Separate financial statements of PKO Bank Polski S.A. for the year ended 31 December 2025

SELECTED FINANCIAL DATA DERIVED FROM THE SEPARATE FINANCIAL STATEMENTS

SELECTED FINANCIAL DATA	PLN million			EUR million
			Change %			Change %
	2025	2024	(A-B)/B	2025	2024	(D-E)/E
	A	B	C	D	E	F
Net interest income	23,062	21,085	9.4%	5,443	4,899	11.1%
Net fee and commission income	4,389	4,353	0.8%	1,036	1,011	2.5%
Net expected credit losses and net impairment allowances on non-financial assets	(1,290)	(1,234)	4.5%	(304)	(287)	5.9%
Administrative expenses	(8,381)	(7,513)	11.6%	(1,978)	(1,746)	13.3%
Profit before tax	13,044	12,202	6.9%	3,078	2,835	8.6%
Net profit	10,240	9,150	11.9%	2,417	2,126	13.7%
Earnings per share for the period - basic (in PLN/EUR)*	8.19	7.32	11.9%	1.93	1.70	13.7%
Net comprehensive income	12,718	10,050	26.5%	3,002	2,335	28.5%
Total net cash flows	(3,040)	(2,625)	15.8%	(717)	(610)	17.5%

SELECTED FINANCIAL DATA	PLN million			EUR million
	31.12.2025	31.12.2024	Change % (A-B)/B	31.12.2025	31.12.2024	Change % (D-E)/E
	A	B	C	D	E	F
Total assets	556,734	500,747	11.2%	131,718	117,189	12.4%
Equity	55,635	49,767	11.8%	13,163	11,647	13.0%
Share capital	1,250	1,250	-	296	293	1.0%
Number of shares (in million)*	1,250	1,250	-	1,250	1,250	-
Book value per share (in PLN/EUR)*	44.51	39.81	11.8%	10.53	9.32	13.0%
Total capital ratio (%)**	18.82	21.26	(11.5%)	18.82	21.26	(11.5%)
Tier 1 capital**	43,598	42,899	1.6%	10,315	10,040	2.7%
Tier 2	4,499	3,039	48.0%	1,064	711	49.6%

* As there were no dilutive instruments, diluted earnings per share are equal to basic earnings per share.

** restated

SELECTED FINANCIAL STATEMENT ITEMS HAVE BEEN TRANSLATED INTO EUR AT THE FOLLOWING RATES	2025	2024
arithmetic mean of the NBP exchange rates at the end of a month (income statement, statement of comprehensive income and cash flow statement items)	4.2372	4.3042
	31.12.2025	31.12.2024
NBP mid exchange rates at the date indicated (statement of financial position items)	4.2267	4.2730

TABLE OF CONTENTS

SEPARATE INCOME STATEMENT

SEPARATE STATEMENT OF COMPREHENSIVE INCOME

SEPARATE STATEMENT OF FINANCIAL POSITION

SEPARATE STATEMENT OF CHANGES IN EQUITY

SEPARATE STATEMENT OF CASH FLOWS

1. Business activities of the Bank

2. Changes in the Group companies

3. Information on members of the Supervisory Board and Management Board

4. Approval of the financial statements

5. Representation by the Management Board

6. Statement of compliance

7. Going concern

8. The basis for preparation of the financial statements

SIGNIFICANT ACCOUNTING POLICIES

9. Functional currency, presentation currency and foreign currencies

10. General significant accounting policies for financial instruments

10.1. Recognition of transactions in the statement of financial position

10.2. Offsetting financial instruments

10.3. Derecognition of financial instruments from the statement of financial position

10.4. The principles for classification of financial instruments

10.5. Measurement category of financial assets at amortized cost

10.6. Measurement category of financial assets at fair value through other comprehensive income

10.7. Financial assets measured at fair value through profit or loss

10.8. Equity instruments

10.9. Reclassification of financial assets

10.10. Modifications - Change in contractual cash flows

10.11. Measurement of purchased or originated credit-impaired financial assets (POCI)

10.12. Measurement of financial liabilities

10.13. Reverse repo transactions

11. Environmental issues

12. Changes in accounting policies applicable from 1 January 2025 and explanation of the differences between previously published financial statements and these financial statements

13. New standards and interpretations, and amendments to standards

SUPPLEMENTARY NOTES TO THE INCOME STATEMENT

14. Interest income and expense and similar income and expense

15. Fee and commission income and expenses

16. Fee and commission income by segment

17. Dividend income

18. Gains/(losses) on financial transactions

19. Net foreign exchange gains/(losses)

20. Other operating income and expenses

21. Net allowances for expected credit losses

22. Impairment of non-financial assets

23. Cost of the legal risk of mortgage loans in convertible currencies

24. Administrative expenses

25. Tax on certain financial institutions

26. Income tax expense

SUPPLEMENTARY NOTES TO THE STATEMENT OF FINANCIAL POSITION – FINANCIAL INSTRUMENTS

27. Cash and balances with the Central Bank

28. Amounts due from banks

29. Hedge accounting and other derivative instruments

29.1. Hedge accounting – financial information

29.2. Other derivative instruments – financial information

30. Securities

31. Loans and advances to customers

32. Amounts due to banks

33. Amounts due to customers

34. Financing received

OTHER SUPPLEMENTARY NOTES TO THE STATEMENT OF FINANCIAL POSITION AND CONTINGENT LIABILITIES

35. Intangible assets

36. Property, plant and equipment

37. Investments in subsidiaries, associates and joint ventures

38. Other assets

39. Other liabilities

40. Provisions

41. Contingent liabilities and off-balance sheet liabilities received and granted

42. Legal claims

43. Equity and shareholding structure of the Bank

FAIR VALUE OF FINANCIAL INSTRUMENTS

44. Fair value hierarchy

45. Financial assets and financial liabilities not presented at fair value in the statement of financial position

RISK MANAGEMENT IN THE BANK

46. Risk management in the Bank

47. Credit risk management

48. Credit risk – financial information

48.1. Financial assets by stage

48.2. Change in the gross carrying amount

48.3. Changes in allowances for expected credit losses

48.4. Other disclosures

49. Offsetting financial assets and financial liabilities

50. Managing credit concentration risk in the Bank

51. Exposure to the counterparty credit risk

52. Forbearance practices

53. Information on package sale of receivables

54. Interest rate risk management

55. Currency risk management

56. Liquidity risk management

57. Assets pledged as collateral for liabilities and transferred financial assets

CAPITAL MANAGEMENT AT THE BANK

58. Capital adequacy

59. Dividends and distribution of retained earnings

OTHER NOTES

60. Notes to the cash flow statement

61. Transactions with the State Treasury and related entities

62. Benefits for the PKO Bank Polski S.A. key management

63. Leases

64. Information on the audit firm authorized to audit the financial statements

65. Interest rate benchmarks reform

66. Events that occurred after the date on which the financial statements are prepared

SEPARATE INCOME STATEMENT

INCOME STATEMENT	Note	2025	2024
Net interest income	14, 16	23,062	21,085
Interest and similar income		31,142	30,009
of which calculated under the effective interest rate method		30,827	29,604
Interest expense		(8,080)	(8,924)
Net fee and commission income	15, 16	4,389	4,353
Fee and commission income		6,146	5,948
Fee and commission expense		(1,757)	(1,595)
Net other income		923	1,622
Dividend income	17	933	1,009
Gains/(losses) on financial transactions	18	179	250
Net foreign exchange gains/(losses)	19	257	249
Gains/(losses) on derecognition of financial instruments		45	111
including measured at amortized cost		8	45
Net other operating income and expense, of which:	20	(491)	3
other operating income		170	182
other operating expenses		(661)	(179)
Result on business activities		28,374	27,060
Net allowances for expected credit losses	21	(781)	(805)
Impairment of non-financial assets	22	(509)	(429)
Cost of legal risk of mortgage loans in convertible currencies	23	(4,365)	(4,899)
Administrative expenses	24	(8,381)	(7,513)
Tax on certain financial institutions	25	(1,294)	(1,212)
Profit before tax		13,044	12,202
Income tax expense	26	(2,804)	(3,052)

Net profit		10,240	9,150

Earnings per share
Earnings per share: basic/diluted for the period (PLN)*		8.19	7.32
Weighted average number of ordinary shares during the period (in million)*		1,250	1,250

* As there were no dilutive instruments, diluted earnings per share are equal to basic earnings per share.

SEPARATE STATEMENT OF COMPREHENSIVE INCOME

STATEMENT OF COMPREHENSIVE INCOME	Note	2025	2024
Net profit		10,240	9,150
Other comprehensive income		2,478	900
Items which may be reclassified to profit or loss		2,483	902
Cash flow hedges (net)	29	1,346	596
Gains/losses recognized in other comprehensive income during the period		221	(552)
Amounts transferred from other comprehensive income to the income statement		1,479	1,288
Deferred tax on cash flow hedges	26	(354)	(140)
Fair value of financial assets measured at fair value through other comprehensive income (net)		1,136	305
Remeasurement of fair value, gross		1,445	443
Gains /losses transferred to the profit or loss (on disposal)		(37)	(66)
Deferred tax on fair value of financial assets measured at fair value through other comprehensive income	26	(272)	(72)
Currency translation differences on foreign operations		1	1
Items which cannot be reclassified to profit or loss		(5)	(2)
Actuarial gains and losses (net)		(5)	(2)
Actuarial gains and losses (gross)	40	(12)	(2)
Deferred tax on actuarial gains and losses	26	7	-

Net comprehensive income		12,718	10,050

SEPARATE STATEMENT OF FINANCIAL POSITION

	Note	31.12.2025	31.12.2024
ASSETS		556,734	500,747
Cash and balances with the Central Bank	27	21,644	23,263
Amounts due from banks	28	6,351	8,349
Hedging derivatives	29	147	344
Other derivative instruments	29	2,446	2,018
Securities	30	236,445	204,877
Reverse repo transactions		2,010	892
Loans and advances to customers	31	272,991	245,908
Property, plant and equipment	36	2,953	2,856
Assets held for sale		5	11
Intangible assets	35	3,482	3,479
Investments in subsidiaries	37	3,560	3,560
Investments in associates and joint ventures	37	275	275
Current income tax receivable		1	-
Deferred tax assets	26	1,423	2,011
Other assets	38	3,001	2,904
LIABILITIES AND EQUITY		556,734	500,747
Liabilities		501,099	450,980
Amounts due to Central bank		10	11
Amounts due to banks	32	3,377	2,271
Hedging derivatives	29	105	302
Other derivative instruments	29	2,724	2,409
Repo transactions		22	-
Amounts due to customers	33	455,662	414,920
Liabilities in respect of debt securities in issue	34	16,034	11,999
Subordinated liabilities	34	6,309	4,291
Other liabilities	39	8,339	7,310
Current income tax liabilities		899	839
- of the Bank		756	693
- of the subsidiaries belonging to the Tax Group		143	146
Provisions	40	7,618	6,628

Equity	43	55,635	49,767
Share capital		1,250	1,250
Reserves and accumulated other comprehensive income		34,708	29,930
Unappropriated profits		9,437	9,437
Net profit or loss for the year		10,240	9,150

SEPARATE STATEMENT OF CHANGES IN EQUITY

FOR THE YEAR ENDED 31 December 2025	Share capital	Reserves and accumulated other comprehensive income					Retained earnings	Net profit or loss for the period	Total equity
		Reserves			Accumulated other comprehensive income	Total reserves and accumulated other comprehensive income
		Supplementary capital	General banking risk fund	Other reserves	Accumulated other comprehensive income	Total reserves and accumulated other comprehensive income
As at the beginning of the period	1,250	22,468	1,070	8,406	(2,014)	29,930	9,437	9,150	49,767
Transfer from retained earnings	-	-	-	-	-	-	9,150	(9,150)	-
Transfer between retained earnings and capitals, including reserve capital for the payment of dividends (including interim dividends)*	-	-	-	2,300	-	2,300	(2,300)	-	-
Dividend	-	-	-	-	-	-	(6,850)	-	(6,850)
Comprehensive income	-	-	-	-	2,478	2,478	-	10,240	12,718
As at the end of the period	1,250	22,468	1,070	10,706	464	34,708	9,437	10,240	55,635

* For information on the distribution of profit for 2024, see Note “Dividends and profit appropriation”

FOR THE YEAR ENDED 31 December 2024	Share capital	Reserves and accumulated other comprehensive income					Retained earnings	Net profit or loss for the period	Total equity
		Reserves			Accumulated other comprehensive income	Total reserves and accumulated other comprehensive income
		Supplementary capital	General banking risk fund	Other reserves	Accumulated other comprehensive income	Total reserves and accumulated other comprehensive income
As at the beginning of the period	1,250	22,468	1,070	6,775	(2,914)	27,399	9,437	4,868	42,954
Transfer from retained earnings	-	-	-	-	-	-	4,868	(4,868)	-
Transfer between retained earnings and equity, including reserve capital for the payment of dividends (including interim dividends)	-	-	-	1,631	-	1,631	(1,631)	-	-
Dividend	-	-	-	-	-	-	(3,237)	-	(3,237)
Comprehensive income	-	-	-	-	900	900	-	9,150	10,050
As at the end of the period	1,250	22,468	1,070	8,406	(2,014)	29,930	9,437	9,150	49,767

FOR THE YEAR ENDED 31 December 2025	Accumulated other comprehensive income
FOR THE YEAR ENDED 31 December 2025	Fair value of financial assets measured at fair value through other comprehensive income	Cash flow hedges	Actuarial gains and losses	Currency translation differences on foreign operations	Total
As at the beginning of the period	(884)	(1,105)	(24)	(1)	(2,014)
Total comprehensive income	1,136	1,346	(5)	1	2,478
As at the end of the period	252	241	(29)	-	464

FOR THE YEAR ENDED 31 December 2024	Accumulated other comprehensive income
FOR THE YEAR ENDED 31 December 2024	Fair value of financial assets measured at fair value through other comprehensive income	Cash flow hedges	Actuarial gains and losses	Currency translation differences on foreign operations	Total
As at the beginning of the period	(1,189)	(1,701)	(22)	(2)	(2,914)
Total comprehensive income	305	596	(2)	1	900
As at the end of the period	(884)	(1,105)	(24)	(1)	(2,014)

SEPARATE STATEMENT OF CASH FLOWS

	Note		2025	2024
Cash flows from operating activities
Profit before tax			13,044	12,202
Income tax paid			(2,774)	(2,523)
Total adjustments:			2,541	(19,133)
Depreciation and amortization		24	1,123	1,077
(Gains)/losses on investing activities			(7)	(17)
Net interest income (from income statement)			(23,062)	(21,085)
Interest received		60	21,532	20,889
Interest paid		60	(7,548)	(10,397)
Dividends received			(932)	(1,039)
Change in:
amounts due from banks			591	(1,144)
hedging derivatives			74	293
other derivative instruments			(114)	(1,231)
securities			(6,541)	(6,486)
loans and advances to customers			(27,409)	(19,847)
reverse repo transactions			(1,116)	(519)
non-current assets held for sale			7	127
other assets			(481)	(1,382)
accumulated allowances for expected credit losses			277	(1,115)
accumulated allowances on non-financial assets and other provisions			1,548	3,115
amounts due to the Central Bank			(1)	1
amounts due to banks			1,106	(707)
amounts due to customers			40,839	21,305
repo transactions			22	-
liabilities in respect of debt securities in issue			(149)	(140)
subordinated liabilities			-	(2)
other liabilities			1,298	(1,163)
Other adjustments			1,484	334
Net cash from/used in operating activities			12,811	(9,454)

	Note	2025	2024
Cash flows from investing activities
Inflows from investing activities		349,876	753,445
Redemption of securities measured at fair value through other comprehensive income		312,456	727,851
Interest received on securities measured at fair value through other comprehensive income		4,128	4,376
Redemption of securities measured at amortized cost		28,126	17,239
Interest received on securities measured at amortized cost		4,165	2,828
Proceeds from disposal of intangible assets, property, plant and equipment and assets held for sale		33	64
Other inflows from investing activities including dividends	60	968	1,087
Outflows on investing activities		(363,906)	(751,090)
Purchase of securities measured at fair value through other comprehensive income		(316,425)	(712,413)
Purchase of securities measured at amortized cost		(46,303)	(37,632)
Purchase of intangible assets and property, plant and equipment		(1,178)	(1,044)
Other outflows on investing activities		-	(1)
Net cash from/used in investing activities		(14,030)	2,355

	Note	2025	2024
Cash flows from financing activities
Distribution of dividends		(6,850)	(4,837)
Proceeds from debt securities in issue	60	7,407	8,524
Redemption of debt securities	60	(3,173)	-
Proceeds from issue of subordinated bonds	60	2,000	1,500
Payment of lease liabilities	60	(269)	(277)
Repayment of interest on financial liabilities	60	(936)	(436)
Net cash from financing activities		(1,821)	4,474
Total net cash flows		(3,040)	(2,625)
of which foreign exchange differences on cash and cash equivalents		(52)	(49)
Cash and cash equivalents at the beginning of the period		26,110	28,735
Cash and cash equivalents at the end of the period	60	23,070	26,110

General information about the bank

1. Business activities of the Bank

Basic information on the parent company:

Name of the reporting entity	Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna (PKO Bank Polski S.A. or the Bank)
Country of registration	Poland
Registered office	Warsaw
Address of the registered office of the entity	On 27 June 2025, the address of the Bank with its registered office in Warsaw changed from: ul. Puławska 15, 02-515 Warsaw to: ul. Świętokrzyska 36, 00-116 Warsaw.
National Court Register	District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register Entry number 0000026438
Statistical ID No (REGON):	016298263
Principal activities	A bank which services both Polish and foreign individuals, legal and other entities.
Place of business:	Poland and through Branches in the Federal Republic of Germany, the Czech Republic, the Slovak Republic, and Romania, as well as representative offices in Sweden and Lithuania

Key information on the Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna Group (the Group)

No.	ENTITY NAME	REGISTERED OFFICE	ACTIVITY	OWNERSHIP INTEREST (%)
No.	DIRECT SUBSIDIARIES	REGISTERED OFFICE	ACTIVITY	31.12.2025	31.12.2024
1	PKO Bank Hipoteczny S.A.	Warsaw	banking activities	100	100
2	PKO Towarzystwo Funduszy Inwestycyjnych S.A.	Warsaw	investment fund management	100	100
3	PKO Leasing S.A.	Warsaw	leasing and lending	100	100
4	PKO BP BANKOWY PTE S.A.	Warsaw	pension fund management	100	100
5	PKO BP Finat sp. z o.o.	Warsaw	services, including transfer agent services and outsourcing of IT specialists	100	100
6	PKO Życie Towarzystwo Ubezpieczeń S.A.	Warsaw	life insurance	100	100
7	PKO Towarzystwo Ubezpieczeń S.A.	Warsaw	other personal insurance and property insurance	100	100
8	PKO Finance AB	Sollentuna, Sweden	financial services	100	100
9	KREDOBANK S.A.	Lviv, Ukraine	banking activities	100	100
10	NEPTUN - fizan1	Warsaw	investing funds collected from fund participants	100	100
11	PKO VC - fizan1	Warsaw	investing funds collected from fund participants	100	100

1 PKO Bank Polski S.A. holds investment certificates of the Fund; the percentage of the Fund’s investment certificates held is presented in the item “Share in capital”.

No.	ENTITY NAME	REGISTERED OFFICE	ACTIVITY	OWNERSHIP INTEREST (%)*
No.	INDIRECT SUBSIDIARIES	REGISTERED OFFICE	ACTIVITY	31.12.2025	31.12.2024
	PKO Leasing S.A. GROUP
1	PKO Agencja Ubezpieczeniowa sp. z o.o.	Warsaw	intermediation in concluding insurance agreements	100	100
	1.1 PKO Leasing Finanse sp. z o.o.	Warsaw	sale of post-lease assets	100	100
2	PKO Leasing Sverige AB	Stockholm, Sweden	leasing	100	100
3	Prime Car Management S.A.	Gdańsk	leasing, fleet management	100	100
	3.1 Futura Leasing S.A.	Gdańsk	sale of post-lease assets	100	100
	3.2 Masterlease sp. z o.o.	Gdańsk	leasing	100	100
	3.3 MasterRent24 sp. z o.o.	Gdańsk	short-term lease of cars	100	100
4	PKO Faktoring S.A.	Warsaw	factoring	100	100
5	Polish Lease Prime 1 DAC1	Dublin, Ireland	SPV established for securitization of lease receivables	-	-
	PKO Życie Towarzystwo Ubezpieczeń S.A. GROUP
	Ubezpieczeniowe Usługi Finansowe sp. z o.o.4	Warsaw	services,	-	100
	KREDOBANK S.A. GROUP
6	“KREDOLEASING” sp. z o.o.	Lviv, Ukraine	leasing	100	100
	NEPTUN - fizan
7	Qualia sp. z o.o.	Warsaw	after-sale services in respect of developer products	100	100
	Sarnia Dolina sp. z o.o. w likwidacji (in liquidation)4	Warsaw	development activities	-	100
8	Bankowe Towarzystwo Kapitałowe S.A.	Warsaw	services,	100	100
	8.1 “Inter-Risk Ukraina” spółka z dodatkową odpowiedzialnością2	Kyiv, Ukraine	debt collection	99.90	99.90
	8.2 Finansowa Kompania „Prywatne Inwestycje” sp. z o.o.3	Kyiv, Ukraine	financial services	95.4676	95.4676
	8.2.1 “Idea Kapitał” sp. z o.o.	Lviv, Ukraine	services,	100	100
9	“Sopot Zdrój" sp. z o.o.	Sopot	property management	72.9769	72.9769
10	“Zarząd Majątkiem Górczewska” sp. z o.o.	Warsaw	property management	100	100
	Molina sp. z o.o. w likwidacji (in liquidation)4	Warsaw	general partner in partnerships limited by shares of a fund	-	100
	Molina spółka z ograniczoną odpowiedzialnością w likwidacji 1 S.K.A. (in liquidation)4	Warsaw	buying and selling real estate on own account, real estate management	-	100
	Molina spółka z ograniczoną odpowiedzialnością 4 S.K.A. w likwidacji (in liquidation) 4	Warsaw		-	100
	Molina spółka z ograniczoną odpowiedzialnością 6 S.K.A. w likwidacji (in liquidation) 4	Warsaw		-	100

* share of direct parent in the entity’s equity

1) In accordance with IFRS 10, PKO Leasing S.A. exercises control over the company, although it does not have a capital share in it. The Company is placed in liquidation.

2) Finansowa Kompania “Prywatne Inwestycje” sp. z o.o. is the second shareholder of the company.

3) “Inter-Risk Ukraina” – a company with additional liability – is the second shareholder of the company.

4) See Note “Changes in the Group companies”.

No.	ENTITY NAME	REGISTERED OFFICE	ACTIVITY	OWNERSHIP INTEREST (%)*
No.	ENTITY NAME	REGISTERED OFFICE	ACTIVITY	31.12.2025	31.12.2024
	Joint ventures of PKO Bank Polski S.A.
1	Operator Chmury Krajowej sp. z o.o.	Warsaw	cloud computing services	50	50
2	Centrum Elektronicznych Usług Płatniczych eService sp. z o.o.	Warsaw	financial services support activities, including handling transactions concluded using payment instruments	34	34
	1 EVO Payments International s.r.o.1	Prague, the Czech Republic	financial services support activities	34	34
	Joint venture NEPTUN - fizan
	2 „Centrum Obsługi Biznesu" sp. z o.o.	Poznań	property management	41.45	41.45
	Joint venture PKO VC - fizan
	3 BSafer sp. z o.o.	Stalowa Wola	managing marketing consents	35.06	35.06
	Associates of PKO Bank Polski S.A.
1	Bank Pocztowy S.A.	Bydgoszcz	banking activities	25.0001	25.0001
2	“Poznański Fundusz Poręczeń Kredytowych" sp. z o.o.	Poznań	guarantees	33.33	33.33
3	System Ochrony Banków Komercyjnych S.A.	Warsaw	manager of the security system referred to in Article 130e of the Banking Law	21.11	21.11

*share in equity of the entity exercising joint control / having a significant impact / the direct parent.

1 share in the entity's equity from the perspective of the parent company PKO Bank Polski S.A.

2. Changes in the Group companies

In 2025, the liquidation process was completed and the following companies were deleted from the National Court Register:

• 5 subsidiaries from the NEPTUN fizan portfolio: Molina spółka z ograniczoną odpowiedzialnością w likwidacji (in liquidation), Molina spółka z ograniczoną odpowiedzialnością w likwidacji 1 S.K.A. w likwidacji (in liquidation), Molina spółka z ograniczoną odpowiedzialnością 4 S.K.A. w likwidacji (in liquidation), Molina spółka z ograniczoną odpowiedzialnością 6 S.K.A. w likwidacji (in liquidation), Sarnia Dolina sp. z o.o. w likwidacji (in liquidation);

• subsidiary of PKO Życie Towarzystwo Ubezpieczeń S.A. - Ubezpieczeniowe Usługi Finansowe sp. z o.o. w likwidacji (in liquidation).

In 2025, the above companies ceased to be part of the Group.

3. Information on members of the Supervisory Board and Management Board

Composition of the Bank's Supervisory Board as at 31 December 2025:

• Tomasz Siemiątkowski – Chair of the Supervisory Board,

• Katarzyna Zimnicka-Jankowska – Deputy Chair of the Supervisory Board,

• Marek Panfil – Secretary of the Supervisory Board

• Maciej Cieślukowski – Member of the Supervisory Board,

• Jerzy Kalinowski - Member of the Supervisory Board,

• Hanna Kuzińska - Member of the Supervisory Board,

• Małgorzata Prochwicz-O’Shaughnessy - Member of the Supervisory Board,

• Jerzy Śledziewski – Member of the Supervisory Board,

• Paweł Waniowski – Member of the Supervisory Board,

• Anna Zabłocka-Wiercińska - Member of the Supervisory Board.

Composition of the Bank's Management Board as at 31 December 2025:

• Szymon Midera – President of the Management Board,

• Krzysztof Dresler – Vice-President of the Management Board,

• Ludmiła Falak-Cyniak - Vice-President of the Management Board,

• Piotr Mazur - Vice-President of the Management Board,

• Tomasz Pol – Vice-President of the Management Board

• Marek Radzikowski - Vice-President of the Management Board,

• Michał Sobolewski – Vice-President of the Management Board

• Mariusz Zarzycki - Vice-President of the Management Board.

A detailed description of the composition, competencies and operating principles of the Management Board and the Supervisory Board of the Bank, including changes in their composition in 2025 – Note 11 “Corporate Governance” of the “Directors’ Report of the PKO Bank Polski S.A. Group for 2025 prepared jointly with the Directors’ Report of PKO Bank Polski S.A. (“Directors’ Report”).

4. Approval of the financial statements

The financial statements of the Bank (financial statements), subject to review by the Audit Committee, were approved for publication by the Management Board on 10 March 2026 and adopted by the Supervisory Board on 11 March 2026.

5. Representation by the Management Board

The Management Board hereby represents that, to the best of their knowledge, the financial statements and the comparative data have been prepared in accordance with the applicable rules of accounting practice and give a true, fair and clear view of the Bank’s financial position and results of operations.

6. Statement of compliance

The financial statements have been prepared in accordance with the International Financial Reporting Standards (IFRS) as endorsed by the European Union (EU) as at 31 December 2025, and in the areas not regulated by these standards, in accordance with the requirements of the Accounting Act of 29 September 1994 and the respective secondary legislation issued on its basis, as well as the requirements relating to issuers of securities registered or applying for registration on the stock exchange official listing market.

7. Going concern

The financial statements have been prepared on the basis of the assumption that the Bank will continue as a going concern for a period of at least 12 months from the date of approval for publication by the Management Board, i.e. from 10 March 2026. As at the date of signing these financial statements, the Bank’s Management Board is not aware of any facts or circumstances that would indicate a threat to the Bank’s ability to continue in operation as a going concern for 12 months following the publication date as a result of any intended or compulsory discontinuation or significant limitation of the Bank’s existing operations.

