient and effective capitalisation of the
Bank to implement the business strategy and development plans, while meeting all internal and external prudential
requirements. This means financial flexibility in the current and future environment to adapt to changing market
and regulatory conditions.
As part of capital management, the Group:
• identifies and assesses the materiality of the risks occurring in its operations,
• conducts activities aimed at estimating and monitoring economic capital, capital requirement and own funds,
• monitors potential risks to capital adequacy,
• allocates economic capital to business lines,
• sets internal limits in order to limit the generated capital requirements and economic capital,
• pursues an appropriate investment policy,
• establish an adequate pricing policy,
• pursues a dividend policy resulting from the long-term capital objective and preferred capital structure,
• plans economic capital and capital requirement and own funds,
• prepares contingency capital plans defining the steps to be taken in the event of a risk to capital adequacy,
• analyses the impact of macroeconomic factors on capital adequacy in accordance with the "Stress Test Policy".
The superior document regulating capital management in the Group is the Capital Management Policy at ING Bank
Śląski S.A.
2. Minimum capital requirements
In accordance with the letter of the Polish Financial Supervision Authority received on 11 December 2024, the Group
maintains the buffer of another systemically important institution buffer equivalent to 1.0% of the total risk
exposure amount.
On 26 November 2025, the Bank received a letter from the Polish Financial Supervision Authority on the non-
determination of an additional capital charge recommended under Pillar II ("P2G") in order to absorb potential
losses resulting from the occurrence of stress conditions.
The minimum level of capital adequacy results from the obligation to maintain minimum levels of capital ratios
resulting from the following external regulations:
• Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 (4.5% for CET1, 6%
for T1 and 8% for TCR),
• Act of 5 August 2015 on macroprudential supervision of the financial system and crisis management in the
financial system sanctioning additional capital buffers, including:
• capital conservation buffer, which in 2025 was 2.5%,
• other systemically important institution buffer of 1% imposed by PFSA decision, received on 11 December 2024
(in 2025 there was no update of its level),
• countercyclical capital buffer applicable to exposures to which such buffer has been imposed by the competent
authorities. The countercyclical buffer is variable over time depending on the structure of the exposures
concerned and the levels of countercyclical buffer rates imposed on the exposures concerned (as at the end
of December 2025, the countercyclical buffer was effectively 1.0013%, compared to 0.009% as at the end
of December 2024),
• Regulation of the Minister of Development and Finance of 18 March 2020 repealing the Regulation on the
systemic risk buffer; however, following a cautious approach, the Bank monitors capital ratios taking into account
the size of the systemic risk buffer.
Consequently, as at 31 December 2025, the minimum capital requirements for the Group are:
• CET1 >= 9.00%,
• T1 >= 10.50%,
• TCR >= 12.50%.

83 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

3. Capital adequacy
On 1 January 2025, amended capital adequacy regulations - CRR3 (Regulation (EU) 2024/1623 of the European
Parliament and of the Council of 31 May 2024 amending Regulation (EU) No 575/2013 as regards requirements for
credit risk, credit valuation adjustment risk, operational risk, market risk and minimum capital threshold) came into
force.
3.1. Capital adequacy objectives
The risk appetite determines the maximum amount of risk that the Group is prepared to accept, thus supporting
stability and further development. As part of risk and capital management, the Group defines risk appetite
parameters (RAS - Risk Appetite Statement) and capital targets of the Group, which enable the Group to implement
its Strategy, including dividend targets.
The Capital Adequacy RAS also defines capital limits for specific risks.
For capital purposes, the Bank maintains a management buffer that enables the implementation of the strategy
in the conditions of unexpected regulatory and business changes.
3.2. Own funds
The Group's own funds consist of:
• Common Equity Tier 1 capital, which at the end of 2025 amounted to PLN 18,167 million (PLN 18,237 million
at the end of 2024),
• Tier 2 capital, which at the end of 2025 amounted to PLN 1,032 million (PLN 1,364 million at the end of 2024).
As at 31 December 2025 similarly as at 31 December 2024 , no Tier 1 additional capital (AT1) is identified in the
Group.
Own funds accepted for calculation of the total capital ratio

as at 31 December |  |
| 2025 | 2024
Tier 1 | 18,167 | 18,237
Tier 1 core capital | 18,167 | 18,237
equity instruments qualifying as Tier 1 core capital | 1,077 | 1,086
retained earnings, including: | 55 | 1,174
retained earnings in previous years | 55 | 81
recognized profit | - | 1,093
accumulated other comprehensive income | 139 | 150
reserve capital | 16,246 | 15,118
general bank risk funds | 1,215 | 1,215
value adjustments due to prudent valuation requirements | -42 | -35
goodwill and other intangible assets | -481 | -495
deferred tax assets based on future profitability and not arising from temporary differences after deducting related income tax liabilities | - | -1
shortfall in credit risk adjustments against expected losses under the IRB approach | -243 | -202
shortfall in coverage for non-performing exposures | -82 | -22
transitional adjustments to common equity Tier 1 capital | 283 | 249
Tier 2 | 1,032 | 1,364
equity instruments qualifying as Tier 2 capital | 1,030 | 1,340
excess of provisions over expected eligible losses under the IRB approach | 2 | 24
Own funds taken into account in total capital ratio calculation | 19,199 | 19,601

*) On 29 April 2025, the Bank’s Ordinary General Meeting approved the distribution of profit for 2024. The inclusion
of the net profit generated in 2024 in own funds as at 31 December 2024 resulted in an increase in own funds
to the level of PLN 19,601 million, which is presented in the table above. According to the value presented in the
annual consolidated financial statements for 2024, the level of own funds was PLN 18,197 million.
3.3. Capital requirement
For reporting purposes, in 2025 and 2024, the Group used the internal ratings-based approach and the
standardised approach to calculate the capital requirement for credit risk. The Group has obtained the approval
of the Polish Financial Supervision Authority and the National Bank of the Netherlands for the use of the Advanced
Internal Ratings Based (AIRB) method for exposure classes: companies and credit institutions for the Bank and
ING Lease Sp. z o.o. At the beginning of 2025 , after the implementation of CRR3, some credit exposures were
covered by the basic internal ratings-based method (F-IRB).
In the area of operational risk, from 1 January 2025, the Group uses the business indicator method.
In the area of market risk, the Group uses the base method and the method of updated average return period
(depending on the type of risk).
The Group also sets capital requirements for concentration risk, settlement risk and credit valuation adjustment
(CVA) risk. In all cases, requirements are set in accordance with the CRR Regulation.

84 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The total capital requirement is dominated by the credit risk requirement. At the end of 2025 it accounted for 87%
of the total requirement compared to 84% at the end of 2024.
3.4. Capital ratios
As at 31 December 2025, the total capital ratio (TCR) for the ING Bank Śląski Capital Group was 14.98% and the Tier
1 ratio was 14.18% compared to 15.67% i 14.58% at the end of 2024.
The main drivers of the change in the total capital ratio are:
• as part of Common Equity Tier 1:
• increase of coverage deficit for non-performing exposures - decrease of the total capital ratio by 0.05 p.p.,
• increase of the shortage of credit risk adjustments in view of expected losses according to the IRB method -
decrease of the total capital ratio by 0.03 p.p.,
• change in the valuation of equity investments included in unrealised gains and losses on the portfolio
measured at fair value through other comprehensive income - increase in the total capital ratio by 0.03 p.p.,
• under Tier 2 capital:
• increase in the amount of subordinated loans not included in own funds due to the fact that they entered the
period of the last 5 years to the maturity date - decrease in the total capital ratio by 0.25 p.p.,
• under the capital requirement
• reduction of risk-weighted assets as a result of CRR3 implementation - increase of the total capital ratio
by 1.81 p.p.,
• increase in risk-weighted assets due to changes in on-balance and off-balance sheet credit exposures -
decrease in the total capital ratio by 1.40 p.p.
• increase in risk-weighted assets due to including the management buffer due to uncertainties related to CRR3 -
decrease in the total capital ratio by 0.50 p.p.,
• increase of risk-weighted assets due to model changes and risk migration - decrease of the total capital ratio
by 0.23 p.p.
The surplus of the total capital ratio over the regulatory requirement (together with P2G) decreased from 4.16 p.p.
to 2.48 p.p. and the surplus of Tier 1 ratio decreased from 5.07 p.p. to 3.68 p.p.
Total capital ratio and Tier 1 capital ratio

as at 31 December |  |
| 2025 | 2024
Own funds taken into account in total capital ratio calculation | 19,199 | 19,601
Capital requirements |  |
capital requirement for credit risk and counterparty credit risk | 8,930 | 8,438
capital requirements for position risk, foreign exchange risk and commodities risk | 131 | 98
operational risk capital requirement | 1,157 | 1,462
capital requirement for credit valuation adjustment risk (CVA) | 33 | 11
Total capital requirement | 10,251 | 10,009
Total capital ratio | 14.98% | 15.67%
minimum required level | 12.50% | 11.51%
surplus TCR ratio | 2.48 p.p. | 4.16 p.p.
Tier 1 capital ratio | 14.18% | 14.58%
minimum required level | 10.50% | 9.51%
surplus T1 ratio | 3.68 p.p. | 5.07 p.p.

*) On 29 April 2025, the Bank’s Ordinary General Meeting approved the distribution of profit for 2024. The inclusion
of net profit generated in 2024 in own funds as at 31 December 2024 resulted in an increase in TCR and Tier 1 of the
Group to 15.67% and 14.58% respectively, which is presented in the table. According to the values presented in the
Group’s annual consolidated financial statements for the period from 1 January 2024 to 31 December 2024,
the Group’s TCR and Tier 1 ratios as at 31 December 2024 were 14.85% and 13.76%, respectively.
Transitional provisions
In the calculation of capital ratios, the Group applies a temporary treatment of unrealised gains and losses
measured at fair value through other comprehensive income in accordance with Article 468 of the CRR. In addition,
as at 31 December 2024, the Group used transitional provisions to mitigate the impact of the implementation
of IFRS 9 on the level of own funds. If the Group did not apply the transitional provisions, the Group’s capital ratios
would be as follows.

as at 31 December |  |
| 2025 | 2024
the level of capital ratios without transitional provisions
for the temporary treatment of unrealised gains and losses measured at fair value through other comprehensive income in accordance with Article 468 of the CRR | 1. for the temporary treatment of unrealised gains and losses measured at fair value through other comprehensive income in accordance with Article 468 of the CRR; and 2. to mitigate the impact of IFRS 9 implementation on the level of own funds
Total capital ratio (TCR) | 14.78% | 15.49%
Tier 1 capital ratio | 13.98% | 14.40%

85 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

4. MREL requirements

as at 31 December |  |
| 2025 | 2024
MREL – TREA (including combined buffer requirement) | 25.22% | 24.15%
minimum required level (including combined buffer requirement) | 20.75% | 19.95%
surplus (+) / deficiency (-) of the MREL – TREA ratio | 4.47 p.p. | 4.20 p.p.
minimum required level (not including combined buffer requirement) | 16.25% | 16.44%
surplus (+) / deficiency (-) of the MREL – TREA ratio | 8.97 p.p. | 7.71 p.p.
MREL - TEM | 10.32% | 11.12%
minimum required level | 5.91% | 5.91%
surplus (+) / deficiency (-) of the MREL – TEM ratio | 4.41 p.p. | 5.21 p.p.

On 5 June 2025, the Bank received a letter from the Bank Guarantee Fund (BFG) regarding a joint decision of the
resolution authorities, i.e. Single Resolution Board (SRB) and the BFG, on the minimum level of own funds and write-
down/conversion liabilities (MREL). This decision is based on the ING Group’s ‘Single Point of Entry’ (SPE) forced
restructuring strategy.
The BFG, in consultation with the SRB, set the MREL requirement for the Bank at 16.25% % of the total risk exposure
amount (TREA) - with the obligation to add a combined buffer of 4.50% as at the end of 2025 and 5.91% of the total
exposure measure (TEM) at the individual level. The Bank is obliged to meet the MREL requirement for both, TREA
and TEM, at the same time. The entire MREL requirement should be met in the form of own funds and liabilities
meeting the criteria set out in Article 98 of the Act on the BGF, which transposes Article 45f(2) of the BRRD2.
In addition, the BFG indicated that the part of the MREL corresponding to the recapitalisation amount should
be satisfied in the form of the following instruments: additional Tier 1 (AT1), Tier 2 capital instruments (T2) and
other subordinated eligible liabilities acquired directly or indirectly by the parent entity. The Bank estimates that the
MREL part of the recapitalisation amount requirement is 8.25% TREA and 2.91% TEM.
At the same time, the BFG indicated that the Common Equity Tier 1 (CET1) instruments held by the Bank for the
purpose of the combined buffer requirement cannot be included in the MREL requirement expressed
as a percentage of the total risk exposure amount (TREA).
At the end of 2025, the Bank had three non-preferred senior loans (NPS) from ING Bank N.V., with a nominal value
of EUR 2,110 million. This value includes:
• a loan of EUR 350 million, taken out on 10 October 2024 for a period of 4 years (with the right to early repayment
after 3 years),
• a loan of EUR 1,500 million, taken out on 22 December 2023 for a period of 4 years (with the right to early
repayment after 3 years) and
• a loan of EUR 260 million, taken out on 5 January 2023 for a period of 6 years (with the right to early repayment
after 5 years).
All loans are an element of the single point of entry (SPE) strategy for ING Group. The Bank includes NPS funds
in eligible liabilities for the purposes of the minimum requirement of own funds and eligible liabilities (MREL).
Interest on the loans is payable quarterly at EURIBOR 3M plus a margin (1.50% for the October 2024 loan, 2.01% for
the December 2023 loan and 2.35% for the January 2023 loan). The financial conditions of the loans do not differ
from market conditions. As at 31 December 2025 , the carrying amount of liabilities due to NPS loans amounted
to PLN 8,949 million (compared to PLN 9,055 million as at 31 December 2024) and was recognised in the statement
of financial position in the item Liabilities to other banks.
5. Dividend policy
The most important assumptions of the Bank's dividend policy are as follows:
• stable realisation of dividend payments in a foreseeable perspective in the amount of up to 75% of the Bank’s
annual net profit in compliance with the prudent management principle and all regulatory requirements the
Bank is obliged to comply with, and taking into account the adopted Best Practice for GPW Listed Companies,
• a proposal to pay dividends in an amount higher than the ratio indicated above is possible if justified by the
bank’s financial situation (e.g. from retained earnings or reserve capital) and provided that all other requirements
of the law and the dividend policy are met,
• possibility of dividend payouts from capital surplus over the minimum capital adequacy ratios and above the
minimum levels of capital ratios determined by the Polish Financial Supervision Authority for dividend payouts.
When deciding on the proposed amount of dividend payment, the Bank’s Management Board takes into account
the supervisory requirements communicated within the framework of the official communication of the PFSA
concerning the dividend policy of banks, as well as the following considerations:
• the current economic and financial condition of the Bank and the Bank’s Group, including limitations when
financial losses are generated or in case of low profitability (low return on assets / equity),
• assumptions of the management and risk management strategy of the Bank and the Bank’s Capital Group,
• restrictions resulting from Art. 56 of the Act on Macro-prudential Supervision over the Financial System and Crisis
Management in the Financial System of 5 August 2015,
• the need to reduce current period profits or unapproved annual profits included in own funds by foreseeable
dividends, in accordance with Article 26 of EU Regulation No 575/2013,
• macroeconomic environment.

86 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

PFSA’s guidelines with respect to dividend for 2025
On 17 December 2025, the Polish Financial Supervision Authority published its position on the dividend policy
in 2026. Up to 50% of the 2025 profit can be paid out only by banks that simultaneously meet the following criteria:
• do not implement a recovery programme,
• are positively assessed as part of the Supervisory Review and Evaluation process (final BION rating not worse than
2.5),
• have a leverage level (LR) of more than 5%,
• have a Common Equity Tier 1 (CET1) ratio not lower than the required minimum: 4.5% + 56.25% * P2R
requirement + combined buffer requirement(1) + P2G(2),
• have a Tier 1 capital ratio (T1) not lower than the required minimum: 6% + 75% * P2R requirement + combined
buffer requirement + P2G,
• have a total capital ratio (TCR) not lower than the minimum required: 8% + P2R + combined buffer + P2G.
The amount of up to 75% of the 2025 profit can be paid out only by banks that meet the criteria for a 50% payout,
and at the same time whose portfolio of receivables from the non-financial sector is characterised by good credit
quality (the share of NPL, including debt instruments, at a level not exceeding 5%).
The Bank should meet the criteria set out above both on an individual and consolidated level, as at the end of 2025
and on the date of the decision on the payment of dividend by the General Meeting.
The maximum dividend level possible to pay is limited to 75%, due to the expectation of ensuring the stability
of the Polish financial sector by adjusting the capital base of supervised entities to the level of risk incurred by them
and protecting recipients of financial services of these entities.
Moreover, for banks that are characterised by too high sensitivity of interest income or the economic value
of capital to changes in interest rates, the dividend rate should be further reduced by 25 b.p. By too high sensitivity
of interest income should be understood higher than the legally permissible levels of SOT NII >-5% and SOT EVE
>-15%, both at the individual and consolidated level.
(1) taking into account the target announced level of the countercyclical capital buffer, i.e. 2%.
(2) Pillar II Guidance or additional capital recommendation - measures the Bank’s sensitivity to an unfavourable macroeconomic scenario
using the results of stress supervisory tests. Sensitivity defined as: relative change in CET1 calculated between the lowest level of CET1 in
the scenario horizon and CET1 at the start of the test, taking into account supervisory adjustments.
Declared and paid dividends
The Management Board of ING Bank Śląski S.A. intends to recommend to the General Meeting of the Bank the
adoption of a resolution on allocation of approx. 75% of the Bank’s 2025 separate profit, i.e. the amount of PLN
3,475 million, for dividend payment. The proposed dividend per share is PLN 26.71 gross. The proposed dividend
date is 22 April 2026 and the proposed dividend payment date is 27 April 2026. As at the date of preparation
of these consolidated financial statements, the Bank meets the criteria and requirements of the PFSA allowing for
the payment of a dividend from the profit for 2025 to the amount of 75%. The amount of the proposed dividend
takes into account both the current financial and capital situation of the Bank and its development plans.
On 29 April 2025 the Ordinary General Meeting of the Bank adopted a resolution on the payment of dividends from
the profit for 2024. On the basis of this resolution, on 12 May 2024, the Bank paid a dividend in the total amount of
PLN 3,276 million, i.e. PLN 25.18 gross per shar e.

87 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

II. Risk management

1. Introduction | 87
2. Credit risk | 90
3. Market risk | 116
4. Liquidity and funding risk | 130
5. Non-financial risk | 138
6. ESG risk | 140
7. Other risks | 142

1. Introduction
1.1. Risk categories
The most important risks in the Group’s operations include:
• credit risk,
• market risk,
• liquidity and funding risk,
• non-financial risk including operational risk and compliance risk (compliance).
In addition, as material risks in its operations, the Group identifies:
• model risk,
• business risk,
• risks related to transaction security and stability of IT systems,
• risks related to the security of personal data.
ESG risks deserve special attention, which are not treated by the Group as a separate risk category, but rather
as a factor strengthening the Group’s basic risk categories (i.e. financial risks - credit, market, liquidity and funding
risks, and non-financial risks).
A detailed description of each of the above risks is presented below.
1.2. Risk management organisation
The Bank’s Management Board and Supervisory Board play a special role in the risk management process. The Bank
also has a number of committees that play an active role in managing individual risk types. The following diagrams
present the organisational structure of risk management, taking into account the functional reporting lines within
the ING Bank Śląski Group and the ING Group.

88 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

1.3. Risk management system
The risk management system is an integrated set of rules, mechanisms and tools (including, among others, policies
and procedures) relating to risk processes. The role of the risk management system is risk management, adequate
to the size and profile of the risk incurred by the Group, through constant identification, measurement
or evaluation, monitoring, risk control, including risk mitigation, and risk reporting along with assessment of the
effectiveness of risk mitigation actions taken. As part of risk control, the Group hedges against risk or mitigates
it by introducing appropriate control mechanisms, a system of limits and an adequate level of provisions
(provisions), as well as capital and liquidity buffers.
As part of the risk management system, the Group:
• has a specified frequency of risk measurement or assessment that is adequate to the scale and complexity of the
business,
• use risk measurement or assessment methods that take into account current and planned activities and
authorisation criteria,
• apply formalised rules for determining the amount of risk taken and rules for risk management,
• apply formalised procedures to identify, measure or estimate and monitor risk, which also take into account the
expected level of risk in the future,
• apply formalised risk limits and rules of conduct in the event of exceeding limits, including introducing methods
and measures to eliminate exceeding limits in the future,
• applies the adopted management reporting system that enables monitoring of the level of risk,
• has an organisational structure adapted to the size and profile of the risk incurred,
• has qualified staff of risk management units and provides training for employees of the first and second lines
of defence.
The risk management system is defined in the General Policy of Risk Management at ING Bank Śląski S.A.
Three Lines of Defence Model
The risk and control structure in the Group is based on the three lines of defence model. This model aims to provide
a stable and effective framework for risk management by defining and implementing three 'levels' of risk
management, with different roles, responsibilities and responsibilities for supervision.
First line of defence
Among other things, it is responsible for:
• assessment, control and mitigation of all risks affecting their business, and the completeness and accuracy
of financial statements and risk reports with respect to their areas of responsibility
• conducting risk assessments and taking mitigating actions to maintain the level of risk consistent with the
designated risk appetite,
• implementation, application and testing of control mechanisms resulting from policies and other regulations, also
for outsourced activities (outsourcing).
Second line of defence
Among other things, he is responsible for:
• formulating and translating risk appetite into methodologies and policies in order to support and monitor risk
control by the Bank’s management.

89 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• issuing regulations and providing risk management methods and tools, including supporting the first line
of defence during this process,
• verifying the application of risk regulations by the first line of defence
• as part of its control activities, it performs its own independent assessment of the effectiveness of the first line
of defence through inspections, tests, reviews and other forms of control.
Third line of defence
It provides an independent assessment of the adequacy and effectiveness of the risk management system,
the internal control system, corporate governance and the implemented systems and processes in the first and
second line of defence.
Internal control system
The internal control system is described in the Policy Internal control system at ING Bank Śląski S.A. It is one of the
elements of Bank management and its foundations, principles and objectives result from the Banking Law Act,
the Regulation of the Minister of Finance, Funds and Regional Policy on the risk management system and internal
control system and remuneration policy in banks and Recommendation H on the internal control system in banks
issued by the Polish Financial Supervision Authority.
The purpose of the internal control system is to ensure:
1. Effectiveness and efficiency of the Bank’s operations.
2. Reliability of financial reporting.
3. Compliance with the Bank’s risk management principles.
4. Compliance of the Bank’s operations with legal regulations, internal regulations and market standards.
The internal control system consists of:
a) Control function - an element of the internal control system, which consists of all control mechanisms in the
processes operating in the Bank, independent monitoring of their compliance and reporting as part of the
control function. Includes positions, groups of people or organisational units responsible for the
implementation of tasks assigned to this function.
b) The Centre of Expertise - Compliance - acting as the compliance unit, with the task of identifying, assessing,
controlling and monitoring the risk of non-compliance of the Bank’s operations with laws, internal regulations
and market standards, and presents reports in this respect.
c) The Internal Audit Department - an independent unit tasked with examining and assessing, in an independent
and objective manner, the adequacy and effectiveness of the risk management system and internal control
system as part of the first and second line of defence.
The internal control system has been developed in accordance with the principle of proportionality, i.e. taking into
account the nature, scale and complexity of operations, the materiality of processes and taking into account the
existing level of risk and the adequacy assessment of control mechanisms existing in individual defence lines,
ensuring the continuity of its operation, including resources, access to information and tools.
1.4. Risk management rules
ING Bank Śląski S.A. manages credit, market, liquidity and funding and non-financial (compliance) risks in
accordance with the principles set out by the standards of Polish law, the regulations of the Polish Financial
Supervision Authority (KNF) and other authorised bodies, as well as in accordance with the standards set by the ING
Group to the extent that it does not lead to a breach of the aforementioned regulations and best practice
documents.
Irrespective of the need to ensure regulatory and legal compliance (compliance), the Group considers the
management of credit, market, liquidity and operational and financial risks as a fundamental and integral part
of the overall Group management.
Risk management is carried out on the basis of appropriate analyses independent of the risk management system,
on the basis of strategies, policies, instructions, procedures and plans.
1.5. Risk appetite
The risk appetite determines the maximum level of risk that the Group is prepared to accept, thus supporting the
stability of the organisation and its further development. As part of risk and capital management, the Group sets
risk appetite limits (RAS - Risk Appetite Statement) in the following key areas:
• RAS on capital adequacy,
• RAS on liquidity and funding and market risk,
• RAS for credit risk
• RAS for non-financial risks (operational, compliance and models).

90 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2. Credit risk

2.1. Introduction | 90
2.2. Credit risk management objectives | 90
2.3. Credit risk management strategy | 90
2.4. Credit risk management system | 90
2.5. Risk appetite RAS | 92
2.6. Principles of credit activity | 92
2.7. Credit risk management rules | 93
2.8. Risk management rules in subsidiaries | 98
2.9. Quantitative disclosure on credit risk | 99

2.1. Introduction
The Group treats credit risk management as a fundamental and integral part of the overall management of the
Group.
Credit risk is understood as:
• a risk of a financial loss that may be suffered by the Group as a result of default by debtors in whole and at the
agreed time on their credit obligations to the Group, or
• a risk of reduced economic value of credit exposures or groups of credit exposures as a result of impaired ability
of debtors to service their debt at the agreed time.
2.2. Credit risk management objectives
The Group’s primary objective in the credit risk management process is to support the effective achievement
of business objectives through proactive risk management and organic growth activities, while:
• maintaining a safe level of capital and liquidity ratios standards and an appropriate level of provisions,
• ensuring compliance with legal regulations and requirements of supervisory authorities.
The specific objectives of credit risk management are:
• supporting business initiatives,
• maintaining credit losses at the assumed level,
• continuous verification, assessment of the adequacy and development of applied procedures, models and other
elements of the risk management system,
• adapting operations to changing external conditions,
• maintaining an appropriate level of capital requirements for credit risk and provisions,
• ensuring compliance with the requirements of the regulator.
2.3. Credit risk management strategy
The credit risk management strategy supports business objectives while maintaining a safe level of solvency and
liquidity of the Bank and an adequate level of provisions. It is designated in order to ensure the optimal
development of the loan portfolio, while maintaining the appropriate quality and profitability of credit operations
and capital allocation. The primary objective of defining the credit risk management strategy is to optimise the
relationship between risk and return on capital, taking into account information about the current and prospective
macroeconomic environment, the Bank’s portfolio and the level of implementation of RAS limits.
The credit risk management strategy takes into account the "look to the future", including the need to maintain
competitiveness, attractiveness and development of the Bank’s offer.
2.4. Credit risk management system
The overriding documents governing credit risk management are: General Risk Management Principles at ING Bank
Śląski and Credit Risk Management Policy at ING Bank Śląski.
The Bank’s credit risk management system consists of:
• general principles of credit risk management and mitigation,
• RAS strategies and limits,
• general principles of concentration risk management,
• credit risk management policies, instructions and procedures,
• credit risk systems, tools and models,
• management reporting system enabling monitoring of the level of credit risk,
• organisational structure adjusted to the size and profile of the credit risk incurred by the Bank.
The activities that the Bank undertakes as part of the risk management system may include:
• risk avoidance - liquidation or limitation of activities that generate an excessively high level of risk or a type of risk
that cannot be effectively controlled,

91 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• risk mitigation - taking actions aimed at reducing the probability of adverse events or limiting the effects of such
events,
• risk transfer - transferring all or part of the risk to another entity, e.g. through insurance or securitisation of a loan
portfolio, or a guarantee,
• accepting risk - refraining from undertaking the above activities for economic or practical reasons, as part of the
Bank’s risk appetite.
In addition, the Bank has a properly defined credit risk assessment and measurement process, independent of the
lending function, including:
• an effective rating system,
• effective process of obtaining relevant information, including forecasts, used to measure expected credit losses,
• an assessment policy that ensures that the measurement of expected credit losses is carried out on an individual
or collective basis,
• an effective model validation process that ensures that models generate accurate, consistent and objective
forecasts and estimates on an ongoing basis,
• clear, formal communication and coordination of all employees involved in the process of risk assessment and
valuation of expected credit losses.
The Bank’s credit risk management system, including the organisational structure, organisation of the credit
process, internal regulation system, tools and models used, is subject to ongoing verification and adaptation
to ensure the implementation of the Bank’s strategy, including the risk appetite. In this way, the Bank achieves the
goal of maintaining the adequacy of its activities in the area of identification, assessment, measurement,
monitoring and management of activities subject to credit risk, as well as maintaining consistency and compliance
with regulatory requirements.
The Group’s risk policy for the credit exposure portfolio takes into account the fact that the activity generating
credit risk may also be related to other types of risks, i.e., among others: liquidity, market, operational, legal and
reputation risk, which may mutually reinforce each other and takes into account ESG risk.
The Group optimises and limits losses due to incurred credit risk by:
• setting internal limits,
• appropriate design of credit products,
• application of security measures,
• use of functional control,
• efficient monitoring, restructuring and recovery,
• monitoring changes in clients’ creditworthiness and creditworthiness,
• regular monitoring and validation of models used to identify and measure credit risk
• conducting analyses of trends and values of key risk indicators.
Credit risk is managed by the Group in an integrated manner based on:
• strategic planning,
• a coherent system of limits, policies and procedures, and
• risk management tools, including risk identification, measurement and control.
This integrated system consists of all processes in the Group carried out in connection with lending activities.
The systems and models supporting the assessment of the clients’ creditworthiness and credit reliability:
• from the Business Customer Line and Wholesale Banking - are built and monitored in accordance with the
requirements of using the IRB method to calculate capital requirements for credit risk and the ING Group
standards (excluding SE/Micro and Easy Lending customers),
• from the Business Customers Division (SE/Micro, including Easy Lending customers) - these are application and
behavioural scoring models reflecting the statistical level of customer risk, built in accordance with the
requirements contained in supervisory regulations,
• from the Individual Customer Division and the Private Banking Customer Division - these are scoring models
(application, behavioural and BIK scoring models) reflecting the statistical level of customer risk, built in
accordance with the requirements contained in supervisory regulations.
In its assessment of credit risk, the Bank uses the following models:
• PD (Probability of Default),
• LGD (Loss given Default),
• EAD (Exposure at Default).
The models are designed in compliance with the requirements set forth in supervisory regulations and are applied
inter alia to determine the volume of provisions, economic capital for credit risk for internal and external reporting
requirements, reporting to the supervisory authority, to determine loan pricing and client profitability.
The effectiveness of the models is reviewed on the basis of monitoring and validation processes.

92 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Credit risk management in the Bank is carried out on the basis of advanced credit risk assessment models. In the
credit risk reporting process, information relating to IRB models is included with a frequency adjusted to the
materiality and type of information presented and the position of the recipient. As a rule, detailed information
relating to IRB models is presented to senior management, in particular to:
• the Bank’s Management Board – results of monitoring of the correctness of functioning of the AIRB approach
in compliance with the Policy of Changes and Monitoring of the Internal Rating Method at ING Bank Śląski S.A.,
• the Credit Policy Committee – results of monitoring of credit risk models, in compliance with the Credit risk model
management instruction at ING Bank Śląski S.A. and the results of model validation in compliance with the Risk
model validation policy.
• the Assets and Liabilities Committee (ALCO) – stress tests in accordance with the Stress Testing Policy.
As part of the Risk Division’s quarterly report, the results of the analysis of the credit risk profile of the corporate and
retail mortgage-backed exposure portfolios are presented to the Bank’s Management Board and the Risk
Committee of the Supervisory Board in accordance with the model monitoring process, in particular:
• risk profiles by categories,
• migration among the categories,
• estimation of relevant parameters in individual categories,
• comparison of realised factors of default, realised LGD values, and realised credit conversion factors (CCF) with
expected values.
The Bank also takes into account in the credit risk management process data on impairment losses (credit
provisions), which are presented in a dedicated report. The monthly report in a shortened version is presented
to the Bank’s Management Board and the quarterly report in a full and shortened version is presented to the Bank’s
Supervisory Board.
2.5. Risk appetite RAS
RAS is a bank-wide risk appetite, defined by setting limit values for the most important measures. The Bank-wide
risk appetite is supported and hedged by setting more detailed strategic and internal limits and other risk
measures.
Types of RAS for credit risk:
• sales limits and portfolio size,
• portfolio quality limits/ for risk parameter values,
• monitoring and recovery efficiency limits,
• sectoral limits,
• concentration limits, including limits for the portfolio of mortgage-backed credit exposures resulting from the
requirements of Recommendation S or sectoral limits,
• quantitative and quality parameters of RAS for ESG risk.
In addition to RAS limits, the Bank sets limits for credit risk for individual areas, business lines, products and
transaction limits, which are accepted by the relevant credit decision maker. In addition, internal concentration
limits are set for industries of the economy, accepted forms of collateral, regions and mortgage-backed credit
exposures. The ongoing performance of RAS limits is monitored and reported during the year, on a monthly basis.
In the further part of the chapter, in the section containing quantitative disclosures, a breakdown of the Group’s
largest exposures to entities / groups of related entities and concentration of exposures to corporate clients in the
national economy industries is presented. The Group does not identify any other significant risk concentrations
than those mentioned above and those presented in this chapter and in the notes to the consolidated financial
statements.
2.6. Principles of credit activity
The basic principle that the Bank follows in its lending activities is compliance with the law and external regulations
related to lending activities, i.e.:
• The Banking Law Act,
• Macroprudential Supervision Act,
• Foreign exchange law,
• Recommendations issued by KNF,
• EBA guidelines, including EBA LOM (Loan Origination and Monitoring) guidelines,
• The CRR Regulation,
• anti-money laundering regulations, etc.
The Bank does not engage in credit transactions and does not engage in activities whose ethical aspect raises
doubts and which could harm the good name of the Bank.
The following principles shall apply in the course of carrying out credit activities:

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• the Bank acquires and maintains in the loan portfolio credit exposures, which ensure security of the Bank’s
deposits and capital,
• the Bank acts in the interest of the client, taking into account both his needs and capabilities; it avoids a situation
in which the granted financing would contribute to the client entering a debt spiral,
• the Bank attracts clients in accordance with the applicable regulations and requirements regarding the provision
of necessary information, documentation and compliance with procedures,
• the Bank provides credit services effectively and professionally, respecting the interest of customers and the
expectations of the Bank's shareholders as regards the increase in the value of ING Bank Śląski S.A. and taking
into account the requirements resulting from the competitive environment,
• the Bank does not conclude transactions or credit exposures without learning and understanding the economic
basis of the transaction,
• the Bank accepts credit risk if it is able to effectively control it and - in the event of default - performs debt
recovery procedures,
• the Bank does not provide exposures in cases where it exposes itself to reputation risk,
• the Bank makes decisions regarding new types or directions of credit exposures (e.g. new markets, market
segments, customer groups, products) after prior analysis and assessment of new opportunities and related risks,
• in business relations, the Bank applies the principle of "equal rights", i.e. it requires the same documents and
information from the same clients - from a credit risk perspective - and pays particular attention to their equal
treatment,
• the Bank maintains open communication with clients regarding information requirements in the credit process.
• as part of cooperation with business partners, the Bank observes the following principles:
• conducts verification of business partners with whom it cooperates in the process of granting loans,
• has procedures for the circulation of documentation between the client, business partner and the Bank,
• has procedures for quality control of business partners,
• does not grant a power of attorney or the right to make credit decisions in the name and on behalf of the Bank
when granting (distributing) loans,
• determines the acceptable level of risk for individual sales channels,
• monitors the quality of the loan portfolio granted through individual business partners.
2.7. Credit risk management rules
Credit risk management is a continuous process consisting of all the Bank’s activities related to the performance
of credit activities. All units and persons who perform tasks within the credit process work closely together to:
• improving the efficiency of risk management, and
• maintaining risk at a level consistent with the strategy, approved risk appetite (RAS) and the Bank’s financial
plans.
The credit risk management process is carried out in the Bank through three functionally and organisationally
independent lines of defence.
The Bank applies organisational solutions taking into account the separation of the function of selling banking
products from the function of risk acceptance at all levels of the organisational structure, including the Bank’s
Management Board. The separation of the function of monitoring and controlling the risk of credit exposures
(including concentration risk) from the function of selling banking products and the risk acceptance function is
maintained at all levels of the Bank’s organisational structure below the level of the Bank’s Management Board, and
for retail credit exposures also at the level of the Management Board.
In the case of simplified, automated credit process paths, the separation of the sales function of banking products
from the risk acceptance function of credit exposures is based on the independence of the process of building and
validating tools supporting the risk acceptance process from the sales and operational functions. Competence
in credit decisions relating to individual credit transactions is separate from decision-making competences in the
sphere of shaping credit policy and credit risk management rules.
Credit risk is managed by the Bank both at the level of the loan exposure portfolio and at the level of individual
transactions.
Risk management of the credit exposure portfolio
Credit risk management of the credit exposure portfolio is carried out by:
• defining the credit risk management strategy,
• reconciliation of quality parameters and quantitative parameters of RAS/their level with the business side,
• development, implementation and monitoring of the credit policy,
• analysing the macroeconomic situation and individual industries and formulating guidelines for lending
directions,
• development and implementation of credit products,

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• determination of competence levels for acceptance of credit policy and product deviations,
• development and implementation of tools supporting risk measurement and assessment,
• analysis and assessment of the method of credit process implementation and the scope of functional control,
• portfolio management of credit exposures,
• training of employees participating in the credit process,
• development and maintenance of an employee incentive system aimed at compliance with internal credit
standards.
Bank managing the credit risk profile:
• sets, monitors and reports internal concentration limits for industries, types of collateral, regions and mortgage-
backed credit exposures,
• monitors and analyses the quality of adopted collateral,
• monitor and report compliance with prudential standards resulting from Regulation (EU) No. 575/2013 of the
European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions
as amended and amending Regulation (EU) No. 648/2012 and the Banking Law Act,
• sets, monitors and reports internal concentration limits, taking into account individual sub-portfolios and
strategic limits approved by the Bank’s Management Board,
• defines changes in credit policy and product offer, taking into account the cyclical nature of the economy and
changes taking place on the real estate market,
• obtains market data about the quality of loan portfolios and compares them with own loan portfolios.
Capital adequacy and creation of provisions for credit risk
The Group secures impairment of credit exposures by recognising impairment for expected credit losses. The Group
further secures fluctuating losses versus the average levels of expected losses (that is unexpected losses)
by ensuring an adequate level of regulatory capital and economic capital.
Risk-weighted assets and capital requirements are calculated by the Bank as follows:
• for exposures from the retail segment and SE/Micro and including Easy Lending customers - in accordance with
the standard method,
• for corporate credit exposures - in accordance with the advanced internal ratings based method, excluding
exposures to governments, central banks, local government units, public sector entities and all exposures
of ING Commercial Finance S.A., for which the Group applies the standardised method.
Calculation of impairment for expected credit losses in the Bank for all credit exposures is performed in accordance
with International Financial Reporting Standards.
Credit risk management of individual credit exposures
Credit risk management of individual credit exposures includes:
• determination of the credit risk management process for credit risk-bearing transactions,
• managing documentation requirements for the Bank’s credit client,
• definition of a credit analysis standard,
• setting a maximum level of DSTI/DSI, LTV, and a minimum level of own contribution for specific products, types
of transactions,
• development of rules for making credit decisions and management of credit competencies,
• managing the following rules:
• determining risk measures using risk models used by the Bank,
• verify the timeliness of repayments,
• monitoring the economic and financial situation of the client,
• monitoring the customer’s compliance with contractual conditions,
• monitoring of other defined warning signals,
• accepting and monitoring collateral accepted by the Bank,
• use and monitoring of limits available at the Bank.
• determination of the rules for recognising allowances for expected credit losses for credit exposures and
provisions for off-balance sheet liabilities,
• credit risk management for clients from the portfolio in Stage 3.
The following activities are carried out as part of the process of granting and managing individually significant credit
exposures:
• client and transaction risk assessment,

95 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• taking credit decision,
• monitoring,
• restructuring and recovery.
Client and transaction risk assessment
The most important elements in the assessment of customer credit risk and transactions include:
• assessment of clients’ creditworthiness,
• assessment of creditworthiness (quantitative assessment),
• collateral assessment,
• transaction risk assessment.
Assessment of clients’ creditworthiness
The Bank reviews clients’ creditworthiness by:
• verifying compliance with minimum criteria,
• determining clients’ rating or score in the rating or scoring process respectively.
Measurement of the client’s risk in the rating or scoring process is based on the estimated PD (default probability).
The condition for providing financing to the client is to establish a rating or scoring assessment for the client
at a specific minimum level for a given type of client, credit process or product.
The assessment of the creditworthiness of MidCorp and SME business clients and Wholesale Banking (WB) clients
in the rating process is based on:
• rating awarded to entities applying for credit exposure, providing collateral (e.g. sureties, guarantors) and other
entities, if required by the specificity of the collateral or transaction (e.g. debtors of receivables assigned to the
Bank),
• the principle of two pairs of eyes, i.e. inter alia:
• commercial functions are separated from the rating approval function that is performed by the CRO Division
units, or
• the rules of operation of automatic rating models, which are approved by the Credit Policy Committee.
The assessment of the creditworthiness of the retail client and the business client from MidCorp/SME and the SE/
Micro business clients (including Easy Lending clients) is based on:
• scoring for retail and SE/Micro customers,
• analysis of history of repayment of obligations to the Bank and other financial institutions,
• features of the borrowers that have material impact on compliance with the existing credit obligations (quality
analysis), e.g:
• personal characteristics of the retail client and SE/Micro: age, marital status, number of persons maintained,
housing and financial status, education, employment history, form of employment, profession pursued, etc.,
• features of the Easy Lending customer, i.e.: legal form, customer type, industry and period of business activity,
customer rating, enforcement titles, punctuality of repayment of liabilities, inflows to the account at the Bank,
regular transfers to ZUS/Tax Office, customer occurrence in the Bank Register of Unreliable Customers, etc.,
• history of the client’s cooperation with the Bank: period of cooperation and history of account maintenance.
The Bank applies scoring models (application, behavioural models and BIK scoring) reflecting the client’s statistical
risk level. The applied clients’ creditworthiness review models are subject to regular monitoring and validation
to ensure good quality of the tools.
Assessment of creditworthiness (quantitative assessment)
Creditworthiness is reviewed by identifying the source of repayment and the amount and stability thereof
throughout the lending process. This is an assessment of repayment potential by the clients of their credit
exposures in the specified amounts, times and subject to terms and conditions determined by the Bank. The clients’
potential is subject to a review of clients’ creditworthiness in the rating and scoring process. The review
of creditworthiness also provides for the FX risk and interest rate risk to which the debtors are exposed.
The analysis of the creditworthiness of a business client and WB may cover the following areas:
• ownership structure of the client,
• the type of activity pursued,
• business and investment strategy,
• market position,
• outlets and suppliers,
• financial analysis, including financial forecast,
• identification and assessment of sources of repayment,
• financial position compared to comparable entities in the industry,

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• factors from the global, macroeconomic, regional and industry environment that currently affect and may have
a significant impact on the financial condition of the enterprise in the future.
The analysis of individual clients’ creditworthiness covers:
• determination of the amount and stability of income obtained (quantitative analysis),
• determination of the amount of the client’s financial liabilities (both credit and non-credit),
• determination of household expenditure.
In assessing creditworthiness, financial measures based on mathematical formulas are used.
Collateral assessment
The Bank applies collateral to mitigate credit risk and the amount of losses that may be suffered when clients’
default on loan repayment. Before collateral is accepted, the Bank assesses the collateral and its value and
effectiveness.
Apart from classic forms of collateral (material and personal), the Bank applies additional instruments to mitigate
the risk of loss in the form of contractual conditions and clauses.
In order to calculate the capital requirement, the Bank applies the approved LGD models in which each collateral
is assigned with an adequate recovery rate. Is the Group’s policy to grant loans in amounts and subject to terms
and conditions that ensure regular repayments without the need to resort to collateral.
Transaction risk assessment
Assessing transactions, the Bank takes the following into account:
• results of the clients’ creditworthiness and credit reliability,
• compliance with credit policy,
• purpose of lending,
• adequacy of the requested product,
• other risks such as:
• business risks – macroeconomic, market, sectoral, seasonal risks,
• structural risks – transaction structure, values of LTV and LGD, client’s own contribution (if required),
effectiveness of clauses, Bank’s position versus other lenders,
• management staff – employment history, experience, substitution risk of decision makers and succession risk,
• financial risks – including FX and interest rate risks,
• concentration risk:
• whether the requested increase in exposure is associated with the use of the limit internally set by the Bank,
• whether the requested increase in exposure affects the utilisation of the large exposure limit,
• reputational risk – can cooperation with the client adversely affect the Bank's reputation.
• relation of risk level to pricing conditions, etc.
Taking credit decision
The decision-making procedure does not relieve any of the participants in the decision-making process of personal
responsibility for the decisions taken.
Credit decision-makers are granted individually personal credit competences within a two-person decision-making
procedure, the amount of which depends on their knowledge and experience. The competence level correlates with
the level of credit risk. If the credit risk is higher, decisions are made by people with more experience. The rules for
granting and revoking credit competences are separate within individual customer segments. In determining the
appropriate level of credit competence for business customers, including Easy Lending customers (excluding other
clients from the SE/Micro segment) and WB, one may take into account, among others, the Group’s total exposure
to the group of related entities to which the customer belongs, and in the case of natural persons and natural
persons conducting business activity, the level of competence results from the Bank’s total exposure to this
customer. Acceptance of all transactions is made in accordance with clearly defined rules of decision making and
credit competence.
The scope of competence to make credit decisions in the scope of risk acceptance of individual credit exposures
is determined by the Credit Policy Committee. The lack of data necessary for risk assessment precludes its
acceptance and decision making.
Commitments to lower amounts, shorter deadlines, with lower risk, are undertaken at lower competence levels.
As credit risk increases - i.e. single or aggregate credit exposure increases, lending extensions, non-standard
elements in the proposal or deviations from existing internal regulations - decisions are taken at higher levels
of credit competence.
Risk assessment and acceptance is based on expert assessment based on the results of risk measurement using
supporting tools defined by credit policy and procedures. The exception are the so-called automatic decisions,
taken by an IT system or semi-automatic decisions made as part of simplified credit process paths.
Credit decisions are made in the right path, based on a comprehensive analysis of transaction risk depending on the
complexity and amount of the transaction. For paths with a higher level of automation, transaction risk analysis

97 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

is based on clearly defined criteria, including behavioural and automatic calculation of a credit limit based
on an algorithm approved by the Credit Policy Committee.
Retail segment (mortgage and retail segment) and business clients from SE/Micro segment (excluding Easy
Lending customers)
Credit decisions for the regular portfolio are made:
• in automatic mode - in accordance with specified criteria,
• in single or double mode - by units from the Operations Division,
• in two-person mode - in the higher risk analysis unit, at the level of directors or members of the management
board - this applies to cases characterised by higher credit risk and non-standard cases.
Irregular portfolio decisions are made in a dedicated recovery and restructuring unit.
Business customer segment excluding SE/Micro customers
Loan decisions for the portfolio in Stages 1 and 2 (excluding automatic paths) are made:
• collectively, through the Bank’s Credit Committee or the Restructuring Committee - this applies to the largest
credit exposures,
• in two-person mode - by business units and transactional credit risk units or dedicated restructuring units,
• in a single-member mode - by the Risk Manager in case of approval of non-significant modifications.
Business Customer Segment and SE/Micro for Easy Lending customers
Loan decisions for the portfolio in Stages 1 and 2 are made:
• in two-person mode - by business units and transactional credit risk units or dedicated restructuring units.
Credit decisions for the portfolio of business clients from MidCorp/SME (Easy Lending) are made depending on the
process path:
• automatically based on:
• verification of the defined qualification criteria,
• customer verification in BRNK, BIK and BIG databases,
• calculation of the EL transaction limit calculated in accordance with the algorithm approved by the NCP,
or
• expertly by the decision-maker of the crediting unit (Front Office) with appropriate credit competencies.
Loan decisions concerning the portfolio in Stage 3 are taken in a single person mode, in a double person mode or by
the Restructuring Committee.
The decision-making procedure does not relieve any of the participants in the decision-making process of personal
responsibility for the decisions taken.
Monitoring
All credit exposures generating credit risk, including concentration risk and financial market transactions, are
monitored. The monitoring of credit exposures shall take place at different levels of risk aggregation, including
portfolio, product/exposure, geographical region, economic sector, obligor and group. The purpose of monitoring
is early identification of warning signals and taking actions to prevent the occurrence of difficult credit and early
identification of indications or objective evidence of impairment of the credit exposure and taking actions to reduce
the Bank’s losses. Monitoring of the granted credit exposure includes:
• the course of repayment of the Bank’s receivables (punctuality),
• the Client’s performance of other contractual terms and conditions,
• the financial standing and/or assets of the client,
• the course of cash use in accordance with the purpose of financing (if specified),
• the degree of investment realisation (in case of investment loans),
• verification of client or transaction warning signals,
• objective evidence or indications of impairment,
• periodic assessment of the quality and value of collateral.
The Bank regularly assesses the risk associated with the granted credit exposures and monitors the debtors’ ability
to repay the debt throughout the loan life cycle.
Restructuring and collection
The Bank supports its clients at every stage of financing. The Bank offers products tailored to their needs and offers
flexible repayment schedules in the event of minor delays in repayment of liabilities. In the event of greater
difficulties in repayment, the Bank may propose debt restructuring. Then, together with the client, the Bank
determines the best form of support or conclusion of a settlement.
The main objective of restructuring activities is to minimise the risk of the Bank’s losses or to minimise the size
of the loss.
The Bank adopts the following behavioural strategies:

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• Debt restructuring - based on cooperation with the client, which may in particular consist in changing the
contractual terms to adjust the terms of debt repayment to the client’s financial capabilities, e.g.:
• extending the repayment period,
• temporary suspension of instalments in the principal part / entire instalment,
• conversion of a renewable product into an instalment product,
• sale of assets (not applicable to the retail segment),
• sale of a part of the borrower’s business activity (not applicable to the retail segment),
• partial write-off of financial liabilities (not applicable to the retail segment),
• the Bank’s participation in restructuring based on the provisions of the Restructuring Law.
The decision to start restructuring is made after a detailed assessment and approval by the relevant decision-
making body in the Bank. After a successfully completed restructuring process, the borrower is again subject
to standard credit risk monitoring procedures.
• Debt collection - i.e. recovery by the Bank of receivables from established legal securities or from other assets of
the client or from assets of obligated third parties. The Bank may pursue its receivables by initiating enforcement
proceedings or participating in bankruptcy proceedings or, in relation to retail clients, by way of amicable
recovery, i.e. enabling the client to make voluntary repayments under the debt collection strategy.
Forbearance
Forbearance occurs if the Bank considers that the client will not be able to meet his financial obligations due
to financial difficulties (established or expected) and decides to grant him amenities.
Forbearance shall be identified if the following cumulative conditions are met:
• the customer is unable to meet its financial obligations under the loan agreement at the Bank due to existing
or expected financial difficulties,
• the Bank shall grant a relaxation facility that would not have been granted if the customer had not experienced
financial difficulties.
Financial difficulties are understood as the situation of a client who is experiencing or will soon begin to experience
difficulties in fulfilling his financial obligations.
Detailed quantitative disclosures regarding the distribution of the loan portfolio between the performing and non-
performing, detailing exposures with forbearance facilities granted, are presented later in the chapter
in section 2.9.5.
2.8. Risk management rules in subsidiaries
Credit risk management in subsidiaries ING Lease (Polska) Sp. z o.o., ING Commercial Finance S.A. and ING Bank
Hipoteczny S.A. is subject to the same main rules as in ING Bank Śląski S.A., taking into account the specificity of the
activities of these entities.
As part of the risk management process, the Bank supervises:
• the credit portfolio of subsidiaries by assessing the size and risk profile of the credit portfolio related to their
activities,
• the principles of identifying, measuring and mitigating risk and credit risk management of individual credit
transactions of subsidiaries,
• the level of market risk (including liquidity risk) in subsidiaries through setting limits and monitoring positions.
Supervision of related entities is exercised by the Bank through:
• application of uniform credit risk models in the rating process/scoring process,
• application of uniform principles for analysing and assessing transactions at credit risk, taking into account the
specificity of the related party,
• application of harmonised rules and levels of credit competence,
• granting authorisations to make credit decisions,
• establishing contractual terms and conditions of mutual cooperation in the field of granting financing in the case
of selected types of transactions with credit risk,
• exchange of information on the Bank’s preferred solutions and tools supporting credit risk management,
• providing information on the Bank’s sectoral policy, directions of lending and other industry documents,
• cooperation in the preparation of credit risk reports,
• monitoring and assessing the level of risk, including the quality of the companies’ portfolio by the NCPs,
• advising on significant initiatives in the area of credit risk management by the NCP.
In the area of determining and reporting impairment losses on credit exposures and provisions for off-balance sheet
credit exposures, related entities are obliged to apply the principles binding at the Bank. The levels of impairment
allowances and provisions set by related entities are presented at quarterly meetings of the LLP Committee.
In addition, the Bank’s representatives are members of the Supervisory Boards of subsidiaries, because the
companies’ activities, similarly to the Bank’s activities, are related to generating credit risk.