The Management Board has analysed the current economic and geopolitical situation as well as the risk associated with foreign currency mortgage loans and has concluded that these factors do not give rise to any material uncertainty regarding the Bank’s ability to continue as a going concern.

External business conditions, including the macroeconomic environment, situation on the financial markets, situation of the Polish banking and non-banking sector, the regulatory and legal environment, as well as factors that will affect future financial results – Note 2 “External business conditions” of the Directors' Report.

8. The basis for preparation of the financial statements

The financial statements of PKO Bank Polski S.A cover the year ended 31 December 2025 and include comparative figures for the year ended 31 December 2024 and as at 31 December 2024.

The financial data is presented in millions of Polish zlotys (PLN), unless otherwise indicated. Figures have been rounded to the nearest million Polish zloty and any differences from previously published figures may be due to rounding.

Annual consolidated financial statements of PKO Bank Polski S.A. Group for the year ended 31 December 2025 will be published and approved on the same date as the separate financial statements of PKO Bank Polski S.A. The requirement for its preparation and publication is based on legal regulations.

In the financial statements, the Bank has applied a fair value basis in respect of financial assets and liabilities measured at fair value through profit or loss, including derivatives, and financial assets measured at fair value through other comprehensive income. The remaining financial assets are recognized by the Bank at amortized cost less allowances for expected credit losses, and remaining financial liabilities at amortized cost. Non-current assets are measured at acquisition cost less accumulated depreciation and impairment losses. Non-current assets (or groups of such assets) classified as held for sale are measured at the lower of their carrying amount and fair value less costs to sell.

While preparing the financial statements, the Bank makes estimates and assumptions that affect the data in the financial statements and supplementary information. Estimates and assumptions concern assets, liabilities, income and expenses. They are based on historical data and other available factors considered appropriate in a given situation. Future expectations and available information are used to measure assets and liabilities that cannot be determined directly. The estimation takes into consideration the reasons and sources of the uncertainties anticipated at the end of the reporting period. Actual results may differ from estimates. Estimates and assumptions are reviewed on a regular basis, and changes in estimates are recognized in the period to which they relate.

SIGNIFICANT ACCOUNTING POLICIES

Significant accounting policies as well as estimates and judgements applied in the preparation of these financial statements are described in this chapter and in individual notes later in this document. These policies were applied consistently in all the presented years.

9. Functional currency, presentation currency and foreign currencies

The financial statements are presented in Polish zlotys (PLN), which are the Bank’s functional and presentation currency. Items of the statement of financial position are translated into the presentation currency from the functional currency using the NBP mid-exchange rate at the end of the reporting period:

• EUR - Branch in Germany and Slovakia,

• CZK - Branch in the Czech Republic,

• RON - Branch in Romania.

Items in the branches’ profit and loss are translated into the presentation currency using the mid-exchange rate quoted at the end of each month of the reporting period. The resulting exchange differences are recognized in other comprehensive income.

• Transactions and balances in foreign currencies

Foreign currency transactions are translated into the functional currency at the exchange rate prevailing on the date of the transaction.

At the end of the reporting period, the Bank translates:

• monetary items – at the closing exchange rate, i.e. the NBP mid-exchange rate as at the end of the period,

• non-monetary items carried at historical cost (e.g. property, plant and equipment, intangible assets) – at the NBP mid-exchange rate as at the transaction date,

• non-monetary items measured at fair value (e.g. equity instruments classified as financial assets) – at the NBP exchange rate as at the date of determining the fair value.

Foreign exchange gains and losses are recognized in the income statement under net foreign exchange gains/(losses).

	EUR/PLN		CZK/PLN			RON/PLN
	2025	2024	2025	2024	2025		2024
Exchange rate prevailing on the last day of the period	4.2267	4.2730	0.1746	0.1699	0.8291		0.8589
Exchange rate representing the arithmetic mean of the exchange rates prevailing on the last day of each month of a given period	4.2372	4.3042	0.1719	0.1712	0.8397		0.8652
Highest exchange rate in the period	4.2778	4.3530	0.1754	0.1753	0.8594		0.8750
Lowest exchange rate in the period	4.1575	4.2678	0.1661	0.1688	0.8291		0.8576

10. General significant accounting policies for financial instruments

10.1. Recognition of transactions in the statement of financial position

Financial assets and financial liabilities are recognized in the statement of financial position when the Bank becomes a party to the contractual provisions of the instrument:

• Financial assets purchased or sold in regular way transactions (with delivery within the time frame established by market regulations) - on the transaction settlement date,

• Loans and advances - when the funds are disbursed to the borrower,

• Derivative instruments - at fair value from the transaction date.

10.2. Offsetting financial instruments

The Bank offsets financial assets and financial liabilities and presents them in the statement of financial position on a net basis if:

• it has a legally enforceable right to offset,

• it intends either to settle them on a net basis, or to realize the asset and settle the liability simultaneously.

10.3. Derecognition of financial instruments from the statement of financial position

The Bank derecognizes financial assets from the statement of financial position when:

• the contractual rights to the cash flows from these assets expire,

• there are no reasonable expectations of recovering them in whole or in part,

• the asset is substantially modified,

• the asset has been transferred to another entity in a transaction in which substantially all the risks and rewards incident to ownership are transferred, or the Bank has neither transferred nor retained substantially all the risks and rewards incident to ownership and has not retained control over the asset.

Assets are also derecognized when they have been invalidated by a final court judgment, forgiven, expired or are uncollectible.

Derecognition is performed against allowances for expected credit losses or gross carrying amount adjustments (e.g. in the case of legal risk relating to mortgage loans in foreign currencies). If no allowances or adjustments to the gross carrying amount for legal risk have been recognized or their amount is lower than the value of the financial asset, before its write-off, such allowance or adjustment is increased by the difference between the value of the asset and the amount of the allowance or adjustment recognized to date.

Financial liabilities are derecognized from the statement of financial position when they are extinguished, i.e. when the obligation specified in the contract is discharged, cancelled or expires.

10.4. The principles for classification of financial instruments

The Bank classifies financial assets into the following categories:

• measured at amortized cost,

• measured at fair value through other comprehensive income,

• measured at fair value through profit or loss.

The Bank classifies financial liabilities into the following categories:

• measured at amortized cost,

• measured at fair value through profit or loss.

Classification of financial assets on the date of acquisition or origination depends on:

• the Bank's business model adopted for managing a given group of assets

• the characteristics of contractual cash flows arising from a single asset or a group of assets.

business model

The business model is determined for groups of assets depending on the area of business in which they originated or were acquired. When determining it, the following is taken into account:

• business objectives and investment policies (how assets are managed and cash flows are generated),

• the method of evaluating and reporting portfolio performance,

• risk management and remuneration policies for the persons managing these portfolios,

• the volume, frequency, timing and reasons for sales of assets.

Upon initial recognition of financial assets, the Bank assigns them to existing business models.

The Bank's business models:

• Held to collect – assets are held to collect contractual cash flows (typical of lending activities).

In the “held to collect” business model, the Bank sets out the following criteria for acceptable sales of financial assets:

• insignificant sales (below 5% of the portfolio), even if frequent,

• infrequent sales – an incidental number of sales transactions during the year, even despite a significant value,

• sales close to maturity (a period not longer than 5% of the remaining time to maturity),

• "incidental sales" in the event of an increase in risk, change in law or regulations - sales executed in order to maintain the assumed level of regulatory capital on the terms described in the management strategy for such portfolios.

• Held to collect and sell – assets are held to collect cash flows, but may also be sold - frequently and in significant value transactions (typical of liquidity management).

• The residual model – other than the "held to collect" and "held to collect and sell" models, comprises portfolios held for sale and those where fair value is the key performance indicator.

Sales levels in the "held to collect and sell" model and in the "residual" model are higher than in the "held to collect" model.

Assessment of the contractual cash flow characteristics

The assessment of the contractual cash flow characteristics involves conducting a test of contractual cash flows (the SPPI test - Solely Payments of Principal and Interest test). The test determines whether the cash flows from this asset are solely:

• payments of principal (the fair value of the financial asset upon initial recognition),

• interest (comprising consideration for the time value of money, credit risk, other basic lending risks and costs, as well as the profit margin).

The characteristics of cash flows do not affect the classification of the asset if:

• it has an insignificant effect on the cash flows (de minimis feature) - the Bank verifies this by calculating the percentage change in cash flows in each reporting period and cumulatively over the life of the instrument,

• it is non-genuine - it affects the cash flows only upon the occurrence of events that are extremely rare, highly abnormal and very unlikely to occur.

The Bank assesses the impact of contractual cash flow characteristics in each reporting period and cumulatively over the entire life of the instrument.

The SPPI test is performed for each asset in the "held to collect" and "held to collect and sell" models upon initial recognition (and following a substantial modification of the asset).

For assets associated with sustainable development (e.g. green loans with a reduced margin upon delivery of an energy certificate), the Bank verifies:

• the impact of this feature on the cash flows in each reporting period and over the entire lending period,

• whether the impact is linked to credit risk.

If the change in margin depends on the level of credit risk (e.g. higher risk equals higher interest rate), the SPPI criteria are met.

The Bank analyses the characteristics of financial assets that cause the SPPI test to fail, including:

• leverage in the calculation of the interest rate (a multiplier higher than 1),

• a creditor's right to participate in the profit (the cash flows are not solely payments of principal and interest),

• limitation of the debtor's liabilities (non-recourse assets),

• prepayment and extension options dependent on events unrelated to the contract or credit risk,

• covenants that result in a negative relationship between the loan margin and the level of credit risk,

• interest rates set unilaterally by the Bank (so-called administered rates) if they are not close to the market floating rate.

If, on the basis of a qualitative assessment in the SPPI test, it cannot be determined whether the cash flows are solely payments of principal and interest, or in the case of a modification of the time value of money, the Bank performs a benchmark test (quantitative assessment). It consists in comparing the non-discounted contractual cash flows with the non-discounted cash flows that would arise if the time value of money had not been modified (the reference level of cash flows). The modification of the time value of money mainly concerns situations involving:

• a mismatch between the frequency of interest rate updates and the interest rate tenor,

• interest rate updates based on averaged values,

• interest rate updates based on lagged values (e.g. rates from one month prior).

The SPPI test is not failed where the result of the benchmark test does not exceed the materiality thresholds of:

• 5% for the sum of non-discounted cash flows over the agreement horizon

• 5% for the sum of cash flows in the quarterly reporting periods.

10.5. Measurement category of financial assets at amortized cost

Debt financial assets are measured at amortized cost if both of the following conditions are met:

• they are held in the “held to collect” business model,

• the contract provides for cash flows that are solely payments of principal and interest (the SPPI test passed).

This category includes amounts due from banks, loans and advances to customers and debt securities.

The carrying amount is determined using the effective interest rate used to calculate interest income generated by the asset in a given period, which includes commissions, transaction costs, premiums and discounts constituting its integral part (Note “Interest income and expense”). The carrying amount of the asset is then adjusted by the adjustment to the gross carrying amount related to the legal risk of foreign currency mortgage loans (Note “Cost of legal risk of mortgage loans in convertible currencies”) and by allowances for expected credit losses (Note “Net allowances for expected credit losses”).

If the schedule of future cash flows necessary to calculate the effective interest rate cannot be determined, the assets are measured at the amount due (including interest on receivables, taking into account allowances for expected credit losses). Fees and commissions related to the origination or determining the financial characteristics of these assets are presented as Other liabilities, amortized on a straight-line basis over the life of the asset and recognized in commission income.

10.6. Measurement category of financial assets at fair value through other comprehensive income

Debt financial assets are measured at fair value through other comprehensive income if both of the following conditions are met:

• they are held in the “held to collect and sell” business model,

• the contract provides for cash flows that are solely payments of principal and interest (the SPPI test passed).

The Bank classifies debt securities, as well as loans and advances to customers, which may be sold to PKO Bank Hipoteczny S.A (pooling), into this category.

Fair value measurement methods are described in Note “Fair value hierarchy”.

Changes in the fair value of these financial assets (until their derecognition or reclassification) are recognized in other comprehensive income, except for the following items recognized in the income statement:

• interest income,

• Net allowances for expected credit losses

• foreign exchange gains and losses.

Upon derecognition of the asset, cumulative gains or losses recognized in other comprehensive income are transferred to the financial profit or loss as a reclassification adjustment.

10.7. Financial assets measured at fair value through profit or loss

If financial assets do not meet the criteria for measurement at amortized cost or measurement at fair value through other comprehensive income, they are classified as measured at fair value through profit or loss (FVPL).

Presentation in the financial statements:

• Held for trading – assets:

• acquired principally for the purpose of selling them in the near term,

• part of a portfolio managed for short-term profit-taking,

• derivatives (except for hedging instruments).

• Not held for trading FVPL - assets that failed the SPPI test or belong to the residual model,

• Designated to FVPL at initial recognition – FVPL measurement option.

This category includes derivatives, loans and advances to customers failing to meet the SPPI test criteria (mainly cash loans, credit cards and revolving loans, whose contractual provisions contain a multiplier in the interest rate formula), and debt and equity securities.

Measurement and presentation:

Fair value measurement methods are described in Note “Fair value hierarchy”.

• Gains and losses on the sale and measurement of FVPL assets are recognized in the financial result under “Gains/(losses) on financial transactions”,

• Gains or losses on measurement constitute the difference between fair value and amortized cost,

• Similar income is recognized under “Interest income and expense”.

Details on the presentation of income and expenses relating to fair value hedges and cash flow hedges - Note “Hedge accounting and other derivative instruments”.

10.8. Equity instruments

Investments in equity instruments are measured at fair value through profit or loss.

10.9. Reclassification of financial assets

In 2025 and 2024, the Bank did not change its business model or perform a reclassification of financial assets.

10.10. Modifications - Change in contractual cash flows

If the cash flows from a financial asset are renegotiated or modified (e.g. by an annex to the agreement or pursuant to legal regulations), the Bank assesses whether the modification is substantial or non-substantial by analyzing qualitative and quantitative criteria.

qualitative criteria:

• currency conversion,

• change of debtor (other than caused by the debtor's death),

• addition or removal of a contractual feature in the agreement that breaches the SPPI test.

The occurrence of a qualitative criterion always constitutes a substantial modification.

quantitative criteria:

• 10% test - analysis of a change in contractual terms resulting in a difference between the value of future cash flows from the modified and the original asset discounted using the original effective interest rate,

• increase in a debtor's exposure by more than 10% (principal and off-balance sheet commitments granted),

• extension of the original lending period for:

• cash loans and business loans by more than 1 year and by more than a twofold increase of the residual period, i.e. the remaining repayment period as at the modification date;

• cash loans and business loans in debt collection by more than 1 year;

• housing loans by more than 4 years.

A result of the quantitative criterion exceeding 10% or exceeding the assumed extension period constitutes a substantial modification.

Non-substantial modification – the Bank does not derecognize the asset, recalculates the carrying amount and recognizes the modification gain/loss in the financial result (Net interest income). The adjustment is amortized over time in net interest income using the effective interest rate method (e.g. in respect of statutory credit holidays).

Substantial modification – the Bank derecognizes the old asset, recognizes the new one at fair value and determines a new effective interest rate and recognizes the difference in gains or losses on derecognition of financial instruments. When the characteristics of the modified new asset (following the conclusion of an annex) comply with arm's length conditions, the carrying amount of this asset as at the balance sheet date constitutes its fair value.

10.11. Measurement of purchased or originated credit-impaired financial assets (POCI)

Purchased or originated credit impaired financial assets (POCI) include debt financial assets measured at amortized cost or at fair value through other comprehensive income. In the Bank, POCI assets arise mainly as a result of a restructuring process, i.e. extension of the contract term or substantial modification of the contract terms, which results in the derecognition of the old asset and the recognition of a new, credit-impaired asset.

Measurement and recognition principles:

• They are initially recognized at a net amount (without an allowance for expected credit losses), corresponding to their fair value.

• Interest is calculated on the net amount using the credit-adjusted effective interest rate over the entire life of the asset.

• Changes in estimates of future recoveries are recognized as a gain or loss on allowances for expected credit losses.

10.12. Measurement of financial liabilities

Liabilities in respect of a short position in securities are measured at fair value through profit or loss. Remaining financial liabilities are measured at amortized cost using the effective interest rate method. If the schedule of future cash flows cannot be determined, and therefore the effective interest rate cannot be determined, the liability is measured at the amount due.

10.13. Reverse repo transactions

Reverse repo transactions are measured at amortized cost. The difference between the purchase and repurchase (sale) price constitutes interest income and is settled over the period of the agreement using the effective interest rate.

11. Environmental issues

The direct impact of the Bank on the environment is insignificant. The indirect impact arises mainly from the financing provided to customers and the products offered. The Bank limits its direct impact and adapts its credit policies for various sectors of the economy.

Detailed information on environmental actions can be found in Chapter 13 of the Directors' Report – “Sustainability Report of the PKO Bank Polski S.A. Group for 2025”. ESG risk is included in the risk management strategy (for details, see the report “Capital adequacy and other information subject to publication by the PKO Bank Polski S.A. Group”).

• Sources of uncertainty of estimates, significant judgments and the ability to continue as a going concern

The Bank is exposed to climate risk, including:

• physical risk -e.g. more frequent and severe weather events

• transition risk - e.g. transition to a low-emission economy.

Climate risk may affect the estimates and judgments applied by the Bank (e.g. in the calculation of allowances for expected credit losses).

Climate issues do not pose a threat to the Bank's ability to continue as a going concern for 12 months following the approval of the financial statements for publication.

• classification and measurement of financial instruments at fair value

Climate risk may affect the expected cash flows from loans, and thus credit losses. Factors such as physical risk, transition risk and borrower characteristics may change cash flow projections and economic scenarios used to calculate allowances. The impact depends on:

• the scale and timing of climate threats,

• the impact on borrowers and the portfolio,

• the length of the lending period.

Currently, the Bank:

• does not apply separate climate scenarios because the impact is currently limited (short loan periods, climate effects mainly in the medium and long term).

• monitors the pace of climate change and its impact on allowances.

• implements tools to assess the impact of extreme events on corporate, business and mortgage portfolios.

• pays special attention to GHG emission allowance prices, energy intensity of buildings and natural disasters.

In the lending process for corporate and business customers the Bank:

• assesses the impact of ESG (environmental, social, governance) factors on creditworthiness,

• identifies leveraged transactions,

• classifies transactions into 4 categories - from a positive to a significantly negative impact on ESG,

• takes into account, inter alia, climate risks, the customer's impact on the climate, social and governance factors (see Note “Credit risk management”).

The Bank does not apply unobservable inputs relating to climate-related risk in fair value measurements of financial instruments classified at Level 3 of the fair value hierarchy:

• Debt securities – financing industries not exposed to significant climate risk (e.g. financial companies, insurance companies, real estate developers).

• Loans – mainly households, valuation using the discounted cash flow method with current margin.

• Shares and equities – no companies from high climate risk sectors.

• non-financial assets

Climate factors do not affect the depreciation/amortization of property, plant and equipment and intangible assets, or the value of inventories (as at 31 December 2025 and 31 December 2024). There was no evidence of impairment of non-financial assets, nor was there any impact on their recoverable amount. A potentially significant impact may arise in the future in the event of a sudden transition of the economy to a low-emission one (e.g. change in the value of leased assets).

Inventories - No impact of climate factors on the carrying amount of inventories (2025 and 2024).

Taxes - No impact of climate on the realization of deferred tax assets (2025 and 2024).

Provisions and legal claims - As at 31 December 2025 and 31 December 2024, there are no proceedings concerning climate or environmental protection issues. In 2025–2024, there were no administrative proceedings related to violations of environmental protection regulations, nor any financial penalties.

12. Changes in accounting policies applicable from 1 January 2025 and explanation of the differences between previously published financial statements and these financial statements

Apart from changes resulting from new standards applicable from 1 January 2025, the Bank did not introduce any new accounting policies. The amendments had no material impact on the Bank’s financial statements.

13. New standards and interpretations, and amendments to standards

• standards and amendments to standards effective from 1 January 2025

Standard / Amendment

Description of standard/amendments

Effective from / endorsed by the EU

Effect on the financial statement.

Amendments to IAS 21

Clarification of principles for applying exchange rates in cases of lack of currency exchangeability and specification of disclosures.

01.01.2025/

12.11.2024

no effect

• New standards and amendments to standards that have been published and endorsed by the EU

Standard / Amendment	Description of standard/amendments	Effective date	Effect on the financial statement.
Amendments to IFRS 9 and IFRS 7	The amendments relate to the derecognition of financial liabilities settled through an electronic payment system, clarify the rules for assessing the contractual cash flow characteristics of assets where the modification of cash flows does not result from a change in the basic risks associated with granting a loan but, for example, from ESG factors, and expand the applicable disclosures.	01.01.2026	No material effect
“Annual Improvements to IFRSs – Volume 11”	Harmonization and clarification of the provisions of selected standards (including IFRS 1, 7, 9, 10, IAS 7) by the International Accounting Standards Board.	01.01.2026	No material effect
Amendments to IFRS 9 and IFRS 7	The amendments relate to renewable energy supply agreements by specifying the conditions that must be met in order to classify such an agreement as for "own use" and to apply hedge accounting to such agreements as hedging instruments. They introduce new disclosures in this area.	01.01.2026	not applicable
IFRS 18 “Presentation and Disclosure in Financial Statements”	The standard replaces IAS 1 and introduces, inter alia, new categories in the income statement and requirements regarding Management Performance Measures (MPMs) and aggregation principles.	01.01.2027	under analysis

• New standards and amendments to standards that have been published and have not been endorsed by the EU

Standard / Amendment	Description of standard/amendments	Effective date	Effect on the financial statement.
IFRS 19 “Subsidiaries without Public Accountability: Disclosures” and amendments to IFRS 19	The Standard introduces reduced reporting and disclosure requirements for subsidiaries without public accountability in their separate financial statements. The amendments to IFRS 19 set out the disclosure requirements in the financial statements of these entities for new or amended Standards issued between February 2021 and May 2024.	01.01.2027	not applicable
Amendments to IAS 21	The standard clarifies the principles for preparing financial statements of entities in a presentation currency being the currency of a hyperinflationary economy, where the functional currency of that entity or its foreign operations is the currency of a non-hyperinflationary economy.	01.01.2027	no effect

SUPPLEMENTARY NOTES TO THE INCOME STATEMENT

14. Interest income and expense and similar income and expense

Significant accounting policies

They comprise interest, premiums and discounts on:

• financial instruments measured at amortized cost,

• instruments measured at fair value through other comprehensive income,

• instruments measured at fair value through profit or loss and derivative hedging instruments (not measured at FV through P&L).

Interest, premiums and discounts are recognized in the income statement using the effective interest rate method – this rate exactly discounts estimated future cash flows through the expected life of the financial asset or liability to the gross carrying amount of a financial asset or to the amortized cost of a financial liability.

Interest income and expense also include fees and commissions constituting a part of the measurement of the instrument and amortized over time using the effective interest rate (e.g. remuneration of agents and intermediaries, employee bonuses for the sale of credit products).

Interest income and expense are calculated on the gross carrying amount of the instrument except for:

• POCI assets (interest on the net carrying amount using the credit-adjusted effective interest rate),

• assets that have become credit-impaired financial assets after acquisition (interest on the net carrying amount).

Interest income also includes:

• the effect of measurement of assets acquired in business combinations,

• the impact of the CJEU ruling (refund of commissions on early loan repayment),

• the effect of statutory credit holidays (Note “LOANS AND ADVANCES TO CUSTOMERS”),

• •the impact of the amendment to the Mortgage Credit Act (refund of the cost associated with waiting for the mortgage to be registered in the mortgage register).

The net interest result on hedging instruments is presented under “Net interest income”:

• positive result → “Interest income”,

• negative result → “Interest expense”.

Financial information

INTEREST AND SIMILAR INCOME FROM:	2025	2024
Loans and other amounts due from banks and the Central Bank1	1,290	1,643
Pooling	7	-
Debt securities	9,648	8,107
measured at amortized cost	5,069	3,524
measured at fair value through other comprehensive income	4,546	4,552
measured at fair value through profit or loss	6	6
held for trading	27	25
Loans and advances to customers2	20,135	20,238
measured at amortized cost	19,254	19,049
measured at fair value through other comprehensive income	599	815
measured at fair value through profit or loss	282	374
Repo transactions	62	21
Total	31,142	30,009
of which: interest income from impaired financial instruments	665	739
of which: non-substantial modification result	(58)	(216)

Interest income calculated using the effective interest rate method on financial instruments measured:	30,827	29,604
at amortized cost	25,682	24,237
at fair value through other comprehensive income	5,145	5,367
Income similar to interest income on instruments measured at fair value through profit or loss	315	405
Total	31,142	30,009

1 Under this item, in 2025, the Bank recognised income on funds in the current account with the NBP of PLN 724 million (PLN 755 million in 2024).

2This item includes the effect of statutory credit holidays recognized in 2024 in the amount of PLN 166 million (Note “Loans and advances to customers”).

INTEREST EXPENSE ON:	2025	2024
Derivative hedging instruments1	(1,378)	(1,780)
amounts due to banks	(91)	(72)
Leases	(46)	(37)
amounts due to customers	(5,650)	(6,373)
repo transactions	(11)	(13)
Issues of securities	(570)	(421)
Subordinated liabilities	(334)	(228)
Total	(8,080)	(8,924)

1 The decrease in interest expense related to derivative hedging instruments by PLN 402 million in 2025 concerns mainly IRS transactions.

15. Fee and commission income and expenses

Significant accounting policies

Fee and commission income:

• directly related to the origination of financial assets (with a repayment schedule) - are recognized in the income statement as part of interest income,

• other - are recognized in accordance with the five stage model for recognizing revenue so that they reflect the transfer of goods or services to the customer.

Types of fee and commission income:

• one-off fees for activities not related to the origination of assets,

• fees amortized on a straight-line basis for the provision of services,

• fees on loans and advances without a set schedule (amortized on a straight-line basis).

Upon entering into a contract, the Bank determines whether the performance obligation will be satisfied over time or at a point in time.

The item “Fee and commission income” also includes exchange rate margin on foreign exchange transactions. The exchange rate margin in customer transactions is calculated as the difference between the exchange rate at which the foreign exchange transaction was executed (buy/sell rate from the bank's exchange rate table, negotiated rate, rate from the NBP's C table) and the averaged buy and sell rate for the current day from the Bank's exchange rate table, except for bureau de change transactions and spot foreign exchange transactions, for which the exchange rate margin is calculated as the difference between the exchange rate of closing the currency position and the transaction rate determined at the conclusion of the transaction.

Financial information

FEE AND COMMISSION INCOME FROM:	2025	2024
Loans and insurance	1,117	1,056
lending	836	823
offering insurance products	281	233
Investment funds, pension funds and brokerage activities	456	505
servicing investment funds and OFE (including management fees)	14	12
brokerage activities	437	488
servicing and sale of investment and insurance products	5	5
Cards	2,289	2,205
Margins on foreign exchange transactions	889	813
Bank accounts and other	1,395	1,369
servicing bank accounts	1,008	984
cash operations	101	103
servicing foreign mass transactions	152	151
customer orders	51	53
fiduciary services	14	12
other	69	66
Total, of which:	6,146	5,948
in respect of income from financial instruments not measured at fair value through profit or loss	5,726	5,584

FEE AND COMMISSION EXPENSE FROM:	2025	2024
Loans and insurance	(120)	(109)
cost of construction project supervision and property appraisal	(54)	(47)
fees to Biuro Informacji Kredytowej	(29)	(27)
commissions paid to external entities for the sale of products	(32)	(25)
loan handling	(5)	(10)
Investment funds, pension funds and brokerage activities	(39)	(31)
Cards	(1,315)	(1,184)
Bank accounts and other	(283)	(271)
on account of guarantees received	(97)	(95)
clearing services	(64)	(75)
sending short text messages (SMS)	(58)	(55)
sale of bank products	(1)	(1)
servicing foreign mass transactions	(33)	(25)
commissions for operational services of banks	(20)	(16)
other	(10)	(4)
Total	(1,757)	(1,595)

Fiduciary activities – The Bank is a participant of the National Depository for Securities (KDPW) and the Securities Register of the NBP. The Bank maintains securities accounts, handles transactions on the domestic and foreign markets, provides fiduciary services and acts as a depository for pension and investment funds. Assets held under these services do not meet the definition of the Bank's assets, therefore they are not recognized in the financial statements. Income from these services is recognized in the item “fiduciary services” under fee and commission income.