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Additional aspects of risk management in subsidiaries
• ING Lease Polska Sp. z o.o.:
• is the owner of the items financed under the leasing agreement, which are the basic collateral for the
transaction,
• after terminating the lease agreement, may take physical control over the collateral and sell it, which reduces
or completely eliminates the loss on the credit exposure,
• has an extensive procedure for verifying the supplier and the leased item in order to reduce the risk of fraud
and the risk associated with financing the item with a physical or legal defect,
• within the scope of internal procedures, it verifies both the supplier (if necessary also entities related to the
supplier) / the intermediary trading in the financed asset, which minimises the risk of delivery of the financed
asset.
• ING Commercial Finance Polska S.A.:
• the main source of repayment of the exposure are receivables covered by the factoring agreement, both in the
case of factoring with and without recourse,
• as a rule, acquires receivables with the assumption of the solvency risk of recipients after prior insurance
of these receivables,
• offers factoring to clients with the assumption of the solvency risk of recipients on the terms of insurance
contracts concluded by clients with insurers, so-called ‘Entering into the rights and obligations of the
customer’s insurance contract’.
• ING Bank Hipoteczny S.A.:
• ING Bank Hipoteczny S.A. acquires from ING Bank Śląski S.A. receivables which, after assessing their suitability
as collateral for loans granted and determining the mortgage lending value of the real estate, secure the issue
of covered bonds,
• ING Bank Hipoteczny S.A. bases its operations on ongoing and close cooperation with the CRO Division and the
COO Division of Bank Śląski S.A.
2.9. Quantitative disclosure on credit risk

2.9.1. Maximum exposure to credit risk | 99
2.9.2. Quality of the loan portfolio | 100
2.9.3. Concentration of exposures | 108
2.9.4. Collaterals | 110
2.9.5. Loan portfolio performing and non-performing and exposures with forbearance granted | 111
2.9.6. Credit quality of other financial assets | 115
2.9.7. Modification of contractual cash flows | 116

2.9.1. Maximum exposure to credit risk

| 2025 | 2024
Loans and other receivables to other banks | 23,954 | 21,635
Financial assets measured at fair value through profit or loss (excluding derivatives and equity instruments), including: | 2,339 | 2,126
Financial assets held for trading | 2,332 | 2,105
valuation of derivatives | 818 | 898
other financial assets held for trading, including: | 1,514 | 1,207
debt securities, including: | 1,090 | 700
Treasury bonds in PLN | 976 | 678
Czech Treasury bonds | 114 | 22
repurchase agreements | 424 | 507
Non-trading financial assets measured at fair value through profit or loss, including: | 7 | 21
loans mandatorily at fair value through profit or loss | 7 | 21
Derivative hedging instruments | 73 | 61
Investment securities (excluding equity instruments), of which: | 65,257 | 58,738
Measured at fair value through other comprehensive income, including: | 38,208 | 31,685
Treasury bonds in PLN | 33,156 | 26,371
European Union bonds | 1,947 | 2,064
European Investment Bank bonds | 2,689 | 2,838
Austrian government bonds | 416 | 412
Measured at amortised cost, including: | 27,049 | 27,053
Treasury bonds in PLN | 15,822 | 11,859
Treasury bonds in EUR | 1,972 | 2,872
European Investment Bank bonds | 7,111 | 6,654
Bonds of the Polish Development Fund (PFR) | 1,845 | 3,860
Bank Gospodarstwa Krajowego bonds | 199 | 1,808
NBP bills | 100 | -

100 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

| 2025 | 2024
Loans and other receivables to customers measured at amortised cost, including: | 180,309 | 166,677
Corporate banking | 97,462 | 93,052
loans in the current account | 15,257 | 14,716
term loans and advances | 57,394 | 53,856
lease receivables | 13,672 | 13,342
factoring receivables | 6,472 | 6,571
corporate and municipal debt securities | 4,667 | 4,567
Retail banking | 79,536 | 70,387
mortgages | 69,096 | 61,114
loans in the current account | 618 | 624
other loans and advances | 9,822 | 8,649
Other receivables | 3,311 | 3,238
Financial receivables in other assets | 32 | 40
Granted off-balance sheet liabilities, of which: | 62,979 | 55,409
Undrawn credit lines | 49,821 | 43,416
guarantees | 9,273 | 8,014
credit card limits | 2,108 | 1,896
undrawn overdrafts in current account | 1,386 | 1,409
letters of credit | 391 | 393
repurchase agreements | - | 281
Total | 334,943 | 304,686

2.9.2. Quality of the loan portfolio
The loan portfolio includes receivables from customers, which consist of loans (both term and overdrafts or card
accounts) and other credit claims, such as leasing receivables, factoring receivables and corporate and municipal
bonds.
Loan portfolio - balance sheet value and impairment for expected credit losses by Stages

as at 31 December |  |  |  |  |  |
| 2025 | 2024
| gross | impairment for expected credit loss | net | gross | impairment for expected credit loss | net
Corporate banking | 100,728 | -3,266 | 97,462 | 96,127 | -3,075 | 93,052
assets in Stage 1 | 83,260 | -134 | 83,126 | 77,535 | -136 | 77,399
assets in Stage 2 | 11,634 | -393 | 11,241 | 13,088 | -394 | 12,694
assets in Stage 3 | 5,795 | -2,739 | 3,056 | 5,457 | -2,545 | 2,912
including individually significant assets | 2,889 | -1,121 | 1,768 | 3,452 | -1,325 | 2,127
POCI assets | 39 | - | 39 | 47 | - | 47
Retail banking, including: | 80,424 | -888 | 79,536 | 71,267 | -880 | 70,387
mortgages | 69,268 | -172 | 69,096 | 61,295 | -181 | 61,114
assets in Stage 1 | 67,502 | -12 | 67,490 | 53,694 | -11 | 53,683
assets in Stage 2 | 1,457 | -44 | 1,413 | 7,308 | -57 | 7,251
assets in Stage 3 | 308 | -116 | 192 | 292 | -113 | 179
POCI assets | 1 | - | 1 | 1 | - | 1
other loans | 11,156 | -716 | 10,440 | 9,972 | -699 | 9,273
assets in Stage 1 | 9,677 | -97 | 9,580 | 8,430 | -94 | 8,336
assets in Stage 2 | 801 | -121 | 680 | 877 | -115 | 762
assets in Stage 3 | 676 | -498 | 178 | 663 | -490 | 173
POCI assets | 2 | - | 2 | 2 | - | 2
Total, including: | 181,152 | -4,154 | 176,998 | 167,394 | -3,955 | 163,439
assets in Stage 1 | 160,439 | -243 | 160,196 | 139,659 | -241 | 139,418
assets in Stage 2 | 13,892 | -558 | 13,334 | 21,273 | -566 | 20,707
assets in Stage 3 | 6,779 | -3,353 | 3,426 | 6,412 | -3,148 | 3,264
POCI assets | 42 | - | 42 | 50 | - | 50

The Group identifies POCI financial assets whose balance-sheet value as at 31 December 2025 was PLN 42 million
(PLN 50 million as at 31 December 2024). These are exposures to impaired receivables purchased in connection with
the acquisition of Bieszczadzka SKOK in 2017 and exposures which were significantly modified as a result
of restructuring, which required the removal of the original credit or leasing exposure and re-recognition of the
asset in the statement of financial position.
Sale of non-performing receivables
In 2025, the Group concluded three agreements for the sale of receivables from the non-performing portfolio, which
included receivables from retail and corporate customers. As a result of the transaction:
• the retail portfolio of non-performing receivables decreased by PLN 126 million and the positive impact of the
transaction on the Group’s gross result amounted to PLN 43 million.
• the corporate non-performing receivables portfolio decreased by PLN 452 million and the positive impact of the
transaction on the Group’s gross result amounted to PLN 19 million.

101 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

In addition, in 2025, the Group sold corporate receivables from the non-working receivables portfolio. As a result
of the transaction, the non-performing receivables portfolio decreased by PLN 5 million and the positive impact
of the transaction on the Group’s gross result amounted to PLN 2 million.
In 2024, the Group carried out five transactions of sale of non-performing receivables. The Group concluded the
following agreements regarding the sale of receivables from the impaired portfolio:
• Three agreement on the sale of corporate receivables, as a result of which the portfolio of impaired receivables
decreased by PLN 396 million. The positive impact of the transaction on the Group's gross result amounted
to PLN 22 million.
• Two agreement on the sale of retail receivables, as a result of which the portfolio of impaired receivables
decreased by PLN 192 million. The positive impact of the transaction on the Group's gross result amounted
to PLN 58 million.
The result on the sale of receivables is presented in the line Profit on the sale of receivables under Impairment for
expected credit losses in the income statement.

102 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Loan portfolio - reconciliation of the gross carrying amount (GVA) and change of the impairment for expected redit losses (ECL)

as at 31 December 2025
| Corporate banking | Retail banking | Total
GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL
Stage 1 | Stage 2 | Stage 3 | POCI | Total | Stage 1 | Stage 2 | Stage 3 | POCI | Total
Opening balance | 77,535 | -136 | 13,088 | -394 | 5,457 | -2,545 | 47 | - | 96,127 | -3,075 | 62,124 | -105 | 8,185 | -172 | 955 | -603 | 3 | - | 71,267 | -880 | 167,394 | -3,955
Changes in the period, including: | 5,725 | 2 | -1,454 | 1 | 338 | -194 | -8 | - | 4,601 | -191 | 15,055 | -4 | -5,927 | 7 | 29 | -11 | - | - | 9,157 | -8 | 13,758 | -199
loans granted in the period | 30,099 | -64 | - | - | - | - | - | - | 30,099 | -64 | 20,876 | -56 | - | - | - | - | - | - | 20,876 | -56 | 50,975 | -120
transfer to and from Stage 1 | 3,186 | -10 | -3,174 | 68 | -12 | 9 | - | - | - | 67 | 5,870 | -5 | -5,854 | 53 | -16 | 13 | - | - | - | 61 | - | 128
transfer to and from Stage 2 | -6,828 | 31 | 6,859 | -201 | -31 | 15 | - | - | - | -155 | -1,112 | 11 | 1,205 | -97 | -93 | 46 | - | - | - | -40 | - | -195
transfer to and from Stage 3 | -908 | 10 | -849 | 65 | 1,757 | -635 | - | - | - | -560 | -228 | 5 | -179 | 30 | 407 | -185 | - | - | - | -150 | - | -710
repayment (total and partial) and the release of new tranches | -19,824 | 33 | -4,290 | 95 | -878 | 587 | - | - | -24,992 | 715 | -10,276 | 27 | -1,081 | 24 | -170 | 83 | - | - | -11,527 | 134 | -36,519 | 849
changed provisioning under impairment for expected credit losses | - | 19 | - | - | - | -668 | - | - | - | -649 | - | 16 | - | -4 | - | -70 | - | - | - | -58 | - | -707
management adjustments | - | -17 | - | -27 | - | 47 | - | - | - | 3 | - | -2 | - | 1 | - | 4 | - | - | - | 3 | - | 6
Total impairment for expected credit losses in the profit and loss account | - | 2 | - | - | - | -645 | - | - | - | -643 | - | -4 | - | 7 | - | -109 | - | - | - | -106 | - | -749
derecognition from the balance sheet (write-downs, sale) | - | - | - | - | -498 | 498 | - | - | -498 | 498 | - | - | - | - | -98 | 97 | - | - | -98 | 97 | -596 | 595
calculation of penalty interest (for late payment) | - | - | - | - | 365 | - | - | - | 365 | - | - | - | - | - | 39 | - | - | - | 39 | - | 404 | -
writing down penalty interest (for late payment) | - | - | - | - | -365 | - | - | - | -365 | - | - | - | - | - | -39 | - | - | - | -39 | - | -404 | -
value adjustment for legal risk of CHF mortgage loans | - | - | - | - | - | - | - | - | - | - | -75 | - | -18 | - | -1 | - | - | - | -94 | - | -94 | -
calculation and write-off of effective interest | - | - | - | - | - | -25 | - | - | - | -25 | - | - | - | - | - | - | - | - | - | - | - | -25
other | - | - | - | 1 | - | -22 | -8 | - | -8 | -21 | - | - | - | - | - | 1 | - | - | - | 1 | -8 | -20
Closing balance | 83,260 | -134 | 11,634 | -393 | 5,795 | -2,739 | 39 | - | 100,728 | -3,266 | 77,179 | -109 | 2,258 | -165 | 984 | -614 | 3 | - | 80,424 | -888 | 181,152 | -4,154

as at 31 December 2024
| Corporate banking | Retail banking | Total
GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL | GCA | ECL
Stage 1 | Stage 2 | Stage 3 | POCI | Total | Stage 1 | Stage 2 | Stage 3 | POCI | Total
Opening balance | 77,536 | -188 | 12,626 | -413 | 3,151 | -1,924 | 51 | - | 93,364 | -2,525 | 58,257 | -128 | 5,606 | -200 | 1,026 | -655 | 3 | - | 64,892 | -983 | 158,256 | -3,508
Changes in the period, including: | -1 | 52 | 462 | 19 | 2,306 | -621 | -4 | - | 2,763 | -550 | 3,867 | 23 | 2,579 | 28 | -71 | 52 | - | - | 6,375 | 103 | 9,138 | -447
loans granted in the period | 30,601 | -93 | - | - | - | - | - | - | 30,601 | -93 | 16,151 | -52 | - | - | - | - | - | - | 16,151 | -52 | 46,752 | -145
transfer to and from Stage 1 | 3,231 | -10 | -3,216 | 68 | -15 | 6 | - | - | - | 64 | 2,749 | -4 | -2,728 | 57 | -21 | 13 | - | - | - | 66 | - | 130
transfer to and from Stage 2 | -9,068 | 45 | 9,097 | -241 | -29 | 13 | - | - | - | -183 | -6,064 | 17 | 6,156 | -106 | -92 | 45 | - | - | - | -44 | - | -227
transfer to and from Stage 3 | -2,013 | 41 | -1,467 | 148 | 3,480 | -1,077 | - | - | - | -888 | -227 | 6 | -160 | 35 | 387 | -193 | - | - | - | -152 | - | -1,040
repayment (total and partial) and the release of new tranches | -22,752 | 40 | -3,952 | 77 | -739 | 244 | - | - | -27,443 | 361 | -8,848 | 31 | -704 | 25 | -200 | 88 | - | - | -9,752 | 144 | -37,195 | 505
changed provisioning under impairment for expected credit losses | - | 14 | - | -43 | - | -286 | - | - | - | -315 | - | -8 | - | -21 | - | -28 | - | - | - | -57 | - | -372
management adjustments | - | 16 | - | 8 | - | 95 | - | - | - | 119 | - | 33 | - | 38 | - | - | - | - | - | 71 | - | 190
Total impairment for expected credit losses in the profit and loss account | - | 53 | - | 17 | - | -1,005 | - | - | - | -935 | - | 23 | - | 28 | - | -75 | - | - | - | -24 | - | -959
derecognition from the balance sheet (write-downs, sale) | - | - | - | - | -391 | 384 | - | - | -391 | 384 | - | - | - | - | -147 | 146 | - | - | -147 | 146 | -538 | 530
calculation of penalty interest (for late payment) | - | - | - | - | 301 | - | - | - | 301 | - | - | - | - | - | 50 | - | - | - | 50 | - | 351 | -
writing down penalty interest (for late payment) | - | - | - | - | -301 | - | - | - | -301 | - | - | - | - | - | -50 | - | - | - | -50 | - | -351 | -
value adjustment for legal risk of CHF mortgage loans | - | - | - | - | - | - | - | - | - | - | 106 | - | 15 | - | 2 | - | - | - | 123 | - | 123 | -
calculation and write-off of effective interest | - | - | - | - | - | 10 | - | - | - | 10 | - | - | - | - | - | 3 | - | - | - | 3 | - | 13
other | - | -1 | - | 2 | - | -10 | -4 | - | -4 | -9 | - | - | - | - | - | -22 | - | - | - | -22 | -4 | -31
Closing balance | 77,535 | -136 | 13,088 | -394 | 5,457 | -2,545 | 47 | - | 96,127 | -3,075 | 62,124 | -105 | 8,185 | -172 | 955 | -603 | 3 | - | 71,267 | -880 | 167,394 | -3,955

103 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Changes in the gross carrying amount of the loan portfolio affect the level of impairment for expected credit losses
primarily through the disbursement of loans in the period, transfers between Stages and repayments made by
borrowers.
In 2025, among loans granted during the year, the most important item were mortgage loans for natural persons
(PLN 15,892 million), investment loans (PLN 10,033 million) and working capital loans (PLN 5,902 million), as well
as cash loans for natural persons(PLN 4,831 million). A significant part were also short-term loans: revolving loans
(PLN 1,186 million), overdrafts (PLN 1,637 million) and loans to entrepreneurs (PLN 1,637 million). In the portfolio
of loans granted during 2025, there were also leasing receivables (PLN 5,826 million) and factoring receivables
(PLN 3,321 million). Additionally, during 2025, penalty interest of PLN 404 million was accrued to the gross carrying
amount of loans and other receivables granted to customers, which were written off in full. At the end of 2025 the
amount of written-off penalty interest that is subject to debt collection activities was PLN 753 million.
In 2024, among loans granted during the year, the most important item were mortgage loans for natural persons
(PLN 11,918 million), investment (PLN 7,267 million) and working capital loans (PLN 7,272 million), in addition to
cash loans for natural persons (PLN 4,073 million). A significant part were also short-term loans: revolving (PLN
1,897 million), overdrafts (PLN 2,291 million) and loans for entrepreneurs (PLN 1,602 million). In the portfolio of
loans granted during 2024, there are also leasing receivables (PLN 5,201 million) and factoring receivables (PLN
4,236 million). Additionally, during 2024, penalty interest of PLN 351 million was accrued to the gross carrying
amount of loans and other receivables granted to customers, which were written off in full. At the end of 2024, the
amount of written-off penalty interest that is subject to debt collection activities was PLN 744 million.
Loan portfolio - on- and off-balance sheet exposures by risk classes
The Group divides risk classes into four basic groups. The risk classes are divided into short-term Moody’s ratings,
as shown in the table below.

No | risk class group | risk class range | short-term rating of Moody's
1. | a group of classes corresponding to investment grade | 1-10 | from Aaa to Baa3
2. | a group of classes corresponding to speculative ratings | 11-17 | from Ba1 to Caa3
3. | a group of classes of potentially non-performing exposures | 18-19 | from Ca to C
4. | a group of classes of non-regular exposures | 20-22 | -

For ratings 20-22, the probability of default is 100%.

104 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Exposures to corporate clients

as at 31 December 2025
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 48,461 | 30,206 | 1,270 | 1,739 | - | - | - | - | 49,731 | 31,945
11-17 | 34,774 | 18,104 | 8,202 | 4,018 | 34 | 2 | - | - | 43,010 | 22,124
18-19 | 25 | 18 | 2,162 | 253 | 20 | - | - | - | 2,207 | 271
20-22 | - | - | - | - | 5,741 | 252 | 39 | - | 5,780 | 252
Total Gross | 83,260 | 48,328 | 11,634 | 6,010 | 5,795 | 254 | 39 | - | 100,728 | 54,592
ECL | -134 | - | -393 | - | -2,739 | - | - | - | -3,266 | -
Net total | 83,126 | 48,328 | 11,241 | 6,010 | 3,056 | 254 | 39 | - | 97,462 | 54,592

Exposure to retail clients – total

as at 31 December 2025
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 64,440 | 5,782 | 574 | 135 | 4 | - | 1 | - | 65,019 | 5,917
11-17 | 12,730 | 509 | 1,387 | 44 | - | - | 2 | - | 14,119 | 553
18-19 | 9 | - | 297 | 1 | - | - | - | - | 306 | 1
20-22 | - | - | - | - | 980 | 4 | - | - | 980 | 4
Total Gross | 77,179 | 6,291 | 2,258 | 180 | 984 | 4 | 3 | - | 80,424 | 6,475
ECL | -109 | - | -165 | - | -614 | - | - | - | -888 | -
Net total | 77,070 | 6,291 | 2,093 | 180 | 370 | 4 | 3 | - | 79,536 | 6,475

Exposure to retail clients - mortgage loans and advances

as at 31 December 2025
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 63,231 | 2,860 | 556 | 16 | 4 | - | 1 | - | 63,792 | 2,876
11-17 | 4,265 | 65 | 781 | 1 | - | - | - | - | 5,046 | 66
18-19 | 6 | - | 120 | - | - | - | - | - | 126 | -
20-22 | - | - | - | - | 304 | - | - | - | 304 | -
Total Gross | 67,502 | 2,925 | 1,457 | 17 | 308 | - | 1 | - | 69,268 | 2,942
ECL | -12 | -1 | -44 | -2 | -116 | -1 | - | - | -172 | -4
Net total | 67,490 | 2,924 | 1,413 | 15 | 192 | -1 | 1 | - | 69,096 | 2,938

Exposure to retail clients - other loans and advances

as at 31 December 2025
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 1,209 | 2,922 | 18 | 119 | - | - | - | - | 1,227 | 3,041
11-17 | 8,465 | 444 | 606 | 43 | - | - | 2 | - | 9,073 | 487
18-19 | 3 | - | 177 | 1 | - | - | - | - | 180 | 1
20-22 | - | - | - | - | 676 | 4 | - | - | 676 | 4
Total Gross | 9,677 | 3,366 | 801 | 163 | 676 | 4 | 2 | - | 11,156 | 3,533
ECL | -97 | 1 | -121 | 2 | -498 | 1 | - | - | -716 | 4
Net total | 9,580 | 3,367 | 680 | 165 | 178 | 5 | 2 | - | 10,440 | 3,537

105 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Exposures to corporate clients

as at 31 December 2024
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 41,017 | 23,240 | 2,057 | 1,469 | - | - | - | - | 43,074 | 24,709
11-17 | 36,489 | 19,471 | 8,558 | 3,729 | 21 | 3 | - | - | 45,068 | 23,203
18-19 | 29 | 72 | 2,473 | 257 | 28 | - | - | - | 2,530 | 329
20-22 | - | - | - | - | 5,408 | 195 | 47 | - | 5,455 | 195
Total Gross | 77,535 | 42,783 | 13,088 | 5,455 | 5,457 | 198 | 47 | - | 96,127 | 48,436
ECL | -136 | -18 | -394 | -30 | -2,545 | -48 | - | - | -3,075 | -96
Net total | 77,399 | 42,765 | 12,694 | 5,425 | 2,912 | 150 | 47 | - | 93,052 | 48,340

Exposure to retail clients – total

as at 31 December 2024
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 49,490 | 4,802 | 5,776 | 143 | - | - | 1 | - | 55,267 | 4,945
11-17 | 12,634 | 505 | 2,098 | 41 | 4 | - | 2 | - | 14,738 | 546
18-19 | 3 | - | 311 | 2 | - | - | - | - | 314 | 2
20-22 | -3 | - | - | - | 951 | 4 | - | - | 948 | 4
Total Gross | 62,124 | 5,307 | 8,185 | 186 | 955 | 4 | 3 | - | 71,267 | 5,497
ECL | -105 | -5 | -172 | -4 | -603 | -3 | - | - | -880 | -12
Net total | 62,019 | 5,302 | 8,013 | 182 | 352 | 1 | 3 | - | 70,387 | 5,485

Exposure to retail clients - mortgage loans and advances

as at 31 December 2024
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 48,503 | 3,069 | 5,736 | 16 | - | - | 1 | - | 54,240 | 3,085
11-17 | 5,194 | 124 | 1,448 | - | 3 | - | - | - | 6,645 | 124
18-19 | - | - | 124 | 1 | - | - | - | - | 124 | 1
20-22 | -3 | - | - | - | 289 | - | - | - | 286 | -
Total Gross | 53,694 | 3,193 | 7,308 | 17 | 292 | - | 1 | - | 61,295 | 3,210
ECL | -11 | - | -57 | - | -113 | - | - | - | -181 | -
Net total | 53,683 | 3,193 | 7,251 | 17 | 179 | - | 1 | - | 61,114 | 3,210

Exposure to retail clients - other loans and advances

as at 31 December 2024
risk class range | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
1-10 | 987 | 1,733 | 40 | 127 | - | - | - | - | 1,027 | 1,860
11-17 | 7,440 | 381 | 650 | 41 | 1 | - | 2 | - | 8,093 | 422
18-19 | 3 | - | 187 | 1 | - | - | - | - | 190 | 1
20-22 | - | - | - | - | 662 | 4 | - | - | 662 | 4
Total Gross | 8,430 | 2,114 | 877 | 169 | 663 | 4 | 2 | - | 9,972 | 2,287
ECL | -94 | -5 | -115 | -4 | -490 | -3 | - | - | -699 | -12
Net total | 8,336 | 2,109 | 762 | 165 | 173 | 1 | 2 | - | 9,273 | 2,275

106 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Exposures to clients by DPD
Exposures to corporate clients

as at 31 December 2025
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 82,764 | 48,224 | 10,999 | 5,968 | 2,245 | 227 | 39 | - | 96,047 | 54,419
1-30 | 493 | 104 | 455 | 36 | 181 | 14 | - | - | 1,129 | 154
31-60 | 1 | - | 156 | 6 | 109 | 7 | - | - | 266 | 13
61-90 | 2 | - | 21 | - | 127 | 1 | - | - | 150 | 1
91-180 | - | - | 2 | - | 262 | 2 | - | - | 264 | 2
181-365 | - | - | 1 | - | 704 | 2 | - | - | 705 | 2
>365 | - | - | - | - | 2,167 | 1 | - | - | 2,167 | 1
Total Gross | 83,260 | 48,328 | 11,634 | 6,010 | 5,795 | 254 | 39 | - | 100,728 | 54,592

Exposure to retail clients – total

as at 31 December 2025
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 76,798 | 6,291 | 1,611 | 180 | 351 | 4 | 3 | - | 78,763 | 6,475
1-30 | 381 | - | 526 | - | 60 | - | - | - | 967 | -
31-60 | - | - | 96 | - | 23 | - | - | - | 119 | -
61-90 | - | - | 25 | - | 17 | - | - | - | 42 | -
91-180 | - | - | - | - | 70 | - | - | - | 70 | -
181-365 | - | - | - | - | 110 | - | - | - | 110 | -
>365 | - | - | - | - | 353 | - | - | - | 353 | -
Total Gross | 77,179 | 6,291 | 2,258 | 180 | 984 | 4 | 3 | - | 80,424 | 6,475

Exposure to retail clients - mortgage loans and advances

as at 31 December 2025
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 67,173 | 2,925 | 1,058 | 17 | 104 | - | 1 | - | 68,336 | 2,942
1-30 | 329 | - | 312 | - | 25 | - | - | - | 666 | -
31-60 | - | - | 72 | - | 9 | - | - | - | 81 | -
61-90 | - | - | 15 | - | 4 | - | - | - | 19 | -
91-180 | - | - | - | - | 25 | - | - | - | 25 | -
181-365 | - | - | - | - | 29 | - | - | - | 29 | -
>365 | - | - | - | - | 112 | - | - | - | 112 | -
Total Gross | 67,502 | 2,925 | 1,457 | 17 | 308 | - | 1 | - | 69,268 | 2,942