16. Fee and commission income by segment

Significant accounting policies: “Interest income and expense”, “Fee and commission income and expense”

Financial information

INTEREST INCOME BY SEGMENT ON:	2025
INTEREST INCOME BY SEGMENT ON:	Retail segment	Corporate and investment segment	Transfer center and other	Total
Loans and other amounts due from banks and the Central Bank	-	566	724	1,290
Pooling	-	7	-	7
Debt securities	-	4,262	5,386	9,648
loans and advances to customers	14,196	5,939	-	20,135
repo transactions	-	62	-	62
Total	14,196	10,836	6,110	31,142

INTEREST INCOME BY SEGMENT ON:	2024
INTEREST INCOME BY SEGMENT ON:	Retail segment	Corporate and investment segment	Transfer center and other	Total
Loans and other amounts due from banks and the Central Bank	-	888	755	1,643
Debt securities	-	4,371	3,736	8,107
loans and advances to customers	14,039	6,199	-	20,238
repo transactions	-	21	-	21
Total	14,039	11,479	4,491	30,009

FEE AND COMMISSION INCOME BY SEGMENT ON:	2025
FEE AND COMMISSION INCOME BY SEGMENT ON:	Retail segment	Corporate and investment segment	Transfer center and other	Total
Loans and insurance	714	403	-	1,117
Investment funds, pension funds and brokerage activities	299	157	-	456
Cards	2,260	29	-	2,289
Margins on foreign exchange transactions	646	243	-	889
Bank accounts and other	982	413	-	1,395
Total	4,901	1,245	-	6,146
FEE AND COMMISSION INCOME BY SEGMENT ON:	2024
FEE AND COMMISSION INCOME BY SEGMENT ON:	Retail segment	Corporate and investment segment	Transfer center and other	Total
Loans and insurance	635	421	-	1,056
Investment funds, pension funds and brokerage activities	357	148	-	505
Cards	2,161	44	-	2,205
Margins on foreign exchange transactions	584	229	-	813
Bank accounts and other	1,003	366	-	1,369
Total	4,740	1,208	-	5,948

17. Dividend income

Significant accounting policies: Income is recognized on the date when the shareholders’ rights to its receipt is determined, if the Bank is entitled to dividend.

Financial information

DIVIDEND INCOME FROM:	2025	2024
subsidiaries	878	929
associates and joint ventures	41	65
financial assets held for trading	1	2
financial instruments not held for trading, measured at fair value through profit or loss	13	13
Total	933	1,009

18. Gains/(losses) on financial transactions

Significant accounting policies:

Gains/(losses) on financial transactions include:

• gains and losses on the sale of financial instruments measured at fair value through profit or loss,

• the effect of their fair value measurement.

Interest income and expense as well as the amortization of premiums and discounts on these instruments are recognized in net interest income (see Note “Interest income and expense”).

This item also includes:

• the ineffective portion of cash flow hedges in strategies involving IRS contracts,

• gains and losses on hedging instruments and hedged items under fair value hedges.

Financial information

GAINS/(LOSSES) ON FINANCIAL TRANSACTIONS	2025	2024
Financial instruments held for trading, of which:	149	175
Derivatives¹	119	160
Equity instruments	15	2
Debt securities	16	14
Other	(1)	(1)
Financial instruments not held for trading, measured at fair value through profit or loss, of which:	27	73
Equity instruments	51	37
Debt securities	3	65
Loans and advances to customers	(27)	(29)
Hedge accounting	3	2
Total	179	250

1 Of which due to stock options and stock exchange indices PLN 56 million (in 2024 - PLN 78 million) and IRS: PLN 53 million (in 2024: PLN 27 million).

19. Net foreign exchange gains/(losses)

Significant accounting policies:

Net foreign exchange gains/(losses) comprise:

• foreign exchange differences, both realized and unrealized, resulting from valuation of assets and liabilities denominated in foreign currencies,

• the fair value measurement of foreign currency derivatives (FX forward, FX swap, CIRS, and foreign exchange options),

• the ineffective portion of cash flow hedges in strategies involving CIRS contracts,

• remeasurement of allowances for expected credit losses in respect of foreign currency-denominated receivables (which are recorded in PLN), when the measurement of the underlying foreign currency-denominated assets changes.

20. Other operating income and expenses

Significant accounting policies:

Other operating income and expenses comprise income and expenses not directly related to the core activities of the Bank.

The Bank enters into purchase and sale transactions for commodity forward contracts for CO2 emission allowances.

• The result from the measurement at fair value and the realization of these contracts is recognized in gains/(losses) on financial transactions.

• These contracts are settled through physical delivery - the transfer of allowances in the EU Registry in exchange for payment.

Purchased CO2 emission allowances, as a tradable commodity for resale, are treated as inventory and measured at fair value. The result of the valuation between the date of acquisition and the date of sale, as well as the result of their sale, is recognized in other operating income and expenses.

Financial information

OTHER OPERATING INCOME	2025	2024
Gains on sale or scrapping of property, plant and equipment, intangible assets and assets held for sale	11	19
Damages, compensation and penalties received	14	3
Ancillary income	35	34
Reversal of provision recognized for legal claims excluding legal claims relating to repaid mortgage loans in convertible currencies (note “Provisions”)	27	11
Income from sale of CO2 emission allowances	21	13
Income from discounts granted by supplier for IT software development	10	15
Revenue from the sale of coins for collectors' purposes	13	8
Recovery of receivables expired, forgiven or written off	5	3
Reversal of provision for potential refunds of fees and commission to customers	1	-
Reversal of provision for future payments	2	2
Other	31	74
Total	170	182

OTHER OPERATING EXPENSES	2025	2024
Recognition of provision for consumer protection issues1	(408)	-
Losses on sale or scrapping of property, plant and equipment, intangible assets and assets held for sale	(4)	(2)
Donations made	(1)	(43)
Sundry expenses	(18)	(18)
Recognition of provision for potential refunds of fees and commission to customers	(16)	-
Recognition of provision for future payments	(3)	(4)
Recognition of provision for legal claims excluding legal claims relating to repaid mortgage loans in convertible currencies	(111)	(22)
Costs from sale of CO2 emission allowances	(11)	(22)
Costs of external services for the recovery	(25)	(24)
Other	(64)	(44)
Total	(661)	(179)

1 See Note Legal claims

21. Net allowances for expected credit losses

Significant accounting policies:

Allowances for expected credit losses are recognized in the following manner:

• Financial assets measured at amortized cost – the allowance reduces the gross carrying amount of the financial asset (adjusted, among others, for adjustments for legal risk of mortgage loans in convertible currencies, statutory credit holidays and for potential reimbursements to customers for the expected early repayment of consumer and mortgage loans); changes in the allowances amount are recognized in the income statement;

• Off-balance sheet liabilities of a financial nature and financial guarantees – the allowance is presented as a provision under liabilities; changes in the provisions amount are recognized in the income statement;

• Debt financial instruments measured at fair value through other comprehensive income - no allowance is recognized in the statement of financial position as the carrying amount of the asset corresponds to its fair value. However, the allowance is recognized and disclosed in the income statement.

Estimates and judgments:

The Bank reviews its loan portfolio for impairment at least quarterly. The methodology and assumptions used to estimate cash flows and their timing are reviewed on a regular basis.

• measurement and assessment of credit risk: expected credit losses

The Bank applies the expected loss model to measure the impairment of financial assets not measured at fair value through profit or loss, comprising:

• debt instruments (loans, securities),

• other financial assets;

• off-balance sheet liabilities (financial and guarantee).

Impairment is estimated as 12-month or lifetime expected credit losses, depending on the increase in credit risk since initial recognition. Assets are allocated to three stages:

• Stage 1 – exposures in which the credit risk is not significantly higher than upon initial recognition and no evidence of impairment is found;

• Stage 2 – exposures in which the credit risk is significantly higher than upon initial recognition, but no evidence of impairment is found;

• Stage 3 – assets in respect of which evidence of impairment is recognized.

• Significant increase in credit risk

The Bank determines the probability of default and its changes as regards the level at initial recognition of the loan.

• Mortgage exposures and other retail exposures – quantitative criteria

The Bank uses a model based on a marginal PD calculation, i.e. the probability of default in a given month, to assess a significant increase in credit risk for mortgage exposures and other retail exposures. This probability depends on the time that has passed from originating the exposure. This enables reflecting the differences in credit quality that are typical of exposures to natural persons over the lifetime of the exposure. The marginal PD curves were determined on the basis of historic data at the level of homogeneous portfolios, which are separated according to the type of product, the year of their origination, the loan currency and the credit quality at the time of origination. The marginal PD is attributed to individual exposures by scaling the curve at the level of the portfolio to the individual assessment of the exposure / customer using application models (using data from loan applications) and behavioural models. The Bank identifies the premise of a significant increase in credit risk for a given exposure by comparing individual PD curves over the exposure horizon as at the date of initial recognition and as at the reporting date. Only the parts of the original and current PD curves which correspond to the period from the reporting date to the date of maturity of the exposure are compared as at each reporting date. The comparison is based on the average probability of default over the life of the loan in the period under review adjusted for current and forecast macroeconomic indicators.

According to data as at the end of 2025, an increase in the PD parameter of an at least 2.2-fold increase in the PD parameter compared to the value at the time of its recognition in the Bank's accounting records in respect of mortgage exposures and an at least 2.5-fold increase in respect of other retail exposures constitutes a premise of a significant deterioration in credit quality.

As regards credit exposures for which the current risk of default does not exceed the level provided for in the price of the loan, the results of the comparison of the probability of default curves as at the date of initial recognition and as at the reporting date do not signify a significant increase in credit risk.

In order to identify the remaining premises of a significant increase in credit risk, the Bank uses all available qualitative and quantitative information listed in the section below “Exposures to institutional customers”.

• Exposures to institutional customers – quantitative criteria

The Bank assesses a significant increase in credit risk for institutional customers based on the model based on the Markov chains. Historical data is used to build matrices of probabilities of customers migrating between individual risk categories determined on the basis of the rating and scoring models. Migrations are analyzed within homogeneous portfolios, taking into account, inter alia, the assessment methodology and customer segment.

On the date of initial recognition of the exposure, the highest acceptable probability of default (PD) value is set for each risk category and portfolio, which, if exceeded, indicates a significant increase in risk. This value is the average PD for risk categories worse than the initial one, weighted by the probability of transition to those categories in the given time horizon.

As at the end of 2025, the minimum deterioration in the risk category constituting a premise of a significant increase in credit risk was:

Risk category	PD range	Minimum range of the risk category deterioration indicating a significant increase in credit risk1
A-B	0.0 – 0.90%	3 categories
C	0.90 – 1.78%	2 categories
D	1.78 – 3.55%	2 categories
E	3.55-7.07%	2 categories
F	7.07-14.07%	1 category
G	14.07-99.99%	not applicable2

1 average values (the ranges are determined separately for homogeneous groups of customers)

2 deterioration of the risk category is a direct indication of impairment

The values are averaged and determined separately for homogeneous groups of customers.

• Qualitative criteria

Additional premises of a significant increase in credit risk include, inter alia:

• restructuring measures introducing forbearance for a debtor in financial difficulties, in the period in which this credit exposure is classified in the forbearance reporting category, unless it meets an impairment indicator,

• delays in repayment exceeding 30 days of a material amount (exceeding PLN 400 for retail exposures, PLN 2,000 for other exposures and >1% of the total exposure),

• early warning signals (e.g. changes in collateral, modifications of the terms of agreement, reduction of the exposure),

• significant increase in the LTV ratio,

• “quarantine” in Stage 2 after the impairment indicator has ceased to exist,

• filing for consumer bankruptcy by a joint borrower,

• transfer to restructuring and debt collection units,

• use of statutory support in mortgage loan repayment.

• Impaired loans and definition of default

The premises for the impairment of a credit exposure are in particular:

• delays in repayment of a material amount of principal, interest or fees exceeding 90 days (exceeding PLN 400 for retail exposures, PLN 2,000 for other exposures or >1% of the total exposure to the Bank),

• a deterioration in the debtor’s financial position or a risk to the completion of the investment project, resulting in classification into a risk category suggesting a material risk of repayment (rating H),

• the conclusion of a restructuring agreement or the application of relief in repayment forced by financial difficulties (until the claim is recognized as remedied),

• filing a motion for bankruptcy, liquidation or the opening of enforcement proceedings against the debtor,

• declaration of consumer bankruptcy by a joint borrower,

• information on the death of all borrowers who are natural persons or entrepreneurs running a business in the form of a sole proprietorship or a civil partnership (except for continuation by a succession manager),

• other events indicating the inability to repay the liability in full.

In accordance with Regulation (EU) No 575/2013 of the European Parliament and of the Council on prudential requirements for credit institutions and investment firms (“CRR”), the Bank defines a state of default if it assesses that the debtor is unable to repay the liability without resorting to exercising the collateral or if the exposure is materially overdue for more than 90 days. The premises of default are identical to the premises for impairment.

The process of assessing a significant increase in credit risk and calculating expected losses is conducted monthly at the level of individual exposures in a dedicated computing environment that allow for the allocation of results to the Bank's units.

The Bank has separated a portfolio of financial assets with low credit risk, comprising instruments for which the average long-term default rate does not exceed the PD specified by the rating agency for the worst investment grade. This portfolio includes, inter alia, exposures to banks, governments, local government units and housing cooperatives and communities.

• Calculation of the expected credit loss

The model for the calculation of the expected credit loss is based on detailed segmentation of the credit portfolio according to product and customer characteristics, such as:

• type of credit product;

• currency of the product;

• year of granting;

• assessment of risk of the customer’s default;

• the customer’s business segment;

• method of assessing the customer risk.

The Bank uses two methods of calculating the expected credit loss:

• an individual basis – for individual exposures,

• a portfolio method – for homogeneous portfolios.

The individual basis is used for exposures for which an impairment indicator has been identified and which are individually significant (i.e. the total balance sheet exposure in respect of principal and off-balance sheet liabilities of a financial or guarantee nature is equal to or higher than PLN 5 million). The expected credit loss is determined as the difference between:

• the gross carrying amount of the exposure (or the balance sheet equivalent for an off-balance sheet exposure), and

• the present value of expected future cash flows, taking into account possible scenarios of the performance of the contract and the management of the exposure, weighted by the probability of their occurrence.

The portfolio method is applied to exposures that do not meet the criteria for applying the individual basis.

The expected credit loss is determined as the product of risk parameters:

• PD – probability of default,

• LGD – loss given default,

• EAD – exposure at default.

Each parameter takes the form of a vector covering the estimation horizon (the number of months). For retail exposures without a repayment schedule, the horizon is determined based on behavioral data from historical observations. The expected loss (both over the entire period and over the 12-month horizon) is the sum of discounted losses from individual periods, using the effective interest rate. The EAD value is adjusted by future repayments, overpayments and underpayments.

In the calculation, projections of macroeconomic conditions are taken into account through the impact of scenarios on risk parameters. The methodology is based on the analysis of the dependence of parameters on macroeconomic indicators based on historical data. The Group applies three scenarios:

• baseline (75% probability),

• and two alternative scenarios: optimistic and pessimistic (probability of 5% and 20%).

Projections include, inter alia: GDP growth rate, unemployment rate, WIBOR 3M rate, CHF/PLN exchange rate, property price index, NBP reference rate.

The final expected loss is the weighted average of losses from individual scenarios. The scenarios used in the calculation are consistent with those used in credit risk budgeting processes.

The baseline scenario is based on macroeconomic projections prepared on the basis of quantitative models, with adjustments taking into account one-off events.

Alternative/extreme scenarios (optimistic and pessimistic) concern an internal shock – external variables (e.g. foreign interest rates) remain unchanged as regards the baseline scenario. They are developed on the basis of statistical and econometric analyses, projecting paths of indicators, rather than specific events.

The probability of the baseline scenario is determined on the basis of the share of the GDP path between the optimistic and the pessimistic scenario. GDP growth is projected taking into account the potential growth rate of the economy that varies over time, calculated on the basis of quarterly data from the Central Statistical Office. After extreme GDP paths are determined, the values of the remaining macroeconomic variables are estimated (unemployment rate, property price index).

The unemployment rate is determined on the basis of the dependence on the difference between GDP growth and the potential growth rate, with adjustments taking into account structural changes in the economy, inter alia:

• ageing of the population (limiting the increase in unemployment in a downturn),

• proximity to full employment (limited space for a further decline),

• influx of migrants (partially included in statistics).

The property price index is projected based on GDP changes and supply-demand conditions, using NBP data and the Bank's analyses.

Deposit rates are based on assumptions regarding central bank interest rates.

The CHF/PLN exchange rate is determined as a cross rate of EUR/PLN and EUR/CHF, and its projections are based on macroeconomic analysis (current and historical), econometric methods, and technical analysis of financial markets.

The macroeconomic model takes into account current domestic and global events, including the macroeconomic situation and the tense geopolitical situation associated with Russia's invasion of Ukraine, affecting fuel prices and the condition of enterprises. Additional factors include:

• the impact of interest rates and inflation on the quality of the credit portfolio on the situation of companies based on historical dependencies,

• exchange rate volatility in the context of foreign currency housing loans.

Due to the influx of refugees following Russia's invasion of Ukraine and uncertainty as to its impact on the labor market, the model did not include a decrease in unemployment as a factor improving portfolio quality.

The macroeconomic approach describes the situation in the entire economy, therefore the Bank conducted additional analyses of the credit portfolio to identify industries particularly affected by the current situation. Analyses by risk experts showed the highest risk in the following industries: construction, automotive, transport, renting of office and retail space, energy-intensive industries and photovoltaic farms. Exposures with the highest PD (rating D or worse) in these industries were marked with the premise of a "significant increase in credit risk" and subjected to higher allowances. In 2025, as a result of the above actions, the Bank increased the allowances for expected credit losses by PLN 157 million (which accounts for approx. 12% of the value of allowances on the entire portfolio of business loans classified in Stage 2).

The table presents the adopted projections of key macroeconomic indicators together with the probabilities of realization.

scenario as at 31.12.2025	baseline			optimistic			pessimistic
probability	75%			5%			20%
	2026	2027	2028	2026	2027	2028	2026	2027	2028
GDP growth y/y	3.5	3.1	3.0	8.5	7.9	4.5	(1.5)	(0.6)	3.0
Unemployment rate	3.1	3.0	2.9	2.8	2.8	2.8	4.3	5.0	2.8
Property price index	101.7	104.3	107.2	105.5	115.7	120.4	93.0	89.1	90.3
WIBOR 3M (%)	3.6	3.6	3.3	4.9	5.3	4.5	2.5	1.8	2.7

scenario as at 31.12.2024	baseline			optimistic			pessimistic
probability	75%			5%			20%
	2025	2026	2027	2025	2026	2027	2025	2026	2027
GDP growth y/y	3.4	3.3	3.1	8.8	8.3	4.7	(1.9)	(1.8)	1.6
Unemployment rate	2.8	2.8	2.8	2.6	2.7	2.8	4.6	5.2	2.8
Property price index	100.2	102.6	105.7	107.3	118.5	124.0	93.5	88.5	89.8
WIBOR 3M (%)	5.5	4.3	3.8	6.5	5.9	4.9	4.4	2.7	2.7

The table below presents the estimated sensitivity of allowances for expected credit losses to changes in macroeconomic conditions. The values show how much the level of allowances for unimpaired exposures would change if the individual macroeconomic scenarios materialized. Improving macroeconomic conditions systematically reduce the sensitivity of allowances.

ESTIMATED CHANGE IN THE LEVEL OF ALLOWANCES FOR EXPECTED CREDIT LOSSES FOR NOT IMPAIRED EXPOSURES DUE TO THE MATERIALIZATION OF PARTICULAR MACROECONOMIC SCENARIOS	31.12.2025		31.12.2024
	optimistic	pessimistic	optimistic	pessimistic
in PLN million	(572)	387	(960)	558

The table below presents the estimated sensitivity of allowances for expected credit losses in the event of scenarios assuming the deterioration or improvement of risk parameters.

ESTIMATED CHANGE IN THE LEVEL OF IMPAIRMENT ALLOWANCE RESULTING FROM MATERIALIZATION OF A SCENARIO OF THE RISK PARAMETERS, THE DETERIORATION OR IMPROVEMENT, OF WHICH:1	scenario +10%	scenario (10%)	scenario +10%	scenario (10%)
	31.12.2025		31.12.2024
Risk parameter: changes in the present value of estimated cash flows for the Bank’s portfolio of individually impaired loans and advances assessed on an individual basis
Loans and advances to customers (Stage 3)	(180)	250	(223)	260
Changes in the probability of default (PD)
Securities	7	(7)	11	(11)
Stage 1	6	(6)	9	(9)
Stage 2	1	(1)	2	(2)
Loans and advances to customers	254	(255)	253	(283)
Stage 1	159	(119)	128	(128)
Stage 2	94	(136)	125	(155)
Changes in recovery rates
Securities	(7)	7	(12)	12
Stage 1	(6)	6	(10)	10
Stage 2	(1)	1	(2)	2
Loans and advances to customers	(680)	683	(617)	618
Stage 1	(213)	213	(200)	200
Stage 2	(264)	263	(240)	241
Stage 3	(204)	206	(177)	177

1 “()” decrease in write-downs, “+” increase in write-downs

Financial information

NET ALLOWANCES FOR EXPECTED CREDIT LOSSES	2025	2024
Amounts due from banks	8	4
Debt securities	30	(21)
- measured at fair value through other comprehensive income	11	1
- measured at amortized cost	19	(22)
Loans and advances to customers	(816)	(917)
- measured at fair value through other comprehensive income (housing loans)	13	(1)
- measured at amortized cost	(829)	(916)
real estate loans	109	33
business loans	(350)	(415)
consumer loans	(588)	(534)
Other financial assets	(2)	3
Provisions for financial liabilities and guarantees granted	(1)	126
Total	(781)	(805)

22. Impairment of non-financial assets

Estimates and judgments:

At the end of each reporting period the Bank assesses whether there are any indications of impairment of any non-financial assets, including non-current assets, right-of-use assets and cash-generating units.

The Bank determines the recoverable amount in the case of:

• intangible assets not subject to amortization, assets not yet brought into use, and goodwill – annually,

• other non-financial assets - if such indications occur.

The recoverable amount is the higher of the following two amounts:

• fair value less costs to sell,

• value in use of the asset or cash-generating unit.

If the amount recognized in the statement of financial position exceeds the recoverable amount, the Bank recognizes an impairment loss in the income statement.

Estimating the recoverable amount requires making assumptions regarding, among others, projected future cash flows from further use or sale of assets.

Financial information

NET IMPAIRMENT OF NON-FINANCIAL ASSETS	2025	2024
Property, plant and equipment	(27)	(18)
Assets held for sale	(1)	(1)
Intangible assets	(119)	-
Other non-financial assets1	(362)	(410)
Total	(509)	(429)

1 In 2025, the Bank recognized an impairment loss on other non-financial assets of PLN 284 million relating to receivables from customers for whom the loan agreements have been legally declared invalid in respect of the principal originally disbursed to these customers (in 2024: PLN 326 million). This item also includes, among other things, allowances for customer-related costs of PLN 35 million (in 2024 - PLN 33 million) and allowances for shortages and damages and other receivables of PLN 17 million (in 2024 - PLN 17 million).

CHANGE IN ACCUMULATED IMPAIRMENT LOSSES ON NON-FINANCIAL ASSETS 2025	Opening balance	Impairment of non-financial assets	Other	Closing balance
Property, plant and equipment	(140)	(27)	13	(154)
Assets held for sale	(1)	(1)	2	-
Intangible assets	(133)	(119)	-	(252)
Investments in subsidiaries	(882)	-	-	(882)
Investments in associates and joint ventures	(186)	-	-	(186)
Other non-financial assets	(629)	(362)	(63)	(1,054)
Total	(1,971)	(509)	(48)	(2,528)

2024
Property, plant and equipment	(128)	(18)	6	(140)
Assets held for sale	-	(1)	-	(1)
Intangible assets	(133)	-	-	(133)
Investments in subsidiaries	(882)	-	-	(882)
Investments in associates and joint ventures	(186)	-	-	(186)
Other non-financial assets	(278)	(410)	59	(629)
Total	(1,607)	(429)	65	(1,971)

23. Cost of the legal risk of mortgage loans in convertible currencies

Significant accounting policies and estimates and judgments:

The Bank, in connection with the current legal disputes regarding foreign currency loans, identifies a risk that the planned cash flows from the portfolio of mortgage loans denominated in or indexed to foreign currencies may not be fully recovered or a liability resulting in an outflow of funds may arise. As a result, the Bank revises cash flow estimates and reduces the gross carrying amount of these loans in accordance with IFRS 9 (paragraph B5.4.6) and recognizes provisions for legal risk in accordance with IAS 37.

The cost of legal risk was determined on the basis of a number of assumptions which have a significant effect on the amount recognized in the financial statements. The Bank recognizes the effect of legal risk as a decrease in the gross carrying amount of mortgage loans in foreign currencies for legal claims and settlements relating to active loans as at the balance sheet date. If the estimated loss exceeds the gross value of the loan, as well as for repaid loans, statutory interest and legal costs, the Bank recognizes provisions (“Provisions for legal claims against the bank relating to mortgage loans in convertible currencies”) in accordance with IAS 37, reflecting the most appropriate estimate of the outflow of funds as at the balance sheet date.

The costs of legal risk were estimated using a statistical method as the sum of the products of:

• the probability of invalidation and the amount of loss if the Bank loses, taking into account the current and expected number of court cases over the lifetime horizon, and

• the probability of reaching a settlement and the amount of loss from the settlement.

The loss model takes into account the case law of the CJEU and national courts (Note “LEGAL CLAIMS”). The Bank estimates the probabilities of adverse outcomes for the actual and potential claims, and takes into account, inter alia, the duration of legal proceedings and high litigation costs. It also takes into account the impact of the tax preferences of customers arising from the Regulation of the Minister of Finance of 11 March 2022 (as amended).

Given the uncertainty as to the assumptions made, the methodology of estimating losses is subject to periodic review. The uncertainty relates to the number of future lawsuits, court decisions, the number of settlements and changes in judicial decisions, interest rates and the PLN/CHF and PLN/EUR exchange rates. The judgment of the CJEU of 15 June 2023 (Case C-520/21) indicated that a bank cannot demand compensation from a consumer that goes beyond the reimbursement of the principal and statutory interest. At the same time, the provisions do not preclude consumers' claims against banks, provided that the objectives of Directive 93/13 and the principle of proportionality are respected. In the Bank's opinion, on the grounds of national legislation, customers do not have additional claims, because they did not provide financial services to the Bank, and the loan funds were used to meet their housing needs.

The Bank monitors the model’s adequacy on a quarterly basis, comparing actual data with calculations and updating assumptions based on new data. The model is adapted to the current settlement offer.

As at 31 December 2025, the Bank updated the probabilities of signing a settlement and filing a lawsuit. The Bank monitors the inflow of lawsuits relating to repaid loans, modeling the expected loss and offering a settlement in each case. The expected levels of conversion from a lawsuit to a settlement are included in the loss calculation and adjusted to the current situation.

The Bank has analyzed the model’s sensitivity to changes in key parameters:

ANALYSIS OF THE MODEL'S SENSITIVITY TO CHANGES IN KEY PARAMETERS	Increase/decrease of the cost of legal risk
	31.12.2025	31.12.2024
1 p.p. increase in the probability of the Bank winning in court (at the cost of a 1 p.p. decrease in the probability of invalidation)	(95)	(105)
1 p.p. decrease in the number of settlements	16	9
1 p.p. increase in the number of lawsuits for the active portfolio (at the cost of inactive customers)	48	41
1 p.p. increase in the lawsuit to settlement conversion ratio	(38)	(31)
1 p.p. increase in the number of lawsuits for the repaid portfolio	72	54
extension of the period for accrual of statutory interest by 90 days	206	199

financial information:

IMPACT OF LEGAL RISK OF MORTGAGE LOANS IN CONVERTIBLE CURRENCIES	Gross carrying amount of loans before the cost of legal risk	Accumulated cost of legal risk	Gross carrying amount of loans including the cost of legal risk
31.12.2025
Loans and advances to customers / adjustment reducing the carrying amount of loans, of which:	7,281	5,742	1,539
- related to the portfolio of mortgage loans in CHF	5,967	4,941	1,026
- related to the portfolio of mortgage loans in EUR	1,295	801	494
Provisions		6,258
- for settlements and judgments of loans in CHF		5,627
- for settlements and judgments of loans in EUR		631
Total		12,000
31.12.2024
Loans and advances to customers / adjustment reducing the carrying amount of loans, of which:	11,455	7,666	3,788
- related to the portfolio of mortgage loans in CHF	9,862	7,666	2,196
- related to the portfolio of mortgage loans in EUR	1,567	-	1,567
Provisions		5,733
- for settlements and judgments of loans in CHF		5,521
- for settlements and judgments of loans in EUR		212
Total		13,399

CHANGE IN THE ACCUMULATED COST OF LEGAL RISK OF MORTGAGE LOANS IN CONVERTIBLE CURRENCIES DURING THE PERIOD	2025	2024
Carrying amount at the beginning of the period	(13,399)	(11,307)
cost of legal risk of mortgage loans in convertible currencies (income statement)1	(4,365)	(4,899)
offset of settlements and judgments for the period against accumulated losses2	6,127	3,096
revaluation of loss for the period and other changes3	(363)	(289)
Carrying amount at the end of the period	(12,000)	(13,399)

1 The amount of these costs is mainly due to updates of the legal risk assessment model parameters, which relate to the forecast of the number of court cases, an increase in the expected costs of the settlement program, and an update of the estimated costs related to statutory interest accrued during the dispute with the customer.

2 The item includes the effects of final judgments invalidating loan agreements, which for 2025 amount to PLN 3,363 million (in 2024: PLN 1,125 million), and concluded settlements, which for 2025 amount to PLN 2,764 million (in 2024: PLN 1,971 million).

3 Revaluation of the loss in respect of the legal risk is associated with the effect of changes in foreign exchange rates on the part of the loss which is recognized in the convertible currency as adjustment to the gross carrying amount of loans.

Information on the number of mediation applications and the number of concluded settlements – Note 8.1.1 of the Directors' Report.

24. Administrative expenses

Significant accounting policies:

Employee benefits

Employee benefits include costs of wages and salaries and social security, including provisions for retirement and disability benefits (described in Note “Provisions”). They also include costs of the employee pension plan (defined contribution plan) and the variable remuneration components program for persons in managerial positions. A portion of this program is recognized as a liability in respect of share-based payments settled in cash, in accordance with IFRS 2 (described in detail in Note “Benefits for the PKO Bank Polski S.A. key management.”).

The Bank also recognizes provisions for future liabilities in respect of compensation and severance payments for employees with whom the employment agreement has been terminated for reasons not related to the employees. Furthermore, it recognizes accruals relating to costs of the current period that will be incurred in the future, including bonuses and accrued holiday entitlements, taking into account all outstanding holiday days.

Overheads - include expenses related to the maintenance of fixed assets, IT and telecommunications services, administrative activities, promotion and advertising, property protection, training, as well as court and stamp duties, and costs of mediation at the PFSA.

Lease payments under short-term and low-value leases are recognized in the income statement on a straight-line basis over the lease term.

Depreciation and amortization

Depreciation of property, plant and equipment, intangible assets and investment properties begins on the first day of the month following the month in which the asset is placed in service, except for right-of-use assets, for which depreciation begins in the month of their initial recognition. Amortization and depreciation ends no later than at the time of:

• equalizing the amortization and depreciation charges with the initial value,

• the end of the lease term,

• scrapping, sale or finding it to be missing,

• determining that the expected residual value exceeds the net carrying amount, taking into account the residual value (the net amount that can be obtained at the end of the useful life, less costs to sell).

For non-financial non-current assets, the residual value is assumed to be zero, unless there is a third-party obligation to buy them back or an active market that allows determining their value at the end of the useful life. Land is not depreciable.

costs of regulatory charges – include fees resulting from regulations governing the Bank's activities, which, in accordance with IFRIC 21, are recognized in the income statement at the time of the obligating event. These fees are paid to institutions such as the PFSA, the Bank Guarantee Fund (BGF) or the Borrowers' Support Fund (BSF). This item also includes other taxes other than income tax and the tax on certain financial institutions (presented in a separate item). The cost structure includes:

• Contributions and payments to the BGF – quarterly contributions to the banks' guarantee fund and annual contributions to the mandatory bank restructuring fund (which are not tax-deductible).

• Fees to the PFSA – annual fees to cover the costs of banking supervision and capital market supervision (which are tax-deductible).

• Other taxes and fees – including flat-rate income tax, property tax, payments to the State Fund for Rehabilitation of Disabled Persons, motor vehicle tax, excise duty, contribution to finance the activities of the Financial Ombudsman, municipal and administrative fees.

Estimates and judgments:

In estimating the useful life, the Bank considers the following factors:

• expected physical wear and tear determined on the basis of the average periods of use recorded to date, the rate of wear and tear and intensity of use, etc.,

• technical or market obsolescence;

• legal and other limitations of the asset’s use;

• expected usage of the asset;

• climate factors which may shorten the useful life (e.g. ageing, legal limitations or unavailability of assets).

If the period of use of an asset results from a contract, the contractual period is assumed, unless the estimated useful life is shorter, in which case the shorter period is applied. At least once a year, the Bank verifies the adopted depreciation and amortization method and useful lives and revises them if necessary.

Depreciation /amortization periods applied by the Bank:

Fixed assets	Useful lives
Buildings, premises, cooperative rights to premises (including investment real estate)	from 25 to 60 years
Leasehold improvements (buildings, premises)	from 1 to 11 years (or the lease term, if shorter)
Machines, technical devices, tools and instruments	from 2 to 15 years
Computer units	from 2 to 10 years
Vehicles	from 3 to 5 years
Intangible assets	Useful lives
Software	from 1 to 25 years
Other intangible assets	from 2 to 20 years

The impact of changes in the useful lives of depreciated assets classified as land and buildings is presented in the table below:

CHANGE IN THE USEFUL LIVES OF DEPRECIATED ASSETS CLASSIFIED AS LAND AND BUILDINGS

2025

2024

+10 years scenario

scenario

-10 years

+10 years scenario

-10 years scenario

Depreciation costs

(47)

213

(26)

145

Financial information

ADMINISTRATIVE EXPENSES	2025	2024
Employee benefits	(4,676)	(4,162)
Wages and salaries, including:	(3,849)	(3,432)
costs of contributions to the employee pension plan	(105)	(94)
Social security, of which:	(671)	(586)
contributions for disability and retirement benefits	(545)	(492)
Other employee benefits	(156)	(144)
Overheads, of which:	(1,923)	(1,899)
Rent	(129)	(119)
IT	(490)	(395)
Depreciation and amortization	(1,123)	(1,077)
property, plant and equipment, of which:	(499)	(495)
IT	(104)	(110)
right-of-use assets	(254)	(259)
intangible assets, of which:	(624)	(582)
IT	(622)	(579)
Costs of regulatory charges	(659)	(375)
Contributions and payments to the Bank Guarantee Fund, of which:	(522)	(258)
to the Resolution Fund	(308)	(258)
to the Bank Guarantee Fund	(214)	-
Fees to PFSA	(70)	(56)
Other taxes and fees	(67)	(61)
Total	(8,381)	(7,513)

25. Tax on certain financial institutions

The tax on certain financial institutions is 0.0366% per month. The tax base for banks is the surplus of total assets exceeding PLN 4 billion. This base may be reduced in accordance with the provisions of the Act of 15 January 2016 on the tax on certain financial institutions. The tax paid is not tax-deductible for corporate income tax purposes.

26. Income tax expense

Significant accounting policies:

Corporate income tax is recognized as current tax and deferred tax.

• Current tax is recognized in the income statement.

• Deferred tax, depending on the source of temporary differences, is recognized in the income statement or in other comprehensive income.

• Current tax

Current tax is calculated on the basis of gross profit adjusted for:

• non-taxable income and non-deductible costs,

• taxable income that is not accounting income,

• tax-deductible costs that are not accounting costs, in accordance with the applicable tax laws.

The main categories of non-deductible costs:

• the cost of legal risk of mortgage loans in convertible currencies except for the elements listed below,

• Tax on certain financial institutions

• contributions and payments to the BGF and

• tax on controlled foreign corporations CIT-CFC (according to Article 24a of the Corporate Income Tax Act, taxpayers with foreign subsidiaries are required to pay tax on the income of a controlled foreign corporation (CFC). The tax is due only on the income of foreign entities that have met the conditions for recognition as controlled foreign corporations in a given tax year. The tax rate is 19% of the tax base).

Pursuant to the Regulation of the Minister of Finance of 11 March 2022 on suspending the collection of income tax on certain types of income (revenue) related to a mortgage loan granted for residential purposes (as amended, hereinafter the "Regulation"), the Bank benefits from the suspension of the collection of income tax on the cancelled principal of the loan under settlements concluded under the terms specified in this Regulation. As regards mortgage loans invalidated by court judgments, the Bank settles them in accordance with the individual interpretation received and the judgment of the Voivodeship Administrative Court in Warsaw.

The correctness of income tax settlements may be audited within 5 years of the end of the year in which the deadline for submitting the tax return passed.

• Deferred income tax

Deferred tax is recognized as the product of the difference between the tax base of assets and liabilities and their carrying amount, and the tax rate.

Offsetting of assets and liabilities is possible only if:

• the Bank has a legally enforceable right to set off current income tax assets against current income tax liabilities,

• the deferred tax relates to the same taxable entity and the same taxation authority.

As regards the cost of legal risk of mortgage loans in convertible currencies, the Bank recognizes deferred income tax assets arising from:

• the suspension of tax collection in accordance with the Regulation,

• the right to adjust tax revenues in connection with judgments invalidating loan agreements.

In accordance with the Act of 6 November 2025 amending the Corporate Income Tax Act and certain other acts (an amendment introducing Articles 38aa-38ab to the CIT Act), in 2026 the Bank's taxable income will be taxed at a rate of 30%. The rate will be gradually reduced to 26% in 2027 and 23% from 2028.

Deferred tax assets and liabilities were measured at the tax rates that, in accordance with the above amendment, will apply when the asset is realized or the liability is settled (see the table “Net deferred tax liabilities and assets”).

For some temporary differences, it is not possible to unambiguously determine the horizon of their realization, as this process remains dependent not only on decisions made by the Bank, but also on external factors. In such cases, the remeasurement of the deferred tax asset required the application of judgment and was carried out taking into account the principle of prudent valuation.

The value of the deferred tax asset resulting from the above remeasurement carried out as at 31 December 2025 increased by PLN 255 million and had a positive impact on the Bank's net financial result of PLN 284 million and a negative impact on other comprehensive income of PLN 29 million.

Financial information

• tax expense

TAX EXPENSE	2025	2024
Income tax expense recognized in the income statement	(2,804)	(3,052)
Current income tax expense	(2,835)	(2,227)
Deferred income tax on temporary differences	31	(825)
Income tax expense recognized in other comprehensive income in respect of temporary differences	(619)	(212)
Total	(3,423)	(3,264)

• reconciliation of the effective tax rate

RECONCILIATION OF THE EFFECTIVE TAX RATE	2025	2024
Profit or loss before tax	13,044	12,202
Tax at the statutory rate in force in Poland (19%)	(2,478)	(2,318)
Effect of permanent differences between profit before income tax and taxable income, including:	(610)	(734)
cost of the legal risk of mortgage loans in convertible currencies	(333)	(599)
tax on certain financial institutions	(246)	(230)
dividend income	177	191
contributions and payments to the Bank Guarantee Fund	(99)	(49)
reserve for proceedings before the President of the UOKiK	(93)	-
tax on controlled foreign corporations CIT-CFC	-	(33)
non-deductible allowances for expected credit losses on credit exposures	(17)	(9)
other permanent differences	1	(5)
Effect of changes in CIT rates	284	-
Income tax expense recognized in the income statement	(2,804)	(3,052)
Effective tax rate	21.50	25.01

• Net deferred tax assets

DEFERRED TAX LIABILITIES AND ASSETS	01.01.2025	Income statement	Other comprehensive income	31.12.2025
Interest accrued on receivables (loans)	348	248	-	596
Interest, discount/premium on securities	428	500	-	928
Valuation of securities	-	25	96	121
Valuation of derivative financial instruments	-	(9)	95	86
Difference between carrying amount and tax base of property, plant and equipment and intangible assets, including leased assets	440	101	-	541
Deferred tax liabilities, gross	1,216	865	191	2,272
Interest accrued on liabilities	158	63	-	221
Valuation of derivative financial instruments	190	68	(258)	-
Valuation of securities	190	(3)	(187)	-
Provision for employee benefits	137	163	7	307
Allowances for expected credit losses	1,356	415	-	1,771
Fair value measurement of loans and initial loss on POCI exposures	210	25	10	245
Commissions to be settled in time using the straight-line valuation method and effective interest rate	431	(291)	-	140
Other deductible temporary differences	14	(4)	-	10
Provision for costs to be incurred	46	25	-	71
Effect legal risk of mortgage loans in convertible currencies	283	370	-	653
Difference between carrying amount and tax base of property, plant and equipment and intangible assets, including leased assets	212	65	-	277
Deferred tax assets, gross	3,227	896	(428)	3,695
Total effect of temporary differences	2,011	31	(619)	1,423
Deferred tax assets (presented in the statement of financial position)	2,011	31	(619)	1,423

DEFERRED TAX LIABILITIES AND ASSETS	01.01.2024	Income statement	Other comprehensive income	31.12.2024
Interest accrued on receivables (loans)	340	8	-	348
Interest on securities	226	202	-	428
Difference between carrying amount and tax base of property, plant and equipment and intangible assets, including leased assets	416	24	-	440
Taxable income on the reversal of IBNR allowance, which was previously tax deductible, on implementation of IFRS 9	13	(13)	-	-
Deferred tax liabilities, gross	995	221	-	1,216
Interest accrued on liabilities	334	(176)	-	158
Valuation of derivative financial instruments	549	(219)	(140)	190
Valuation of securities	355	(80)	(85)	190
Provision for employee benefits	106	31	-	137
Allowances for expected credit losses	1,439	(83)	-	1,356
Fair value measurement of loans and initial loss on POCI exposures	205	(8)	13	210
Commissions to be settled in time using the straight-line valuation method and effective interest rate	682	(251)	-	431
Other deductible temporary differences	20	(6)	-	14
Provision for costs to be incurred	48	(2)	-	46
Effect legal risk of mortgage loans in convertible currencies	109	174	-	283
Difference between carrying amount and tax base of property, plant and equipment and intangible assets, including leased assets	196	16	-	212
Deferred tax assets, gross	4,043	(604)	(212)	3,227
Total effect of temporary differences	3,048	(825)	(212)	2,011
Deferred tax assets (presented in the statement of financial position)	3,048	(825)	(212)	2,011

As a result of analyses concerning the current results of the Bank and estimated results for future reporting periods, the Bank concluded that the deferred tax asset is fully realizable.

When calculating deferred tax assets, the Bank takes into account the potential tax effect in respect of future settlements and invalidations of mortgage loans. As at 31 December 2025, the Bank recognized deferred tax assets in respect of future settlements and invalidations of mortgage loans in the amount of PLN 653 million, and guided by the principle of prudent valuation, estimating the realization date of individual differences and taking into account current case law and the interpretation line of the tax authorities, the Bank did not recognize a deferred tax asset in the amount of PLN 492 million. Additionally, the Bank did not recognize a deferred tax asset relating to planned adjustments and overpayment claims that are likely to be realized in subsequent years, but as at the balance sheet date there is no certainty as to the amounts or the calculation of the overpayment amount has not been finalized.

• Tax Group

Pursuant to the agreement of 5 November 2024, PKO Bank Polski S.A., PKO Bank Hipoteczny S.A. and PKO Leasing S.A. extended for the years 2025 - 2027 the operation of the Tax Group of Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna (“Tax Group”), established under the agreement of 5 November 2018. The agreements were registered by the competent head of the tax office.

A tax group is a tax law institution provided for in the Corporate Income Tax Act. Its creation means that the income of the companies included in the group is consolidated for tax purposes and makes it possible to use solutions provided for such groups, including operational facilitations.

The Bank acts as the parent company. Current income tax settlements are presented broken down into receivables and liabilities of the Bank and subsidiaries belonging to the Tax Group.

• Global minimum tax

The global minimum tax legislation is effective in Poland from 1 January 2025. In jurisdictions where the Bank operates, the rules have been in force since 1 January 2024, including:

• Germany, the Czech Republic, Romania – global and domestic top-up tax,

• Slovakia – domestic top-up tax,

Between 2025 and 2026, the Bank plans to use the temporary CbCR (Country by Country Reporting) safe harbour. The Bank estimates that the implementation of the OECD Pillar 2 will not have a material impact on its financial position.

• Tax policy

The Bank has a Tax Strategy for PKO Bank Polski S.A. adopted by resolution of the Management Board No. 392/C/2021 of 5 October 2021 and approved by resolution of the Supervisory Board No. 154/2021 of 14 October 2021. The strategy was published on the Bank's website at: https://www.pkobp.pl/o-banku/odpowiedzialna-dzialalnosc/strategia-podatkowa.

In 2025, PGK PKO Banku Polskiego S.A. prepared the Information on the implemented tax strategy for 2024, which is published on the Bank's website at: https://www.pkobp.pl/grupa-pko-banku-polskiego/pko-bank-polski/strategia-podatkowa/ or: https://www.pkobp.pl/informacja-o-realizowanej-strategii-podatkowej/. On 28 November 2025, the Bank informed the competent head of the tax office of the address of the website where the Information was published.

Corporate income tax in 2025 and 2024 by tax jurisdiction:

CORPORATE INCOME TAX	2025	2024
PKO Bank Polski S.A.	2,835	2,227
- Poland	2,804	2,213
- Germany	20	4
- Czech Republic	9	10
- Slovak Republic	2	-

SUPPLEMENTARY NOTES TO THE STATEMENT OF FINANCIAL POSITION – FINANCIAL INSTRUMENTS

27. Cash and balances with the Central Bank

Significant accounting policies: General accounting policies for financial instruments.

Financial information

CASH AND BALANCES WITH THE CENTRAL BANK	31.12.2025	31.12.2024
Current account with the Central Bank	17,772	19,567
Cash	3,833	3,696
Other	39	-
Total	21,644	23,263

During the course of a working day, the Bank may use funds accumulated on the mandatory reserve account for ongoing cash settlements on the basis of an instruction submitted to the NBP, provided that the average monthly balance on this account is maintained at the level specified in the mandatory reserve declaration.The value of the mandatory reserve as at 31 December 2025 was PLN 14,778 million (as at 31 December 2024: PLN 13,605 million).

28. Amounts due from banks

Significant accounting policies “General significant accounting policies for financial instruments”.

Financial information

For information on credit risk exposures, see Note “Credit risk – financial information”.

AMOUNTS DUE FROM BANKS		31.12.2025	31.12.2024
Measured at amortized cost		6,362	8,368
Deposits with banks		1,128	2,434
Current accounts		341	428
Loans and advances granted		4,301	5,506
Amounts due from PKO Bank Hipoteczny S.A. in respect of the sale of mortgage-secured housing loans by the Bank		592	-
Gross carrying amount		6,362	8,368
Allowances for expected credit losses		(11)	(19)
Net carrying amount		6,351	8,349
AMOUNTS DUE FROM BANKS BY MATURITY	31.12.2025			31.12.2024
up to 1 month	1,678			3,050
1 to 3 months	60			-
3 months to 1 year	20			160
1 to 5 years	4,593			5,139
Total	6,351			8,349

29. Hedge accounting and other derivative instruments

Significant accounting policies:

The Bank uses derivative financial instruments to manage risks related to the Bank's operations. The most frequently used instruments are: IRS, CIRS, FX Swap, options, commodity swap, FRA, Forward and Futures. Derivative financial instruments are stated at fair value from the transaction date.

A derivative instrument is presented as:

• “Derivative hedging instruments” – if it meets the hedge accounting criteria

• “Other derivative instruments” – if it does not meet these criteria.

The instrument is recognized as an asset if its fair value is positive, or as a liability if it is negative.

For instruments not designated for hedge accounting, changes in fair value and the result on settlement are recognized in gains/(losses) on financial transactions or in net foreign exchange gains/(losses) - depending on the type of instrument.

The Bank applies hedge accounting to mitigate interest rate risk and foreign exchange risk. Cash flows related to the transactions performed and the fair value of assets and liabilities held are hedged. The Bank decided to continue applying IAS 39 for hedge accounting and did not implement IFRS 9 in this area.

Cash flow hedges

Changes in the fair value of a cash flow hedging instrument in the effective portion are recognized in other comprehensive income.

These amounts are transferred to the income statement in the periods in which the hedged planned transaction affects the result. Interest and foreign exchange differences are presented in “Net interest income” and “Net foreign exchange gains/(losses)”, respectively. The Bank hedges both assets generating interest income and liabilities generating interest expense using IRS or CIRS transactions. The net interest result on hedging instruments is presented in the line “derivative hedging instruments” under “Net interest income”: a positive total result in “Interest income”, a negative one in “Interest expense”.

Hedge effectiveness is verified prospectively and retrospectively every month. The tests include the valuation of hedging transactions net of accrued interest and foreign exchange differences (for CIRS). The ineffective portion of gains or losses is recognized in the financial result: for CIRS – in “Net foreign exchange gains/(losses)”, and for IRS – in “Gains/(losses) on financial transactions”.

Fair value hedges

Changes in the fair value of a derivative hedging instrument designated as fair value hedge are recognized in “Gains/ (losses) financial transactions”, net of the interest component. The interest component is presented in the same line item as interest income on the hedged item, i.e. in “Net interest income”.

The Bank hedges both assets that generate interest income and liabilities that generate interest expense using IRS transactions. A change in the fair value adjustment to the hedged item is recognized in “Gains/(losses) on financial transactions”.

Hedge effectiveness is verified prospectively and retrospectively every month. The tests comprise the measurement of hedging transactions net of accrued interest.

The items “Securities”, “Loans and advances to customers” and “Amounts due to customers” include an adjustment for fair value hedge accounting for the respective hedged items.

Estimates and judgments

The fair value of derivative instruments other than options is designated using the valuation models that base on discounted cash flows which may be obtained from a given instrument. The Bank applies measurement techniques based on yield curves constructed on the basis of available market data (e.g. deposit rates on the interbank market, quotations of IRS transactions). Options are valued using option valuation models, using, where available, data derived from observable markets.

The fair value of derivative instruments accounts for credit risk adjustments:

• CVA (credit value adjustment) – counterparty risk

• DVA (debit value adjustment) – own risk.

The process of calculation of CVA and DVA adjustments includes:

• the selection of a method for determining the credit risk spread (e.g. a market price method based on the continuous price quotations of debt instruments issued by the counterparty, a method of spread implied from Credit Default Swap contracts),

• an estimation of the probability of default by the counterparty or the Bank,

• determining the recovery rate,

• the calculation of CVA and DVA adjustments.

The Bank makes simulations aimed at assessing the impact of the changes in the yield curves on the measurement of the instruments.

ESTIMATED CHANGE IN VALUATION OF HEDGING DERIVATIVES OTHER THAN OPTIONS FOLLOWING A PARALLEL SHIFT IN YIELD CURVES:	31.12.2025		31.12.2024
	+50bp scenario	scenario -50bp	+50bp scenario	scenario -50bp
IRS	(507)	515	(644)	653
CIRS	(162)	165	(78)	79
other instruments	(1)	1	(2)	2
Total	(670)	681	(724)	734

ESTIMATED CHANGE IN VALUATION OF DERIVATIVES OTHER THAN OPTIONS FOLLOWING A PARALLEL SHIFT IN YIELD CURVES	31.12.2025		31.12.2024
	+50bp scenario	scenario -50bp	+50bp scenario	scenario -50bp
IRS	(503)	510	(646)	655
CIRS	(162)	166	(78)	79
other instruments	1	(1)	(3)	3
Total	(664)	675	(727)	737

29.1. Hedge accounting – financial information

types of hedging strategies used by the Bank

As at 31 December 2025, the Bank had active relationships as part of:

• 3 strategies for hedging cash flow volatility;

• 4 strategies for hedging fair value volatility.

In 2025, the Bank discontinued:

• one relationship under the strategy “Hedges against fair value volatility of fixed-interest-rate loans in convertible currencies resulting from interest rate risk, using IRS transactions” due to failure to meet the prospective effectiveness test.

• the hedging strategy “Hedges against fluctuations in cash flows on variable interest loans in convertible currencies, resulting from interest rate risk and currency risk, and hedging against fluctuations in cash flows on negotiated deposits in PLN, resulting from interest rate risk, using two transactions: IRS and CIRS-EP” due to the expiry of the transaction.

The total impact on the result in 2025 of the discontinuation of the above strategy was approximately PLN 0.2 million.

No changes were made to other hedging strategies in 2025. In 2024, the Bank discontinued 2 hedging strategies due to failure to meet the prospective effectiveness test:

Summary of the types of strategies applied in the Bank.

Type of hedging strategy	Cash flow hedges (strategy No: 6, 19)
Risk hedged	foreign exchange risk and interest rate risk
Hedging instrument	fixed – float CIRSs
Hedged item	• the portfolio of floating interest loans in foreign currencies and • fixed interest rate financial liability denominated in foreign currency
sources of hedge ineffectiveness	• margin on the hedging instrument • differences in discount on the hedged item and the hedging instrument • CVA/DVA adjustment of the hedging instrument
The period in which cash flows are expected to occur and affect the financial results: January 2026 – November 2031
Strategy No	Strategy Name
6	Hedges against fluctuations in cash flows on variable interest loans in convertible currencies, resulting from interest rate risk and currency risk, and hedging against fluctuations in cash flows on negotiated deposits in PLN, resulting from interest rate risk, using two transactions: IRS and CIRS-EP (inactive).
19	Hedges against fluctuations in cash flows on variable interest PLN loans, resulting from interest rate risk, and hedging against fluctuations in cash flows on a fixed-rate financial liability in a convertible currency resulting from foreign currency risk, using CIRS transactions.
Type of hedging strategy	Cash flow hedges (Strategies No: 2, 3)
Risk hedged	interest rate risk
Hedging instrument	fixed - float IRSs
Hedged item	the portfolio of loans in PLN or foreign currencies indexed to a floating interest rate
sources of hedge ineffectiveness	• change in market parameters between the moment of determining the terms and conditions relating to the hedged item and the moment of concluding the hedge • differences in discount on the hedged item and the hedging instrument • CVA/DVA adjustment of the hedging instrument
The period in which cash flows are expected to occur and affect the financial results: January 2026 – November 2035
Strategy No	Strategy Name
2	Hedges against fluctuations in cash flows from variable interest loans in PLN, resulting from interest rate risk, using IRS transactions.
3	Hedges against fluctuations in cash flows from variable interest loans in convertible currencies, resulting from interest rate risk, using IRS transactions.
Type of hedging strategy	Fair value volatility hedges (strategy No: 10, 11, 13, 17, 18)
Risk hedged	interest rate risk
Hedging instrument	fixed - float IRSs
Hedged item	• interest rate risk component relating to a fixed interest rate loan or security in a foreign currency or in PLN, which corresponds to the market IRS rate • interest rate risk component of a portfolio of financial liabilities replicated by a portfolio of fixed-rate instruments measured at amortised cost, corresponding to the market IRS rate
sources of hedge ineffectiveness	• change in market parameters between the moment of determining the terms and conditions relating to the hedged item and the moment of concluding the hedge • CVA/DVA adjustment of the hedging instrument • difference between the present value of the floating leg of IRS and the present value of the nominal value of a security
Strategy No	Strategy Name
10	Hedges against fair value volatility of fixed-interest-rate loans in convertible currencies resulting from interest rate risk, using IRS transactions.
11	Hedges against fair value volatility of fixed-interest-rate security in convertible currencies measured at amortized cost, resulting from interest rate risk, using IRS transactions.
13	Hedges against fair value volatility of fixed-interest-rate FVOCI security in PLN resulting from interest rate risk, using IRS transactions.
17	Hedges against fluctuations in the fair value of a portfolio of financial liabilities in PLN measured at amortized cost, resulting from interest rate risk, using IRS transactions
18	Hedges against fluctuations in the fair value of a portfolio of financial liabilities in convertible currencies measured at amortized cost, resulting from interest rate risk, using IRS transactions.