Exposure to retail clients - other loans and advances

as at 31 December 2025
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 9,625 | 3,366 | 553 | 163 | 247 | 4 | 2 | - | 10,427 | 3,533
1-30 | 52 | - | 214 | - | 35 | - | - | - | 301 | -
31-60 | - | - | 24 | - | 14 | - | - | - | 38 | -
61-90 | - | - | 10 | - | 13 | - | - | - | 23 | -
91-180 | - | - | - | - | 45 | - | - | - | 45 | -
181-365 | - | - | - | - | 81 | - | - | - | 81 | -
>365 | - | - | - | - | 241 | - | - | - | 241 | -
Total Gross | 9,677 | 3,366 | 801 | 163 | 676 | 4 | 2 | - | 11,156 | 3,533

107 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Exposures to corporate clients

as at 31 December 2024
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 76,410 | 42,693 | 12,223 | 5,412 | 2,182 | 173 | 47 | - | 90,862 | 48,278
1-30 | 1,121 | 90 | 625 | 39 | 195 | 2 | - | - | 1,941 | 131
31-60 | 2 | - | 193 | 4 | 105 | 3 | - | - | 300 | 7
61-90 | 1 | - | 39 | - | 77 | - | - | - | 117 | -
91-180 | - | - | 8 | - | 441 | - | - | - | 449 | -
181-365 | - | - | - | - | 791 | 20 | - | - | 791 | 20
>365 | 1 | - | - | - | 1,666 | - | - | - | 1,667 | -
Total Gross | 77,535 | 42,783 | 13,088 | 5,455 | 5,457 | 198 | 47 | - | 96,127 | 48,436

Exposure to retail clients – total

as at 31 December 2024
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 61,814 | 5,307 | 7,502 | 186 | 340 | 4 | 3 | - | 69,659 | 5,497
1-30 | 310 | - | 552 | - | 62 | - | - | - | 924 | -
31-60 | - | - | 101 | - | 18 | - | - | - | 119 | -
61-90 | - | - | 30 | - | 16 | - | - | - | 46 | -
91-180 | - | - | - | - | 67 | - | - | - | 67 | -
181-365 | - | - | - | - | 113 | - | - | - | 113 | -
>365 | - | - | - | - | 339 | - | - | - | 339 | -
Total Gross | 62,124 | 5,307 | 8,185 | 186 | 955 | 4 | 3 | - | 71,267 | 5,497

Exposure to retail clients - mortgage loans and advances

as at 31 December 2024
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 53,446 | 3,193 | 6,877 | 17 | 112 | - | 1 | - | 60,436 | 3,210
1-30 | 248 | - | 333 | - | 22 | - | - | - | 603 | -
31-60 | - | - | 79 | - | 5 | - | - | - | 84 | -
61-90 | - | - | 19 | - | 5 | - | - | - | 24 | -
91-180 | - | - | - | - | 18 | - | - | - | 18 | -
181-365 | - | - | - | - | 26 | - | - | - | 26 | -
>365 | - | - | - | - | 104 | - | - | - | 104 | -
Total Gross | 53,694 | 3,193 | 7,308 | 17 | 292 | - | 1 | - | 61,295 | 3,210

Exposure to retail clients - other loans and advances

as at 31 December 2024
number of days past due | Stage 1 | Stage 2 | Stage 3 | POCI | Total
on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet | on-balance sheet | off-balance sheet
0 | 8,368 | 2,114 | 625 | 169 | 228 | 4 | 2 | - | 9,223 | 2,287
1-30 | 62 | - | 219 | - | 40 | - | - | - | 321 | -
31-60 | - | - | 22 | - | 13 | - | - | - | 35 | -
61-90 | - | - | 11 | - | 11 | - | - | - | 22 | -
91-180 | - | - | - | - | 49 | - | - | - | 49 | -
181-365 | - | - | - | - | 87 | - | - | - | 87 | -
>365 | - | - | - | - | 235 | - | - | - | 235 | -
Total Gross | 8,430 | 2,114 | 877 | 169 | 663 | 4 | 2 | - | 9,972 | 2,287

108 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2.9.3. Concentration of exposures
Concentration of exposures to corporate clients in national economy sectors

as at 31 December 2025 |
National economy sector | balance sheet and off-balance sheet exposure in PLN million (gross carrying amount) | share in the total exposure
Stage 1 | Stage 2 | Stage 3 | Total | (in %)
wholesale trade | 15,048 | 2,344 | 590 | 17,982 | 11.6%
construction | 8,830 | 1,608 | 435 | 10,873 | 7.0%
property services | 8,569 | 1,387 | 507 | 10,463 | 6.7%
financial intermediation | 9,467 | 8 | 2 | 9,477 | 6.1%
other business operations | 7,107 | 1,517 | 245 | 8,869 | 5.7%
retail trade | 7,689 | 595 | 254 | 8,538 | 5.5%
production of foodstuffs and beverages | 5,536 | 827 | 151 | 6,514 | 4.2%
land transport and pipelines | 5,055 | 886 | 508 | 6,449 | 4.2%
manufacturing of metal final products | 4,547 | 1,291 | 372 | 6,210 | 4.0%
rental of equipment | 4,526 | 751 | 56 | 5,333 | 3.4%
power generation | 4,470 | 300 | 31 | 4,801 | 3.1%
public administration and national defence | 4,381 | 226 | - | 4,607 | 3.0%
rubber industry | 3,618 | 708 | 152 | 4,478 | 2.9%
production of chemicals, chemical products | 2,911 | 177 | 1,363 | 4,451 | 2.9%
sales, repair and maintenance of motor vehicles | 3,393 | 413 | 123 | 3,929 | 2.5%
post and telecommunications | 3,275 | 127 | 23 | 3,425 | 2.2%
wood and paper industry | 2,489 | 650 | 127 | 3,266 | 2.1%
computer science and related activities | 2,533 | 205 | 90 | 2,828 | 1.8%
machine industry | 1,933 | 310 | 175 | 2,418 | 1.6%
others | 26,211 | 3,314 | 884 | 30,409 | 19.6%
Total | 131,588 | 17,644 | 6,088 | 155,320 | 100%

as at 31 December 2024 |
National economy sector | balance sheet and off-balance sheet exposure in PLN million (gross carrying amount) | share in the total exposure
Stage 1 | Stage 2 | Stage 3 | Total | (in %)
wholesale trade | 14,265 | 2,432 | 478 | 17,175 | 11.9%
construction | 8,474 | 1,323 | 437 | 10,234 | 7.1%
financial intermediation | 9,610 | 36 | 15 | 9,661 | 6.7%
property services | 7,843 | 1,085 | 497 | 9,425 | 6.5%
other business operations | 7,275 | 1,632 | 271 | 9,178 | 6.3%
retail trade | 6,708 | 548 | 301 | 7,557 | 5.2%
land and pipeline transport | 4,595 | 1,013 | 472 | 6,080 | 4.2%
production of foodstuffs and beverages | 4,918 | 725 | 185 | 5,828 | 4.0%
manufacturing of metal final products | 4,765 | 783 | 257 | 5,805 | 4.0%
rubber industry | 3,635 | 1,079 | 123 | 4,837 | 3.3%
production of chemicals, chemical products | 3,004 | 289 | 1,359 | 4,652 | 3.2%
rental of equipment | 3,284 | 821 | 48 | 4,153 | 2.9%
sales, repair and maintenance of motor vehicles | 3,246 | 293 | 101 | 3,640 | 2.5%
post and telecommunications | 3,272 | 214 | 24 | 3,510 | 2.4%
wood and paper industry | 2,479 | 876 | 116 | 3,471 | 2.4%
power generation | 2,822 | 283 | 103 | 3,208 | 2.2%
public administration and national defence | 1,756 | 878 | - | 2,634 | 1.8%
machine industry | 1,784 | 512 | 95 | 2,391 | 1.7%
agriculture, forestry, fishery | 1,870 | 396 | 71 | 2,337 | 1.6%
others | 24,729 | 3,308 | 750 | 28,787 | 19.9%
Total | 120,334 | 18,526 | 5,703 | 144,563 | 100%

109 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Group’s largest exposures
The table presents the 20 largest exposures of the Group to individual entities or groups of related debtors.
The presented groups of entities include groups in which the parent entity is an institution within the meaning
of CRR regulations (including the parent entity towards the Group) and groups of entities owned by the State
Treasury or in which the State Treasury exercises control on another basis.
The amount of exposures includes the value of on-balance sheet assets (loans granted, deposits submitted, debt
securities), off-balance sheet liabilities granted and the value of balance sheet equivalent of derivatives. Exposures
were reduced by the amounts of exclusions allowed under Regulation (EU) No 575/2013 of the European
Parliament and of the Council of 26 June 2013 (CRR) and the Regulation of the Minister of Finance of 1 July 2016
on the types of exposures of banks excluded from large exposure limits. The effects of applying risk reduction
techniques in accordance with CRR were also taken into account.
The amount of the exposure of the groups of debtors related to the State Treasury includes not only exposures
to companies of the State Treasury or controlled by it on another basis, but also the non-exclusive value of State
Treasury bonds(1) and guarantees and sureties of Korporacja Ubezpieczeń Kredytów Eksportowych (KUKE) S.A.
For the above exposures, the Bank has the consent of the PFSA pursuant to Article 500a paragraph 2 of CRR
to temporarily application of increased limits of large exposures (up to 40% of Tier 1 capital)
(1) In the July-December 2024 period, the Bank used the temporary possibility to exclude in limits of large exposures positions resulting
from public debt denominated in the currency of another EU Member State on the basis of the CRR provisions amended by Regulation
(EU) 2024/1623 of the European Parliament and of the Council of 31 May 2024 amending Regulation (EU) No 575/2013 as regards credit
risk requirements, credit valuation adjustment risk, operational risk, market risk and minimum capital threshold.

as at 31 December |
Entity/group of related entities | Group’s exposures
2025 | 2024
Group 1 */** | 4,581 | 2,145
Group 2 */** | 3,731 | 1,366
Group 3 */** | 3,714 | 329
Group 4 */** | 3,621 | 1,128
Group 5 */** | 3,147 | 677
Group 6 (banking) | 3,060 | 3,025
Group 7 */** | 3,032 | -
Group 8 */** | 3,072 | 430
Group 9 */** | 2,676 | 236
Group 10 */** | 2,571 | -
Group 11 | 2,355 | 2,328
Group 12 | 2,349 | 1,829
Group 13 (banking) * | 1,817 | 1,553
Group 14 *** | 1,612 | 1,632
Group 15 | 1,541 | 1,254
Group 16 | 1,626 | 1,062
Group 17 | 1,345 | 1,350
Group 18 (banking) | 1,064 | 1,288
Group 19 | 1,026 | 1,026
Group 20 | 1,023 | 1,005

*) exclusions of exposures from concentration limits were applied on the basis of the provisions of Article 400 CRR
**) group with the participation of entities related to the State Treasury
***) exposure shall also include securitisation.

110 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2.9.4. Collaterals
Group’s largest exposures
The Group applies collateral on the following assets: cash (deposit in the Bank or another bank), liquid securities,
real estate, means of transport, receivables, machinery and equipment, inventories, intangible assets and other
collateral.
As at 31 December 2025, the value of collateral for Stage 3 credit exposures was PLN 2,210 million, compared
to PLN 2,206 million at the end of 2024. If the value of collateral exceeds the credit exposure balance, it was
assumed that the value of collateral is equal to the exposure balance.
The tables show the value of collateral not exceeding the carrying amount of the related credit exposures.
The presented values of collateral result from the assumptions adopted by the Group for determining the nominal
value of collateral, the general principles of which for the main types of collateral are as follows:
• The value of real estate collateral is the lower of the two values, i.e. the value determined as a result of the
Group’s verification of the value of the real estate (not higher than the market value specified in the valuation
report or internal valuation report) determined in the cyclical monitoring / update process, after deducting the
previously incurred mortgage charges or the value of the mortgage register entry.
• The value of collateral for machinery and equipment is the lower of the sum insured for this item, the net present
book value or the highest amount of collateral in the case of a registered pledge agreement.
• The value of the collateral in the case of guarantees other than those of the parent or other related company
is the lower of the two values, i.e. the amount to which the guarantee is issued or the amount of the credit
exposure to which the collateral relates.

as at 31 December 2025 |  |  |  |  |
| Maximum recognisable amount of collateral or guarantee
mortgage-backed loans | other secured loans | financial guarantees received
housing loans | commercial loans | cash funds (issued debt instruments) | others
Loans and advances, of which: | 62,797 | 20,767 | 51 | 19,035 | 12,125
other financial institutions | 7 | 108 | - | 86 | 2,890
non-financial entities | 784 | 19,432 | 43 | 16,902 | 7,770
households | 62,006 | 1,226 | 8 | 1,728 | 1,465
including: loans to purchase residential properties | 60,900 | 736 | - | - | -
other entities (banks, budgetary sector) | - | 1 | - | 319 | -

as at 31 December 2024 |  |  |  |  |
| Maximum recognisable amount of collateral or guarantee
| mortgage-backed loans | other secured loans | financial guarantees received
| housing loans | commercial loans | cash funds (issued debt instruments) | others
Loans and advances, of which: | 57,333 | 21,315 | 47 | 19,863 | 11,804
other financial institutions | 8 | 19 | - | 76 | 3,533
non-financial entities | 1,349 | 20,308 | 47 | 17,879 | 6,948
households | 55,976 | 984 | - | 1,785 | 1,320
including: loans to purchase residential properties | 54,733 | 643 | - | - | -
other entities (banks, budgetary sector) | - | 4 | - | 123 | 3

111 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2.9.5. Loan portfolio performing and non-performing and exposures with forbearance granted
The tables below present the breakdown of the loan portfolio into the performing and non- performing portfolio with the breakdown of exposures with forbearance granted. The Group classifies exposures to the quarantine class for which
facilities have been applied in the past, and which are currently in the observation period before full healing.
In the income statement for 2025, in Interest income - interest on loans and other receivables to customers, interest income on exposures with forbearance facilities was recognised in the amount of PLN 291 million (PLN 368 million for
2024), of which PLN 167 million relates to exposures in the performing portfolioand PLN 124 million to exposures in the non- performing portfolio (PLN 242 million and PLN 126 million, respectively, for 2024).
Loan portfolio - split into the performing and non-performing portfolio, detailing exposures with forbearance granted

as at 31 December 2025 |  |  |  |  |  |  |  |  |  |  |
| Performing exposures | including forbearance |  |  |  | Non-performing exposures |  |  |  |  |
modification of terms and conditions | refinancing | quarantine | including forbearance | modification of terms and conditions | refinancing | overdue portfolio | impaired portfolio
Gross loan portfolio, of which: | 174,330 | 2,644 | 2,644 | 0 | 2,499 | 6,822 | 3,434 | 3,434 | 0 | 3,433 | 2,663
Corporate banking, of which: | 94,894 | 2,143 | 2,143 | - | 2,019 | 5,834 | 3,043 | 3,043 | - | 3,043 | 2,273
loans in the current account | 15,112 | 523 | 523 | - | 523 | 457 | 264 | 264 | - | 264 | 264
term loans and advances | 56,045 | 1,485 | 1,485 | - | 1,485 | 3,804 | 1,955 | 1,955 | - | 1,955 | 1,185
lease receivables | 13,110 | 116 | 116 | - | - | 693 | 45 | 45 | - | 45 | 45
factoring receivables | 5,958 | 19 | 19 | - | 11 | 880 | 779 | 779 | - | 779 | 779
corporate and municipal debt securities | 4,669 | - | - | - | - | - | - | - | - | - | -
Retail banking segment, including: | 79,436 | 501 | 501 | - | 480 | 988 | 391 | 391 | - | 390 | 390
mortgages | 68,959 | 411 | 411 | - | 390 | 309 | 90 | 90 | - | 89 | 89
loans in the current account | 624 | 2 | 2 | - | 2 | 63 | 5 | 5 | - | 5 | 5
other loans and advances | 9,853 | 88 | 88 | - | 88 | 616 | 296 | 296 | - | 296 | 296
Impairment for expected credit losses, including: | -806 | -107 | -107 | 0 | -105 | -3,348 | -1,496 | -1,496 | 0 | -1,495 | -1,495
Corporate banking, of which: | -532 | -97 | -97 | - | -95 | -2,734 | -1,243 | -1,243 | - | -1,243 | -1,243
loans in the current account | -93 | -16 | -16 | - | -16 | -219 | -93 | -93 | - | -93 | -93
term loans and advances | -382 | -79 | -79 | - | -79 | -2,073 | -852 | -852 | - | -852 | -852
lease receivables | -42 | -2 | -2 | - | - | -89 | -5 | -5 | - | -5 | -5
factoring receivables | -13 | - | - | - | - | -353 | -293 | -293 | - | -293 | -293
corporate and municipal debt securities | -2 | - | - | - | - | - | - | - | - | - | -
Retail banking segment, including: | -274 | -10 | -10 | - | -10 | -614 | -253 | -253 | - | -252 | -252
mortgages | -56 | -4 | -4 | - | -4 | -116 | -38 | -38 | - | -37 | -37
loans in the current account | -24 | - | - | - | - | -45 | -4 | -4 | - | -4 | -4
other loans and advances | -194 | -6 | -6 | - | -6 | -453 | -211 | -211 | - | -211 | -211

112 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December 2024 |  |  |  |  |  |  |  |  |  |  |
| Performing exposures | including forbearance |  |  |  | Non-performing exposures |  |  |  |  |
modification of terms and conditions | refinancing | quarantine | including forbearance | modification of terms and conditions | refinancing | overdue portfolio | impaired portfolio
Gross loan portfolio, of which: | 160,933 | 3,515 | 3,134 | 381 | 3,326 | 6,461 | 3,164 | 3,163 | 1 | 1,317 | 2,372
Corporate banking, of which: | 90,623 | 2,894 | 2,513 | 381 | 2,720 | 5,504 | 2,773 | 2,772 | 1 | 1,175 | 1,982
loans in the current account | 14,645 | 448 | 448 | - | 448 | 289 | 109 | 109 | - | 66 | 109
term loans and advances | 52,612 | 2,258 | 1,877 | 381 | 2,258 | 3,706 | 1,826 | 1,825 | 1 | 1,045 | 1,035
lease receivables | 12,825 | 165 | 165 | - | - | 619 | 44 | 44 | - | 44 | 44
factoring receivables | 5,970 | 23 | 23 | - | 14 | 890 | 794 | 794 | - | 20 | 794
corporate and municipal debt securities | 4,571 | - | - | - | - | - | - | - | - | - | -
Retail banking segment, including: | 70,310 | 621 | 621 | - | 606 | 957 | 391 | 391 | - | 142 | 390
mortgages | 61,003 | 508 | 508 | - | 493 | 292 | 116 | 116 | - | 34 | 115
loans in the current account | 630 | 2 | 2 | - | 2 | 58 | 4 | 4 | - | 2 | 4
other loans and advances | 8,677 | 111 | 111 | - | 111 | 607 | 271 | 271 | - | 106 | 271
Impairment for expected credit losses, including: | -811 | -116 | -116 | - | -113 | -3,144 | -1,228 | -1,228 | - | -681 | -1,227
Corporate banking, of which: | -534 | -105 | -105 | - | -102 | -2,541 | -998 | -998 | - | -582 | -998
loans in the current account | -90 | -14 | -14 | - | -14 | -128 | -28 | -28 | - | -21 | -28
term loans and advances | -389 | -88 | -88 | - | -88 | -2,073 | -756 | -756 | - | -548 | -756
lease receivables | -38 | -3 | -3 |  | - | -64 | -3 | -3 |  | -3 | -3
factoring receivables | -13 | - | - |  | - | -276 | -211 | -211 |  | -10 | -211
corporate and municipal debt securities | -4 | - | - | - | - | - | - | - | - | - | -
Retail banking segment, including: | -277 | -11 | -11 | - | -11 | -603 | -230 | -230 | - | -99 | -229
mortgages | -68 | -4 | -4 | - | -4 | -113 | -44 | -44 | - | -18 | -43
loans in the current account | -24 | - | - | - | - | -40 | -3 | -3 | - | -1 | -3
other loans and advances | -185 | -7 | -7 | - | -7 | -450 | -183 | -183 | - | -80 | -183

113 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Exposures with forbearance granted by risk classes

as at 31 December 2025 |  |  |  |  |  |  |  |  |  |  |  |
risk class range | Corporate banking | Retail banking | Total
performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio
on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure
1-10 | 5 | 2 | - | - | 269 | - | - | - | 274 | 2 | - | -
11-17 | 862 | 319 | 2 | - | 219 | - | 1 | - | 1,081 | 319 | 3 | -
18-19 | 1,276 | 96 | 1 | - | 13 | - | - | - | 1,289 | 96 | 1 | -
20-22 | - | - | 3,040 | 140 | - | - | 390 | - | - | - | 3,430 | 140
Total (gross) | 2,143 | 417 | 3,043 | 140 | 501 | - | 391 | - | 2,644 | 417 | 3,434 | 140

as at 31 December 2024 |  |  |  |  |  |  |  |  |  |  |  |
risk class range | Corporate banking | Retail banking | Total
performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio
on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure
1-10 | 50 | - | - | - | 415 | - | - | - | 465 | - | - | -
11-17 | 1,616 | 2 | - | - | 192 | - | 2 | - | 1,808 | 2 | 2 | -
18-19 | 1,228 | 5 | 1 | - | 14 | - | - | - | 1,242 | 5 | 1 | -
20-22 | - | - | 2,772 | 9 | - | - | 389 | - | - | - | 3,161 | 9
Total (gross) | 2,894 | 7 | 2,773 | 9 | 621 | - | 391 | - | 3,515 | 7 | 3,164 | 9

114 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Exposures with forbearance granted by DPD

as at 31 December 2025 |  |  |  |  |  |  |  |  |  |  |  |
number of days past due | Corporate banking | Retail banking | Total
performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio
on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure
0 | 2,091 | 417 | 1,759 | 129 | 460 | - | 245 | - | 2,551 | 417 | 2,004 | 129
1-30 | 34 | - | 37 | 11 | 36 | - | 28 | - | 70 | - | 65 | 11
31-60 | 14 | - | 13 | - | 5 | - | 7 | - | 19 | - | 20 | -
61-90 | 4 | - | 53 | - | - | - | 6 | - | 4 | - | 59 | -
91-180 | - | - | 89 | - | - | - | 14 | - | - | - | 103 | -
181-365 | - | - | 271 | - | - | - | 21 | - | - | - | 292 | -
>365 | - | - | 821 | - | - | - | 70 | - | - | - | 891 | -
Total (gross) | 2,143 | 417 | 3,043 | 140 | 501 | - | 391 | - | 2,644 | 417 | 3,434 | 140

as at 31 December 2024 |  |  |  |  |  |  |  |  |  |  |  |
number of days past due | Corporate banking | Retail banking | Total
performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio | performing portfolio | non-performing portfolio
on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure | on-balance sheet exposure | off-balance sheet exposure
0 | 2,856 | 7 | 1,779 | 7 | 576 | - | 249 | - | 3,432 | 7 | 2,028 | 7
1-30 | 29 | - | 59 | 2 | 41 | - | 31 | - | 70 | - | 90 | 2
31-60 | 6 | - | 17 | - | 4 | - | 6 | - | 10 | - | 23 | -
61-90 | 3 | - | 20 | - | - | - | 5 | - | 3 | - | 25 | -
91-180 | - | - | 48 | - | - | - | 15 | - | - | - | 63 | -
181-365 | - | - | 384 | - | - | - | 23 | - | - | - | 407 | -
>365 | - | - | 466 | - | - | - | 62 | - | - | - | 528 | -
Total (gross) | 2,894 | 7 | 2,773 | 9 | 621 | - | 391 | - | 3,515 | 7 | 3,164 | 9

115 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

2.9.6. Credit quality of other financial assets
Credit quality of loans and other receivables granted to other banks
Loans and other receivables granted to other banks are presented in the consolidated statement of financial
position in Loans and other receivables to other banks (note 15) and - in the cash equivalent part - in Cash and cash
equivalents (note 14).
As at 31 December 2025 and as at 31 December 2024, loans and other receivables granted to other banks were
in approx. 99% in low risk classes (rating 1-10), others in medium and higher risk classes with ratings from 11 to 19
(as at the end of 2024). Exposures of PLN 24,147 million (PLN 21,826 million as at 31 December 2024) were fully
in Stage 1.
The change in the level of the allowance for expected credit losses in 2025 and 2024 resulted from changes in the
credit parameters of the portfolio described above.
Credit quality of debt securities
As at 31 December 2025, all debt securities in the portfolio of financial assets held for trading and the portfolio
of investment securities were in low risk classes with ratings from 1 to 10 (as at the end of 2024). Both at the end
of 2025 and at the end of 2024, all debt securities in the investment securities portfolio were in Stage 1.
The change in the level of the allowance for expected credit losses in 2025 and 2024 resulted from changes in the
credit parameters of the portfolios described above.
In 2025, similarly to 2024, changes in the gross value of investment securities measured at fair value through other
comprehensive income and measured at amortised cost did not have a significant impact on the level
of allowances for expected credit losses.
In 2025 and 2024, there were no transfers of investment securities between stages with different ways
of measuring expected credit losses.
Investment securities - carrying amount and the level of impairment for expected credit losses by Stages

as at 31 December |  |  |  |  |  |
| 2025 | 2024
Stage 1 | Stage 1
carrying amount (gross) | impairment for expected credit losses | carrying amount (net) | carrying amount (gross) | impairment for expected credit losses | carrying amount (net)
Debt securities at fair value through other comprehensive income*, including: | 38,208 | -14 | - | 31,685 | -12 | -
Treasury bonds in PLN | 33,156 | -14 | - | 26,371 | -12 | -
European Union bonds | 1,947 | - | - | 2,064 | - | -
European Investment Bank bonds | 2,689 | - | - | 2,838 | - | -
Austrian government bonds | 416 | - | - | 412 | - | -
Debt securities measured at amortised cost, including: | 27,056 | -7 | 27,049 | 27,063 | -10 | 27,053
Treasury bonds in PLN | 15,828 | -6 | 15,822 | 11,864 | -5 | 11,859
Treasury bonds in EUR | 1,973 | -1 | 1,972 | 2,873 | -1 | 2,872
European Investment Bank bonds | 7,111 | - | 7,111 | 6,654 | - | 6,654
Bonds of the Polish Development Fund (PFR) | 1,845 | - | 1,845 | 3,864 | -4 | 3,860
Bank Gospodarstwa Krajowego bonds | 199 | - | 199 | 1,808 | - | 1,808
NBP bills | 100 | - | 100 | - | - | -

*) In the case of financial assets measured at fair value through other comprehensive income, the carrying amount
is not reduced by the allowance for expected credit losses.
Investment securities - changes in impairment for expected credit losses

for the year ended 31 December |  |  |  |  |  |
| 2025 | 2024
Stage 1 | Stage 1
measured at fair value through other comprehensive income | measured at amortised cost | Total | measured at fair value through other comprehensive income | measured at amortised cost | Total
Opening balance impairment | 12 | 10 | 22 | 12 | 14 | 26
Changes during the period, including: | 2 | -3 | -1 | - | -4 | -4
provisions recognised/ reversed | 2 | -3 | -1 | - | -4 | -4
Closing balance impairment | 14 | 7 | 21 | 12 | 10 | 22

Quality of other financial assets
The tables below present the credit quality of other financial assets, which are presented in item Other assets of the
consolidated statement of financial position and in note 26.