• carrying amount of hedging instruments

CARRYING AMOUNT OF HEDGING INSTRUMENTS	31.12.2025		31.12.2024
CARRYING AMOUNT OF HEDGING INSTRUMENTS	Assets	Liabilities	Assets	Liabilities
Cash flow hedges	128	105	324	302
interest rate risk – IRS PLN (strategy 2)	128	23	20	71
foreign exchange risk and interest rate risk – CIRS	-	82	304	231
CIRS – EP EUR/PLN (strategy 6)		-	205	-
CIRS PLN/EUR (strategy 19)	-	82	99	231
Fair value hedges of interest rate risk – IRS EUR (strategy 10,11,18)	19	-	20	-
Total	147	105	344	302

• Cash flow hedges

CHANGE IN OTHER COMPREHENSIVE INCOME RELATING TO CASH FLOW HEDGES AND AN INEFFECTIVE PORTION OF CASH FLOW HEDGES	2025	2024
Accumulated other comprehensive income at the beginning of the period, net	(1,105)	(1,701)
Impact on other comprehensive income during the period, gross	1,700	736
Gains/losses recognized in other comprehensive income during the period	221	(552)
Amounts transferred from other comprehensive income to the income statement, of which:	1,479	1,288
- net interest income	1,412	1,748
- net foreign exchange gains/ (losses)	67	(460)
Tax effect	(354)	(140)
Accumulated other comprehensive income at the end of the period, net	241	(1,105)

INEFFECTIVE PORTION OF CASH FLOW HEDGES RECOGNIZED IN THE INCOME STATEMENTS, INCLUDING IN:	2025	2024
Net foreign exchange gains/ (losses) – CIRS (strategy 6 and 19)	(1)	2
Gains/(losses) on financial transactions – PLN IRS (strategy 2)	3	2

• Fair value volatility hedges

INTEREST RATE RISK HEDGE	31.12.2025	31.12.2024
Fair value measurement of the hedging derivative instrument	623	487
Interest rate risk hedge – fixed - float IRSs	623	487
Fair value adjustment of the hedged instrument attributable to the hedged interest rate risk	(450)	(267)
Securities	(18)	(19)
Loans and advances to customers	-	(1)
Fair value adjustment of hedged instruments recognised in other comprehensive income before designation for hedge accounting	(5)	(10)
Amounts due to customers	(427)	(237)

FAIR VALUE ADJUSTMENT OF THE HEDGED INSTRUMENT ATTRIBUTABLE TO THE HEDGED RISK BY TYPE OF HEDGING INSTRUMENT	31.12.2025	31.12.2024
IRS EUR (strategy 10, 11, 18)	(37)	(56)
IRS USD (strategy 10, 18)	(2)	-
IRS PLN (strategy 13.17)	(411)	(211)
Total	(450)	(267)

• nominal value of hedging instruments by maturity

Strategy No	Hedging derivative	up to 1 month	1 to 3 months	3 months to 1 year	1 to 5 years	More than 5 years	Total	Change in the fair value since designation	Nominal-weighted average fixed interest rate
	31.12.2025
	Hedge type: Cash flow hedges; Hedged risk: interest rate risk
2	PLN fixed - float IRSs	1,150	5,201	18,932	31,812	4,357	61,452	315	3.8781%
3	EUR fixed – float IRSs		634	1,416	1,802	3	3,855	7	2.1803%
	Hedge type: Cash flow hedges; Hedged risk: foreign exchange and interest rate risks
19	Float PLN/fixed EUR CIRSs
	float PLN	-	-	3,201	9,657	2,109	14,967	(175)
	fixed EUR	-	-	3,164	9,494	2,108	14,766	(175)	2.0444%
	Hedge type: Fair value hedges; Hedged risk: interest rate risk
17	PLN fixed – float IRSs	600	1,200	-	8,360	591	10,751	380	5.0849%
18	USD fixed – float IRSs	-	-	-	108	-	108	2	3.8830%
10,11,18	EUR fixed – float IRSs	85	169	758	1,441	203	2,656	34	2.5462%

	31.12.2024
	Hedge type: Cash flow hedges; Hedged risk: interest rate risk
2	PLN fixed - float IRSs	1,225	839	9,338	51,812	2,608	65,822	(1,461)	3.5617%
3.6	EUR fixed – float IRSs	-	855	2,456	3,896	4	7,211	(1)	2.2635%
	Hedge type: Cash flow hedges; Hedged risk: foreign exchange and interest rate risks
19	Float PLN/fixed EUR CIRSs
	float PLN	-	2,595	-	7,522	-	10,117	(200)	-
	fixed EUR	-	2,350	-	7,458	-	9,808	(200)	2.1708%
6	CIRS EP float PLN/fixed EUR
	float PLN	-	-	2,348	-	-	2,348	219	-
	fixed EUR	-	-	2,136	-	-	2,136	219	6.8186%
	Hedge type: Fair value hedges; Hedged risk: interest rate risk
17	PLN fixed – float IRSs	600	1,200	-	4,910	1,341	8,051	185	5.9261%
18	USD fixed – float IRSs	-	-	123	123	-	246	-	4.1972%
10,11,18	EUR fixed – float IRSs	94	188	656	2,380	308	3,626	50	2.5184%

• financial information on hedged items (in original currencies)

HEDGED ITEM	CARRYING AMOUNT OF THE HEDGED ITEM	ITEM OF THE STATEMENT OF FINANCIAL POSITION	CHANGE IN THE FAIR VALUE OF THE HEDGED ITEM	STRATEGY NO
31.12.2025	CARRYING AMOUNT OF THE HEDGED ITEM	ITEM OF THE STATEMENT OF FINANCIAL POSITION	CHANGE IN THE FAIR VALUE OF THE HEDGED ITEM	STRATEGY NO
Cash flow hedges
Loans in PLN	61,451	Loans and advances to customers	(317)	2
Loans in EUR	912	Loans and advances to customers	(1)	3
Loans in EUR	-	Loans and advances to customers	-	6
Negotiated deposits in PLN	-	Amounts due to customers	-	6
Loans in PLN	14,967	Loans and advances to customers	180	19
Financial liability in EUR	3,493	Liabilities in respect of debt securities in issue	180	19
Fair value hedges
Loans in EUR	2	Loans and advances to customers	-	10
Security in EUR	30	Securities measured at amortized cost	(4)	11
Security in PLN	-	Securities measured at fair value through other comprehensive income	(5)	13
Financial liabilities in USD	10,751	Amounts due to customers	(407)	17
Financial liabilities in EUR	596	Amounts due to customers	(4)	18
Financial liabilities in USD	30	Amounts due to customers	-	18

31.12.2024
Cash flow hedges
Loans in PLN	65,821	Loans and advances to customers	1,469	2
Loans in EUR	1,188	Loans and advances to customers	(1)	3
Loans in EUR	500	Loans and advances to customers	(216)	6
Negotiated deposits in PLN	2,348	Amounts due to customers	(216)	6
Loans in PLN	10,117	Loans and advances to customers	203	19
Financial liability in EUR	2,295	Liabilities in respect of debt securities in issue	203	19
Fair value hedges
Loans in EUR	9	Loans and advances to customers	-	10
Security in EUR	30	Securities measured at amortized cost	(4)	11
Security in PLN	-	Securities measured at fair value through other comprehensive income	(10)	12
Financial liabilities in USD	8,051	Amounts due to customers	(202)	17
Financial liabilities in EUR	810	Amounts due to customers	(8)	18
Financial liabilities in USD	60	Amounts due to customers	-	18

29.2. Other derivative instruments – financial information

OTHER DERIVATIVE INSTRUMENTS - BY TYPE	31.12.2025		31.12.2024
OTHER DERIVATIVE INSTRUMENTS - BY TYPE	Assets	Liabilities	Assets	Liabilities
IRS	361	672	163	479
CIRS	31	27	39	20
FX Swap	576	538	687	747
Options	325	584	357	573
Commodity swap1	132	124	93	84
FRA	-	-	26	23
Forward	494	282	374	233
Commodity Forward2	527	496	279	250
Other	-	1	-	-
Total	2,446	2,724	2,018	2,409

1 The item includes valuation of gas market participation contracts: assets of PLN 41 million (PLN 31 million as at 31 December 2024) – and liabilities of PLN 37 million (PLN 28 million as at 31 December 2024).

2 The item includes valuation of contracts for CO2 emission allowances.

	31.12.2025	31.12.2024
CVA and CDA adjustments	3	2

NOMINAL AMOUNTS OF UNDERLYING INSTRUMENTS (BUY AND SELL TOGETHER) – other derivative instruments
31.12.2025	up to 1 month	1 to 3 months	3 months to 1 year	1 to 5 years	more than 5 years	Total
IRS	10,484	25,228	91,646	260,348	42,030	429,736
Purchase	5,242	12,614	45,823	130,174	21,015	214,868
Sale	5,242	12,614	45,823	130,174	21,015	214,868
CIRS	-	-	-	13,910	8	13,918
Purchase	-	-	-	6,956	4	6,960
Sale	-	-	-	6,954	4	6,958
FX Swap	46,925	15,152	13,346	19,905	-	95,328
Purchase of currencies	23,464	7,586	6,650	9,968	-	47,668
Sale of currencies	23,461	7,566	6,696	9,937	-	47,660
Options	18,718	19,890	39,256	28,662	436	106,962
Purchase	9,293	9,896	19,391	14,166	218	52,964
Sale	9,425	9,994	19,865	14,496	218	53,998
FRA	-	-	30,185	560	-	30,745
Purchase	-	-	16,026	220	-	16,246
Sale	-	-	14,159	340	-	14,499
Forward	7,784	11,702	22,664	9,090	-	51,240
Purchase of currencies	3,898	5,889	11,437	4,530	-	25,754
Sale of currencies	3,886	5,813	11,227	4,560	-	25,486
Other, including commodity swap, commodity forward and futures	854	2,234	4,591	1,086	128	8,893
Purchase	430	1,124	2,329	538	56	4,477
Sale	424	1,110	2,262	548	72	4,416

NOMINAL AMOUNTS OF UNDERLYING INSTRUMENTS (BUY AND SELL TOGETHER) – other derivative instruments
31.12.2024	up to 1 month	1 to 3 months	3 months to 1 year	1 to 5 years	more than 5 years	Total
IRS	8,222	7,888	63,876	258,614	37,100	375,700
Purchase	4,111	3,944	31,938	129,307	18,550	187,850
Sale	4,111	3,944	31,938	129,307	18,550	187,850
CIRS	551	74	496	7,547	10	8,678
Purchase	283	37	248	3,774	5	4,347
Sale	268	37	248	3,773	5	4,331
FX Swap	43,219	15,077	16,015	14,040	-	88,351
Purchase of currencies	21,557	7,541	7,989	7,042	-	44,129
Sale of currencies	21,662	7,536	8,026	6,998	-	44,222
Options	16,456	28,734	30,837	22,407	-	98,434
Purchase	8,188	14,255	15,157	11,012	-	48,612
Sale	8,268	14,479	15,680	11,395	-	49,822
FRA	-	-	32,850	5,399	-	38,249
Purchase	-	-	16,496	2,685	-	19,181
Sale	-	-	16,354	2,714	-	19,068
Forward	8,488	10,425	21,694	11,645	-	52,252
Purchase of currencies	4,246	5,248	10,930	5,870	-	26,294
Sale of currencies	4,242	5,177	10,764	5,775	-	25,958
Other, including commodity swap, commodity forward and futures	1,008	885	7,120	2,401	19	11,433
Purchase	508	448	3,564	1,182	10	5,712
Sale	500	437	3,556	1,219	9	5,721

30. Securities

Significant accounting policies “General significant accounting policies for financial instruments”.

Financial information

For information on credit risk exposures, see Note “Credit risk – financial information”.

SECURITIES 31.12.2025	held for trading	not held for trading, measured at fair value through profit or loss	measured at fair value through other comprehensive income	measured at amortized cost	Total
Debt securities	330	41	103,221	132,494	236,086
NBP money bills	-	-	11,992	-	11,992
treasury bonds (in PLN)	272	-	72,742	99,430	172,444
treasury bonds (in foreign currencies)	2	41	4,816	-	4,859
treasury bills	4	-	1,134	-	1,138
corporate bonds (in PLN) secured with the State Treasury guarantees	6	-	4,353	4,649	9,008
municipal bonds (in PLN)	7	-	4,760	12,214	16,981
corporate bonds (in PLN)1	18	-	1,266	4,672	5,956
corporate bonds (in foreign currencies)2	-	-	2,158	11,025	13,183
mortgage covered bonds	21	-	-	504	525
Equity securities	41	336	-	-	377
Total (excluding adjustment relating to hedge accounting)	371	377	103,221	132,494	236,463
Adjustment relating to fair value hedge accounting (note “Hedge accounting and other derivative instruments”)	-	-	-	(18)	(18)
Total	371	377	103,221	132,476	236,445

1 The item includes, among other items, bonds of international financial organizations of PLN 2,784 million.

2 The item includes, among other items, bonds of international financial organizations of PLN 10,812 million.

SECURITIES 31.12.2024	held for trading	not held for trading, measured at fair value through profit or loss	measured at fair value through other comprehensive income	measured at amortized cost	Total
Debt securities	337	389	94,175	109,633	204,534
NBP money bills	-	-	7,996	-	7,996
treasury bonds (in PLN)	243	-	58,694	73,499	132,436
treasury bonds (in foreign currencies)	1	288	9,466	-	9,755
corporate bonds (in PLN) secured with the State Treasury guarantees	24	-	8,065	13,974	22,063
municipal bonds (in PLN)	10	-	5,213	10,399	15,622
corporate bonds (in PLN)1	53	101	1,903	3,994	6,051
corporate bonds (in foreign currencies)2	-	-	2,838	7,268	10,106
mortgage covered bonds	6	-	-	499	505
Equity securities	36	326	-	-	362
Total (excluding adjustment relating to hedge accounting)	373	715	94,175	109,633	204,896
Adjustment relating to fair value hedge accounting (note “Hedge accounting and other derivative instruments”)	-	-	-	(19)	(19)
Total	373	715	94,175	109,614	204,877

1 The item includes, among other items, bonds of international financial organizations of PLN 4,013 million.

2 The item includes, among other items, bonds of international financial organizations of PLN 7,599 million.

	31.12.2025	31.12.2024
allowance not reducing the fair value of securities measured at fair value through other comprehensive income	22	33

SECURITIES BY MATURITY (excluding adjustments relating to hedge accounting)	31.12.2025	31.12.2024
without a stated maturity – equity securities	377	362
up to 1 month	12,865	11,881
1 to 3 months	4,368	11,851
3 months to 1 year	24,193	26,772
1 to 5 years	141,664	102,848
above 5 years	52,996	51,182
Total	236,463	204,896

31. Loans and advances to customers

Significant accounting policies “General significant accounting policies for financial instruments”.

The Bank adjusts the gross carrying amount of housing loans measured at amortized cost by recognizing the effect of:

• legal risk related to potential litigation for the portfolio of mortgage loans in convertible currencies and existing legal claims related to credit exposures recognized as at the balance sheet date in the statement of financial position (“Cost of legal risk of mortgage loans in convertible currencies”)

• statutory credit holidays resulting from the amendment to the Act of 12 April 2024 on support for borrowers who have taken out a mortgage loan and are in a difficult financial situation and the Act on the crowdfunding of business ventures and on assistance for borrowers of 7 July 2022 . The realized loss on statutory credit holidays, excluding the effect of the settlement to date, amounted to PLN 166 million.

Estimates and judgments: Net expected credit losses, Cost of legal risk of mortgage loans in convertible currencies

Financial information

For information on credit risk exposures, see Note “Credit risk – financial information”.

LOANS AND ADVANCES TO CUSTOMERS	31.12.2025	31.12.2024
real estate	116,331	106,225
consumer	44,721	36,401
business	111,939	103,283
Loans and advances to customers (excluding adjustment relating to hedge accounting)	272,991	245,909
Adjustment relating to fair value hedge accounting (note “Hedge accounting and other derivative instruments”)	-	(1)
Total	272,991	245,908

LOANS AND ADVANCES TO CUSTOMERS 31.12.2025	not held for trading, measured at fair value through profit or loss	measured at fair value through other comprehensive income	measured at amortized cost	Total
retail and private banking	1,926	8,249	145,366	155,541
real estate	1	8,249	102,570	110,820
consumer	1,925	-	42,796	44,721
businesses	7	-	14,683	14,690
real estate	-	-	5,052	5,052
business	7	-	9,631	9,638
corporate	-	-	102,760	102,760
real estate	-	-	459	459
business	-	-	102,301	102,301
Loans and advances to customers (excluding adjustment relating to hedge accounting)	1,933	8,249	262,809	272,991
Total	1,933	8,249	262,809	272,991

LOANS AND ADVANCES TO CUSTOMERS 31.12.2024	not held for trading, measured at fair value through profit or loss	measured at fair value through other comprehensive income	measured at amortized cost	Total
retail and private banking	2,092	9,465	125,952	137,509
real estate	1	9,465	91,642	101,108
consumer	2,091	-	34,310	36,401
businesses	59	-	13,481	13,540
real estate	-	-	5,005	5,005
business	59	-	8,476	8,535
corporate	15	-	94,845	94,860
real estate	-	-	112	112
business	15	-	94,733	94,748
Loans and advances to customers (excluding adjustment relating to hedge accounting)	2,166	9,465	234,278	245,909
Adjustment relating to fair value hedge accounting (note “Hedge accounting and other derivative instruments”)	-	-	(1)	(1)
Total	2,166	9,465	234,277	245,908

The Bank analyses its portfolio of foreign currency mortgage loans to individuals in a specific manner. The risk of this portfolio is taken into consideration in the capital adequacy and equity management.

HOUSING LOANS AND ADVANCES TO INDIVIDUALS (RETAIL AND PRIVATE BANKING) BY CURRENCY	31.12.2025			31.12.2024
	gross	impairment loss	net	gross	impairment loss	net
in local currency	110,710	(1,289)	109,421	98,858	(1,300)	97,558
PLN	110,710	(1,289)	109,421	98,858	(1,300)	97,558
in foreign currency	1,538	(139)	1,399	3,788	(238)	3,550
CHF	1,026	(100)	926	2,196	(154)	2,042
EUR	494	(36)	458	1,567	(80)	1,487
USD	15	(3)	12	21	(4)	17
other	3	-	3	4	-	4
Total	112,248	(1,428)	110,820	102,646	(1,538)	101,108

LOANS AND ADVANCES TO CUSTOMERS BY MATURITY (excluding adjustments relating to fair value hedge accounting)	31.12.2025	31.12.2024
up to 1 month	11,617	10,928
1 to 3 months	7,414	8,752
3 months to 1 year	40,031	37,386
1 to 5 years	102,494	90,709
above 5 years	111,435	98,134
Total	272,991	245,909

32. Amounts due to banks

Significant accounting policies: “General significant accounting policies for financial instruments”.

Financial information

AMOUNTS DUE TO BANKS	31.12.2025	31.12.2024
Measured at fair value through profit or loss	28	4
Liabilities in respect of a short position in securities	28	4
Measured at amortized cost	3,349	2,267
Deposits from banks	1,364	597
Current accounts	1,972	1,656
Other monetary market deposits	13	14
Total	3,377	2,271

AMOUNTS DUE TO BANKS BY MATURITY	31.12.2025	31.12.2024
Measured at fair value through profit or loss up to 1 month	28	4
Measured at amortized cost	3,349	2,267
up to 1 month	3,318	2,267
3 months to 1 year	31	-
Total	3,377	2,271

33. Amounts due to customers

Significant accounting policies: General accounting policies for financial instruments.

Financial information

AMOUNTS DUE TO CUSTOMERS 31.12.2025	Amounts due to households1	Amounts due to business entities	Amounts due to public sector	Total
Measured at fair value through profit or loss (liabilities in respect of a short position in securities)	1	43	40	84
Measured at amortized cost	343,540	88,637	22,974	455,151
Cash on current accounts and overnight deposits of which	249,947	68,154	20,866	338,967
savings accounts and other interest-bearing assets	66,575	19,517	14,526	100,618
Term deposits	92,836	19,820	2,037	114,693
Other liabilities	757	663	71	1,491
Amounts due to customers (excluding adjustment relating to hedge accounting)	343,541	88,680	23,014	455,235
Adjustment relating to fair value hedge accounting (“Hedge accounting and other derivative instruments”)	427	-	-	427
Total	343,968	88,680	23,014	455,662

1Households include private individuals, sole proprietors and individual farmers.

AMOUNTS DUE TO CUSTOMERS 31.12.2024	Amounts due to households1	Amounts due to business entities	Amounts due to public sector	Total
Measured at fair value through profit or loss (liabilities in respect of a short position in securities)	-	32	-	32
Measured at amortized cost	315,190	77,831	21,630	414,651
Cash on current accounts and overnight deposits of which	228,014	54,901	19,961	302,876
savings accounts and other interest-bearing assets	58,760	13,283	14,134	86,177
Term deposits	86,511	22,239	1,636	110,386
Other liabilities	665	691	33	1,389
Amounts due to customers (excluding adjustment relating to hedge accounting)	315,190	77,863	21,630	414,683
Adjustment relating to fair value hedge accounting (“Hedge accounting and other derivative instruments”)	237	-	-	237
Total	315,427	77,863	21,630	414,920

1Households include private individuals, sole proprietors and individual farmers.

AMOUNTS DUE TO CUSTOMERS BY MATURITY (excluding adjustment relating to fair value hedge accounting)	31.12.2025	31.12.2024
Measured at fair value through profit or loss – up to 1 month	84	32
Measured at amortized cost	455,151	414,651
up to 1 month	379,423	343,466
1 to 3 months	41,364	34,989
3 months to 1 year	23,880	23,655
1 to 5 years	7,107	6,727
above 5 years	3,377	5,814
Total	455,235	414,683

AMOUNTS DUE TO CUSTOMERS BY SEGMENT	31.12.2025	31.12.2024
Amounts due to customers (excluding adjustment relating to hedge accounting)	455,235	414,683
retail and private banking	312,819	285,984
corporate	88,693	79,533
businesses	53,723	49,166
Adjustment relating to fair value hedge accounting (note “Hedge accounting and other derivative instruments”)	427	237
Total	455,662	414,920

34. Financing received

Significant accounting policies: General accounting policies for financial instruments.

Financial information

Type of interest rate	Notional amount	Currency	Issue date		Maturity date	Carrying amount
Type of interest rate	Notional amount	Currency	Issue date		Maturity date	31.12.2025	31.12.2024
Liabilities in respect of debt securities in issue – bonds						16,034	11,999
Fixed 5.625%	750	EUR	01.02.2023	01.02.2026		-	3,369
6M WIBOR +1.59%	1,000	PLN	28.02.2024	28.02.2029		1,021	1,025
Fixed 4.5%	500	EUR	27.03.2024	27.03.2028		2,181	2,201
Fixed 4.5%	500	EUR	18.06.2024	18.06.2029		2,155	2,175
Fixed 3.875%	750	EUR	12.09.2024	12.09.2026		3,202	3,229
Fixed 3.375%	750	EUR	16.01.2025	16.06.2028		3,221	-
Fixed 3.625%	500	EUR	30.06.2025	30.06.2031		2,144	-
Fixed 3.625%	500	EUR	20.11.2025	20.11.2031		2,110	-
Subordinated liabilities						6,309	4,291
6M WIBOR +1.55%	1,700	PLN	28.08.2017	28.08.2027		1,737	1,743
6M WIBOR +1.50%	1,000	PLN	05.03.2018	06.03.2028		1,020	1,024
6M WIBOR +2.20%	1,500	PLN	16.10.2024	16.10.2034		1,519	1,524
6M WIBOR +1.75%	2,000	PLN	24.09.2025	24.09.2035		2,033	-
Total						22,343	16,290

For details of the issues carried out by the Bank, see section 1.3 “Main events and financial results achieved in 2025” of the Directors’ Report

PROJECTIONS OF THE DEVELOPMENT OF THE BANK'S FINANCIAL LIABILITIES 31.12.2025 (non-auditable data)	Projected value	Actual performance	Difference between projection and performance	percentage of total liabilities on the balance sheet* (projection)	percentage of total liabilities on the balance sheet* (performance)
Liabilities in respect of debt securities in issue (including subordinated liabilities)	22,932	22,343	(3%)	4.63%	4.57%
Leases	1,055	1,093	4%	0.21%	0.22%
Value of financial liabilities	485,645	488,776	1%	98.02%	97.54%

* Total liabilities of the balance sheet is understood as the sum of liabilities excluding equity

There were no material differences between the published projections and the actual performance of the development of financial liabilities in respect of debt securities in issue as at the end of 2025.

OTHER SUPPLEMENTARY NOTES TO THE STATEMENT OF FINANCIAL POSITION AND CONTINGENT LIABILITIES

35. Intangible assets

Significant accounting policies:

Software - Acquired software licenses are recognized in the amount of costs of purchase and preparation for use, less accumulated amortization and impairment losses.

The Bank uses cloud-based software. The Bank assesses whether it has real control over the asset, including:

• the right to take ownership of the software without incurring significant costs,

• the ability to use it independently without loss of usefulness,

• the possibility of running it on own hardware or with another supplier. Based on these criteria, a portion of the software is classified as intangible assets, and a part as a service (costs recognized in operating expenses).

Goodwill - The impairment test is carried out at least once a year.

Other intangible assets – are recognized at the cost of purchase or manufacture, less accumulated amortization and impairment losses.

Development costs - are classified as intangible assets if the following conditions are met: the possibility and intention to complete and use the asset, the availability of technical and financial resources, and the ability to reliably measure the expenditure incurred during development. The Bank recognizes the value of in-house development work if it can be used in the Bank's operations.

Related notes:

• Useful lives – note “Administrative expenses”;

• Impairment losses – note “Net impairment losses on non-financial assets”

Financial information

INTANGIBLE ASSETS 2025	Software	Goodwill	Other, including capital expenditure		of which: software		Total
Gross carrying amount at the beginning of the period	7,580	872	671	620		9,123
Purchase	-	-	762	761		762
Transfers from capital expenditure	768	-	(768)	(768)		-
Scrapping and sale	(1)	-	-	-		(1)
Other	(99)		87	86		(12)
Gross carrying amount at the end of the period	8,248	872	752	699		9,872
Accumulated amortization as at the beginning of the period	(5,463)	-	(48)	-		(5,511)
Amortization charge for the period	(622)	-	(2)	-		(624)
Scrapping and sale	1	-	-	-		1
Other	(3)	-	(1)	-		(4)
Accumulated amortization as at the end of the period	(6,087)	-	(51)	-		(6,138)
Impairment losses as at the beginning of the period	(16)	(117)	-	-		(133)
Recognized during the period	(104)	-	(15)	(15)		(119)
Impairment losses as at the end of the period	(120)	(117)	(15)		(15)		(252)
Carrying amount as at the beginning of the period, net	2,101	755	623		620		3,479
Carrying amount as at the end of the period, net	2,041	755	686		684		3,482

INTANGIBLE ASSETS 2024	Software	Goodwill	Customer relations		Other, including capital expenditure	of which: software		Total
Gross carrying amount at the beginning of the period	6,893	872	86	686		628	8,537
Purchase	-	-	-	705		704	705
Transfers from capital expenditure	764	-	-	(764)		(764)	-
Scrapping and sale	(98)	-	(86)	(8)		-	(192)
Other	21	-	-	52		52	73
Gross carrying amount at the end of the period	7,580	872	-	671		620	9,123
Accumulated amortization as at the beginning of the period	(4,977)	-	(85)	(54)		-	(5,116)
Amortization charge for the period	(579)	-	(1)	(2)		-	(582)
Scrapping and sale	98	-	86	8		-	192
Other	(5)	-	-	-		-	(5)
Accumulated amortization as at the end of the period	(5,463)	-	-	(48)		-	(5,511)
Impairment losses as at the beginning of the period	(16)	(117)	-	-		-	(133)
Impairment losses as at the end of the period	(16)	(117)	-		-	-		(133)
Carrying amount as at the beginning of the period, net	1,900	755	1		632	628		3,288
Carrying amount as at the end of the period, net	2,101	755	-		623	620		3,479

Expenditure on the Integrated Information System (IIS) is a significant item of intangible assets for the Bank. Total capital expenditure incurred on the IIS in 2007–2025 amounted to PLN 1,417 million (of which PLN 1,345 million in 2007–2024). The net carrying amount of the IIS as at 31 December 2025 was PLN 464 million (PLN 657 million as at 31 December 2024). The expected useful life of the system is 25 years, and as at the end of 2025 its remaining useful life is 6 years.

• Goodwill

Net goodwill	31.12.2025	31.12.2024
Nordea Bank Polska S.A.	747	747
Assets taken over from CFP sp. z o.o.	8	8
TOTAL	755	755

Impairment test of Nordea Bank Polska S.A. goodwill – method

Upon acquisition, two cash-generating units (CGUs) were distinguished: retail and corporate, corresponding to the operating segments. The goodwill from the acquisition of Nordea Bank Polska S.A. was allocated to these CGUs.

The goodwill allocated to the corporate CGU amounted to PLN 117 million. The Bank recognized an impairment loss on this amount on 30 June 2020. The goodwill allocated to the retail CGU amounts to PLN 747 million.

The impairment test is performed by comparing the carrying amount of the CGUs with their recoverable amount. The recoverable amount of the retail CGU was calculated by extrapolating the projected cash flows beyond the projection period, applying a growth rate of 2.5%. The projections covered a 10-year period and were based on the Bank's financial plan for 2026. For discounting, a rate of 10.75% was applied, taking into account the risk-free rate and the risk premium.

The tests carried out as at the end of 2025 and 2024 did not indicate any impairment of the goodwill allocated to the retail CGU.

36. Property, plant and equipment

Significant accounting policies:

property, plant and equipment - are measured at the cost of purchase or manufacture, less accumulated depreciation and impairment losses. Property, plant and equipment comprises controlled fixed assets and capital expenditure for their construction. Fixed assets include items with a useful life of more than one year, which are used for own purposes or handed over to other entities for use under a lease agreement.

capital expenditure - The carrying amount of property, plant and equipment is increased by additional capital expenditure incurred during their use, provided that they satisfy the criteria for recognition as a fixed asset.

Right-of-use assets are presented in the same items in which the underlying assets would be presented, if they were owned by the Bank (Note "Leases").

Related notes:

• Useful lives – note “Administrative expenses” and Impairment losses – note “Net impairment losses on non-financial assets”

Financial information

PROPERTY, PLANT AND EQUIPMENT 2025	Land and buildings	Machinery and equipment, including computer hardware	Fixed assets under construction	Other, including vehicles	Total
Gross carrying amount at the beginning of the period	4,481	1,724	319	777	7,301
Purchase, including modifications	211	-	416	2	629
Transfers from capital expenditure	213	147	(442)	82	-
Scrapping and sale	(20)	(89)	-	(55)	(164)
Other	(35)	(4)	(5)	(2)	(46)
Gross carrying amount at the end of the period	4,850	1,778	288	804	7,720
Accumulated amortization as at the beginning of the period	(2,437)	(1,349)	-	(519)	(4,305)
Depreciation charge for the period	(302)	(132)	-	(65)	(499)
Scrapping and sale	18	87	-	55	160
Other	25	4	-	2	31
Accumulated amortization as at the end of the period	(2,696)	(1,390)	-	(527)	(4,613)
Impairment losses as at the beginning of the period	(135)	(5)	-	-	(140)
Recognized during the period	(28)	-	-	-	(28)
Reversed during the period	1	-	-	-	1
Other	13	-	-	-	13
Impairment losses as at the end of the period	(149)	(5)	-	-	(154)
Carrying amount as at the beginning of the period, net	1,909	370	319	258	2,856
Carrying amount as at the end of the period, net	2,005	383	288	277	2,953

2024
Gross carrying amount at the beginning of the period	4,195	1,697	286	697	6,875
Purchase, including modifications	304	-	339	29	672
Transfers from capital expenditure	55	146	(296)	95	-
Scrapping and sale	(26)	(112)	-	(44)	(182)
Other	(47)	(7)	(10)	-	(64)
Gross carrying amount at the end of the period	4,481	1,724	319	777	7,301
Accumulated amortization as at the beginning of the period	(2,179)	(1,329)	-	(508)	(4,016)
Depreciation charge for the period	(302)	(137)	-	(56)	(495)
Scrapping and sale	21	110	-	44	175
Other	23	7	-	1	31
Accumulated amortization as at the end of the period	(2,437)	(1,349)	-	(519)	(4,305)
Impairment losses as at the beginning of the period	(124)	(4)	-	-	(128)
Recognized during the period	(17)	(1)	-	-	(18)
Other	6	-	-	-	6
Impairment losses as at the end of the period	(135)	(5)	-	-	(140)
Carrying amount as at the beginning of the period, net	1,892	364	286	189	2,731
Carrying amount as at the end of the period, net	1,909	370	319	258	2,856

37. Investments in subsidiaries, associates and joint ventures

Significant accounting policies

Investments are measured at cost less impairment losses.

Financial information

	31.12.2025			31.12.2024
	Gross carrying amount	Impairment	Net carrying amount	Gross carrying amount	Impairment	Net carrying amount
SUBSIDIARIES
PKO Bank Hipoteczny S.A.	1,650	-	1,650	1,650	-	1,650
KREDOBANK S.A.	1,072	(845)	227	1,072	(845)	227
PKO Leasing S.A.	496	-	496	496	-	496
PKO Życie Towarzystwo Ubezpieczeń S.A.	241	-	241	241	-	241
PKO Towarzystwo Funduszy Inwestycyjnych S.A.	225	-	225	225	-	225
PKO VC - fizan1	200	-	200	200	-	200
PKO BP BANKOWY PTE S.A.	151	(37)	114	151	(37)	114
NEPTUN - fizan1	252	-	252	252	-	252
PKO Towarzystwo Ubezpieczeń S.A.	110	-	110	110	-	110
PKO Finance AB	24	-	24	24	-	24
PKO BP Finat sp. z o.o.	21	-	21	21	-	21
JOINT VENTURES
Centrum Elektronicznych Usług Płatniczych eService sp. z o.o.	197	-	197	197	-	197
Operator Chmury Krajowej sp. z o.o.	78	-	78	78	-	78
ASSOCIATES
Bank Pocztowy S.A.	184	(184)	-	184	(184)	-
“Poznański Fundusz Poręczeń Kredytowych" sp. z o.o.	2	(2)	-	2	(2)	-
Total	4,903	(1,068)	3,835	4,903	(1,068)	3,835

1 The Bank holds investment certificates of the Fund which allow it to control the Fund in accordance with IFRS.

The impairment loss test performed as at 31 December 2025 and 31 December 2024 did not indicate a need to change the impairment losses on investments in subsidiaries, associates and joint ventures.

38. Other assets

Significant accounting policies: General accounting policies for financial instruments.

Other financial assets - are measured at amounts due, comprising also potential interest, taking into consideration allowances for expected credit losses. Other non-financial assets - are measured in accordance with the policies applicable to specific categories of assets recognized in this item.

Financial information

Information on other financial assets in terms of credit risk exposure - note „Credit risk – financial information”.

OTHER ASSETS	31.12.2025	31.12.2024
Other financial assets	1,916	2,319
Settlements in respect of card transactions	1,371	1,533
Settlement of financial instruments	51	178
Receivables in respect of cash settlements	368	395
Receivables and settlements in respect of trading in securities	13	9
Sale of foreign currencies	-	92
Trade receivables	111	110
Other	2	2
Other non-financial assets	1,085	585
Inventories	17	18
Receivables from subsidiaries belonging to the Tax Group	143	145
Assets for sale	11	28
Prepayments and deferred costs	103	107
Receivables from customers for whom the mortgage loan agreements in convertible currencies have been legally declared invalid in respect of the principal originally disbursed to these customers	672	129
Other	139	158
Total	3,001	2,904

OTHER FINANCIAL ASSETS	31.12.2025	31.12.2024
current	1,914	2,319
long-term	2	-
Total	1,916	2,319

OTHER NON-FINANCIAL ASSETS	31.12.2025	31.12.2024
Gross carrying amount	2,139	1,214
Odpisy1	(1,054)	(629)
Net carrying amount	1,085	585

1 In 2025, the Bank recognized impairment losses of PLN 284 million (in 2024: PLN 326 million) relating to receivables from customers for whom the mortgage loan agreements in convertible currencies have been legally declared invalid in respect of the principal originally disbursed to these customers (see Note "Net impairment of non-financial assets").

39. Other liabilities

Significant accounting policies: General significant accounting policies for financial instruments

Other financial liabilities - are measured at amounts due which cover potential interest. Provisions for future payments are determined at a reliably estimated amount necessary to meet the present obligation as at the end of the reporting period.

OTHER NON-FINANCIAL LIABILITIES are measured in accordance with the measurement policies applicable to particular categories of liabilities recognized in this item. The provision for accrued holiday entitlements is recognized at the amount of expected outflows of funds, excluding discounting, based on the outstanding holiday days to be utilized by the Bank's employees and the average monthly salary.

Financial information

OTHER LIABILITIES	31.12.2025	31.12.2024
Other financial liabilities	3,913	3,911
Costs to be paid	248	252
Interbank settlements	535	520
Liabilities arising from investing activities and internal operations	272	249
Amounts due to suppliers	161	187
Liabilities and settlements in respect of trading in securities	531	505
Settlement of financial instruments	16	22
Liabilities in respect of foreign exchange activities	743	746
Liabilities in respect of payment cards	296	305
Lease liabilities	1,093	1,112
Other	18	13
Other non-financial liabilities	4,426	3,399
Deferred income	610	698
Liability in respect of tax on certain financial institutions	115	106
Liabilities in respect of a contribution to the BFG maintained in the form of payment obligations1	1,052	896
to the Resolution Fund	602	510
to the Bank Guarantee Fund	450	386
Liabilities under the public law	683	563
Commitments relating to the reimbursement of principal and interest instalments paid by customers on invalidated mortgage loan agreements in convertible currencies	931	396
Provision for accrued holiday entitlements	146	122
Provision for other employee benefits	769	503
Other	120	115
Total	8,339	7,310

1Note "Assets pledged to secure liabilities and financial assets transferred".

OTHER FINANCIAL LIABILITIES (Carrying amount)	31.12.2025	31.12.2024
current	3,072	3,039
long-term	841	872
Total	3,913	3,911

40. Provisions

Significant accounting policies:

• provisions for financial liabilities and guarantees granted

The provision is established at the amount of expected credit losses (Note "Net allowances for expected credit losses").

In the portfolio analysis, portfolio parameters estimated using statistical methods are used, based on historical data for exposures with the same characteristics. These parameters define:

• the probability of evidence of impairment,

• the average utilization of an off-balance sheet liability,

• and the expected loss in the event of impairment in subsequent months from the reporting date to the calculation horizon.

For individually significant exposures, the provision is determined on an individual basis - as the difference between the expected amount of the balance sheet credit exposure which will arise from the granted off-balance sheet liability at the time of impairment, and the present value of expected future cash flows from this exposure.

• provisions for legal claims, excluding legal claims relating to mortgage loans in convertible currencies

Provisions include legal claims with counterparties, customers and external institutions (e.g. UOKiK), which are created based on an evaluation of the probability of a court case being lost by the Bank and the expected amount of payment (legal claims Note "Legal claims"). Provisions are recognized in the amount of expected outflow of economic benefits.

• Provisions for potential legal claims against the bank relating to mortgage loans in convertible currencies - Note "Cost of legal risk of mortgage loans in convertible currencies".

• provision for retirement benefits and other defined post-employment benefits

The provision for retirement, disability and death-in-service benefits resulting from the Labor Code is recognized individually for each employee on the basis of an actuarial valuation. The basis for determining the value of provisions are the Bank's internal regulations. The Bank recognizes these provisions in accordance with IAS 19 as a defined benefit plan.

Valuation of provisions is performed using actuarial techniques and assumptions. It takes into account all severance payments that may be paid in the future, based on a list of employees containing the data necessary for the calculation (length of service, age, gender, probability of death in a given year). The provisions correspond to discounted future payments, taking into account staff turnover.

Actuarial gains and losses are recognised in full in other comprehensive income. The Bank recognises employment costs and net interest on the defined benefit obligation in the income statement.

• provisions for consumer protection issues - Note "Legal claims (section: Proceedings before the President of the Office of Competition and Consumer Protection).

• other provisions

They mainl y include the provision for donations to the PKO Bank Polski S.A. Foundation, for potential claims related to the sale of receivables (Note "Information on the sale of impaired loan portfolios"), and for employee disputed claims.

Provisions for future payments are measured at reliably estimated amounts necessary to meet the present obligation as at the end of the reporting period. Other provisions are recognized in the income statement.

Estimates and judgments concerning the provision for retirement benefits and other defined post-employment benefits:

The Bank updated its estimates of provisions using calculations performed by an external actuary.

COMPONENTS AFFECTING THE PROVISION AMOUNT (%)	31.12.2025	31.12.2024
financial discount rate adopted	5.15	5.85
weighted average ratio of employee turnover	8.66	8.94
average remaining period of service in years	7.52	7.51
10-year average assumed annual increase in the basis calculation of retirement benefits	2.67	2.69

The impact of the increase/decrease in the financial discount rate and of the planned increases of 1 p.p. in the provision base on the decrease/increase in the value of the provision is presented in the table below:

ESTIMATED CHANGE IN PROVISION for retirement benefits and other defined post-employment benefits	31.12.2025			31.12.2024
	+1pp scenario		-1pp scenario	+1pp scenario		-1pp scenario
Discount rate	(5)	6		(4)	5
Planned increases in base amounts	8	(6)		6	(5)

Financial information

FOR THE YEAR ENDED 31.12.2025	provisions for financial liabilities and guarantees granted	Provisions for legal claims, excluding legal claims relating to mortgage loans in convertible currencies	Provisions for legal claims against the bank relating to mortgage loans in convertible currencies1,2	Provisions for retirement benefits and other defined post-employment benefits	Restructuring		Provisions for consumer protection issues	Other provisions, including provisions for employee disputed claims		Total
As at the beginning of the period	621	113	5,733	76	23		-	62		6,628
Increases, including increases of existing provisions	1	111	3,037	26	-		408	21		3,604
Utilized amounts	-	(5)	(2,510)	(5)	(6)		-	(52)		(2,578)
Unused provisions reversed during the period	-	(27)	-	(1)	-		-	(2)		(30)
Other changes and reclassifications	(2)	(1)	(2)	-	-		-	(1)		(6)
As at the end of the period	620	191	6,258	96	17		408	28		7,618
Short-term provisions	481	15	2,053	16	17		197	-		2,779
Long-term provisions	139	176	4,205	80	-		211	28		4,839
FOR THE YEAR ENDED 31.12.2024
As at the beginning of the period	748	107	3,001	69	29	-			50	4,004
Increases, including increases of existing provisions	-	22	4,266	12	-	-			51	4,351
Utilized amounts	-	(5)	(956)	(4)	(6)	-			(37)	(1,008)
Unused provisions reversed during the period	(126)	(11)	-	(1)	-	-			(2)	(140)
Other changes and reclassifications	(1)	-	(578)	-	-	-			-	(579)
As at the end of the period	621	113	5,733	76	23	-			62	6,628
Short-term provisions	467	-	1,870	15	23	-			46	2,421
Long-term provisions	154	113	3,863	61	-	-			16	4,207

1 See note “Cost of legal risk of mortgage loans in convertible currencies”.

2 The value of PLN 578 million in 2024 in the line “other changes and reclassifications” relates to the allocation in 2024 of the provision for legal risk of mortgage loans to loans and advances to customers as a deduction from their gross carrying amount.

Provisions for disability and retirement benefits (actuarial provision)	2025	2024
Provision at the beginning of the period	73	67
Current service cost	3	3
Interest expense	4	4
Actuarial (gains) and losses recognized in other comprehensive income	12	2
Benefits paid	(4)	(3)
Provision at the end of the period (net)	89	73

Provisions for death-in-service benefits (actuarial provision)	2025	2024
Provision at the beginning of the period	-	-
Past service cost	5	-
Provision at the end of the period (net)	5	-

Breakdown of actuarial gains and losses (actuarial provision)	Total amount of provisions
	2025	2024
Change in financial assumptions	5	(6)
Change in demographic assumptions	3	1
Other changes	4	7
Total actuarial (gains) and losses	12	2

41. Contingent liabilities and off-balance sheet liabilities received and granted

Significant accounting policies:

For the principles of recognizing provisions for off-balance sheet commitments granted, see the Note "Provisions".

Upon initial recognition financial guarantee agreements are stated at fair value. In subsequent periods, financial guarantees are measured at the higher of the following two amounts: the amount of commission recognized initially, less accumulated amortization in accordance with IFRS 15.

Financial information

• Contractual commitments

VALUE OF CONTRACTUAL COMMITMENTS CONCERNING	31.12.2025	31.12.2024
intangible assets	34	58
property, plant and equipment	18	34
Total	52	92

• Financial liabilities and guarantees granted

For information on credit risk exposures, see note “Credit risk – financial information”.

FINANCIAL AND GUARANTEE COMMITMENTS GRANTED 31.12.2025	Notional amount	Provisions per IFRS 9	Value less provisions
Credit lines and limits	93,089	(556)	92,533
real estate	8,096	(17)	8,079
business	72,024	(441)	71,583
consumer	12,969	(98)	12,871
Other	3,587	-	3,587
Total financial commitments granted, including:	96,676	(556)	96,120
irrevocable commitments granted	46,863	(294)	46,569

guarantees in domestic and foreign trading	13,036	(60)	12,976
to financial entities	4,739	(14)	4,725
to non-financial entities	8,214	(46)	8,168
to state budget entities	83	-	83
domestic corporate bonds (to financial entities)	1,000	-	1,000
domestic municipal bonds (state budget entities)	80	-	80
letters of credit	1,485	(4)	1,481
to financial entities	60	-	60
to non-financial entities	1,425	(4)	1,421
payment guarantees to financial entities	77	-	77
Total guarantees and sureties granted, including:	15,678	(64)	15,614
irrevocable commitments granted	13,071	(60)	13,011
performance guarantee	4,525	(27)	4,498
Total financial and guarantee commitments granted	112,354	(620)	111,734

FINANCIAL AND GUARANTEE COMMITMENTS GRANTED 31.12.2024	Notional amount	Provisions per IFRS 9	Value less provisions
Credit lines and limits	87,483	(544)	86,939
real estate	6,716	(30)	6,686
business	69,027	(402)	68,625
consumer	11,740	(112)	11,628
Other	3,940	-	3,940
Total financial commitments granted, including:	91,423	(544)	90,879
irrevocable commitments granted	41,536	(306)	41,230

guarantees in domestic and foreign trading	11,822	(74)	11,748
to financial entities	4,116	(1)	4,115
to non-financial entities	7,676	(73)	7,603
to state budget entities	30	-	30
domestic corporate bonds (financial entities)	1,000	-	1,000
domestic municipal bonds (state budget entities)	138	-	138
letters of credit	1,488	(3)	1,485
to financial entities	31	-	31
to non-financial entities	1,457	(3)	1,454
payment guarantees to financial entities	93	-	93
Total guarantees and sureties granted, including:	14,541	(77)	14,464
irrevocable commitments granted	11,915	(73)	11,842
performance guarantee	3,788	(46)	3,742
Total financial and guarantee commitments granted	105,964	(621)	105,343

Additionally, as at 31 December 2025, the Bank also had commitments granted in respect of binding offers amounting to PLN 5,779 million, relating mainly to the financing of business loans, mortgage loans and loans to individuals, as well as organizing bond issues for local government units.

• nominal value of commitments granted by maturity

COMMITMENTS GRANTED BY MATURITY AS AT 31.12.2025	up to 1 month (inclusive)	1 to 3 months (inclusive)	More than 3 months up to 1 year (inclusive)	More than 1 year up to 5 years (inclusive)	More than 5 years	Total
financial	7,096	4,738	34,678	29,580	20,584	96,676
guarantees and sureties	430	1,199	5,932	6,223	1,894	15,678
Total	7,526	5,937	40,610	35,803	22,478	112,354

31.12.2024
financial	16,879	5,663	27,955	28,956	11,970	91,423
guarantees and sureties	770	1,080	3,496	6,779	2,416	14,541
Total	17,649	6,743	31,451	35,735	14,386	105,964

• Off-balance sheet liabilities received

OFF-BALANCE SHEET LIABILITIES RECEIVED BY NOMINAL VALUE	31.12.2025	31.12.2024
Financial	253	106
Guarantees	20,202	20,123
Total	20,455	20,229

• synthetic securitization transaction

On 12 May 2025, the Bank concluded a package of agreements with a private investor, Christofferson, Robb & Company, acting through one of its investment vehicles, concerning a synthetic securitization transaction carried out on a portfolio of corporate loans with a nominal value of PLN 1,892 million (as at 28 February 2025). The Transaction was the first operation of this kind in the Bank's history. As part of the concluded transaction, the Bank transferred to the investor a significant part of the credit risk from the selected portfolio subject to securitization without the need to sell it. The selected portfolio of corporate loans covered by the securitization remains in the Bank's statement of financial position.

The risk transfer of the securitized portfolio is carried out through a credit protection instrument in the form of a financial guarantee secured by a deposit placed with the Bank. The transaction meets the requirements for significant risk transfer specified in the CRR Regulation and has been structured as meeting the STS criteria (simple, transparent, and standardized securitization) in accordance with Regulation (EU) 2017/2402 of the European Parliament and of the Council of 12 December 2017.

• guarantee agreement

On 30 January 2025, the Bank concluded an amendment to the guarantee agreement providing unfunded credit protection in respect of a portfolio of selected corporate credit receivables of the Bank, in accordance with the CRR (“Guarantee”). Following the execution of this annex, the terms and conditions of the Guarantee changed to the effect that the total value of the Bank's debt portfolio covered by the Guarantee was PLN 16,886 million, and the portfolio consisted of the bond portfolio of PLN 2,365 million (“Portfolio A”) and the portfolio of other receivables of PLN 14,521 million (“Portfolio B”). The coverage ratio is 100% for Portfolio A and 80% for Portfolio B, with the total maximum amount of the Guarantee remaining unchanged at PLN 13,982 million.

42. Legal claims

The total value of court proceedings in which the Bank acts as:	31.12.2025	31.12.2024
defendant	13,798	15,526
plaintiff	5,861	6,834

• Material litigation concerning credit products offered by the Bank

As at 31 December 2025, the Bank participates in court proceedings related to three main categories of credit products: mortgage loans in convertible currencies (mainly CHF), mortgage loans bearing interest at a floating rate (WIBOR), and consumer loans subject to the so-called free credit sanction.

1) mortgage loans in convertible currencies

As at 31 December 2025, 31,997 court proceedings were pending against the Bank with a total value in dispute of PLN 13,343 million (as at 31 December 2024: 36,004 proceedings amounting to PLN 14,764 million).

The subject matter of the claims are mainly demands for declaration of invalidity of agreements or for repayment of performance rendered by customers in execution of allegedly invalid agreements. Customers allege abusive provisions and/or that the agreements are contrary to the law. None of the clauses used by the Bank in the agreements was entered in the register of prohibited contractual clauses. In the Bank's assessment, the number of proceedings is strongly influenced by marketing campaigns of law firms, which encourage borrowers to file lawsuits.

The Bank monitors on an ongoing basis the case law of national and EU courts in foreign currency loan cases.

By 31 December 2025, 15,542 final rulings were issued in the Bank's cases, the vast majority of which were favourable to borrowers.

On 25 April 2024, in case ref. III CZP 25/22, the Supreme Court, sitting as the full Civil Chamber, issued a resolution which has the force of law. In this resolution, the Supreme Court held, inter alia, that after finding the exchange rate clause to be abusive, it cannot be replaced by another mechanism, and consequently the agreement is not binding in its entirety. It was also indicated that the parties have independent claims for the repayment of wrongful performance, and the limitation period of the Bank's claim for repayment of the disbursed principal begins to run, in principle, from the day the agreement was challenged by the customer. However, the parties to the agreement are not entitled to interest until there is a delay in the repayment of the performance, nor to other consideration for the use of the capital.

The Bank files lawsuits for the repayment of disbursed capital (restitution lawsuits). As at 31 December 2025, 19,599 such cases were pending in the Bank, for a total amount of PLN 6,022 million (as at 31 December 2024: PLN 18,827 million). Additionally, restitution claims are raised as alternative claims in other cases, including debt collection proceedings.

On 19 June 2025, in case C-396/24, the CJEU issued a judgment in which it held, inter alia, that Article 7(1) of Directive 93/13 precludes national regulations which allow the seller or supplier to demand reimbursement of the entire nominal amount of the loan, irrespective of the repayments made by the consumer.

In July 2025, the Regional Court in Warsaw referred a request for a preliminary ruling to the CJEU concerning, inter alia, whether the provisions of the above-mentioned Directive preclude the application, in the settlement between the parties to an invalid loan agreement, of an arrangement under which the consumer's claim for reimbursement of payments made in performance of such an agreement is ex officio set off by the court against the bank's claim for reimbursement of the loan capital disbursed, with the result that, in the view of the court, the consumer's claim on this basis arises only when the sum of his payments exceeds the amount of the loan capital disbursed (C-510/25). The Bank submitted a written position on this matter.

On 27 November 2025, in case C-746/24, the CJEU ruled that Article 6(1) and Article 7(1) of Council Directive 93/13 preclude national legislation allowing a consumer – acting as a defendant who has lost a case in an action for the return of borrowed capital, brought by a seller or supplier following the invalidation of a credit agreement due to the unfair nature of its terms – to be charged with the costs of proceedings, including court fees, which, due to the differentiation introduced by that legislation when calculating the amount of those fees depending on whether the claimant has the status of a consumer, significantly exceed the costs that consumer would have had to bear if he or she had lost the case in an action brought by him or her.