116 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Other financial assets - gross carrying amount and the level of impairment for expected credit losses by Stages

as at 31 December |  |  |  |  |  |
| 2025 | 2024
gross | impairment for expected credit loss | net | gross | impairment for expected credit loss | net
brutto | odpis | netto | brutto | odpis | netto
assets in Stage 1 | 32 | - | 32 | 40 | - | 40
assets in Stage 3 | 33 | -33 | - | 33 | -33 | -
Total | 65 | -33 | 32 | 73 | -33 | 40

Other financial assets - changes in impairment for expected credit losses

as at 31 December |
| 2025 | 2024
Stage 3 | Stage 3
Opening balance impairment | 33 | 43
Changes in the period, including: | - | -10
additional provision for expected credit losses | 4 | 7
exclusion from the statement of financial position as a result of write-down | - | -3
exclusion from the statement of financial position due to repayment | -4 | -14
Closing balance impairment | 33 | 33

Other financial assets - reconciliation of the gross carrying amount

as at 31 December |
| 2025 | 2024
Stage 1 | Stage 3 | Total | Stage 1 | Stage 3 | Total
Opening balance of gross carrying amount | 40 | 33 | 73 | 38 | 43 | 81
Changes in the period, including: | -8 | - | -8 | 2 | -10 | -8
transfer to and from Stage 3 | -4 | 4 | - | -7 | 7 | -
exclusion from the statement of financial position due to write-down | - | - | - | - | -3 | -3
recognition of new financial instruments, repayments and other changes | -4 | -4 | -8 | 9 | -14 | -5
Closing gross value | 32 | 33 | 65 | 40 | 33 | 73

2.9.7. Modification of contractual cash flows
In 2025, credit exposures in the amount of PLN 2,608 million (PLN 1,474 million in 2024) were subject
to modification of contractual cash flows, which did not result in their deletion and re-recognition of a financial
asset. In addition, in 2024 , exposures in the amount of PLN 5,849 million due to credit holidays were not subject
to exclusion and re-recognition as a financial asset.
Modifications in contractual cash flows, which do not result in their deletion and re-recognition of a financial asset,
i.e. lead to the recognition of gains or losses from the modification, result from business premises or credit risk
events in the form of facilities (forbearance) granted to customers. If business indications occur, the method
of determining the allowance for expected credit losses does not change. The granting of facilities to customers
(forbearance) proves a significant increase in credit risk, resulting in classification to Stage 2, in the event of granting
another facility, there is classification to Stage 3 in accordance with the principles for estimating impairment losses
described in chapter III. Significant accounting principles, in point 13.11. Expected credit losses.
The table presents information on financial assets for which the contractual cash flows have been modified, while
the corresponding allowance for expected credit losses was measured at an amount equal to lifetime expected
credit losses (i.e. financial assets in Stages 2 and 3).

as at 31 December |
| 2025 | 2024
Financial assets modified in the period |  |
amortised cost before modification | 191 | 343
net loss due to modification | -1 | -1
Financial assets that have been modified since their initial recognition |  |
the gross carrying amount of previously modified financial assets for which the allowance for expected credit losses has changed during the period to an amount equal to 12-month expected credit losses (i.e. these financial assets have been transferred to Stage 1) | 51 | 30

3. Market risk

3.1. Introduction | 116
3.2. Market risk management objectives | 117
3.3. Market risk management policies | 117
3.4. Market risk management process | 117
3.5. Structure of books and methods of risk measurement | 117
3.6. FX structure of assets and liabilities | 120
3.7. Impact of the benchmark reform | 123
3.8. Hedge accounting | 124
3.9. The approach to risk management in subsidiaries | 129

3.1. Introduction
Market risk is defined as a potential loss that may be incurred by the Bank due to unfavourable changes in market
prices (such as yield curves, exchange rates, prices on the capital market), market parameters (market price
volatility, correlation between movements of individual prices) and customer behaviour (e.g. early repayment
of loans).

117 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

3.2. Market risk management objectives
The main objectives of market risk management at ING Bank Śląski S.A. are: to ensure that there is awareness and
understanding of the Bank’s exposure to market risk and that this exposure is appropriately managed and, where
applicable, within the limits set.
3.3. Market risk management policies
The Market Risk Management Department has normative documents that describe the scope, principles and
responsibilities of the department. In order to optimise the market risk management process, the M arket Risk
Management Policy has been developed at ING Bank Śląski S.A. It describes the bank’s approach to market risk
management. It defines the principles, methodology of management and measurement of market risk in the Bank,
as well as the general principles of process management.
The document is a detailed document entitled General principles of risk management at ING Bank Śląski S.A., which
is approved by the Bank’s Supervisory Board, on the basis of a recommendation from the Risk Committee.
The Policy is subject to approval by the Bank’s Management Board.
Another document is the policy describing the Bank’s approach to the process of defining the risk appetite in the
area of market and liquidity risk (Policy for determining and monitoring the risk appetite in the area of market and
liquidity risk). This policy is also approved by the Bank’s Management Board.
3.4. Market risk management process
The Bank’s market risk management process includes:
• identification,
• measurement,
• monitoring and
• risk reporting.
The Market Risk Management Department (MRM) provides managers of the Financial Markets Area of Wholesale
Banking and the Centre of Expertise Treasury, selected members of the Management Board and the ALCO
Committee with regular risk reports. Moreover, ALCO, the Bank’s Management Board and the Supervisory Board
receive periodic reports containing the most important market risk measures. The approval of individual market risk
limits is carried out at the level of ALCO Committee, the Bank’s Management Board or the Supervisory Board,
in accordance with the division of responsibility in determining the levels of limits defined in the Policy for
determining and monitoring risk appetite in the area of market and liquidity risk. The employees of the Market Risk
Management Department are qualified specialists and the independence of the department is ensured by its
separation from risk generating units.
The Bank’s market risk management also includes a Product Control function, which ensures the correct valuation
of Financial Market products in the Wholesale Banking Division and the Centre of Expertise Treasury by monitoring
the correctness of valuation models and controlling the quality of market data used for the valuation and
calculation of financial result. Decisions related to valuation models issues from September 2025 are made by the
AI Risk and Model Management Committee. Decisions related to issues related to the valuation process, such as:
sources of market data used for valuation, calculation of adjustments to market valuation models (bid-offer spread
and BVA), are taken by the Market Data and Valuation Models Committee and the Committee for parameterisation
of financial instruments measured at fair value.
In the reporting period, the market risk profile and the manner of managing this risk did not change significantly.
3.5. Structure of books and methods of risk measurement
3.5.1. Structure of books
The Bank maintains a structure of books based on intent, which translates into many processes, including market
risk management. The structure of the books reflects the types of market risk that are expected and accepted in
individual areas of the Bank and where market risk should be internally transferred/hedged. The Bank’s transactions
are allocated to individual portfolios belonging to the banking or trading book on the basis of the purpose
of concluding the transaction and the product mandate. The books are grouped into:
• trading (positions taken in order to generate benefits in a short period of time due to market price fluctuations),
and
• banking (all other positions).
The trading and banking portfolio includes internal and external transactions.
Banking Books
The Banking Books are split into Banking Commercial Books and Banking Books of the Centre of Expertise Treasury
(CoE Treasury). The Banking Commercial Books include books of the retail and corporate divisions containing
deposits and commercial loans. The risks relating to those positions are transferred to:
• banking books of the Centre of Expertise Treasury (used to manage the interest rate risk of the banking book,
the underlying risk and the liquidity risk as a whole), and
• commercial books of the Financial Markets Area in Wholesale Banking Division (for FX risk) via internal
transactions.
The process ensures that the banking commercial books do not retain any material economic market risk. However,
as described in more detail further below, the short-term financial result in those books is sensitive to changes
of market rates. The commercial activity of the subsidiary companies are included in the Bank's commercial books.

118 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Maintenance of open positions is permissible within the adopted product mandate and risk limits:
• for the banking book - BPV (Basis Point Value), slope risk (adverse impact on the result caused by an uneven shift
in the yield curve), CS01 (change in the market value of a security due to an increase in the credit spread), SOT NII
(Standard Outlier Test Net Interest Income at Risk), NIIaR (Net Interest Income at Risk), SOT EVE (Standard Outlier
Test on Economic Value of Equity), NPVaR (Net Present Value at Risk), Par-tial PV01 (a measure shows a change
in the value of an instrument due to a change in the curve in a given tenor Risk), Tenor Basis (underlying risk
affecting interest income), IR Gap (interest rate gap),
• for the trading book – VaR (Value at Risk), Slope risk (negative impact on the result caused by an uneven shift
of the yield curve), CS01 (change in the market value of a security due to an increase in the credit spread), BPV
(Basis Point Value),
• CS RRaR (Credit Spread Revaluation Reserve at Risk) – the measure shows the potential impact of changing credit
spreads on the level of revaluation reserve of HTC&S securities portfolio,
• IR RRaR (Interest Rate Revaluation Reserve at Risk) – the measure shows the potential impact of changing interest
rates on the level of revaluation reserve of HTC&S securities portfolio.
Hedge accounting is a tool supporting the management of interest rate risk in the banking book. The developed
assumptions to the hedging strategy are applied consistently with the approach to market risk management within
the approved market risk limits as described above. Detailed information on the assumptions underlying each
strategy in hedge accounting are described in this chapter, in item 13.8.1 Hedge Accounting.
Trading books
Trading Books are the books of the Financial Markets Area in Wholesale Banking Division: FX and interest rate books.
The books embrace positions maintained for a short time in order:
• to be resold, or
• to obtain financial benefits on the current price fluctuations or expected within a short time,
• or positions opened for arbitration purposes.
3.5.2. Measurement of interest rate risk in banking book
In measuring interest rate risk in the banking book, the Bank uses the measures required by the European Banking
Supervision (EBA/GL/2022/14). The core measures are as follows:
• income exposed to risk in regulatory scenarios (SOT NII) - measurement of the sensitivity of interest results
to sudden changes in interest rates over a 1-year time horizon; the assumptions regarding the recognition
of individual items, the size and shape of shock scenarios and the method of aggregation of results are specified
in Regulation (EU) 2024/856 of the European Commission,
• Net Interest Income at Risk – a measure of sensitivity of the reported results of positions recognised on an accrual
basis on the basis of a set of interest rate scenarios which provide for various potential shifts of the profitability
curve.
• Net Interest Income at Risk plus market value changes - measurement of the sensitivity of the reported results
of the position recorded on an accrual basis taking into account changes in the market value of instruments
measured at fair value over a given time period, based on a set of interest rate scenarios, which assume various
possibilities of shifting the yield curve,
• Economic Value of Equity (EVE)- measurement of the sensitivity of the economic value of capital to sudden
changes in interest rates; assumptions regarding the recognition of individual items, the size and shape of shock
scenarios and the method of aggregation of results are specified in Regulation (EU) 2024/856 of the European
Commission,
• Net Present Value at Risk – a measure of sensitivity of the economic value of interest rate positions to sudden
interest rate changes on the basis of a set of interest rate scenarios which provide for various potential shifts
of the profitability curve.
The Bank also pays special attention to measuring the credit spread risk from the banking book business (CSRBB)
using the following measures:
• change in interest income due to changes in credit spread (CSRBB NII) - measurement of the sensitivity
of reported interest results of positions sensitive to changes in credit spread (CSRBB) based on a set of credit
spread scenarios,
• change in interest income taking into account changes in market value due to changes in credit spread (CSRBB
NII + market value changes) - measurement of the sensitivity of reported interest results taking into account
changes in the market value of instruments measured at fair value over a given time horizon sensitive to changes
in credit spread (CSRBB) based on a set of credit spread scenarios,
• change in market value due to changes in credit spread (CSRBB NPV) - measurement of the sensitivity of positions
sensitive to changes in credit spread (CSRBB) based on a set of credit spread scenarios.
Additionally, the Bank measures in its banking books:
• option risk – potential losses on the positions resulting from premature deposit withdrawal and/or loan
prepayment,
• underlying risk - potential loss on positions resulting from mismatches in the repricing periods of assets and
liabilities

119 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• residual risk – a potential loss on those positions resulting from the application of non-standard pricing
mechanisms that are transferred to the Centre of Expertise Treasury managing interest rate risk.
Due to the fact that the positions of the Centre of Expertise Treasury are usually subject to valuation at amortised
cost, the Bank monitors BPV which limits economic risk of interest rate positions. Additionally, fluctuations of the
revaluation reserve are restricted with CS01, IR RRaR (for HTC&S portfolio) and CS RRa limits (for HTC&S portfolio).
3.5.3. Market risk measurement in the trading book
The VaR measured by the Bank is compliant with the best market practices. In the calculation of VaR, the Bank
applies the following assumptions:
• one-day positions, 99% confidentiality level,
• 260-day observation period.
In order to reinforce risk control, in the area of FX risk books the Bank has additionally implemented the
measurement and monitoring of the risk in the context of the approved limits on intra-day basis.
The Bank calculates also Stressed VaR. Stressed VaR is a measure replicating the calculation of historic simulations
with an assumption that the current portfolio is used for the measurement and historic market data from
a continuous 12-month period characterised with major fluctuations of market parameters that are material for
the portfolio.
Every year a general stress test is carried out covering, among others, market risk, liquidity and financing risk, credit
risk using a regulatory scenario and scenarios prepared by the Bank’s economists and accepted by ALCO.
Additionally, a stress test of derivatives is carried out on a quarterly basis, which shows the impact of shock
changes on the valuation of these instruments:
3.5.4. Sensitivity to currency risk in the trading book
The table below presents the VaR* measure (in PLN thousand) at the end of 2025 and 2024:

FX area |  |  |  |  |
| Limit | at the end of year | Average | Min | Max
2025 | 1,944 | 316 | 308 | 8 | 1,155
2024 | 1,709 | 249 | 273 | 4 | 1,313

*) All VaR limits and their utilisation in ING Bank Śląski S.A. are expressed in EUR. The limits levels and their utilisation
have been converted into PLN using the daily NBP fixing rates especially for the purposes of presentation in the
consolidated financial statements; in the column "Limit" the amounts determined using the fixing rate from the last
day of the year. Consolidated currency risk is present in the accounts of the Wholesale Banking Division of Financial
Markets and in subsidiaries.
3.5.5. Sensitivity of economic result and interest income to interest rate risk in regulatory measures
Sensitivity to interest rate risk is presented below for the following measures:
• The change in the present value of capital (Standard Outlier Test for Economic Value of Equity) is a measure
of the sensitivity of the economic value of interest rate positions to sudden changes in interest rates.
• The change in Net Interest Income (Standard Outlier Test for Net Interest Income) is a measure of the sensitivity
of interest results to sudden changes in interest rates over a 1-year horizon.
The following measures apply to significant currencies, i.e. PLN and EUR. The parameters for parallel scenarios are
250 bps (PLN) and 200 bps (EUR). In the case of non-parallel scenarios, changes are assumed (for PLN and EUR
respectively):
• for short-term rates - by 350 bps and 250 bps,
• for long-term rates - by 150 bps and 100 bps.
The assumptions for the recognition of individual items, the size and shape of shock scenarios and the method
of aggregating results are set out in Regulation (EU) 2024/856 of the European Commission.
• resulting from the banking book - the observed changes in EVE measurements are mainly due to two factors:
• changes (growth) in product volumes and
• changes in model parameters used for non-maturity product portfolios.
Changes in PLN million

as at 31 December |
Shock scenarios used for supervisory purposes * | 2025 | 2024 | 2025 | 2024
changes in the carrying amount of the revalued capital | changes in net interest income
Parallel increase in shock | -541 | 48 | 298 | 379
Parallel decrease in shock | 52 | 59 | -325 | -557
Fall in short-term rates and increase in long-term rates (steepener) | 670 | 347 | - | -
Increase in short-term rates and decrease in long-term rates (flattener) | -1,326 | -515 | - | -
Increases in short-term rates | -1,339 | -453 | - | -
Fall in short-term rates | 785 | 374 | - | -

120 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Changes in relation to Tier 1 capital

as at 31 December |
Shock scenarios used for supervisory purposes * | 2025 | 2024 | 2025 | 2024
changes in the carrying amount of the revalued capital in relation to Tier 1 capital | changes in net interest income in relation to Tier 1 capital
Parallel increase in shock | -2.98% | 0.28% | 1.64% | 2.25%
Parallel decrease in shock | 0.29% | 0.35% | -1.79% | -3.31%
Fall in short-term rates and increase in long-term rates (steepener) | 3.69% | 2.06% | - | -
Increase in short-term rates and decrease in long-term rates (flattener) | -7.30% | -3.06% | - | -
Increases in short-term rates | -7.38% | -2.69% | - | -
Fall in short-term rates | 4.32% | 2.22% | - | -

*) Positive results in a given scenario are scaled with factor 0.5 in accordance with EBA guidelines in the IRRBB area.
• sensitivity of equity to changes in interest rates resulting from debt instruments measured at fair value through
other comprehensive income in the Centre of Expertise Treasury portfolio:

| approximate change in the regulatory capital base for curve movement
-2% | -1% | +1% | +2%
2025 | 47 | 23 | -23 | -47
2024 | 67 | 34 | -34 | -67

3.6. FX structure of assets and liabilities
The consolidated statement of financial position and off-balance sheet liabilities of the Group are presented below,
with a breakdown by major currencies. The following exchange rates were used to calculate the value in the original
currency:

exchange rate as at 31 December |  |
| 2025 | 2024
EUR | 4.2267 | 4.2730
USD | 3.6016 | 4.1012
CHF | 4.5390 | 4.5371

121 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December 2025 |  |  |  |  |  |  |  |  |
| PLN | EUR | USD | CHF | other currencies | Total
converted to PLN | in currency | converted to PLN | in currency | converted to PLN | in currency | converted to PLN
Assets |
Cash and cash equivalents | 6,809 | 321 | 76 | 93 | 26 | 9 | 2 | 78 | 7,310
Loans and other receivables to other banks | 837 | 23,117 | 5,469 | - | - | - | - | - | 23,954
Financial assets measured at fair value through profit | 2,175 | 29 | 7 | 3 | 1 | - | - | 133 | 2,340
Derivative hedge instruments | 67 | 6 | 1 | - | - | - | - | - | 73
Investment securities | 58,531 | 7,025 | 1,662 | - | - | - | - | - | 65,556
Loans and other receivables to customers | 152,249 | 25,426 | 6,016 | 1,025 | 285 | 56 | 12 | 1,553 | 180,309
Investments in subsidiaries and associates measured | 204 | - | - | - | - | - | - | - | 204
Property, plant and equipment | 938 | - | - | - | - | - | - | - | 938
Intangible assets | 551 | - | - | - | - | - | - | - | 551
Current income tax assets | 12 | - | - | - | - | - | - | - | 12
Deferred tax assets | 621 | - | - | - | - | - | - | - | 621
Other assets | 152 | 5 | 1 | - | - | - | - | - | 157
Total assets | 223,146 | 55,929 | 13,232 | 1,121 | 312 | 65 | 14 | 1,764 | 282,025

Liabilities |
Liabilities to other banks | 770 | 13,953 | 3,301 | 318 | 88 | - | - | 1 | 15,042
Financial liabilities measured at fair value through profit or loss | 747 | 130 | 31 | 14 | 4 | - | - | 25 | 916
Derivative hedge instruments | 65 | 12 | 3 | - | - | - | - | - | 77
Liabilities to customers | 204,050 | 25,435 | 6,018 | 4,835 | 1,342 | 84 | 19 | 924 | 235,328
Liabilities from debt securities issued | 1,521 | - | - | - | - | - | - | - | 1,521
Subordinated liabilities | - | 2,548 | 603 | - | - | - | - | - | 2,548
Provisions | 631 | 11 | 3 | 1 | - | - | - | - | 643
Current income tax liabilities | 924 | - | - | - | - | - | - | - | 924
Other liabilities | 3,323 | 360 | 85 | 1 | - | - | - | - | 3,684
Total liabilities | 212,031 | 42,449 | 10,044 | 5,169 | 1,434 | 84 | 19 | 950 | 260,683
Equity |  |  |  |  |  |  |  |  |
Share capital | 130 | - | - | - | - | - | - | - | 130
Reserve capital - surplus from sale of shares above their nominal value | 956 | - | - | - | - | - | - | - | 956
Accumulated other comprehensive income | -1,869 | -15 | -4 | - | - | - | - | - | -1,884
Retained earnings | 22,149 | - | - | - | - | - | - | - | 22,149
Total equity | 21,357 | -15 | -4 | - | - | - | - | - | 21,342
Total equity and liabilities | 233,388 | 42,434 | 10,040 | 5,169 | 1,434 | 84 | 19 | 950 | 282,025
Contingent liabilities granted | 51,018 | 11,161 | 2,641 | 756 | 210 | 12 | 3 | 32 | 62,979
Contingent liabilities received | 25,538 | 2,541 | 601 | - | - | - | - | 83 | 28,162

122 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

as at 31 December 2024 |  |  |  |  |  |  |  |  |
| PLN | EUR | USD | CHF | other currencies | Total
converted to PLN | in currency | converted to PLN | in currency | converted to PLN | in currency | converted to PLN
Assets |
Cash and cash equivalents | 7,876 | 265 | 62 | 139 | 34 | 10 | 2 | 71 | 8,361
Loans and other receivables to other banks | 856 | 20,779 | 4,863 | - | - | - | - | - | 21,635
Financial assets measured at fair value through profit | 1,612 | 58 | 14 | 193 | 47 | - | - | 85 | 1,948
Derivative hedge instruments | 51 | 10 | 2 | - | - | - | - | - | 61
Investment securities | 50,934 | 8,058 | 1,886 | - | - | - | - | - | 58,992
Transferred assets | 179 | - | - | - | - | - | - | - | 179
Loans and other receivables to customers | 139,851 | 25,004 | 5,852 | 1,103 | 269 | 100 | 22 | 619 | 166,677
Investments in subsidiaries and associates measured | 185 | - | - | - | - | - | - | - | 185
Property, plant and equipment | 1,011 | - | - | - | - | - | - | - | 1,011
Intangible assets | 457 | - | - | - | - | - | - | - | 457
Current income tax assets | 14 | - | - | - | - | - | - | - | 14
Deferred tax assets | 690 | - | - | - | - | - | - | - | 690
Other assets | 142 | 5 | 1 | 2 | - | - | - | - | 149
Total assets | 203,859 | 54,179 | 12,680 | 1,437 | 350 | 110 | 24 | 775 | 260,359

Liabilities |
Liabilities to other banks | 1,173 | 14,292 | 3,345 | 2 | - | - | - | 1 | 15,468
Financial liabilities measured at fair value through profit or loss | 1,209 | 154 | 36 | 7 | 2 | - | - | 30 | 1,400
Derivative hedge instruments | 68 | 15 | 4 | - | - | - | - | - | 83
Liabilities to customers | 188,598 | 25,319 | 5,925 | 4,959 | 1,209 | 69 | 15 | 1,051 | 219,996
Liabilities from debt securities issued | 509 | - | - | - | - | - | - | - | 509
Subordinated liabilities | - | 1,499 | 351 | - | - | - | - | - | 1,499
Provisions | 615 | 20 | 5 | 1 | - | - | - | - | 636
Current income tax liabilities | 16 | - | - | - | - | - | - | - | 16
Deferred tax liability | 1 | - | - | - | - | - | - | - | 1
Other liabilities | 3,224 | 340 | 80 | 4 | 1 | 13 | 3 | - | 3,581
Total liabilities | 195,413 | 41,639 | 9,746 | 4,973 | 1,212 | 82 | 18 | 1,082 | 243,189
Equity |  |  |  |  |  |  |  |  |
Share capital | 130 | - | - | - | - | - | - | - | 130
Reserve capital - surplus from sale of shares above their nominal value | 956 | - | - | - | - | - | - | - | 956
Accumulated other comprehensive income | -4,640 | -59 | -14 | - | - | - | - | - | -4,699
Retained earnings | 20,783 | - | - | - | - | - | - | - | 20,783
Total equity | 17,229 | -59 | -14 | - | - | - | - | - | 17,170
Total equity and liabilities | 212,642 | 41,580 | 9,732 | 4,973 | 1,212 | 82 | 18 | 1,082 | 260,359
Contingent liabilities granted | 45,770 | 8,589 | 2,010 | 999 | 244 | 1 | - | 50 | 55,409
Contingent liabilities received | 25,329 | 814 | 190 | - | - | - | - | 81 | 26,224