On 11 December 2025, in case C-767/24, the CJEU ruled that Article 7(1) of Directive 93/13, in connection with the invalidity of a credit agreement as a result of the elimination of prohibited contractual provisions from it, must be interpreted as meaning that it precludes national case-law according to which the submission by a consumer of a declaration of set-off of his or her claim against the bank's claim entails an implicit waiver of the statute of limitations objection regarding the bank's claim.

In 2024, the Regional Court in Warsaw referred a preliminary ruling question to the CJEU (ref. C-753/24) concerning the compatibility with EU law of national provisions allowing for the grant of a time-barred claim by the Bank if equity considerations so require. The question concerns the interpretation of Article 7(1) of Directive 93/13 and the principles of effectiveness, proportionality, legal certainty and access to justice. The Bank and other parties, including the European Commission and the Republic of Poland, submitted written observations. The Bank submitted a request for oral proceedings before the CJEU.

In 2025, the Regional Court in Warsaw in the Bank's cases referred further questions for a preliminary ruling as to whether the set-off of mutual claims made by a consumer may deprive him or her of the right to default interest on his or her claim extinguished by the set-off.

On 22 January 2026, in case C-902/24, the CJEU indicated that a seller or supplier may effect an alternative set-off, i.e. in the event that the agreement is declared invalid, however, the seller's or supplier's claim for the return of capital becomes due only after the dispute over the validity of the agreement has ended.

In the Bank's assessment, both the CJEU case law and the practice of applying the Supreme Court resolution will be of material significance for the further course of proceedings concerning foreign currency loans.

2) MORTGAGE LOANS BEARING INTEREST AT A FLOATING RATE

As at 31 December 2025, 635 court proceedings were pending against the Bank (as at 31 December 2024: 302), in which customers challenge the floating interest rate structure and the rules for setting the WIBOR benchmark rate. The total value of the subject matter of litigation in these cases was PLN 153 million (as at 31 December 2024: PLN 81 million). The Bank has not established a provision for the above proceedings, assessing the claims as unfounded.

In cases brought by clients against the Bank, Regional Courts referred requests for a preliminary ruling to the CJEU concerning the possibility of examining contractual clauses relating to:

1) On 31 May 2024, the Regional Court in Częstochowa (Case C-471/24) – interest rates based on the WIBOR index in light of the provisions of Council Directive 93/13/EEC, in particular:

• whether examination of these clauses as potentially unfair is possible,

• whether these clauses may be regarded as non-transparent or as causing a contractual imbalance to the detriment of the consumer,

• and whether it is possible to maintain the contract in force with an interest rate based solely on the bank's margin (i.e. with a fixed interest rate), in the event of elimination of the WIBOR index.

The preliminary ruling request has been served on the Bank, which submitted a written position on the case. The hearing took place on 11 June 2025, and on 11 September 2025 the Opinion of the Advocate General of the CJEU was delivered. On 12 February 2026, the CJEU ruled that a variable interest rate clause based on a benchmark index, such as WIBOR, may be examined in the light of Directive 93/13/EEC, provided that national courts are not entitled to examine the methodology for determining the WIBOR index, as it results from the EU BMR Regulation. Furthermore, the transparency requirement provided for in the Directive does not impose an obligation on the bank to provide the consumer with detailed information on the methodology of the benchmark index, and any failure by the bank to provide information on the specific features of the benchmark index, including the lack of transactionality or the provision of input data by the bank, does not mean that the clause is abusive. The CJEU also indicated that if the abusiveness of a clause is to be assessed, the contractual interest rate should be compared, inter alia, with the statutory interest rate and the interest rate on loans commonly applied on the market.

2) On 30 June 2025, the Regional Court of Warsaw-Praga in Warsaw (ref. C-586/25):

• whether a claim seeking to deprive an enforceable title of enforceability constituted by a final order for payment may be granted where the basis for the consumer's claim is the allegation that the credit agreement contains unfair terms, although the defendants — despite having been served with a copy of the order for payment — failed to lodge objections to that order within the statutory time limit;

• whether a contractual term (in an agreement concluded before the entry into force of the BMR) introducing a variable interest rate clause can be regarded as drafted in plain and intelligible language where:

• the bank informed the borrower that the interest rate consists of a margin and a reference index;

• the bank did not inform the borrower how and by whom the reference index is determined, nor how it fluctuated in previous years;

• the agreement in the scope of the benchmark index refers to an external information service to which the consumer is not guaranteed access throughout the entire lending period and the period after the expiry of the agreement, when he or she may invoke the rights resulting from the inclusion of unfair terms in it.

• whether, in a consumer credit agreement, a term providing that the factor influencing changes in the interest rate is the WIBOR reference index — which, on the date the credit agreement was concluded by the parties, was not regulated by binding statutory provisions but was determined by a third party not subject to institutional supervision, and the lending bank had an indirect influence on the level of that index — causes a significant imbalance in the parties' rights and obligations to the detriment of the consumer;

• whether, if the term determining a variable interest rate is found to be unfair due to its reference to the WIBOR reference index, the parties may remain bound by the credit agreement on the assumption that it is a fixed-rate loan at the level of the bank's fixed margin specified in the agreement, or whether the consequence of the consumer not being bound by the unfair term determining the variable interest rate is that the agreement must be declared null and void ex tunc.

3) On 25 September 2025, the Regional Court in Warsaw (ref. C-630/25) - of an agreement concluded before 1 January 2018 relating to:

• Directive 93/13 imposes on a bank an obligation to inform the consumer of:

a) the entity which develops the reference index forming the basis of the loan interest rate;

b) the detailed rules governing the determination of that reference index underlying the loan interest rate, including, in particular, providing the consumer with the text of the rulebook containing those rules and informing the consumer that the index is calculated on the basis of declarations by a group of banks rather than actual market transactions;

• under Directive 93/13, whether a contractual term determining the loan interest rate which uses a reference index may be regarded as unfair where that index:

a) is calculated on the basis of declarations by a group of banks rather than actual market transactions;

b) is not defined in national or EU law but in the internal rulebook of an association established by banks or bank employees, and no State authority supervises the manner in which that index is developed;

c) does not reflect the actual costs of financing the loan.

Case C-586/25 has been joined for joint examination with case C-630/25. The request for a preliminary ruling has been served on the Bank, which submitted a written position on the joined cases.

3) LITIGATION AGAINST THE BANK CONCERNING THE FREE CREDIT SANCTION

As at 31 December 2025, there were 6,676 court proceedings pending against the Bank relating to the free credit sanction, with a total value in dispute of PLN 179 million (as at 31 December 2024: 4,212 proceedings with a value of PLN 100 million). These proceedings are initiated by customers or entities that have acquired receivables from customers and relate to the provisions of cash loan agreements. The Bank disputes the validity of the claims raised in these cases, and the case law to date is largely in favour of the Group. The Bank had not set up a provision for these proceedings.

By order of 25 January 2024, the District Court for Warsaw-Śródmieście addressed preliminary ruling questions to the CJEU concerning, inter alia:

• the possibility of assignment of consumer rights to a third party who is not a consumer,

• the court's obligation to examine of its own motion unfair terms in claim assignment agreements.

The proceedings were pending under case number C-80/24. The Bank submitted a written position. On 30 April 2025, the Advocate General's opinion was delivered. The judgment was delivered on 9 October 2025.

By order of 19 July 2024, the Regional Court in Poznań referred legal issues to the Supreme Court (ref. III CZP 15/25) concerning, inter alia:

• the scope of the court's obligation in examining the free credit sanction,

• the time limit for the expiry of the right to submit a statement regarding the sanction,

• the grounds for applying the free credit sanction,

• the principles of charging interest on non-interest costs of the loan,

• the effects of incorrect calculation of the annual percentage rate.

On 30 July 2025, a session of the Supreme Court was held, at which an order was issued to suspend the case until the resolution of cases pending before the CJEU (concerning other banks: C-566/24 of 21 August 2024, C-744/24 of 24 October 2024, and concerning the Bank described below - C-831/24).

By order of 19 November 2024, the District Court in Białystok referred preliminary ruling questions to the CJEU concerning the obligations of the national court when examining claims relating to the free credit sanction, including:

• the scope of examining infringements of legal provisions,

• requirements concerning the early repayment procedure,

• the effects of the absence of a complete description of this procedure.

The proceedings are pending under case number C-831/24. The Bank submitted its written position in April 2025.

By order of 28 March 2025, the Regional Court in Opole (ref. C-429/25) addressed a question to the CJEU regarding the interpretation of provisions on sanctions for breaching the information obligation in consumer credit agreements. The preliminary ruling request has been served on the Bank. The Bank submitted its written observations within the prescribed deadline.

By order of 22 May 2025, the District Court for Kraków-Nowa Huta in Kraków (ref. C-473/25) referred questions for a preliminary ruling to the CJEU concerning the obligations of a national court when hearing claims arising from the free credit sanction, including:

• the conformity of the Consumer Credit Act with the Directive on credit agreements for consumers;

• whether the nature of the infringement is relevant when applying the free credit sanction;

• the principles of charging interest on non-interest costs of the loan,

• the manner in which the total amount of loan is defined in the agreement.

The preliminary ruling request has been served on the Bank. The Bank submitted its written observations within the prescribed deadline.

In a case (concerning another bank, ref. No C-472/23) the CJEU issued a ruling on 13 February 2025, stating that:

• the specification of an overstated APRC in a credit agreement, as a consequence of certain terms of that agreement being found to be unfair, does not in itself constitute an infringement of the obligation to provide information,

• the indication in a credit agreement of circumstances justifying an increase in charges, where a reasonably observant and circumspect consumer is not in a position to ascertain whether they have arisen and their effect, constitutes an infringement of the obligation to provide information, where it calls into question the possibility for the consumer to assess the extent of his or her liability,

• In the event of an infringement of the obligation to provide information, the bank may be deprived of its right to interest and charges, where that infringement affects the consumer’s ability to assess the extent of his or her liability, with the verification falling within the competence of the national court.

• Proceedings before the President of the Office of Competition and Consumer Protection (UOKiK)

1) Proceedings relating to modification clauses

The proceedings were initiated on 12 March 2019 and concern provisions of the template agreement enabling the Bank to unilaterally amend the terms and conditions of the agreement, including fees and commission. In the opinion of the President of UOKiK, these clauses give the Bank unlimited freedom in shaping the content of the agreement, which may violate good practice and be a gross violation of consumers' interests. In its response of 31 May 2019, the Bank challenged the validity of the allegations, indicating that the provisions are precisely defined and clearly specify the conditions for their application. In the course of the proceedings, UOKiK issued summonses to provide additional information, including by orders of 7 June 2022 and 19 April 2024. The Bank provided responses respectively on: 11 July and 30 September 2022 and 24 May and 27 June 2024. On 1 September 2025, the Bank submitted to the UOKiK information on the amount of turnover achieved in 2024. By a summons dated 11 February 2026, the Bank was obliged to provide further information in connection with the proceedings. The current deadline for the conclusion of the proceedings, as indicated by the UOKiK, is 30 June 2026. In 2025, the Bank recognised a provision for these proceedings in the amount of PLN 211 million.

2) Proceedings in respect of unauthorised transactions

The proceedings were initiated on 2 February 2024 and concern two main practices of the Bank which, in the opinion of UOKiK, may violate the collective interests of consumers:

• informing consumers, in responses to reports of unauthorised transactions, about establishing their responsibility for unauthorised transactions solely on the basis of a correct authentication process, without specifying concrete evidence of gross negligence or intentional action, which may breach Article 45(2) of the Act on payment services,

• withdrawing the conditional refund in the case of negative investigation of the complaint, which – according to UOKiK – may be inconsistent with Article 46(1) of the same Act.

In a letter of 27 March 2024, the Bank challenged the allegations, claiming that they were unfounded, and on 26 June 2024 declared its willingness to engage in discussions with UOKiK in order to find a solution that takes into account the interests of both parties. In a letter to UOKiK of 9 May 2025, the Bank presented proposals for commitments, and on 28 May 2025 a meeting with UOKiK took place at which these were discussed. The Bank provided further information in letters dated 11 June 2025, and 10 July 2025. On 29 July 2025, the Bank received a proposal for a Uniform Commitment Statement, to which it responded on 1 September 2025. On 7 October 2025, a meeting was held between the banks and the Polish Bank Association (ZBP) and the Office of Competition and UOKiK concerning the UOKiK’s proposal. On 29 October 2025, workshops were held to discuss the Uniform wording of the commitment, which were attended by the banks subject to the proceedings and the UOKiK. On 16 December 2025, the Bank sent a letter to the UOKiK supplementing the commitment proposal. On 15 January 2026, the UOKiK sent the Bank a supplement to the template of the uniform wording of the commitment, and on 4 February 2026, the Bank received another request from the UOKiK, to which it replied on 18 February 2026. The current deadline for the conclusion of the proceedings, as indicated by the UOKiK, is 30 September 2026. In 2025, the Bank recognised a provision for these proceedings in the amount of PLN 197 million.

3) proceedings relating to interest rate variation clauses

The proceedings were initiated by a decision of 5 April 2024 and relate to clauses contained in contractual templates which allow the Bank to change the interest rate on the revolving limit based on changes in the basic NBP interest rates or WIBOR benchmark rates (1M, 3M, 6M, 9M, 12M). UOKiK challenged:

• the possibility of changing the interest rate in the event of a change in rates by at least 0.25 percentage points (for NBP rates) or 0.10 percentage points (for WIBOR), to an extent reaching even three times these changes,

• the possibility of making a change to the interest rate within six months of the occurrence of the grounds for the change.

In its response of 29 May 2024, the Bank deemed the allegations unfounded. On 25 April 2025, the Bank provided additional information concerning turnover and the number of active contracts containing the challenged provisions as well as information about refraining from submitting commitments. On 27 May 2025, UOKiK requested the provision of further information, which was provided by the Bank on 9 June 2025. On 27 October 2025, the UOKiK requested the Bank to provide further explanations in the case, which were submitted on 4 November 2025. On 7 November 2025, the UOKiK notified the Bank of the conclusion of the evidentiary proceedings. The Bank responded to this notice on 19 November 2025. On 8 and 22 December 2025, the UOKiK requested the Bank to provide further information, which was provided on 19 and 31 December 2025, respectively. On 2 January 2026, the UOKiK notified the Bank of the conclusion of the evidentiary proceedings.

On 23 January 2026, the UOKiK issued a decision in which it declared the provisions of the template agreements applied by the Bank as inadmissible and prohibited their use. In addition, the President of UOKiK:

• ordered the Bank to inform all consumers being parties to annexes to agreements concluded on the basis of template agreements whose provisions were declared inadmissible and about the consequences of this declaration – within one month from the effective date of the decision,

• imposed an obligation to publish an appropriate declaration on the Bank's website for a period of four months, no later than within one month from the effective date of the decision, and on the account maintained by the Bank on the Instagram social networking site in the specified period and frequency,

• imposed a fine on the Bank of PLN 79.3 million, payable to the Financial Education Fund.

The decision is not final. On 20 February 2026, the Bank filed an appeal against the decision. The Bank recognized a provision for the proceedings relating to interest rate variation clauses in the amount of PLN 79.3 million.

• Proceedings before the court of competition and consumer protection

1) Proceedings on spread clauses

The proceedings were initiated by the Bank’s appeal (submitted on 13 November 2020) against the decision of the President of UOKiK dated 16 October 2020. In the said decision, the President of UOKiK declared the provisions contained in the template agreement "Annex to the housing loan/mortgage loan agreement" in the section "Appendix to the annex 'Rules for determining foreign exchange spreads at PKO BP S.A.'" as inadmissible provisions and prohibited their further use. In addition, the President of UOKiK:

• obliged the Bank to inform all consumers being parties to the indicated annexes about the decision to declare their provisions inadmissible and the consequences of this decision - within three months from the effective date of the decision

• imposed the obligation to publish an appropriate declaration on the Bank's website for a period of four months, no later than within one month from the effective date of the decision;

• imposed a fine on the Bank of PLN 40.7 million, payable to the Financial Education Fund.

In its appeal against the decision, the Bank requested that it be annulled or amended, challenging the validity of declaring the indicated contractual provisions as inadmissible, the legality and proportionality of the interference of the President of the UOKiK in the Bank's pricing policy, as well as the abnormally high – in the Bank's opinion – penalty amount. The President of UOKiK sustained its position in response to the appeal. In a judgment of 10 October 2023, the Court of Competition and Consumer Protection (SOKiK) overturned the decision of the President of UOKiK in its entirety. However, as a result of appeals filed by the President of UOKiK and the public prosecutor, the Court of Appeal in Warsaw, in a judgment of 5 July 2024, amended the judgment of SOKiK and dismissed the Bank's appeal. The Bank filed a request for a statement of reasons, a request to suspend enforcement of the judgment and decision, and then - on 4 November 2024 - filed a cassation complaint. By order of 12 July 2024, the Court of Appeal halted enforcement of the appealed judgment and the decision of the President of UOKiK pending completion of the proceedings before the Supreme Court. On 11 December 2024, the UOKiK's response to the cassation complaint was received. On 14 February 2025, the Supreme Court notified the composition of the adjudicating panel and assigned a case reference number. The Bank recognizes a provision for these proceedings of PLN 41 million (no changes compared to 31 December 2024).

2) Proceedings related to restrictive practices on the market of payments with payment cards in Poland

The Bank is a party to proceedings initiated by the President of UOKiK on the basis of a decision dated 23 April 2001 upon the request of the Polish Trade and Distribution Organization – Employers Association (Polska Organizacja Handlu i Dystrybucji – Związek Pracodawców) against operators of the Visa and Europay payment systems and banks issuing Visa and Europay/ Eurocard/ Mastercard banking cards. The proceedings concern the suspicion of applying practices limiting competition on the market of card payments in Poland, in particular through joint determination of interchange fees and limiting access to the market for external entities. By decision of 29 December 2006, the President of UOKiK found that these practices restrict competition and imposed a fine of PLN 16.6 million on the Bank. Following the Bank's appeal, the Court for Competition and Consumer Protection (SOKiK) in a judgment of 21 November 2013 reduced the fine to PLN 10.4 million. As a result of appeals by the parties, the Court of Appeal in Warsaw in a judgment of 6 October 2015 reinstated the original fine of PLN 16.6 million and PLN 4.8 million against Nordea Bank Polska S.A., of which the Bank is the legal successor. The fine was paid by the Bank in October 2015, but after the judgment was annulled by the Supreme Court (judgment of 25 October 2017) and the case was submitted for re-examination, it was reimbursed to the Bank on 21 March 2018. In subsequent proceedings, on 23 November 2020, the Court of Appeal in Warsaw revoked the judgment of the Warsaw District Court of 2013 and submitted it for re-examination. The case is currently proceeding again at first instance before the Warsaw District Court. The Bank maintains a provision for these proceedings of PLN 21 million (no changes compared to 31 December 2024).

• proceedings before the Polish Financial Supervision Authority

1) The PFSA is conducting proceedings against the Bank, operating through an organizationally separate unit - the Brokerage Office, regarding the imposition of an administrative penalty in connection with suspected violations of the Act on counteracting money laundering and terrorist financing ("AML"). The Bank provided explanations concerning, inter alia, benefits or avoided losses resulting from violations, potential losses of third parties and possible penalties imposed under the AML Act. The PFSA also informed the Bank about forwarding a letter to the GIFI requesting information on the Bank's AML violations to date. The deadline for the conclusion of the administrative proceedings was planned for 30 September 2025. On 24 October 2025, at the request of the PFSA, the Bank indicated an address for electronic service. On 23 December 2025, a new deadline for the conclusion of the proceedings was set for 3 March 2026. On 9 January 2026, the PFSA modified the subject matter of the proceedings and on 4 February 2026 informed that it intended to conclude the proceedings, pointing to the possibility for the Bank to provide additional comments on the evidence and materials collected in these proceedings. The Bank replied on 12 February 2026. The Bank has not recognized a provision for this.

2) The PFSA is conducting administrative proceedings against the Bank regarding the imposition of sanctions pursuant to Article 3c of the Act on financial market supervision. The proceedings concern suspected breach by the Bank of the provisions of Regulation (EU) No 1286/2014 on key information documents for packaged retail and insurance-based investment products (PRIIPs), in particular Article 5(1) and Article 14 in conjunction with Article 4(1), (3), (4) and (5). On 20 June 2025, the PFSA informed about extending the scope of the administrative proceedings by changing the period under examination, i.e. changing the existing period from 15 May 2024 to 10 October 2024 to a new period from 1 January 2018 to 27 June 2024, and about changing the legal basis of the suspected violation indicated in this notice from Article 14 PRIIPs to Article 13(1) PRIIPs. On 13 February 2026, the PFSA informed about the change in the scope of the proceedings and the extension of the proceedings until April 2026. The Bank has not recognized a provision for this.

3) The PFSA is conducting administrative proceedings against the Bank pursuant to Article 138(7a) of the Banking Law Act regarding the imposition of a financial penalty in connection with suspected violations by the Bank of the provisions on structured deposits set out in the Banking Law Act and in the Regulation of the Minister of Finance of 21 January 2019 on the provision of services by banks in relation to structured deposits. The proceedings are pending. The Bank had not set up a provision for these proceedings.

4) The PFSA is conducting administrative proceedings against the Bank for the imposition of an administrative penalty on the Bank in connection with a suspected failure by the Bank to comply with obligations arising from the Act on counteracting money laundering and terrorist financing. The conclusion of the proceedings is planned for 6 March 2026. The Bank has not recognized a provision for this.

• other proceedings

1) Proceedings before the general inspector of financial information (GIFI)

The GIFI is conducting administrative proceedings against the Bank for the imposition of an administrative penalty for failure to comply with its obligations under the Act of 1 March 2018 on the prevention of money laundering and terrorist financing (AML). The failure to comply with obligations was identified by the PFSA during an inspection conducted at the Bank from 22 December 2022 to 9 March 2023, covering: (a) the period from 13 July 2018 to 22 December 2022 with regard to the implementation of the obligation specified in Article 72 of the AML Act, (b) the period from 20 July 2021 to 22 December 2022 with regard to the implementation of the other obligations specified in the AML Act. The Bank responded to the GIFI's letter, also requesting to refrain from imposing an administrative penalty due to the corrective actions taken. On 26 November 2025 and 28 January 2026, the Bank received requests from the GIFI to provide explanations in the matter. The Bank responded to the requests on 10 December 2025 and 4 February 2026, respectively. On 18 February 2026, the GIFI requested the Bank to answer questions in the matter. The deadline for the conclusion of the proceedings was extended until 31 March 2026. In 2025, the Bank recognized a provision for these proceedings in the amount of PLN 15 million.

2) Proceedings before the Head of the Customs and Tax Office

The Head of the Mazovian Customs and Tax Office in Warsaw (hereinafter, the “Head”) initiated proceedings to impose a financial penalty on the Bank in connection with the violation of Article 1(1) in connection with Article 2(1) of the Act on special solutions in the field of counteracting aggression in Ukraine and Article 1(1) of Council Regulation No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and Belarus' participation in Russia's aggression against Ukraine. Due to the explanations submitted to the Head, the Bank requested that no administrative penalty be imposed. The Bank has not recognised a provision for these proceedings. By a decision dated 14 November 2025, the imposition of a financial penalty was waived.

3) Claims for damages in respect of the interchange fee

The Bank was served eight summons to participate, as an outside intervener on the defendant’s side, in cases relating to the interchange fees. Other banks are defendants in the case and, in some cases, also card organizations. At present, the total value of the claims amounts to PLN 830 million and concerns damages for excessive interchange fees resulting from practices that restrict competition, as well as capitalised statutory interest for delay.

The Bank joined these proceedings as an outside intervener. Since these proceedings are not pending against the Bank, their value was not included in the total value of the cases against the Bank. If the courts find the claims justified, the defendants may claim recourse in separate court proceedings from other banks including from the Bank.

As at 31 December 2025, five of these proceedings resulted in final judgments in favour of the defendants dismissing the plaintiffs' claims (including a partial judgment). A cassation appeal was filed in one case. In the remaining proceedings, non-final judgments were issued dismissing the plaintiffs' claims. In all cases, the objection of the statute of limitations was upheld.

43. Equity and shareholding structure of the Bank

Significant accounting policies:

Equity constitutes capital and reserves created in accordance with the legal regulations. The classification to particular components results from the Polish Commercial Companies Code, the Banking Law and the requirements of IAS 1.

Selected equity components:

• Share capital is the capital of the Bank, stated at the nominal value in accordance with the Articles of Association and entry in the Register of Businesses.

• Supplementary capital is created according to the Articles of Association of the Bank, from annual write-downs from net profit, made until this capital reaches at least one third of the share capital. It is intended to cover balance sheet losses or for other purposes, including increasing the share capital.

• General banking risk fund is created from net profit in accordance with the Banking Law, and it is to cover unidentified risks of the Bank’s operations.

• Other reserves are created from the appropriation of net profit, intended to cover any potential balance-sheet losses or for other purposes, including the payment of dividends, interim dividends or the purchase of own shares for cancellation.

Financial information

• Shareholding structure of the Bank

According to the information available as at 31 December 2025, the Bank’s shareholding structure is as follows:

ENTITY NAME	number of shares	% of votes	Nominal value of 1 share	Ownership interest (%)
As at 31 December 2025
State Treasury	367,918,980	29.43%	PLN 1	29.43%
Nationale Nederlanden Otwarty Fundusz Emerytalny1	91,532,147	7.32%	PLN 1	7.32%
Allianz Polska Otwarty Fundusz Emerytalny1	75,052,392	6.01%	PLN 1	6.01%
Other shareholders2	715,496,481	57.24%	PLN 1	57.24%
Total	1,250,000,000	100%	---	100%
As at 31 December 2024
State Treasury	367,918,980	29.43%	PLN 1	29.43%
Nationale Nederlanden Otwarty Fundusz Emerytalny1	98,669,361	7.89%	PLN 1	7.89%
Allianz Polska Otwarty Fundusz Emerytalny1	83,713,383	6.70%	PLN 1	6.70%
Other shareholders2	699,698,276	55.98%	PLN 1	55.98%
Total	1,250,000,000	100%	---	100%

1 Calculation of shareholdings as at the end of the year published by PTE in bi-annual and annual information about the structure of fund assets and quotation from Bloomberg.

2 Including Bank Gospodarstwa Krajowego, which as at 31 December 2025 and 31 December 2024 held 24,487,297 shares carrying 1.96% of the votes at the GSM.

All shares of the Bank carry the same rights and obligations. No shares are preference shares – one share carries one vote. The Bank's Articles of Association limit the voting rights of shareholders holding more than 10% of the total number of votes at the General Shareholders’ Meeting, prohibiting them from exercising more than 10% of the votes. The restriction does not apply to:

• the State Treasury and BGK (shareholders holding >10% of the votes on the date of introducing the limitation),

• A-series registered shares (the State Treasury),

• shareholders acting jointly with the above based on an agreement.

The limitation expires when the share of the State Treasury in the share capital drops below 5%. In accordance with § 6 (2) of the Articles of Association, the conversion of A-series registered shares into bearer shares or their transfer requires the approval of the Council of Ministers. After obtaining the approval, the restrictions expire to the extent covered by the approval. Pursuant to Article 13(1)(26) of the Act on the rules for managing the State property, the shares of PKO Bank Polski S.A. owned by the State Treasury may not be sold (excluding statutory exceptions).

The Bank’s shares are listed on the Warsaw Stock Exchange.

• Structure of PKO Bank Polski S.A.’s share capital:

Series	Type of shares	Number of shares	Notional amount of 1 share	Nominal value of the series in PLN
A Series	ordinary registered shares	312,500,000	PLN 1	312,500,000
A Series	ordinary bearer shares	197,500,000	PLN 1	197,500,000
B Series	ordinary bearer shares	105,000,000	PLN 1	105,000,000
C Series	ordinary bearer shares	385,000,000	PLN 1	385,000,000
D Series	ordinary bearer shares	250,000,000	PLN 1	250,000,000
Total	- - -	1,250,000,000	- - -	1,250,000,000

The amount of the Bank’s share capital did not change in 2025 and 2024. The issued shares of the Bank carry no preference and are fully paid-up.