123 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

3.7. Impact of the benchmark reform
Further work is currently underway to reform the WIBOR reference rate. The publication of the WIBOR rate and its
replacement by a new POLSTR benchmark is planned for 31 December 2027.
These changes have an impact on the Group, its customers and the financial sector as a whole, and expose the
Group to risks. These risks include legal, operational and financial risks. Legal risk is associated with all required
changes in documentation for new and existing transactions. Operational risk is related to required changes
in IT systems, reporting infrastructure and operational processes for new reference rates. Financial risk (largely
limited to interest rate risk), as a consequence of changes in the valuation of financial instruments referring
to these reference rates and decreasing market liquidity may have an impact on transactions directly or the ability
to hedge the risk resulting from these transactions. Changes in valuation, interest calculation methodology
or documentation may also result in customer complaints and litigation.
In order to mitigate these risks, the Group has established an implementation project, with an extensive structure
and the progress of work is monitored on an ongoing basis by the steering committee, operating in the Group's
parent entity. The project analyses and coordinates the necessary actions to introduce the required changes
to internal processes and systems, taking into account valuation, risk management, legal documentation and
impact on customers. The Group continues to monitor market developments and the results of the analysis
in terms of uncertainty resulting from the reform and regulatory standards related to the transformation, in order
to assess the impact on the project, customers and related risks.
WIBOR
In January 2025, the Steering Committee of the National Working Group (KS NGR) for benchmark reform in Poland
published the decision to select the name POLSTR (Polish Short Term Rate) for the new benchmark, which was
selected in the public consultation process conducted last year. In April 2025, KS NGR published an updated
roadmap of the WIBOR replacement process and in June announced the launch of POLSTR.
Later in the year, KS NGR adopted a number of product recommendations based on the POLSTR index. It was also
informed that on 1 September 2025, the first application of the new index took place on the domestic financial
market and thus POLSTR became a benchmark in accordance with the requirements of the BMR. Regulation.
On 30 September 2025, the administrator of GPW Benchmark S.A. benchmarks published a decision to discontinue
the provision of WIBOR reference rates for the following fixing dates:
• Overnight (O/N) – as of 1 October 2026,
• Tomorrow/Next (T/N) – as of 22 December 2025,
• 2 weeks (2W) - as of 22 December 2025,
• 1 year (1Y):
• as of 22 December 2025 calculated on the basis of the existing method, the,
• as of 22 December 2026 calculated after the change in the method of developing the indicator in this tenor.
Another important milestone of the process, which was implemented in 2025, was the first issue of Treasury bonds,
the interest rate of which refers to the new POLSTR benchmark.
In the last months of the year, the NGR SC also adopted recommendations on the conversion of interest rate
derivatives and financial instruments in the business client segment, which are crucial for the progress of work
on the reform.
Further work is planned in the coming years, including in particular building a market for financial products based
on a new benchmark and achieving regulatory and operational readiness of all market participants to offer and
operate these financial products.
The planned replacement of the WIBOR rate causes uncertainty as to the occurrence of cash flows resulting from
the WIBOR rate, which were designated to hedge as part of the hedging relationship of cash flows on the portfolio
basis (Macro Cash Flow Hedge). As a result, the Group applied the amendment to IAS 39 Phase 1 and thus adopted
the assumption that the reference rate on the basis of which the cash flows resulting from WIBOR are calculated
in terms of the hedging instrument and the hedged item remain unchanged as a result of the reform. The same
assumption is used to assess the probabilities of future transactions that are hedged against cash flows. As a result,
the Group continues its hedging relationships. Amendments to IAS 39 Stage 1 will cease to apply when the
uncertainty resulting from the change in the WIBOR rate ceases to exist in terms of the time and amounts resulting
from the reference rate of a given instrument. The following table presents the nominal values of hedging
instruments referencing WIBOR.

as at 31 December |
| net nominal value of the position on the hedging instrument
2025 | 2024
Assets | Liabilities | Assets | Liabilities
Cash flow hedging instruments | 107,776 | 8,824 | 100,348 | 1,377
Instruments hedging the fair value of securities | 19,112 | - | 15,012 | -

124 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Structure of financial assets and liabilities referring to WIBOR rate
As at 31 December 2025, the following financial instruments refer to the WIBOR reference rate, which is expected
to be discontinued after 31 December 2027 and is material for the Group. Non-derivative financial assets and
liabilities are presented at gross carrying amount, off-balance sheet items are presented at liability amount and
derivatives are presented at nominal value.
Financial instruments referencing WIBOR

as at 31 December |
| 2025 | 2024
with maturity date after 31 Dec 2025 | with maturity date after 31 Dec 2027 | with maturity date after 31 Dec 2024 | with maturity date after 31 Dec 2027
Non-derivative financial assets | 140,480 | 107,318 | 129,336 | 82,980
Non-derivative financial liabilities | 1,637 | 1,522 | 604 | 509
Derivatives | 1,406,780 | 583,421 | 1,307,090 | 362,190
Off-balance sheet items | 19,638 | 5,218 | 15,865 | 2,824

3.8. Hedge accounting
3.8.1. Fair Value Hedge accounting
In fair value hedge accounting, the risk is equivalent to change in the fair value of a financial asset as a result
of changes to interest rates. The hedge covers the fair value of debt instruments with a fixed interest rate that
is a position (a part of position) in a security that is classified to a portfolio of assets kept to collect contractual cash
flows or for sale (hereinafter: HTC&S) which at the time a hedge relationship is established holds a specific fair value
recognised in other comprehensive income.
For the needs of the strategy, the recognition of a part change to the fair value due to the hedged risk is made
on the basis of valuation models relying on assumptions that are similar to those applicable to valuation models
of interest rate derivative instruments. The valuation curves applied in the model are designed on the basis
of market rates corresponding to repricing tenors of variable interest rates of hedging instruments.
Interest Rate Swap, swapping fixed interest rate into variable interest rate is the hedging instrument. The above
shows that changes to the fair value of the hedging instrument manifest a trend that is opposite to changes of the
fair value of the hedged position. In this connection, as a result of the established hedge relationship, the profit and
loss account contains a compensating effect of changes to the fair value of the hedging instrument and the hedged
position due to the hedged risk. In order to confirm the effectiveness of the strategy, the Group carries out:
• prospective effectiveness test:
• qualitative based on the maturity of the hedged item and the hedging instrument, and
• quantitative based on the BPV (basis point value) ratio of the hedged item and a hedging instrument,
• retrospective effectiveness test as the quotient of changes in the hedging instrument measurement and changes
in the measurement of the hedged item due to the risk being hedged.
The sources of ineffectiveness of strategies that is manifested in the profit and loss account, may result from:
• differences in the repricing and realisation dates of cash flows of hedged items in relation to the repricing and
realisation dates of cash flows of derivative hedging instruments,
• mismatch resulting from the use of various valuation curves (that is: interest rate derivative instruments are
valued on the basis of valuation curves developed on the basis of daily hedges of valuation exposures – OIS
discounting),
• changes to credit risk constituting a valuation component to fair value of the hedged position from the HTC&S
portfolio,
• adjustments to valuation of hedging instruments due to pre-settlement credit risk (bilateral value adjustment);
however, those do not have material impact on the presented values due to the fact that only interbank market
transactions were designated as hedging instruments and that are additionally hedged with a deposit margin
placed or received respectively, depending on the exposure type, as well as transactions forwarded for
settlement on a daily basis via the Central Counterparty,
• component of the valuation of hedging instruments due to settlement of the price aligment amout resulting
from “settled to marked” approach to settlement via the Central Counterparty.
Since hedging covers only one type of risk (interest rate risk), changes to the fair value of the hedged position
classified as HTC&S resulting from other unhedged risks are recognised as other comprehensive income.
From the viewpoint of economic relationships, the Group’s existing hedging strategies contain two types of hedge
relationships:
• hedge of the fair value of securities in PLN with a fixed interest coupon classified as HTC&S with IRS transactions
“pay fixed, collect variable”, denominated in PLN,
• hedge of the fair value of securities in EUR with a fixed interest coupon classified as HTC&S with IRS transactions
“pay fixed, collect variable”, denominated in EUR.

125 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The table below presents the fair values and nominal values of hedging and hedged instruments in fair value hedge accounting.

2025 |  |  |  |  |  |  |  |  |
| item in the statement of of financial position - number of note | fair value | unrealised valuation result | cumulative valuation adjustment due to the hedged risk ka | cumulative part of valuation of unsecured risks recognised in other comprehensive income* | nominal value of instruments with remaining maturity
Assets | Liabilities | less than 1 year | over 1 year | Total
Instruments hedging fair value of securities, of which: | Derivative hedge instruments | - | 12 | -489 | - | - | 812 | 22,146 | 22,958
settled via CCP |  | - | 12 | -489 | - | - | 812 | 22,146 | 22,958
Interest rate swaps (IRS PLN) fixed - float |  | - | 12 | -468 | - | - | 812 | 18,300 | 19,112
Interest rate swaps (IRS EUR) fixed - float |  | - | - | -21 | - | - | - | 3,846 | 3,846
Hedged instruments, of which: |  | 23,824 | - | -164 | 503 | -667 | 812 | 22,146 | 22,958
Investment securities measured at fair value through other comprehensive income, including: | Investment securities | 23,824 | - | -164 | 503 | -667 | 812 | 22,146 | 22,958
State Treasury bonds in PLN | Note 19 | 19,188 | - | -156 | 492 | -648 | - | 18,300 | 18,300
European Investment Bank bonds in PLN | Note 19 | 813 | - | 8 | -6 | 14 | 812 | - | 812
European Investment Bank bonds in EUR | Note 19 | 1,876 | - | 18 | -16 | 34 | - | 1,944 | 1,944
European Union bonds in EUR | Note 19 | 1,947 | - | -34 | 33 | -67 | - | 1,902 | 1,902

*) presented in the comprehensive income statement in the position: debt securities measured at fair value via other comprehensive income – gains/losses on revaluation carried through equity
With respect to the IRS/FRA interest rate derivatives clearing approach, the Group applies the settled to market service, as specified in the regulations of Central Counterparties/CCP with which the Group cooperates. Detailed information
is provided in note 17. Valuation of derivatives.

2024 |  |  |  |  |  |  |  |  |
| item in the statement of of financial position - number of note | fair value | unrealised valuation result | cumulative valuation adjustment due to the hedged risk ka | cumulative part of valuation of unsecured risks recognised in other comprehensive income* | nominal value of instruments with remaining maturity
Assets | Liabilities | less than 1 year | over 1 year | Total
Instruments hedging fair value of securities, of which: | Derivative hedge instruments | - | 11 | -56 | - | - | 1,300 | 17,686 | 18,986
settled via CCP |  | - | 11 | -56 | - | - | 1,300 | 17,686 | 18,986
Interest rate swaps (IRS PLN) fixed - float |  | - | 9 | 9 | - | - | 1,300 | 13,712 | 15,012
Interest rate swaps (IRS EUR) fixed - float |  | - | 2 | -65 | - | - | - | 3,974 | 3,974
Hedged instruments, of which: |  | 19,006 | - | -85 | 42 | -127 | 1,300 | 17,686 | 18,986
Investment securities measured at fair value through other comprehensive income, including: | Investment securities | 19,006 | - | -85 | 42 | -127 | 1,300 | 17,686 | 18,986
State Treasury bonds in PLN | Note 19 | 14,273 | - | -77 | 12 | -89 | 1,300 | 12,900 | 14,200
European Investment Bank bonds in PLN | Note 19 | 782 | - | -38 | -34 | -4 | - | 812 | 812
European Investment Bank bonds in EUR | Note 19 | 1,887 | - | -12 | 6 | -18 | - | 1,966 | 1,966
European Union bonds in EUR | Note 19 | 2,064 | - | 42 | 58 | -16 | - | 2,008 | 2,008

126 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Time distribution profile of nominal amounts and the corresponding average interest rates of hedging instruments

2025 |  |  |
| nominal value of instruments with remaining maturity | weighted average fixed rate %
up to 1 year | over 1 year
Interest rate swaps (IRS PLN) fixed - float | 812 | 18,300 | 4.65%
Interest rate swaps (IRS EUR) fixed - float | - | 3,846 | 2.72%

2024 |  |  |
| nominal value of instruments with remaining maturity | weighted average fixed rate %
up to 1 year | over 1 year
Interest rate swaps (IRS PLN) fixed - float | 1,300 | 13,712 | 5.14%
Interest rate swaps (IRS EUR) fixed - float | - | 3,974 | 2.73%

Net interest on derivative hedging instruments is disclosed as interest on securities measured through other
comprehensive income which presents net interest of positions hedged within the described strategy.
Measurements of hedging instruments including component due to the settlement of the price alignment amount
and hedged transactions are presented in the Group’s consolidated income statement as Net (loss)/income
on hedge accounting and in note 6.
The split of the result of measurements of hedging and hedged transaction into individual hedging strategies
is presented in the table below.

Type of economic relation | 2025 | 2024
change in fair value used to test strategy effectiveness | ineffective part of the hedging relationship recognised in P&L | change in fair value used to test strategy effectiveness | ineffective part of the hedging relationship recognised in P&L
hedged position | hedging instrument | hedged position | hedging instrument
Hedging of debt securities in PLN | 528 | -481 | 47 | -245 | 256 | 11
Hedging of debt securities in EUR | -45 | 43 | -2 | 82 | -83 | -1
Total | 483 | -438 | 45 | -163 | 173 | 10

3.8.2. Cash flow hedge accounting
The Group applies hedge accounting principles for cash flows to a specified portfolio of assets / liabilities / highly
probable planned financial transactions of the Group (e.g. extrapolations of financial flows resulting from renewable
deposits / overdraft facilities). The applied hedging strategies are aimed at hedging the Group’s exposures against
the risk of changes to future cash flows resulting from interest rate risk.
The hedge applies to a specified portfolio of financial assets and/or liabilities or a portfolio of planned transactions
that cover variable interest rate financial instruments (financial products based on WIBOR/ EURIBOR) and thus that
are exposed to the risk of changes to future cash flows due to changes to market rates – WIBOR/EURIBOR.
For its strategy relating to calculations of changes to the fair value of future cash flows in the hedged portfolio, the
Group applies the method of a “hypothetical derivative” (being a method which provides for a possibility to reflect
the hedged position and nature of the hedged risk in the form of a derivative instrument). The valuation principles
are similar to the valuation principles of interest rate derivative instruments. Strategy effectiveness research also
includes:
• prospective high-probability test of future cash flows,
• retrospective high-probability test of future cash flows confirming, on the basis of actual values, that the adopted
model works correctly,
• retrospective test of homogeneity of the portfolio of the hedged item based on statistical analysis (regression
method).
The sources of ineffectiveness of strategies that is manifested in the profit and loss account, may result from:
• differences in the repricing and realisation dates of cash flows of hedged items in relation to the repricing and
realisation dates of cash flows of derivative hedging instruments,
• adjustments to valuation of hedging instruments due to pre-settlement credit risk (bilateral value adjustment);
however, those do not have material impact on the presented values due to the fact that only interbank market
transactions were designated as hedging instruments and that are additionally hedged with a deposit margin
placed or received respectively, depending on the exposure type.
From the viewpoint of economic relationships, the Group’s existing hedging strategies contain the following types
of hedge relationships:
• the hedging instrument for active positions in the interest rate risk hedging strategy is the position on the
Interest Rate Swap of the "pay floating, receive the fixed" type, while the

127 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• hedging instrument hedging the liability is the position on the Interest Rate Swap of the "pay fixed, receive
variable”.
Due to the fact that the hedged position covered with specific strategies keeps affecting the profit and loss account)
(by measurement at amortised cost), net interest of the derivative instruments hedging the portfolio:
• of financial assets is presented as interest on loans and other receivables granted to customers, measured
at amortised cost,
• of financial liabilities is presented as interest on liabilities to customers.
The tables below present the fair values and nominal values of hedged instruments in cash flow hedge accounting.
Notional amounts of the derivatives were presented in the amounts purchased.

2025 |  |  |  |  |
| fair value | nominal value of instruments with remaining maturity
Assets | Liabilities | up to 1 year | over 1 year | Total
Cash flow hedges, of which: | 73 | 65 | 123,882 | 321,500 | 445,382
settled via CCP | 73 | 65 | 123,882 | 321,500 | 445,382
Interest rate swaps (IRS EUR) fixed - float | 67 | 53 | 117,403 | 275,099 | 392,502
Interest rate swaps (IRS PLN) fixed - float | 6 | 12 | 6,479 | 46,401 | 52,880

2024 |  |  |  |  |
| fair value | nominal value of instruments with remaining maturity
Assets | Liabilities | up to 1 year | over 1 year | Total
Cash flow hedges, of which: | 61 | 72 | 137,551 | 329,657 | 467,208
settled via CCP | 61 | 62 | 136,772 | 329,658 | 466,430
Interest rate swaps (IRS EUR) fixed - float | 51 | 59 | 131,003 | 280,385 | 411,388
Interest rate swaps (IRS PLN) fixed - float | 10 | 13 | 6,548 | 49,272 | 55,820

As at 31 December 2025 , PLN -2,023 million (including tax) was recorded in other comprehensive income regarding
the effective part of the hedging relationship in cash flow hedge accounting (PLN -4,849 million as at 31 December
2024). The ineffective part of the hedging relationship resulting from the mismatch in offsetting changes in the fair
value of the hedging instrument and the hedged item recognised in profit or loss in 2025 amounted to PLN
-60 million compared to PLN 0 million in 2024.

128 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Impact of the application of cash flow hedge accounting on profit and loss account and other comprehensive income

2025 |  |  |  |  |  |  |
| fair value | changes to fair value of hedging instruments used to review the effectiveness of the strategy | amount reclassified from other comprehensive income
Assets | Liabilities | unrealised result on revaluation recognised in the period* | the effective part of the hedge recognised in other comprehensive income in the period** | ineffective part of hedging relationship recognised in profit or loss | resulting interest income from existing hedging relationships | amortization of the result of the completed strategy security
Cash flow hedges, of which: | 73 | 65 | 3,435 | -3,495 | -60 | -1,920 | 1
Interest rate swaps (IRS) hedging the portfolio of financial assets in PLN | 58 | 26 | 4,558 | -4,618 | -60 | -2,235 | -
Interest rate swaps (IRS) hedging the portfolio of financial assets in EUR | 5 | 11 | -36 | 36 | - | -35 | -
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in PLN | 9 | 27 | -1,086 | 1,086 | - | 336 | -
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in EUR | 1 | 1 | -1 | 1 | - | 14 | -
CIRS EUR/PLN resulting from decomposition of an actual transaction, hedging the portfolio of financial assets in EUR | - | - | - | - | - | - | 1

2024 |  |  |  |  |  |
| fair value | changes to fair value of hedging instruments used to review the effectiveness of the strategy | amount reclassified from other comprehensive income
Assets | Liabilities | unrealised result on revaluation recognised in the period* | the effective part of the hedge recognised in other comprehensive income in the period** | resulting interest income from existing hedging relationships | amortization of the result of the completed strategy security
Cash flow hedges, of which: | 61 | 72 | 395 | -395 | -2,182 | 1
Interest rate swaps (IRS) hedging the portfolio of financial assets in PLN | 43 | 34 | 252 | -252 | -3,022 | -
Interest rate swaps (IRS) hedging the portfolio of financial assets in EUR | 8 | 11 | 154 | -154 | -210 | -
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in PLN | 7 | 25 | -2 | 2 | 1,041 | -
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in EUR | 3 | 2 | -9 | 9 | 9 | -
CIRS EUR/PLN resulting from decomposition of an actual transaction, hedging the portfolio of financial assets in EUR | - | - | - | - | - | 1

*) disclosed in the statement of financial position as Derivative hedge instruments
**) disclosed in the statement of financial position as Accumulated other comprehensive income and in note 35.2. (the amount in the table does not include tax)
***) disclosed in the profit and loss account in the dedicated line item Net (loss)/income on hedge accounting and in note 6.

129 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Time distribution profile of nominal amounts and the corresponding average interest rates of hedging
instruments

2025 |  |  |
| notional value of the position on the hedging instrument with a remaining maturity | weighted average fixed rate%
up to 1 year | over 1 year
Interest rate swaps (IRS) hedging the portfolio of financial assets in PLN | 12,633 | 95,144 | -
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in PLN | -6,444 | 15,268 | 4.86%
Interest rate swaps (IRS) hedging the portfolio of financial assets in EUR | 1,500 | 11,531 | 1.60%
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in EUR | 42 | 152 | 1.08%

2024 |  |  |
| notional value of the position on the hedging instrument with a remaining maturity | weighted average fixed rate%
up to 1 year | over 1 year
Interest rate swaps (IRS) hedging the portfolio of financial assets in PLN | 4,273 | 96,075 | 4.11%
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in PLN | -19,530 | 20,906 | 4.91%
Interest rate swaps (IRS) hedging the portfolio of financial assets in EUR | -66 | 10,695 | 1.53%
Interest rate swaps (IRS) hedging the portfolio of financial liabilities in EUR | 64 | 452 | 0.98%

The periods in which the Group expects the hedged cash flows in cash flow hedge accounting and thus which will
affect the financial profit are presented below.

2025 |  |  |  |  |
| cash flows in PLN (PLN million) | cash flows in EUR (EUR million)
inflows (assets) | outflows (liabilities) | net cash flows | inflows (assets) | net cash flows
up to 1 year | 3,686 | -447 | 3,239 | 59 | 59
over 1 year | 10,622 | -2,017 | 8,605 | 183 | 183

2024 |  |  |  |  |  |
| cash flows in PLN (PLN million) | cash flows in EUR (EUR million)
inflows (assets) | outflows (liabilities) | net cash flows | inflows (assets) | outflows (liabilities) | net cash flows
up to 1 year | 5,279 | -931 | 4,348 | 59 | -3 | 56
over 1 year | 9,261 | -4,276 | 4,985 | 141 | -20 | 121

3.8.3. Impact of the reform of key interest rate benchmarks on the Group's hedging strategies
Group applies fair value and cash flow hedge accounting in accordance with IAS 39, and interest rate and foreign
currency risks are designated as hedged risks in various micro and macro models. The hedged exposures are
mainly loan portfolios, purchased debt securities and savings/deposits.
The Group applied the amendments to IAS 39 published in September 2019 to a hedging relationship based
on WIBOR due to the ongoing work on the reform of this rate, in accordance with the information disclosed in
chapter II.3.7. Impact of the benchmark rate reform.
3.9. The approach to risk management in subsidiaries
The policies of ING Bank Śląski S.A. with respect to market risk management in its subsidiary companies provides for
maintaining market risk at a low level. The core market risk categories that may occur in connection with the
business of the subsidiary companies include FX risk and interest rate risk. Ongoing control and monitoring of
market risk level is performed with periodic measurements of market risk categories related to the business of the
subsidiary companies.
The company operating on an autonomous basis is ING Bank Hipoteczny S.A. This unit operates within the risk
appetite accepted by ING Bank Śląski S.A. and managed at the level of ING Bank Hipoteczny S.A. The market risk
management process at ING Bank Hipoteczny S.A. was built based on the best practices of ING Bank Śląski SA. Some
of the technical activities are outsourced to ING Bank Śląski S.A., in accordance with the signed SLA between the
two banks. The ALCO ING Bank Śląski S.A. Committee performs a supervisory role in relation to the ALCO ING Bank
Hipoteczny S.A. Committee.
The Bank’s Management Board, ALCO, the Market Risk Management Department, the Centre of Expertise Finance
Support and Innovations and other competent units of the Bank are involved in market risk management.
Determination of limits mitigating market risk for each subsidiary company at a consolidated level is a major
elements of the market risk management process in the Group of ING Bank Śląski S.A. The measurement techniques
of market risk in the Group are the same as for the Bank. In accordance with the Bank’s policies, risk volumes and
compliance with the approved risk limits are monitored on a monthly basis.

130 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

4. Liquidity and funding risk

4.1. Introduction | 130
4.2. Liquidity and funding risk management objectives | 130
4.3. Liquidity and funding risk management policies | 130
4.4. Liquidity and funding risk management process | 130
4.5. Types of liquidity and funding risk | 131
4.6. Structure and organisation of the risk management process | 131
4.7. Risk management framework | 132
4.8. Centralisation of the risk management process | 135
4.9. Liquidity risk reporting and measurement systems | 135
4.10. Approach to risk management in subsidiaries | 135
4.11. Analysis of the maturity of financial assets and liabilities | 136

4.1. Introduction
Group recognises the process of stable management of liquidity and funding risk as a major process at the Group.
Liquidity and funding risk is understood by the Group as the risk of the lack of ability to perform financial liabilities
under on- and off-balance sheet items at reasonable prices. The Group maintains liquidity so that the Group's
financial liabilities can always be repaid with the available funds, inflows from maturing transactions, available
funding sources at market prices and/or liquidation of negotiable assets.
4.2. Liquidity and funding risk management objectives
The main objective of the liquidity and funding risk management process is to maintain an appropriate level
of liquidity in order to ensure safe and stable operation of the Group under normal market conditions and during
the crisis.
4.3. Liquidity and funding risk management policies
In order to optimise the process of liquidity and financing risk management, the Bank has created the Liquidity and
Funding Risk Management Policy at ING Bank Śląski S.A., which aims to describe the rules ensuring appropriate
sources of financing and minimising the risk and costs associated with funding. The Policy describes the general
approach to the process of liquidity risk management and funding in the Group. The Liquidity and Funding Risk
Management Policy at ING Bank Śląski S.A. is complemented by the Instruction Contingency Financing Plan
at ING Bank Śląski S.A., which defines the organisation and activities aimed at eliminating liquidity shortages
in stressed conditions.
The Policy results from the business risk management strategy approved by the Supervisory Board (including the
liquidity and funding risk management strategy). In particular, it reflects the risk appetite defined in the strategy
and approved by the Supervisory Board.
The permissible level of liquidity and funding risk is defined through a multi-element system. This approach
is consistent with the approach described in the Policy for determining and monitoring risk appetite in the area of
market risk and liquidity.
4.4. Liquidity and funding risk management process
The general approach to liquidity and funding risk management is composed of five recurring activities:
1. risk identification,
2. risk assessment,
3. risk control,
4. monitoring and
5. reporting.
Risk identification and assessment
Risk identification is performed annually or ad-hoc by organising workshops to identify the level of liquidity and
financing risk. Each identified risk is assessed in order to determine the significance of such risk for the Bank.
Risk identification is also carried out in the process of implementing new products. The valuation of risk and its
materiality is assessed on the basis of the probability with which this risk occurs and the magnitude of the financial
impact if this risk materialises.
Control
Risks are controlled through actions that reduce the probability of a risk materialising or actions that reduce the
impact if a risk materialises. One of the elements of risk control is the definition of an acceptable level of risk.
Monitoring and reporting
An important element of risk management is continuous checking whether the implemented risk control
is performed. Regular checks show that risk control measures are effective. An important element of the liquidity
and financing risk management process is appropriate reporting, which provides managers with information
necessary for risk management. The ability to show shareholders and partners that the Bank controls risk allows

131 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

them to gain their trust, one of the most important elements in banking. Well-organised and designed regular
inspections and monitoring are essential for good risk management.
In addition, the Bank prepares an ILAAP process report. It presents, in a comprehensive and consistent manner, key
indicators and figures on the Bank’s liquidity risk profile. It takes into account the Bank’s strategy, financing plan
and risk tolerance. The report results are approved by the Management Board, which informs the Supervisory Board
of the assessment results.
In accordance with Recommendation S, the Bank makes a detailed analysis of long-term liquidity with focus
on mortgage loans. The above liquidity analysis shows risk levels related to long-term funding of mortgage loans.
On the basis of the analysis, it was concluded that the currently implemented processes within the framework
of long-term liquidity supervision are correct. Therefore, it was recommended to maintain the current activities.
The Bank pursues an active policy of liquidity management with reference to core currencies. For those currencies,
liquidity risk measurement and limitation is made per currency and the management of operational liquidity is
performed separately for each currency and it is incorporated in the risk transfer system.
Intraday liquidity is actively managed by the Centre of Expertise Treasury. The process manages the position and
risk of short-term liquidity (one day and intraday). The objective is to comply with payment and settlement duties
in a timely manner in regular operations and in extraordinary/stress situations.
The Bank operates a risk transfer system within which market risks, including liquidity and financing risk, are
transferred to the Centre of Expertise Treasury. Applying adequate tools, it manages the risks in a centralised
manner within the limit system applied by the Bank.
The liquidity risk management procedures adopted at the Bank are presented annually to the relevant bank
employees involved in the bank's liquidity management process. Persons involved in the bank's liquidity
management process confirm that they have familiarized themselves with and understand the procedures used
and control the correctness of their implementation.
4.5. Types of liquidity and funding risk
The Bank splits liquidity and financing risk into two groups:
• liquidity risk resulting from external factors, and
• risk of internal factors relating to the specific bank.
The Bank's goal is a conservative approach to liquidity risk management that will allow safely survive events specific
for ING Bank Śląski S.A. and for the entire banking sector.
In terms of time horizon, the Bank splits liquidity risk into:
• operational – focused on current financing of the Bank’s position and management of nostro positions,
• strategic – focused on ensuring that the Bank's structural liquidity positions are at an acceptable level.
Considering the tenor and clients’ behaviour (the two aspects affecting the Bank’s liquidity), the Bank identifies
three types of liquidity and funding risk:
• structural – understood as a potentially adverse impact on the Bank's revenues due to a mismatch between the
anticipated maturities of the Bank's assets and liabilities as well as the risk of no re-financing possibilities in the
future,
• related to clients’ behaviour – understood as a potentially adverse impact on the Bank's revenues due to the
embedded liquidity options in the products offered by the Bank,
• related to stress – understood as a risk of lack of possibility by the Bank to comply with its financial obligations
when due to insufficient available funds or when the generation of such funds is impossible at any price which
results in immediate insolvency of the Bank.
4.6. Structure and organisation of the risk management process
The Bank's Management Board and the Asset and Liability Committee (ALCO) play a specific role in liquidity and
funding risk management.
The Supervisory Board is responsible for:
• approving the liquidity risk tolerance, the overall accepted level of liquidity and funding risk (in HL RAS) presented
to the Supervisory Board by the Management Board.
The Bank's Management Board is responsible for:
• designing a strategy related to liquidity and funding risk, the target liquidity position, the relevant funding
methods and liquidity risk profile,
• determination of the Bank’s current and future risk readiness,
• establishment of an acceptable level of risk (risk appetite), liquidity risk tolerance and presenting it to the Risk
Committee for the purpose of issuing recommendations and to the Supervisory Board for approval,
• acceptance of changes to the limits of liquidity and funding risk (in MB RAS),
• acceptance of the liquidity and financing risk management policy and significant changes in the policy, including
in particular strategic limits adjusted to the general level of acceptable risk approved by the Supervisory Board,
• ensuring the allocation of appropriate human resources and appropriate work tools (including IT solutions) within
the Bank to implement the policy,

132 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• introduction of a division of tasks, carried out at the Bank, ensuring independence of liquidity risk management
and financing at the first level (first line of defence), from risk management at the second level (second line
of defence),
• supervision of liquidity risk management and financing on the first and second level,
• approving the levels of liquidity bonuses based on the level advised by the Centre of Expertise Treasury resulting
from the liquidity premium review and / or adjusts it when deemed necessary due to strategic changes in the
balance sheet or other factors.
The Asset and Liability Committee (ALCO) is responsible for:
• implementation of the Bank's strategy with respect to liquidity and funding risk,
• management of a liquidity buffer within the relevant policies and limits approved by the Bank's Management
Board, the related operational actions are delegated to the Centre of Expertise Treasury,
• supervision and monitoring of liquidity risk levels as well as the funding structure in the Bank's balance sheet,
• management of structural liquidity position (in terms of the flow gap),
• analysis of all proposed modifications to the Liquidity and Financing Risk Management Policy at ING Bank Śląski
S.A. and submission of positively reviewed modifications to the Bank's Management Board,
• monthly analysis of the short-, medium- and long-term liquidity profile (strategic liquidity positions) presented
in reports defined by the regulator and internal reports, in the event of identified structural problems (e.g. the
need for very high refinancing in the future) ALCO is responsible for issuing instructions to the appropriate
business units in order to obtain an appropriate liquidity profile,
• acceptance of changes in liquidity and funding risk limits (in LCS and ALCO RAS,
• approval of proposals to change liquidity risk limits in the scope of MB RAS and HL RAS in order to present these
limits for approval by the Bank’s Management Board and Supervisory Board, respectively,
• implementation of limits within the adopted risk appetite (approved in accordance with the division
of responsibilities in determining the levels of limits defined in the Policy for determining and monitoring risk
appetite in the area of market risk and liquidity risk).
4.7. Risk management framework
The framework liquidity and funding risk management principles contain all material methods with respect
to intraday, shorty-term, medium-term and long-term liquidity and funding risk management. This is made
up of the following key elements:
• limit system and liquidity risk measurement,
• monitoring of funding sources and concentration risk,
• liquidity reserve management,
• management of intraday liquidity,
• management of hedging items,
• stress tests and contingency plans.
Limits system and liquidity risk measurement
Formal limits are set by the regulator of the banking sector and/or the Bank for various liquidity risk measures. The
acceptable level of funding and liquidity risk is defined by a several-element system: the general level of the Bank's
acceptable risk, which is approved by the Bank's Supervisory Board, and the system of limits, which is approved
in accordance with the division of responsibilities in determining the levels of limits defined in the Policy for
determining and monitoring risk appetite in the area of market risk and liquidity risk. The Supervisory Board
is provided with information on compliance with the measures, minimum on a quarterly basis.
The limit level is based on the Bank's strategic objectives, identified liquidity risks, results of stress tests and the
principles set forth by regulatory authorities. The limits are taken into account in the planning processes (i.e. the
implementation of the adopted plans must not lead to exceeding the limits). The respective levels of the monitoring
limits of the Contingency Financing Plan are related (correlated) to the ranges defined for initiating the respective
phases of the Contingency Financing Plan.The admissible liquidity risk level is determined and updated minimum
once a year.
The limit system is more detailed than the risk level approved by the Supervisory Board. An acceptable level of risk
is guaranteed by monitoring risk in various reports on liquidity and funding risk in the Bank’s normal/regular
operations and in emergency/stress situations. The Bank monitors, among others, the risk of concentration of
financing, internal liquidity security buffer and examines the stability of external funds.
On a weekly basis, the Bank’s Management Board receives a liquidity and financing risk report containing
information on key liquidity measures. On a monthly basis, the Bank’s Management Board and the ALCO
Committee receive comprehensive information on liquidity and financing risk.

133 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Liquidity coverage ratio (LCR) and net stable funding ratio (NSFR)
In accordance with the obligations and principles set out in Regulation (EU) No 575/2013 (CRR) of the European
Parliament and of the Council (CRR), as amended by Regulation (EU) No 2019/876 of the European Parliament and
of the Council and Commission Delegated Regulations (EU) 2015/61 and 2018/1620, Commission Implementing
Regulation (EU) 2022/1994 and Regulation (EU) 2024/1623 of the European Parliament and of the Council (CRR3),
the Bank calculates supervisory liquidity measures:
• short-term liquidity measures (LCR - Liquidity Covered Ratio) - it is to ensure that the Bank has an appropriate
level of high-quality liquid assets that will cover liquidity needs over a period of 30 calendar days in stressed
conditions. In 2025, a regulatory limit of 100% was in force,
• long-term liquidity measures (NSFR - Net Stable Funding Ratio) - it aims to ensure a minimum level of available
funding in the medium and long term. In 2025, a regulatory limit of 100% was in force.
The Group is obligated to report the liquidity measures to the regulator monthly and quarterly.
At the end of 2025 and 2024 the consolidated supervisory liquidity measures were:

Liquidity measures |  |  |
| Minimum value | 2025 | 2024
|  | transformed data*
LCR | Liquidity coverage ratio | 100% | 251% | 264%
NSFR | Net stable funding ratio | 100% | 161% | 178%

*) In 2025, based on an analysis of the EBA’s interpretation contained in questions and answers (Q&A_2024_720),
the Group introduced a change in the presentation of non-retail deposits in liquidity reporting. The LCR ratio
presented in the table above for 2024 has been modified and its level has changed compared to that presented in
the annual consolidated financial statements for the previous year.
The following table presents a breakdown of Level 1 liquid assets used by the Group in the calculation of the LCR
liquidity ratio (as defined in Commission Delegated Regulation (EU) 2015/61) as at the end of 2025 and 2024,
respectively. Level 1 liquid assets include assets with exceptionally high liquidity and credit quality.

Level 1 liquid assets |  |
| 2025 | 2024
Cash | 865 | 774
Cash in nostro accounts with the Central Bank net of the required reserve | 4 | 4
Other exposures to the Central Bank (O/N deposit, cash bills) | 100 | -
Unencumbered Treasury bonds | 49,797 | 43,163
Assets constituting exposures to public sector entities | 1,921 | 2,059
Unencumbered European Investment Bank bonds | 8,905 | 8,542
Unencumbered BGK bonds | 192 | 1,756
Total | 61,784 | 56,298

In Level 1 liquid assets, securities are presented at their market value. The liquidity position of the Group is reduced
by securities encumbered (underlying, locked) and increased by securities received as collateral in reverse-repo
or buy-sell-back transactions.
Long-Term Funding Ratio (WFD)
In accordance with the obligations and principles set out in the WFD Recommendation on the Long-Term Financing
Ratio - issued by Resolution No. 243/2024 of the Financial Supervision Authority on July 15, 2024, starting from 31
July 2024, the Bank calculates the supervisory liquidity measure WFD (Long-Term Financing Ratio) at the
consolidated level and reports to the PFSA monthly as of the last day of the month. According to section 3.1. WFD
Recommendation at the level of 40% is expected to come into force on 31 December 2026. On 21 November 2025,
the PFSA announced a draft amendment to the WFD Recommendation of the PFSA, whose proposal is to change
the methodology of calculating the ratio and its expected level to 20%. At the end of 2025 , the WFD ratio was
24.2% (compared to 29.6% at the end of 2024).
Additional liquidity monitoring measures (ALMM)
In compliance with the Commission Implementing Regulations (EU) 2022/1994, the Bank reports a set of additional
monitoring rations for liquidity reporting. The reports include:
• mismatch by maturity,
• financial concentration by counterparty,
• financial concentration by product type,
• prices for various financing periods,
• prolonged financing,
• concentration of ability to balance liquidity by issuer/counterparty.
Internal liquidity reports
Another major element in the Bank's liquidity management risk process covers internally defined reports
presenting detailed and varied approach by the Bank to measurement and management of the risk. The Bank
models liquidity characteristics, both of its assets and liabilities in order to provide for clients’ anticipated/actual
behaviour. Modelling is mixed. This means than an analysis of clients’ behaviour relies on historic data and expert
judgment.
A structural liquidity report is one of such internal liquidity reports. The report presents the gap between the Bank's
assets and liabilities in time buckets on correctly functioning markets. The report is used to monitor and manage
medium- and long-term liquidity positions. It serves as a support in the planning process of the balance sheet and
funding. It also indicates all major funding needs in the future.

134 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The report is a scenario for the current balance sheet in normal market conditions. It does not cover any additional
projections of balance sheet development. However, it provides for clients’ typical behaviour observed in previous
periods. For instance: cash flows under mortgage loans, cash loans, loans in the current account provide for
prepayments and cash flows for savings accounts and current accounts are allocated subject to characteristics
of liquidity.
Report of structural liquidity

| 1-6 months | 7-12 months | 1-5 years | 6-10 years | 11-15 years | over 15 years
2025 |  |  |  |  |  |
Liquidity gap | 68,930 | 11,877 | 26,047 | -18,644 | -77,097 | -11,112
Cumulative liquidity gap | 68,930 | 80,807 | 106,854 | 88,210 | 11,112 | -
2024 |  |  |  |  |  |
Liquidity gap | 48,796 | 11,404 | 11,644 | -18,202 | -46,164 | -7,478
Cumulative liquidity gap | 48,796 | 60,200 | 71,844 | 53,642 | 7,478 | -

In ING Bank Śląski S.A. Group, the Bank follows liquidity risk monitoring and limiting based on measurements of the
cumulative gap. In order to properly exercise supervision over liquidity risk in the Group entities, limits are set
separately for each company.
Monitoring of funding sources and concentration risk
The Group determines once a year the general business strategy of the Group and the resulting medium-term
financial plan together with the general risk strategy. An inherent element of the strategy is the financing plan,
which ensures effective diversification of sources and dates of financing.
The ALCO Committee actively manages the funding base. Additionally, it monitors funding sources in order to:
• verify compliance with the strategy and financial plan,
• identify potential risks related to funding.
Customers’ deposits (retail and corporate) are the core funding source for Group. The Group monitors the funding
structure and thus verifies concentration risk by analysing its deposit base split into:
• type of financing,
• client segment,
• product type,
• currencies,
• geographical region, and
• concentration of large deposits
Periodical analyses also monitor the risk generated by related clients (within capital groups).
The existing funding structure is well diversified. Below is the funding structure as at 31 December 2025 and
31 December 2024, split into direct and mutual funding. Direct funding covers products where transaction is "one-
sided": funds are taken and then repaid. Mutual funding covers products where funding is simultaneously given and
taken (in separate currencies or in separate products). Direct funding is provided mainly by retail and corporate
clients while mutual funding comprised primarily funds acquired from other banks. The visible y/y increase in direct
financing in the corporate customer area, while the decrease in the retail customer area, is the result of a change in
the customer segment classification implemented in 2025.
Direct funding:

Core client segments | 2025 | 2024
direct funding | share | direct funding | share
Retail clients | 135,054 | 49.9% | 141,045 | 55.9%
Corporate clients | 98,636 | 36.4% | 77,445 | 30.7%
Equity | 23,560 | 8.7% | 22,184 | 8.8%
Own issue / subordinated loan | 12,954 | 4.8% | 11,012 | 4.4%
Banks | 436 | 0.2% | 437 | 0.2%

Mutual funding:

Core client segments | 2025 | 2024
mutual funding | share | mutual funding | share
Banks | 27,114 | 85.0% | 27,641 | 92.6%
Corporate clients | 4,780 | 15.0% | 2,223 | 7.4%

Liquidity reserve management
Maintenance of an adequate liquidity buffer is a major element in managing the Group’s liquidity. The liquidity
buffer presents the available liquidity, required to cover the gap between cumulative outflows and inflows within
a relatively short time. It covers assets that are “unencumbered” and easily available to acquire liquidity.
Unencumbered assets are understood as assets that are free of any legal, regulatory, contractual restrictions
to have them disposed of by the Group. The liquidity buffer is crucial in the times of a crisis when the Bank has
to obtain liquidity in a short time when the standard funding sources are unavailable or insufficient.
The liquidity buffer is maintained as a safeguard against materialisation of various extraordinary scenarios,
providing for needs of additional liquidity which may arise at any time in extraordinary circumstances and
in normal conditions.

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Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

The table below presents the structure of the liquid asset buffer as at 31 December 2025 and 31 December 2024:

| 2025 | 2024
Structure of the liquidity buffer | share | share
Treasury bonds or bonds issued by the Polish government or central bank in PLN | 75.1% | 65.0%
BGK and PFR bonds in PLN | 3.1% | 9.6%
Bonds issued by foreign governments or banks in PLN | 11.0% | 11.7%
including EIB bonds | 11.0% | 11.7%
Treasury bonds or bonds issued by the Polish government or central bank in EUR | 3.0% | 4.8%
Bonds issued by foreign governments or banks in EUR | 7.8% | 8.9%
including EIB bonds | 4.2% | 4.7%

The Group provides for realistic reductions due to impairment of securities with the level thereof being regularly
reviewed and approved by ALCO. The reductions are assessed inter alia on the basis of market liquidity and depth,
volatility of market prices, requirements of the central bank.
The Group also observes asset concentrations ensuring their safe diversification in terms of issuer, maturity and
currency.
Management of intraday liquidity
The Bank actively manages positions and risks of short-term (one-day and intraday) liquidity in order to comply
with its payment and settlement obligations when due in normal market conditions and in extraordinary/stress
situations.
The intraday liquidity management process is critical for correct functioning of the Bank as a whole and applies
to normal market conditions and extraordinary (crisis) situations. It is a component of current operational liquidity
management. Managing its intraday liquidity, the Bank applies intraday ratios. Intraday liquidity ratios are
monitored on an ongoing basis and presented to the competent liquidity risk management units and to ALCO.
Intraday liquidity management includes the maintenance of readiness to comply with the Bank’s obligations also
in crisis circumstances. In this connection, it is necessary to maintain an adequate liquidity buffer on the basis
of information on the potential worsening of the Bank's access to intraday liquidity as a result of a market stress.
In order to maintain an adequate liquidity buffer, the Bank applies intraday stress tests in its stress test program.
Management of hedging items
The management of hedging items covers both positions under CSA and GIMRA contracts as well as positions
of liquid assets related to operations with the central bank. This is performed on the level corresponding to the
provided services, the Bank's portfolio, funding profile and liquidity requirements.
Most of the Bank's counterparties in derivative transactions have signed Credit Support Annexes (CSA) to ISDA
agreements. They regulate the issue of support to portfolios of derivative transactions. They provide for the right
to demand margin deposits by parties whose valuation of the portfolio is positive on a specific day (the party’s
portfolio is in-the-money) and the right to demand release of the margin when the valuation changes.
Within the strategy of setting margins for each counterparty to CSA, the transaction portfolio is measured daily for
margin requirements.
Derivative instruments such as FRA and IRS are settled via CCP (Central Clearing Party) clearing houses. This provides
for effective management of margin deposits and mitigates the counterparty settlement risk. ING Bank Śląski S.A.
has signed agreements with KDPW CCP and London Clearing House (LCH) and EUREX.
4.8. Centralisation of the risk management process
The process of liquidity and financing risk management is fully centralised in treasury and risk management
functions. Liquidity risk (along with the generated liquidity position) of each business line is transferred to the
Centre of Expertise Treasury for central management.
The Bank provides for costs and benefits of various types of liquidity risks in the system of internal transfer pricing,
in its measurement of profitability and the approval process of new products in all major business areas (both on-
and off-balance sheet). The Centre of Expertise Treasury manages the positions transferred to its books over the
risk transfer system, including the management of liquidity risk related to resetting the premium for liquidity.
In order to ensure correct, independent and centralised performance of the tasks in the liquidity risk management
process (including risk management and reporting as well as preparation, review and updates of documentation),
the Bank operates the Market Risk Management Department which reports to a Deputy President of the
Management Board.
4.9. Liquidity risk reporting and measurement systems
Reporting and measuring liquidity risk is an automated process. The Bank has tools to generate a set of liquidity
reports automatically on a daily or monthly basis. Information on risk measures allows for ongoing monitoring
of the liquidity profile and control of the underlying measures. Reports presenting liquidity and financing risk are
presented to entities involved in the process of managing this risk.
4.10. Approach to risk management in subsidiaries
ING Bank Hipoteczny S.A. performs an important role in managing the Group’s long-term liquidity. Its role is to raise
long-term liquidity so that the Group:
• improves funding stability,
• ensures diversified funding for the mortgage loan portfolio,
• is able to better manage any mismatch of its assets and liabilities.

136 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

ING Bank Hipoteczny S.A. is a company operating on an autonomous basis. This unit operates within the risk
appetite accepted by ING Bank Śląski S.A. and managed at the level of ING Bank Hipoteczny S.A.
Liquidity risk of the Bank’s other subsidiary companies is maintained at a minimum level with funding being
provided within the ING Group.
4.11. Analysis of the maturity of financial assets and liabilities
4.11.1. Breakdown of financial assets and liabilities by maturity
The tables below present the breakdown of financial assets and liabilities by maturity. Data are presented
at carrying amount. Financial assets payable on demand and for which the maturity date has expired are
presented in the range "up to 1 month". The column ‘unspecified’ includes the value of equity instruments.
The column "Reconciliation to the net balance sheet value" presents the value of the allowance for expected credit
losses for loans and other receivables measured at amortised cost.
Financial assets by maturity

as at 31 December 2025
| up to 1 month | over 1 to 3 months | over 3 to 12 months | over 1 to 5 years | over 5 years | no deadline specified | reconciliation to the net carrying amount | Total
Cash and cash equivalents | 7,310 | - | - | - | - | - | - | 7,310
Loans and other receivables to other banks | 14,645 | - | 32 | 9,277 | - | - | - | 23,954
Financial assets measured at fair value through profit or loss | 474 | 32 | 282 | 1,258 | 293 | 1 | - | 2,340
Derivative hedge instruments | - | - | 5 | 43 | 25 | - | - | 73
Investment securities | 799 | 135 | 4,562 | 53,148 | 6,613 | 299 | - | 65,556
Loans and other receivables to customers measured at amortised cost | 15,946 | 10,748 | 27,900 | 59,835 | 70,034 | - | -4,154 | 180,309
Investments in associates accounted for using the equity method | - | - | - | - | - | 204 | - | 204
Other assets | - | 3 | 29 | - | - | - | - | 32
Total assets | 39,174 | 10,918 | 32,810 | 123,561 | 76,965 | 504 | -4,154 | 279,778

Financial liabilities by maturity

as at 31 December 2025
| current and saving deposits | up to 1 month | over 1 to 3 months | over 3 to 12 months | over 1 to 5 years | over 5 years | Total
Liabilities to other banks | 733 | 1,049 | 238 | 1,177 | 11,624 | 221 | 15,042
Financial liabilities measured at fair value through profit or loss (excluding the valuation of derivatives) | - | 56 | 44 | 57 | 481 | 278 | 916
Derivative hedge instruments | - | 12 | - | 5 | 44 | 16 | 77
Liabilities to customers | 199,146 | 19,087 | 6,256 | 9,647 | 54 | 1,138 | 235,328
Liabilities from debt securities issued | - | - | 21 | - | 1,500 | - | 1,521
Subordinated liabilities | - | 12 | - | - | 1,479 | 1,057 | 2,548
Other financial liabilities | - | 1,917 | 166 | 39 | 94 | 489 | 2,705
Total financial liabilities | 199,879 | 22,133 | 6,725 | 10,925 | 15,276 | 3,199 | 258,137

Financial assets by maturity

as at 31 December 2024
| up to 1 month | over 1 to 3 months | over 3 to 12 months | over 1 to 5 years | over 5 years | no deadline specified | reconciliation to the net carrying amount | Total
Cash and cash equivalents | 8,361 | - | - | - | - | - | - | 8,361
Loans and other receivables to other banks | 14,353 | 6,432 | 350 | 500 | - | - | - | 21,635
Financial assets measured at fair value through profit or loss | 781 | 126 | 298 | 459 | 283 | 1 | - | 1,948
Derivative hedge instruments | 1 | - | 2 | 40 | 18 | - | - | 61
Investment securities | 197 | 2,432 | 9,299 | 42,893 | 3,917 | 254 | - | 58,992
Transferred assets | - | - | 44 | - | 135 | - | - | 179
Loans and other receivables to customers measured at amortised cost | 13,321 | 11,086 | 28,240 | 55,434 | 62,551 | - | -3,955 | 166,677
Investments in associates accounted for using the equity method | - | - | - | - | - | 185 | - | 185
Other assets | 6 | 7 | 26 | 1 | - | - | - | 40
Total assets | 37,020 | 20,083 | 38,259 | 99,327 | 66,904 | 440 | -3,955 | 258,078

137 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Financial liabilities by maturity

as at 31 December 2024
| current and saving deposits | up to 1 month | over 1 to 3 months | over 3 to 12 months | over 1 to 5 years | over 5 years | Total
Liabilities to other banks | 826 | 1,320 | 257 | 1,041 | 11,834 | 190 | 15,468
Financial liabilities measured at fair value through profit or loss (excluding the valuation of derivatives) | - | 249 | 52 | 136 | 522 | 441 | 1,400
Derivative hedge instruments | - | 13 | - | 7 | 37 | 26 | 83
Liabilities to customers | 184,717 | 18,059 | 6,617 | 9,529 | 46 | 1,028 | 219,996
Liabilities from debt securities issued | - | - | 9 | - | 500 | - | 509
Subordinated liabilities | - | 3 | - | - | 1,496 | - | 1,499
Other financial liabilities | - | 1,684 | 171 | 33 | 116 | 524 | 2,528
Total financial liabilities | 185,543 | 21,328 | 7,106 | 10,746 | 14,551 | 2,209 | 241,483

4.11.2. Analysis of the maturity of financial assets and liabilities according to contractual payment terms
The tables below present financial assets and liabilities (excluding valuation of derivatives) split by remaining (from
the reporting date) contractual maturities. The presented values provide for future interest payments. With respect
to contingent liabilities granted, the maturity analysis covers the closest possible performance of the liabilities
by the Group.
Financial assets payable on demand, financial assets for which the maturity date has expired and liabilities
on account of current and saving deposits are recognised within 1 month.

2025 |  |  |  |  |
| without a specific date | up to 1 month | 1- 12 months | 1-5 years | over 5 years
Financial assets, including: | 504 | 38,985 | 52,841 | 161,345 | 115,284
Cash and cash equivalents | - | 7,310 | - | - | -
Loans and other receivables to other banks | - | 14,642 | 66 | 9,290 | -
Financial assets measured at fair value through profit or loss (excluding the valuation of derivatives) | 1 | 426 | 60 | 1,079 | 177
Investment securities | 299 | 829 | 6,117 | 65,507 | 1,871
Loans and other receivables to customers measured at amortised cost | - | 15,778 | 46,566 | 85,469 | 113,236
Investments in associates accounted for using the equity method | 204 | - | - | - | -
Other financial assets | - | - | 32 | - | -
Financial Liabilities, including: | - | 221,591 | 16,688 | 13,543 | 3,000
Liabilities to other banks | - | 1,412 | 414 | 9,493 | 9
Financial liabilities measured at fair value through profit or loss (excluding the valuation of derivatives) | - | 15 | 4 | 405 | 97
Liabilities to customers | - | 218,233 | 15,903 | 54 | 1,138
Liabilities from debt securities issued | - | - | 80 | 1,713 | -
Subordinated liabilities | - | 14 | 82 | 1,784 | 1,267
Other financial liabilities | - | 1,917 | 205 | 94 | 489
Contingent liabilities granted | - | 3,463 | 24,802 | 18,442 | 16,272

2024 |  |  |  |  |
| without a specific date | up to 1 month | 1- 12 months | 1-5 years | over 5 years
Financial assets, including: | 440 | 49,848 | 55,381 | 126,290 | 105,518
Cash and cash equivalents | - | 8,361 | - | - | -
Loans and other receivables to other banks | - | 14,551 | 6,481 | 667 | -
Financial assets measured at fair value through profit or loss (excluding the valuation of derivatives) | 1 | 518 | 174 | 466 | 281
Investment securities | 254 | 225 | 13,140 | 49,650 | 2,607
Loans and other receivables to customers measured at amortised cost | - | 26,187 | 35,553 | 75,506 | 102,630
Investments in associates accounted for using the equity method | 185 | - | - | - | -
Other financial assets | - | 6 | 33 | 1 | -
Financial Liabilities, including: | - | 203,012 | 22,507 | 15,814 | 1,667
Liabilities to other banks | - | 2,149 | 1,706 | 12,886 | 190
Financial liabilities measured at fair value through profit or loss (excluding the valuation of derivatives) | - | 184 | 20 | 427 | 217
Liabilities to customers | - | 198,974 | 20,500 | 60 | 736
Liabilities from debt securities issued | - | 16 | 16 | 596 | -
Subordinated liabilities | - | 5 | 61 | 1,729 | -
Other financial liabilities | - | 1,684 | 204 | 116 | 524
Contingent liabilities granted | - | 5,575 | 21,990 | 15,638 | 12,207

The tables below present a maturity analysis of derivative financial instruments with a negative valuation as at the
reporting date. The analysis is based on remaining contractual maturities.
Derivative financial instruments settled in net amounts
Derivative financial instruments settled by the Group on a net basis cover IRS, FRA, options and FX Forward NDF
transactions. The data in tables reflect – in case of IRS transactions – non-discounted future interest cash flows;
in case of other transactions, the cash flows equivalent to the valuation as at 31 December 2025 and 31 December
2024 respectively.

2025 |  |  |  |
| up to 1 month | 1- 12 months | 1-5 years | over 5 years
IRS transactions, of which: | -232 | -166 | -6,844 | -523
hedging transactions in hedge accounting | -17 | -9 | -2,499 | -252
other derivatives | -5 | -21 | -9 | -

2024 |  |  |  |
| up to 1 month | 1- 12 months | 1-5 years | over 5 years
IRS transactions, of which: | 698 | -572 | -5,703 | -783
hedging transactions in hedge accounting | 381 | -485 | -2,106 | -562
other derivatives | -10 | -43 | -10 | -

138 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

Derivative financial instruments settled in gross amounts
Derivative financial instruments settled by the Group on a gross basis cover FX Swap, FX Forward and CIRS
transactions. The data in tables reflect non-discounted contractual cash outflows and inflows of nominal and –
in case of CIRS transactions – as interest, as at 31 December 2025 and 31 December 2024 respectively.

2025 |  |  |  |
| up to 1 month | 1- 12 months | 1-5 years | over 5 years
outflows | -1,936 | -2,637 | -2,925 | -205
inflows | 1,896 | 2,566 | 2,799 | 201

2024 |  |  |
| up to 1 month | 1- 12 months | 1-5 years
outflows | -4,847 | -5,846 | -2,180
inflows | 4,781 | 5,700 | 2,000

5. Non-financial risk
Non-financial risk encompasses operational risk and compliance (compliance) risk management functions and
is based on a common framework defining clear rules and standards for identifying, assessing, monitoring,
mitigating and reporting risk.
The Bank manages non-financial risk in accordance with its Management Board Strategy and Non-Financial Risk
Appetite Declaration, which set out the limits and risk tolerance. Compliance with the declared risk appetite
is monitored using the periodic non-financial risk report. In addition, the Bank has a Non-Financial Risk Committee
appointed by the Bank’s Management Board, which oversees non-financial risk management (identification,
measurement, mitigation and monitoring of risk) and ensures that appropriate actions are taken to mitigate non-
financial risk. In addition, the Supervisory Board, with the support of the Risk Committee, also supervises operational
risk management and assesses the effectiveness of activities in this area at least once a year.
The existing non-financial risk management framework allows for active identification of the main risks and gaps
and related risks that may cause adverse events. They are supported by such processes as: risk and control self-
assessment, monitoring of key risk indicators or testing key controls. The results of analyses of internal and external
events constantly improve the adequacy and effectiveness of the internal control system operating in the bank.
An effective control environment is essential to build and maintain a sustainable business, and also preserves and
increases the trust of customers, employees and shareholders.
5.1. Operational risk
Introduction
Operational risk is defined in the Bank as the possibility of direct or indirect loss resulting from maladjustment
or failure of internal processes, people and systems or from external events. Operational risk also includes model
risk (described in point 5.1.1.) and legal risk (described in point 5.1.2.).
Operational risk management is an integral part of the Group’s management process. The operational risk
management process and business processes show mutual dependence, which means that information obtained
in the operational risk management process is taken into account when making decisions concerning business
activities, and the operational risk management process takes into account business decisions.
Operational risk management objectives
The operational risk management objectives, which are part of the Bank’s overall risk management strategy, are
defined on the basis of:
• regulatory requirements,
• recommendations of the Bank’s Management Board and Supervisory Board,
• plans and good practices of the ING Group,
• the need to implement the risk mitigation measures identified in the course of external and internal evaluations
and audits,
• improvement plans in the area of risk management.
In addition, in consultation with the Supervisory Board, in the risk appetite declaration the Management Board has
specified the maximum permissible loss limits, capital limits and the scope of risk that it is willing to take in order
to achieve the planned business objectives - in full compliance with the law and regulations. The level of utilisation
of limits is monitored and periodically presented to the Non-Financial Risk Committee, the Risk Committee and and
Supervisory Board.
Continuous improvement of the security of the Bank and its customers and improvement of the effectiveness of the
risk function remain the main objective of operational risk management. These activities focus on comprehensive
strengthening of non-financial risk management by optimising structures and processes, as well as increasing
automation and integration of the tools used.
In addition to the implementation of basic processes in the area of operational risk, in 2025 the Bank focused its
activities on:
• optimisation of the operational risk management structure and the rules of operation of the Non-Financial Risk
Committee,
• developing a single control framework for subsidiaries,
• commencement of work on the integration of local and group tools in the area of non-financial risk,
• transferring selected activities to the first line of defence (registration and monitoring of recommendations and
deviations),

139 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

• implementation of a new approach to the control function matrix (automation),
• optimisation of data metrics and the risk monitoring and reporting process, as well as the list of significant
processes,
• clarification of the definition of events at the interface of operational and credit risk,
• updating regulations and methodologies, including those related to DORA, AI Act, CRR 3, ESG, rules for the
management of third and intra-group entities, as well as policies and standards for IT risk (including digital
resilience), business continuity and security of people and resources,
• increasing the granularity of risk appetite limits by creating additional KRIs,
• improving the risk culture among employees through training and webinars, with particular emphasis
on proactive risk identification in the first line of defence.
Operational risk management policies
With regard to operational risk management, the Bank has a consistent and continuously updated package
of internal normative documents.
The principles and guidelines contained in the regulations are aimed at limiting the effects and probability
of financial losses and reputational damage.
The Bank’s operational risk management system is based on:
• legal norms,
• regulatory requirements,
• Operational risk management policy and detailed regulations, instructions and procedures relating to individual
sub-processes related to operational risk management.
Operational risk management process
The Bank has a permanent Non-Financial Risk Committee whose main task is to supervise non-financial risk
management. In mid-2025, the Bank increased the frequency of the Committee’s work from quarterly to monthly.
The Bank has effective and consistent processes for identifying, monitoring and controlling non-financial risk in all
of the Bank’s products, activities, processes and systems.
The operational risk management system applies to all areas of the Bank’s operations and the Group’s, as well
as cooperation with clients, suppliers and partners, that has been developed in accordance with the principle
of proportionality, i.e. taking into account the nature, scale and complexity of the business, as well as the
materiality of the processes and the operational risk profile of the Bank. It constitutes a coherent, continuing
practice that includes the following elements:
• risk identification and assessment, including, among others, risk assessments, analysis of internal and external
events or scenario analyses and stress tests,
• risk mitigation and monitoring of mitigation actions,
• carrying out inspections,
• monitoring and quality assurance.
5.1.1. Model risk
Model risk management is carried out in accordance with the Model Risk Management Policy at ING Bank Śląski.
The Policy defines the key obligations with respect to risk management of models that must be observed for each
type of model. These responsibilities are defined in relation to the general principles of model risk management as
well as in relation to the various stages of the model life cycle.
The Model Risk Management Department provides a register of models (iModel), which is a repository of information
on models operating in the Group, and which is updated by participants in the model risk management process,
including model owners, validators and modellers. The model register shall contain, inter alia, information on the
relevance of the models, the results of monitoring their performance and the results of model validation (model
light together with the validation findings).
The Group regularly assesses the risks of individual models and, if required, allocates capital charges for models
in accordance with the principles adopted in internal regulations.
The performance of models is verified as part of the monitoring of model performance and model validation. Model
validation is performed in accordance with the Model Validation Policy at ING Bank Śląski and validation instructions.
Management reporting to the Model Risk and AI Risk Management Committee, the Bank’s Management Board and
the Supervisory Board on the status of model management and validation activities includes, among others,
assessment of the aggregated level of model risk in the context of the adopted level of model risk tolerance and the
status of the validation plan.
The Bank has a Model Risk and AI Risk Management Committee, whose aim is to supervise all areas of model risk,
including controlling the level of model risk and supervising the risk of GenAI (Generative AI) models and solutions.

140 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

5.1.2. Legal risk
Legal risk is the risk related to:
• inability (or alleged inability) to comply with relevant laws, regulations and standards,
• contractual obligations which have been breached or which cannot be enforced intentionally or have been
unexpectedly or undesirably enforced, and
• liability (tort liability) towards third parties in connection with an act or omission for which the Bank is responsible,
(potentially) resulting in a breach of the Bank’s integrity, leading to a breach of its reputation, the imposition of legal
or supervisory sanctions and financial losses.
The places of legal risk are:
• changes in the legal environment affecting the Bank’s operations and the conduct of business,
• differences in interpretation of the law and uneven jurisprudence,
• shaping and enforcing contractual relations with the Bank’s clients and business partners and the Bank’s impact
on third parties.
Mitigation measures include, but are not limited to:
• active monitoring of changes in the legal and supervisory environment and preparation of Legal Information
to ensure compliance of internal regulations with common law,
• agreeing positions (interpretation of legal regulations) with market regulators and state authorities on legal
issues relevant to the Bank,
• issuing opinions on the Bank’s internal legal documentation and agreements concluded by the Bank with clients/
counterparties,
• ongoing legal advice for the Bank’s units,
• managing legal claims and lawsuits, including initiating/coordinating appropriate legal actions,
• module of legal claims in the Risk Navigator application, used to manage claims,
• training for management and employees on legal and supervisory issues.
5.2. Compliance risk
The Bank’s mission in terms of compliance is to build an organisational culture based on knowledge of and
compliance with legal regulations, internal regulations, market standards as well as ING’s Values and Behaviours,
specified in the so-called Orange Code.
Compliance risk is understood as the risk of the consequences of non-compliance with the Bank’s processes with
the laws, internal regulations and market standards.
The Bank’s Supervisory Board supervises the compliance risk management, and the Bank’s Management Board
is responsible for the effective compliance risk management, including:
• implementation of organisational solutions, regulations and procedures enabling effective compliance risk
management, and
• ensuring adequate resources and resources required for the performance of tasks.
Centre of Expertise - Compliance is an organisationally separate, independent unit responsible for the organisation
and functioning of the compliance risk management process. The aim of the Centre of Expertise - Compliance
is to shape solutions for identifying, assessing, controlling and monitoring the risk of non-compliance of the Bank’s
operations with laws, internal regulations and market standards, and to present reports in this respect. Compliance
activities are aimed at the active participation of the Bank’s employees in compliance risk management by shaping
a risk culture based on knowledge of and compliance with laws, internal regulations and market standards.
6. ESG risk
Introduction
In accordance with the ECB Guide on climate-related and environmental risks - supervisory expectations relating
to risk management and disclosure of November 2020, the Bank considers ESG risk as a set of factors potentially
strengthening the probability and severity of traditional risk categories, such as: credit risk (including concentration
risk), market risk, liquidity and financing risk, operational risk, compliance risk and business and reputation risk.
ESG risk management consists in integrating the mechanisms for its identification, measurement, assessment,
mitigation, monitoring and reporting into standard processes as part of managing the previously listed risk
categories.
Definitions and methodology
When establishing the principles and framework for ESG risk management, the Bank follows EBA (European Banking
Authority) guidelines EBA/GL/2020/06 of May 2020 on lending and monitoring (Loan origination and monitoring).
Since 30 June 2021, the Bank has been obliged, among others, to take into account in the credit process
an assessment of the ESG exposure of its clients’ business. Following these guidelines, the Bank has taken into
account environmental, social and management factors in its credit risk appetite and has taken them into account

141 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

in the credit assessment processes of corporate clients. A sector assessment of climate and environmental risks
referring to the DMA (Double Materiality Assessment) methodology is currently determined for these portfolios and
those ESRS (sustainability issues) sub-topics for which risk materiality has been identified in the DMA process and
is a reference point for the assessment of an individual corporate client in manual paths.
In the ESG risk management standards, the Bank also took into account the provisions of the ECB Guide on climate-
related and environmental risks - Supervisory expectations relating to risk management and disclosure, of November
2020, and the EBA Report on management and supervision on ESG risk for credit institutions and investment firms,
EBA/REP 2021/18, of July 2021.
The Bank has indicated the methods, definitions and international standards used in its ESG risk management
policy. Among others, this document defines environmental, social and corporate governance risks, using the
provisions of the EBA Report on management and supervision on ESG risk for credit institutions and investment firms,
EBA/REP 2021/18, of July 2021. In the List of Inflows, Risks and Opportunities in the ESG area, the Bank indicated the
basic ESG risk factors and channels of their transmission to traditional risk types.
In 2025, the Bank worked intensively on the implementation of the EBA/GL/2025/01 Guidelines on ESG risk
management, including requirements for the identification, measurement and monitoring of these risks. In parallel,
the Bank developed the Prudential Transformation Plan, defining objectives and activities to respond
to transformation and physical risk. The Bank also implemented an ESG risk monitoring system based on required
indicators and metrics and developed processes to obtain ESG data from large corporate clients.
The Bank monitors on an ongoing basis the regulatory risk resulting from changes in the legal environment
in relation to the financial sector - following the work of supervisory authorities and legislative proposals. The Bank
participates in the work of the Polish Bank Association in the interpretation of ESG regulations.
Key ESG risks
The risks in the ESG area, which according to the Bank will have the greatest impact on its operations, are indicated
below. They were presented in order of the most significant expected impact and grouped according to traditional
risk categories.
ESG risk in credit risk
As part of the transformation risk, the Bank identifies:
• risk of deterioration in the quality of receivables from companies from high-emission industries due to a decrease
in their revenues / an increase in costs / an increase in debt,
• risk of a decrease in the value of properties with low energy efficiency accepted to secure them,
• risk of deterioration of the quality of mortgage loans granted to individual customers using real estate with low
energy efficiency,
• risk of deterioration in the quality of receivables from loans financing commercial properties with low energy
efficiency.
As part of the physical climate risk, the Bank identifies:
• risk of a decrease in the value of property accepted as collateral, exposed to sudden or long-term physical
threats,
• risk of deterioration in the quality of corporate receivables due to a decrease in their income / increase in costs /
increase in debt due to their operations in a place exposed to sudden or long-term physical threats,
Within environmental and social risks, the Bank identifies the risk of deterioration of the quality of corporate
receivables due to a decrease in their income / increase in costs / increase in debt due to their activities having
a negative impact on the environment or a negative impact on employees / communities.
ESG risk in compliance risk
As part of the compliance risk, the Bank identifies the risk of non-compliance in the processes operating in the Bank
with the law, internal regulations and market standards.
ESG risk in liquidity risk
As part of the transformation risk and physical climate risk, the Bank identifies the risk of liquidity disruption to the
Bank as a result of increased outflow of deposits from the Bank or increased credit needs of customers in
connection with the need to cover additional expenses resulting from the materialisation of transformation risk
or physical risk.
The Bank also manages the remaining ESG risks, although not all of them have been described due to, among
others:
• the estimated low impact of these risks (e.g. operational risk of disrupting the continuity of operations and the
security of persons and resources due to physical climate risk),
• historically well-established and effective system of managing these risks in the Bank (e.g. social risk resulting
from improper HR practices, social and environmental risk related to cooperation with suppliers).
Supervision of ESG risk management
The organisational structure of risk management, including the role of the Supervisory Board, the Bank’s
Management Board and the Division supervised by the CRO (Chief Risk Officer), is set out in the Policy - General
Principles of Risk Management at ING Bank Śląski S.A. The Supervisory Board monitors and supervises the risk
management process, including credit, market, liquidity and financing and non-financial risks. In the performance
of this task, it is supported by the Risk Committee, which includes at least three members of the Supervisory Board.

142 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

At the beginning of 2025, the Supervisory Board approved the Risk Management Strategy, in which the key
objectives for 2025-2027 include the continuation of activities to better identify, measure and assess ESG risk,
as well as activities to ensure compliance of the Bank’s policies, procedures and processes with the requirements
resulting from external regulations.
The Bank’s Management Board is involved in monitoring and supervising the risk management process, including
credit, market, liquidity and financing risks and non-financial risks. The Bank’s Management Board approves the
business strategy and the risk management strategy, the elements of which are ESG risk strategies. The approved
strategy is a response to the assessment of the expected effects of ESG risk in the short, medium and long term.
In addition, the Bank’s Management Board established a permanent ESG Risk Committee, which was entrusted with
tasks related to the creation of the structure, policy, methods and tools of ESG risk management and appointed
members of this Committee.
The Management Board appointed a CRO as a member of the Management Board responsible for the
implementation of key tasks as part of the implementation of ESG risk management into the risk management
system.
The Sustainability Panel, established in 2024, operates at the Supervisory Board of ING Bank Śląski S.A. as a
consultative and advisory body for the Council when it comes to the work of the Council conducted in the area of
ESG and Sustainability. Its purpose is to regularly inform, inspire and initiate discussions in this field at Council level.
ESG Risk Committee
The ESG Risk Committee is a standing committee of ING Bank Śląski dealing with matters related to ESG risk. As part
of his activities, he performs decision-making functions for all the bank’s organisational units and advisory functions
to the Bank’s Management Board. The Chairman of the ESG Risk Committee is CRO.
The tasks of the Committee include:
• setting and changing the level of ESG risk appetite limits,
• creating an ESG risk management policy,
• defining the process of comprehensive ESG risk management, including defining IT systems supporting the
process of ESG risk management,
• monitoring and assessment of the level of ESG risk at the standalone and consolidated levels,
• ensuring compliance with laws, supervisory regulations, making decisions regarding the implementation of the
ING N.V. Group’s guidelines and recommendations on ESG risk and approving all other issues related to ESG risk.
7. Other risks
7.1. Security of personal data
The Bank strives to ensure that the rights to privacy and personal data protection, as set out in the Charter
of Fundamental Rights of the European Union, the European Convention on Human Rights, the General Data
Protection Regulation (GDPR) and the case law of the European Court of Justice, are taken into account when
processing personal data. The Bank has regulated this area in the Personal Data Protection Policy, which reflects the
requirements resulting from legal regulations and defines the Bank’s obligations in this respect. The following are
responsible for ensuring compliance and implementation of the policy provisions: at the level of a Member of the
Management Board of the Bank Data Protection Executive and Protection Of Personal Data.
The principles related to the processing of personal data included in the policy include:
• their confidentiality, data minimisation and processing for a specific purpose,
• transparency and information requirements for individuals with regard to processing and their rights,
• ensure that the storage of personal data is limited,
• conducting a data protection impact assessment, in terms of the impact of data processing on the rights and
freedoms of natural persons,
• assessing the impact of data transfers outside the European Economic Area to countries not providing adequate
protection.
The policy requirements set personal data protection standards, which are followed by the Bank’s employees
to ensure compliance with legal regulations and to meet the expectations of customers, suppliers, business
partners and employees.
The Bank is constantly working on solutions that will protect clients and their finances from actions that violate
security. The Bank secures the IT environment, classifies data collected in specific applications and determines the
significance of this data. Depending on the level of relevance of the data, technical and organisational security
measures are implemented, as well as appropriate contractual provisions with suppliers. The activities carried out
by the Bank on an ongoing basis are aimed, on the one hand, at reducing the risk related to the protection
of privacy of persons whose data the Bank processes, and on the other hand, at improving the services provided.
In the event of personal data breaches, the Bank shall take the necessary restrictive and mitigating measures as
soon as possible after identifying such an event. An appropriate analysis of the probability of a breach of the rights
and freedoms of data subjects and, if necessary, the Bank reports the breach to supervisory authorities
in accordance with regulatory requirements is carried out. If required, the Bank shall also inform the data subjects,
indicating the possible consequences of the personal data breach and a description of the measures taken

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or proposed to address the breach and minimise its possible negative effects. The Bank analyses the process in
which the breach occurred and introduces additional security measures to prevent similar events in the future.
In July 2025, the President of the Personal Data Protection Office imposed a fine of PLN 18 million on the bank for
the practice of scanning identity cards in the period from April 2019 to September 2020. The Bank established
a provision for the amount of the penalty and recognised it in the costs of 2025. The Bank appealed against the
decision using the right to lodge a complaint with the Voivodeship Administrative Court in Warsaw. The Bank fully
cooperated with the President of the Personal Data Protection Office at every stage of the proceedings. The Bank
collected scans of identity documents in situations where it was necessary to perform its obligations under the Act
on counteracting money laundering and terrorist financing. The scans were obtained solely for this purpose.
7.2. Cybersecurity and security of IT transactions
Cybersecurity is a set of processes, best practices and technological solutions used to protect IT networks, devices,
programmes and data against attacks, damage or unauthorised access. Cybersecurity is the resilience
of IT systems to activities that violate the confidentiality, integrity, availability and authenticity of the data being
processed or the services associated with it.
Cybersecurity Action Strategy
The strategy in the area of cybersecurity is stable, consistent with the business strategy and assumptions of the
development of the Bank’s ICT environment. It is focused on creating effective IT solutions and channels
of interaction with customers with high resistance to cyber threats. The Bank observes the following rules:
• security at the centre of everything the Bank does in the area of ICT infrastructure.
• security as an integral part of business awareness,
• security as a competitive advantage.
The Bank places particular emphasis on:
• building secure and fault-tolerant IT solutions, compliant with the security architecture and operational model.
• a multi-layered model of ICT environment protection.
• safeguard all resources, whether they are vulnerable to internal or external threats.
• enhance the contribution of hazard modelling and the use of expertise to technological risk assessment,
at all stages of ICT implementation and operation.
• the use of automated control mechanisms.
• building awareness of IT security threats and competencies.
• secure provision of services by external providers.
• compliance with internal and external regulations.
Cybersecurity activities
All employees are responsible for ensuring the security of data and IT systems, within their areas and tasks.
The Bank also has dedicated units that perform this task in a special way. The Cybersecurity and IT Risk Expert
Centre is the unit responsible for ensuring the protection of ICT infrastructure, services and employees against cyber
threats, grouping the functions resulting from the operational model for the IT security area. This unit includes
teams responsible for:
• threat detection and response (SDR.),
• prevention and reduction of vulnerability (ASM),
• data leak prevention (DLP), security architecture and IT risk management.
Due to the continuous development of new, advanced attack methods, the Bank’s security teams are constantly
improving existing systems and building new, more effective detection and prevention mechanisms.
The Bank ensures compliance for the cybersecurity area with the requirements of:
• The Act on the National Cybersecurity System (UKSC), the subject of which is the organisation of the national
cybersecurity system and the definition of tasks and responsibilities of entities included in the national
cybersecurity system.
• The Digital Operational Resilience Regulation (DORA), which sets out a new European framework for the efficient
and comprehensive management of digital risks in financial markets.
All actions are aimed at protecting the Bank’s resources against threats from inside and outside, and thus
protecting clients and the funds entrusted to the Bank. Many of these activities are carried out jointly by the Bank
with other ING Group units, as well as in cooperation with financial institutions and state authorities. As in previous
years, the Bank actively participates in the work of the Cybersecurity Banking Centre Fincyber.pl operating within
the Polish Bank Association.
Fraud prevention
The second importan t element in the field of cybersecurity is counteracting fraud. The unit responsible for taking
actions in the field of external and internal fraud is the Expert Centre - Fraud Prevention, which aims to reduce
losses of customers and the Bank. The unit is also responsible for prompt response in the event of suspicion
of a crime and adapting preventive actions to the fraudsters’ activities. This expert centre includes, among others,
monitoring of incoming and outgoing transactions, analysis of customer reports on unauthorised transactions

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in accordance with the provisions of the Payment Services Act and the Fraud Complaints Handling procedure, as well
as preventive measures aimed at adequately protecting banking processes and products against fraud attempts.
Thanks to close cooperation between business units, the Bank is constantly improving its internet banking systems,
introducing new mechanisms to secure and reduce the risk of fraud, while ensuring clear and understandable
communication with the client. The Bank also improves mechanisms for detecting anomalies, both in the Bank’s
transaction system and in transactions ordered by clients, thus detecting suspicious transactions ordered
by unauthorised persons. The Bank also takes care of the integrity of transactions ordered by the client, reducing
the risk of internal fraud.
In Internet banking and mobile banking applications, the Bank uses various solutions to increase client security.
In addition, the centre’s employees conduct campaigns to raise awareness of how to avoid fraud for various groups
of clients, both consumers and corporate clients, and conduct awareness campaigns and training for the bank’s
employees, in accordance with the adopted training plan.
7.3. Business risk
Within business risk, the Group distinguishes several risk sub-categories, of which only macroeconomic risk was
classified as material risk.
Macroeconomic risk is defined as risk arising from changes in macroeconomic factors and their impact on the level
of minimum capital requirements.The Group manages this risk by regularly conducting internal and stress tests
in accordance with the Stress Testing Policy, which allows for ongoing monitoring of the sensitivity of the minimum
capital requirements to macroeconomic factors.
Based on the results of internal stress tests, in accordance with the Methodology for calculating economic capital for
macroeconomic risk, the Group estimates additional economic capital to hedge against the effects
of materialisation of the tested scenario. Due to the events of recent years, including the war in Ukraine, dynamic
changes in the macroeconomic and political environment and the results of stress tests, the Group continues
to maintain additional economic capital for macroeconomic risk.

145 | ING Bank Śląski S.A. Group | Annual consolidated financial statements for the period from 1 January 2025 to 31 December 2025 | Data in PLN million

Contents | Consolidated income statement | Consolidated statement of comprehensive income | Consolidated statement of financial position | Consolidated statement of changes in equity | Consolidated cash flow statement | Accounting policy and additional notes | Risk and capital management

SIGNATURES OF THE MANAGEMENT BOARD MEMBERS OF ING BANK ŚLĄSKI S.A.

2026-03-03 | Michał Bolesławski President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Joanna Erdman Vice-President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Marcin Giżycki Vice-President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Bożena Graczyk Vice-President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Marcin Kościński Vice-President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Maciej Ogórkiewicz Vice-President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Wojciech Sieńczyk Vice-President | The original Polish document is signed with a qualified electronic signature
2026-03-03 | Alicja Żyła Vice-President | The original Polish document is signed with a qualified electronic signature

SIGNATURE OF THE PERSON RESPONSIBLE FOR ACCOUNTS

2026-03-03 | Jolanta Alvarado Rodriguez Lead of Centre of Expertise Accounting Policy and Financial Reporting | The original Polish document is signed with a qualified electronic signature