FAIR VALUE OF FINANCIAL INSTRUMENTS

44. Fair value hierarchy

Significant accounting policies

Depending on the classification of financial assets and liabilities to a specific level of the hierarchy, different methods of fair value measurement are used.

Level 1: Prices quoted on active markets

In Level 1, the Bank classifies financial instruments for which there is an active market and for which the fair value is determined with reference to market prices:

• debt securities valued at prices from the "Treasury Bonds Fixing" organized by the NBP, quotations from the BondSpot platform, or valuations published by Bloomberg and LSEG (if they relate directly to the specific security),

• debt and equity securities which are traded on regulated markets, including in the Biuro Maklerskie PKO BP portfolio;

• derivative instruments, which are traded on a regulated market.

Level 2: Valuation techniques based on observable market data

In Level 2, the Bank classifies financial instruments for which there is no active market but for which there are observable inputs:

financial assets and liabilities measured at fair value	valuation method (technique)	observable inputs
cirs, irs, fra	Discounted cash flow valuation model	Yield curves built on market data: money market rates, FRA, IRS, OIS, basis swap
fx forwards and fx swaps	Discounted cash flow valuation model	Yield curves built on market data: exchange rates, swap points, basis swaps
currency options	Valuation models specific for particular type of a foreign exchange option.	Yield curves built on market data: exchange rates, swap points, basis swaps; volatility surfaces for relevant currency pairs
interest rate options	Valuation model for the respective interest rate option type	Yield curves built on market data: money market rates, FRA, IRS, OIS, basis swap, caplet/floorlet volatility surfaces for relevant tenors
equity options	Valuation model for the respective equity option type	Yield curves built on market data: money market rates, FRA, IRS, OIS, basis swap; volatility surfaces determined using a local volatility model based on prices and volatilities of the relevant underlying instruments
commodity swaps, commodity forwards	Discounted cash flow valuation model	Yield curves built on market data: money market rates, FRA, IRS, OIS, basis swap; forward curves for relevant commodities constructed based on futures prices and forward exchange rates (i.e. determined based on exchange rates, swap points)
commodity options	Valuation model for the respective commodity option type	Yield curves built on market data: money market rates, IRS; volatility surfaces for relevant commodities
equity swaps	Discounted cash flow valuation model	Yield curves built on market data: money market rates, FRA, IRS, OIS, basis swap; forward curves for relevant underlying instruments based on futures prices
municipal bonds (in pln) corporate bonds	Yield curve and risk margin model.	Yield curves are built based on market rates, money market data, IRS transactions market.
municipal bonds (in pln) corporate bonds	Valuations published by informational services such as Bloomberg and the London Securities Exchange Group (if they are determined based on data related to comparable assets or liabilities).	Data concerning comparable assets or liabilities (which are not liquid quotes directly observable for the specific security), including: yields on government bonds, yields on comparable non-government bonds, money market rates, and interest rate swap rates.
nbp money bills	Yield curve method	Yield curves built on money market and OIS transaction market data.
TREASURY BILLS IN PLN	Yield curve method	Yield curves built on money market and OIS transaction market data.

Level 3: Other valuation techniques

Level 3 includes financial assets and liabilities measured based on models in which the inputs are not observable on the market. Here, the Bank classifies instruments measured using internal valuation models.

financial assets and liabilities	valuation method (technique)	unobservable input
Loans and advances to customers	Discounted cash flow method.	Current margin on loans.
c-series preference shares of visa inc.	Estimation of the fair value based on the current market value of the listed ordinary shares of Visa Inc., including a discount which takes into account the limited liquidity of C-series shares and the terms and conditions of conversion of C-series shares into ordinary shares.	Discount taking into account the limited liquidity of C-series shares and the terms of converting the C-series shares into ordinary shares.
corporate bonds	Yield curve and risk margin model. Yield curves are built based on market rates, money market data and IRS transactions market data.	Credit spread (credit margins determined on the basis of initial margins modified by credit indices quotes ascribed to issuers based on their ratings and business sectors).
shares in Biuro Informacji Kredytowej S.A., shares in Krajowa Izba Rozliczeniowa S.A., shares in Polski Standard Płatności sp. z o.o.	Estimation of the fair value based on the present value of projected results of the company	Projected results of the company. Discount rate.
shares in society for worldwide interbank financial telecommunication	Market value of the shares estimated by the company.	Market value estimated by the company. Discount rate.

Financial information

ASSETS MEASURED AT FAIR VALUE 31.12.2025	Carrying amount	Level 1	Level 2	Level 3
Hedging derivatives	147	-	147	-
Other derivative instruments	2,446	1	2,445	-
Securities	103,969	80,784	22,707	478
held for trading	371	367	4	-
debt securities	330	326	4	-
equity securities	41	41	-	-
not held for trading, measured at fair value through profit or loss	377	61	3	313
debt securities	41	41	-	-
equity securities	336	20	3	313
measured at fair value through other comprehensive income (debt securities)	103,221	80,356	22,700	165
Loans and advances to customers	10,182	-	-	10,182
not held for trading, measured at fair value through profit or loss	1,933	-	-	1,933
measured at fair value through other comprehensive income – housing loans	8,249	-	-	8,249
Total financial assets measured at fair value	116,744	80,785	25,299	10,660

ASSETS MEASURED AT FAIR VALUE 31.12.2024	Carrying amount	Level 1	Level 2	Level 3
Hedging derivatives	344	-	344	-
Other derivative instruments	2,018	1	2,017	-
Securities	95,263	72,920	21,701	642
held for trading	373	370	-	3
debt securities	337	334	-	3
equity securities	36	36	-	-
not held for trading, measured at fair value through profit or loss	715	310	1	404
debt securities	389	289	-	100
equity securities	326	21	1	304
measured at fair value through other comprehensive income (debt securities)	94,175	72,240	21,700	235
Loans and advances to customers	11,631	-	-	11,631
not held for trading, measured at fair value through profit or loss	2,166	-	-	2,166
measured at fair value through other comprehensive income – housing loans	9,465	-	-	9,465
Total financial assets measured at fair value	109,256	72,921	24,062	12,273

LIABILITIES MEASURED AT FAIR VALUE 31.12.2025	Carrying amount	Level 1	Level 2	Level 3
Hedging derivatives	105	-	105	-
Other derivative instruments	2,724	1	2,723	-
Liabilities in respect of a short position in securities	112	112	-	-
Total financial liabilities measured at fair value	2,941	113	2,828	-

LIABILITIES MEASURED AT FAIR VALUE 31.12.2024	Carrying amount	Level 1	Level 2	Level 3
Hedging derivatives	302	-	302	-
Other derivative instruments	2,409	1	2,408	-
Liabilities in respect of a short position in securities	36	36	-	-
Total financial liabilities measured at fair value	2,747	37	2,710	-

IMPACT OF ESTIMATES ON FAIR VALUE MEASUREMENT OF LEVEL 3 FINANCIAL INSTRUMENTS	31.12.2025		31.12.2024
	Fair value in		Fair value in
	positive scenario	negative scenario	positive scenario	negative scenario
Shares in Visa Inc.1	21	20	56	52
Other equity investments2	307	278	262	237
Corporate bonds3	165	165	339	338
Loans and advances to customers4	10,691	9,673	12,212	11,049

1 scenario assuming a discount rate in respect of the future conditions of converting C-series shares to ordinary shares at a level of 0%/100% respectively

2 scenario assuming a change in the company’s valuation of +/- 5%

3 scenario assuming a change in the credit spread of +/- 10%

4 scenario assuming a change in the company’s value of +/- 0.5p.p.

RECONCILIATION OF CHANGES DURING THE REPORTING PERIOD TO FAIR VALUE OF FINANCIAL INSTRUMENTS AT LEVEL 3	2025	2024
Opening balance at the beginning of the period	12,273	14,235
Acquisition of equity instruments	-	1
Acquisition of corporate bonds	-	3
Redemption of corporate bonds	(172)	(36)
Granting and increase in exposure to loans and advances to customers	960	705
Repayment of loans and advances to customers	(1,887)	(2,082)
Sale	(497)	(401)
Derecognition of loans and advances to customers	(30)	(238)
Write-off of loans and advances to customers	(78)	(257)
Net gain/(loss) on financial instruments measured at fair value through profit or loss	15	58
Change in the valuation recognized in OCI	23	70
Other, including exchange difference1	53	215
Closing balance	10,660	12,273

1 The item "Other, including exchange difference" includes a decrease due to conversion of Visa Inc. series C shares into Visa series A Preferred shares (PLN 26 million in 2025 and PLN 43 million in 2024).

45. Financial assets and financial liabilities not presented at fair value in the statement of financial position

The Bank holds financial instruments which are not presented at fair value in the statement of financial position. For many of them, market values are unavailable, hence valuation techniques based on models are used. The models include simplifications and are sensitive to the assumptions made. For instruments for which no material differences between their carrying amount and fair value are expected (e.g. short-term, highly correlated with market parameters), it has been assumed that the carrying amount is close to the fair value.

ITEM	MAJOR METHODS AND ASSUMPTIONS USED WHEN ESTIMATING FAIR VALUES OF FINANCIAL INSTRUMENTS NOT MEASURED AT FAIR VALUE
amounts due from and to banks	• interbank placements and deposits – cash flows discounted using the current interbank market rates, • interbank deposits and placements with maturities of up to 7 days or with variable interest, loans or advances granted and received on the interbank market with variable interest (with interest rate changes occurring every 3 months or less) – fair value equals the carrying amount.
securities	• treasury bonds – market quotations; • corporate bonds secured with the State Treasury guarantees - discounted cash flows using yield curves, Bloomberg (BVAL - Bloomberg Valuation Service) and Refinitiv Eikon valuation • corporate and municipal bonds – discounted cash flow method, using yield curves and credit margins.
loans and advances to customers	• loans and advances to customers not impaired - discounted cash flows using current interest rates and credit risk margins as well as adjusted maturities derived from the agreements. The current level of margins was determined for transactions concluded in the last 6 months preceding the balance sheet date involving instruments with a similar credit risk profile. The current margin for loans in PLN adjusted for the cost of foreign currency acquisition in basis-swap transactions was applied to loans in foreign currencies. • a part of the housing loan portfolio (the “old” housing loan portfolio), loans and advances with no specific repayment schedule, loans due as at the moment of valuation, impaired loans – fair values are equal to their carrying amounts.
amounts due to customers	• liabilities with fixed maturities: the model of expected cash flows discounted using current interest rates appropriate for the individual deposit products. The fair value is calculated for each deposit and liability, and then the fair values for the entire deposit portfolio are grouped by product type and by customer segment. • liabilities with no specific repayment schedule, other specific products for which no active market exists – fair values are equal to their carrying amounts.
liabilities in respect of debt securities in issue	The model of expected cash flows discounted using the current interbank market rates and market quotations
subordinated liabilities	The model of expected cash flows discounted based on yield curves
mortgage covered bonds	The discounted cash flow method, calculated using yields; prices provided by Bloomberg and LSEG (London Stock Exchange Group) information services.

In the case of cash in hand and balances at the Central Bank, liabilities to the Central Bank, and other financial assets and liabilities, the Bank assumes that the fair value is equal to their carrying amount.

31.12.2025	carrying amount	Level 1	Level 2	Level 3	Total fair value
Cash and balances with the Central Bank	21,644	3,833	17,811	-	21,644
Amounts due from banks	6,351	-	6,351	-	6,351
Securities (excluding adjustments relating to fair value hedge accounting)	132,494	111,518	19,598	2,702	133,818
treasury bonds (in PLN)	99,430	100,598	-	-	100,598
corporate bonds (in PLN) secured with the State Treasury guarantees	4,649	-	4,549	-	4,549
municipal bonds (in PLN)	12,214	-	12,375	-	12,375
corporate bonds (in PLN)	4,672	834	1,184	2,702	4,720
corporate bonds (in foreign currencies)	11,025	10,086	981	-	11,067
mortgage covered bonds	504	-	509	-	509
Reverse repo transactions	2,010	-	2,010	-	2,010
Loans and advances to customers (excluding adjustment relating to fair value hedge accounting)	262,809	-	-	265,631	265,631
real estate loans	108,081	-	-	107,174	107,174
business loans	111,932	-	-	114,226	114,226
consumer loans	42,796	-	-	44,231	44,231
Other financial assets	1,916	-	-	1,916	1,916
Amounts due to Central bank	10	-	10	-	10
Amounts due to banks	3,349	-	3,349	-	3,349
Repo transactions	22	-	22	-	22
Amounts due to customers (excluding adjustment relating to fair value hedge accounting)	455,151	-	-	455,004	455,004
amounts due to households	343,540	-	-	343,392	343,392
amounts due to business entities	88,637	-	-	88,637	88,637
amounts due to public sector	22,974	-	-	22,975	22,975
Liabilities in respect of debt securities in issue	16,034	-	16,290	-	16,290
Subordinated liabilities	6,309	-	6,408	-	6,408
Other financial liabilities	3,913	-	-	3,913	3,913

31.12.2024	carrying amount	Level 1	Level 2	Level 3	Total fair value
Cash and balances with the Central Bank	23,263	3,696	19,567	-	23,263
Amounts due from banks	8,349	-	8,349	-	8,349
Securities (excluding adjustments relating to fair value hedge accounting)	109,633	73,133	29,612	3,938	106,683
treasury bonds (in PLN)	73,499	70,988	-	-	70,988
corporate bonds (in PLN) secured with the State Treasury guarantees	13,974	2,145	11,461	-	13,606
municipal bonds (in PLN)	10,399	-	10,432	-	10,432
corporate bonds (in PLN)	3,994	-	-	3,938	3,938
corporate bonds (in foreign currencies)	7,268	-	7,220	-	7,220
mortgage covered bonds	499	-	499	-	499
Reverse repo transactions	892	-	892	-	892
Loans and advances to customers (excluding adjustment relating to fair value hedge accounting)	234,278	-	-	236,490	236,490
real estate loans	96,759	-	-	95,728	95,728
business loans	103,209	-	-	104,833	104,833
consumer loans	34,310	-	-	35,929	35,929
Other financial assets	2,319	-	-	2,319	2,319
Amounts due to Central bank	11	-	11	-	11
Amounts due to banks	2,267	-	2,267	-	2,267
Amounts due to customers (excluding adjustment relating to fair value hedge accounting)	414,651	-	-	415,211	415,211
amounts due to households	315,190	-	-	315,480	315,480
amounts due to business entities	77,831	-	-	77,831	77,831
amounts due to public sector	21,630	-	-	21,630	21,630
Liabilities in respect of debt securities in issue	11,999	-	12,180	-	12,180
Subordinated liabilities	4,291	-	4,335	-	4,335
Other financial liabilities	3,911	-	-	3,911	3,911

RISK MANAGEMENT IN THE BANK

46. Risk management in the Bank

Risk management is a key process at the Bank. Its objective is to ensure the profitability of business activities while controlling the level of risk within the system of limits and risk tolerances adjusted to the changing macroeconomic environment. The level of risk is a significant element of the planning process.

The Bank identifies and analyzes risks affecting its operations. All risks are managed, and the risks material from the perspective of profitability and capital are:

• credit risk

• legal risk of foreign currency mortgage loans for households,

• currency risk,

• interest rate risk

• liquidity risk (including financing risk),

• operating risk, business risk, risk of macroeconomic changes and model risk.

The assessment of the materiality of risks is carried out at least annually.

Objectives of risk management:

• protect shareholder value;

• protect customer deposits;

• support the Bank in conducting efficient operations.

Principles of Risk Management

• covers all identified types of risk,

• are adjusted to the scale of operations and the complexity of risks,

• methods and models are periodically verified and validated,

• the risk management area is independent of business activities,

• integration with planning and controlling systems,

• ongoing monitoring and control of risk,

• compliance with the Bank's strategy and the risk management strategy.

Elements of the process:

• risk identification,

• risk measurement and assessment,

• risk control,

• risk forecasting and monitoring,

• risk reporting,

• management actions.

The organization of risk management in the Bank is presented in the diagram below:

The risk management process is carried out at three independent but complementary levels:

A detailed description of the policies for managing significant types of risk and the specific actions taken by the Bank in risk management in 2025 is provided in the report Capital Adequacy and Other Information of the Powszechna Kasa Oszczędności Bank Polski Spółka Akcyjna Group Subject to Disclosure as at 31 December 2025 and in the Directors' Report.

47. Credit risk management

Credit risk means the possibility of incurring a loss as a result of a customer’s default on its liabilities towards the Bank or a decrease in the value of receivables as a result of a deterioration in a customer’s ability to service their debt.

Objective of credit risk management - Mitigating losses on the loan portfolio and minimizing the risk of impairment of exposures, while maintaining the expected profitability and value of the portfolio.

Organizational structures - In the Bank, there are risk units responsible for:

• developing methodologies for credit risk assessment and recognition of provisions and allowances;

• control over and monitoring of credit risk in the lending process;

• the quality of restructuring and debt collection.

Decision-making limits - depending on the amount of exposure, the transaction value and the lending period. The process is supported by credit committees for transactions with an increased level of risk.

Description of performing the estimates of expected credit losses – note “Net allowances for expected credit losses”.

• measurement and assessment of credit risk: Credit risk measurement and assessment methods

The Bank applies various methods for assessing credit risk and the profitability of portfolios, including:

• probability of default (PD);

• loss given default (LGD);

• credit conversion factor (CCF);

• expected credit loss (ECL);

• credit value at risk (CVaR);

• the share and structure of impaired credit exposures;

• coverage ratio of impaired loans;

• cost of credit risk;

• stress testing.

The Bank develops the scope of the measures applied, taking into account the requirements of the IRB method, and extends their application to the entire loan portfolio. Portfolio methods allow, among other things, to:

• reflect the risk in the price of products,

• determine the conditions of financing,

• recognition of allowances for expected credit losses;

The Bank performs analyses and stress-tests relating to the impact of macroeconomic changes on the quality of the portfolio, and reports the results to the Bank's governing bodies. This information supports the identification of risks and actions mitigating the effects of unfavorable market conditions.

The credit risk assessment process takes into account the requirements of the PFSA as laid down in the PFSA Recommendations.

• measurement and assessment of credit risk: Rating and scoring methods

The Bank assesses the risk of individual credit transactions using scoring and rating methods, supported by dedicated IT applications. The assessment rules are defined by internal regulations, ensuring a uniform and objective risk assessment.

Retail customers - the creditworthiness assessment is performed in two dimensions:

• quantitative – an analysis of the financial position,

• qualitative – a scoring assessment and credit history from internal and external databases.

Institutional customers

• SMEs (simple transactions) – the scoring method (borrowing capacity and creditworthiness).

• Other cases – the rating method, covering the assessment of the customer (rating) and the transaction (ability to repay).

Rating models are developed based on internal data, taking into account financial ratios, qualitative and behavioral factors. For specialized financing, models dedicated to large projects (real estate, infrastructure) are used.

The models are integrated with IT tools and are subject to periodic reviews. The process takes into account the PFSA requirements (Recommendations S, T and W).

ESG and levered transactions - in the process of assessing corporate customers, the Bank analyzes the impact of ESG (environmental, social, governance) factors on the creditworthiness and classifies transactions in terms of their impact on ESG (from positive to materially negative). It takes into account, inter alia, climate risk, factors related to human capital, health and safety, and organizational culture ("Environmental issues").

Rating and scoring assessments are used in risk management, the decision-making authorization system, determining the conditions for activating risk services, and in credit risk measurement and reporting.

• measurement and assessment of credit risk: Credit risk forecasting and monitoring

The Bank prepares forecasts of the credit risk level and monitors deviations from the assumptions (e.g. limits, thresholds, plans, supervisory recommendations). It regularly performs stress tests (specific and comprehensive) and verifies forecasts (backtesting).

Scope of monitoring:

• the level of individual customers, groups of related customers, transactions and their collateral,

• portfolio level.

Transactions are monitored in accordance with internal regulations concerning:

• credit risk assessment and customer assessment methodologies,

• identification of groups of related customers,

• evaluation of collateral and inspection of investments,

• recognition of allowances for expected credit losses;

• Early Warning System (SWO);

• operating procedures.

Early Warning System - The Bank uses the EWS in order to respond quickly to signals of an increase in risk.

Portfolio monitoring - comprises supervision of the risk level based on measurement tools, analysis of risk sources and effects of management actions, and recommending preventive measures in the event of an increased risk.

• Use of credit risk mitigation techniques – collateral

The collateral policy in the Bank is aimed at appropriately mitigating credit risk by establishing the most liquid collateral, i.e. collateral that can be sold quickly without a significant loss in value.

The Bank strives to diversify the forms and objects of collateral and evaluates their actual usefulness as a source of satisfying claims. The assessment takes into account, among other things:

• the financial position of entities providing personal guarantees,

• the condition and market value of tangible collateral and its vulnerability to depreciation,

• economic benefits (e.g. the possibility of reducing allowances for credit losses),

• the method of establishing collateral, the time and costs of its maintenance and enforcement,

• the complexity and effectiveness of realizing the collateral in the context of legal restrictions,

• the risk level of the customer or transaction.

Examples of collateral used:

• Housing and commercial loans – a mortgage on the financed property (temporary collateral is possible until it is established).

• Consumer loans – personal guarantees, collateral on an account, car or securities.

• Loans for SMEs and corporations – collateral on receivables, accounts, movables, real estate, securities.

The collateral policy is defined in the internal regulations of the Bank. During the periods ended 31 December 2025 and 31 December 2024, the Bank did not change its collateral policy.

Collateral is taken into account when estimating the expected credit loss for individually significant exposures. In the case of impaired exposures, future collateral recoveries are estimated individually, taking into account the probability of implementing the debt recovery scenario. The value of collateral recoveries estimated under the debt recovery scenario for individually significant exposures amounted to PLN 1,099 million (2024: PLN 953 million). Collateral includes, among other things: mortgages, registered pledges, transfer of ownership, restrictions on an account, insurance of the exposure, as well as guarantees and sureties. The Bank does not have any exposures for which, due to the value of the collateral, it has not recognized an allowance for expected credit losses.

48. Credit risk – financial information

48.1. Financial assets by stage

• Amounts due from banks – As at 31 December 2025 and 31 December 2024 all amounts due from banks were classified as Stage 1.

• Securities (excluding adjustments relating to fair value hedge accounting)

SECURITIES 31.12.2025	Stage 1	Stage 2	Stage 3	Total
measured at fair value through other comprehensive income
Gross/net carrying amount – fair value	103,164	49	8	103,221
Measured at amortized cost
Gross carrying amount	131,834	734	-	132,568
Allowances for expected credit losses	(58)	(16)	-	(74)
Net carrying amount	131,776	718	-	132,494
Total securities
Gross carrying amount	234,998	783	8	235,789
Allowances for expected credit losses	(58)	(16)	-	(74)
Net carrying amount	234,940	767	8	235,715

31.12.2024
measured at fair value through other comprehensive income
Gross/net carrying amount – fair value	93,843	322	10	94,175
Measured at amortized cost
Gross carrying amount	108,491	1,236	-	109,727
Allowances for expected credit losses	(68)	(26)	-	(94)
Net carrying amount	108,423	1,210	-	109,633
Total securities
Gross carrying amount	202,334	1,558	10	203,902
Allowances for expected credit losses	(68)	(26)	-	(94)
Net carrying amount	202,266	1,532	10	203,808

• Loans and advances to customers (excluding adjustment relating to fair value hedge accounting)

LOANS AND ADVANCES TO CUSTOMERS 31.12.2025		Stage 1	Stage 2		Stage 3		POCI			Total
Measurement method: measured at fair value through other comprehensive income
Gross/net carrying amount – fair value		7,666	550		30		3			8,249
Measurement method: at amortized cost
Gross carrying amount		237,902	24,031		8,401		629			270,963
real estate loans		100,269	8,126		1,077		68			109,540
business loans		97,883	12,564		5,197		462			116,106
consumer loans		39,750	3,341		2,127		99			45,317
Allowances for expected credit losses		(1,083)	(2,948)		(4,251)		128			(8,154)
real estate loans		(54)	(827)		(588)		10			(1,459)
business loans		(442)	(1,312)		(2,432)		12			(4,174)
consumer loans		(587)	(809)		(1,231)		106			(2,521)
Net carrying amount		236,819	21,083		4,150		757			262,809
real estate loans		100,215	7,299		489		78			108,081
business loans		97,441	11,252		2,765		474			111,932
consumer loans		39,163	2,532		896		205			42,796
Loans and advances to customers, total
Gross carrying amount		245,568	24,581		8,431		632			279,212
Allowances for expected credit losses		(1,083)	(2,948)		(4,251)		128			(8,154)
Net carrying amount		244,485	21,633		4,180		760			271,058
LOANS AND ADVANCES TO CUSTOMERS 31.12.2024	Stage 1			Stage 2		Stage 3		POCI	Total
Measurement method: measured at fair value through other comprehensive income
Gross/net carrying amount – fair value	8,890			542		31		2	9,465
Measurement method: at amortized cost
Gross carrying amount	204,003			29,549		7,972		561	242,085
real estate loans	88,511			8,526		1,237		71	98,345
business loans	84,158			17,735		4,877		400	107,170
consumer loans	31,334			3,288		1,858		90	36,570
Allowances for expected credit losses	(1,097)			(2,891)		(3,915)		96	(7,807)
real estate loans	(59)			(823)		(717)		13	(1,586)
business loans	(535)			(1,345)		(2,064)		(17)	(3,961)
consumer loans	(503)			(723)		(1,134)		100	(2,260)
Net carrying amount	202,906			26,657		4,058		657	234,278
real estate loans	88,452			7,702		521		84	96,759
business loans	83,623			16,389		2,814		383	103,209
consumer loans	30,831			2,566		723		190	34,310
Loans and advances to customers, total
Gross carrying amount	212,893			30,091		8,003		563	251,550
Allowances for expected credit losses	(1,097)			(2,891)		(3,915)		96	(7,807)
Net carrying amount	211,796			27,200		4,088		659	243,743

The decrease in the gross value of corporate loans and the nominal value of credit facility lines recognized in Stage 2, with a similar level of impairment allowances, resulted from the migration of items between individual stages (migration from Stage 2 to other stages) with the simultaneous recognition of additional allowances for expected credit losses for exposures to customers from increased risk industries, which were in Stage 2 as at 31 December 2025.

• Other financial assets

OTHER FINANCIAL ASSETS 31.12.2025	Stage 1	Stage 3	Total
Gross carrying amount	1,915	87	2,002
Allowances for expected credit losses	-	(86)	(86)
Net carrying amount	1,915	1	1,916

31.12.2024
Gross carrying amount	2,318	128	2,446
Allowances for expected credit losses	-	(127)	(127)
Net carrying amount	2,318	1	2,319

• Financial liabilities and guarantees granted

FINANCIAL AND GUARANTEE COMMITMENTS GRANTED 31.12.2025	STAGE 1		STAGE 2		STAGE 3		POCI		Total nominal amount	Total provisions per IFRS 9	Total net amount
FINANCIAL AND GUARANTEE COMMITMENTS GRANTED 31.12.2025	Notional amount	Provision	Notional amount	Provision	Notional amount	Provision	Notional amount	Provision	Total nominal amount	Total provisions per IFRS 9	Total net amount
Credit lines and limits	87,046	(154)	5,560	(303)	478	(99)	5	-	93,089	(556)	92,533
real estate	8,013	(10)	82	(6)	1	(1)	-	-	8,096	(17)	8,079
business	67,749	(123)	3,816	(226)	458	(92)	1	-	72,024	(441)	71,583
consumer	11,284	(21)	1,662	(71)	19	(6)	4	-	12,969	(98)	12,871
Other	3,587	-	-	-	-	-	-	-	3,587	-	3,587
Total financial commitments granted, including:	90,633	(154)	5,560	(303)	478	(99)	5	-	96,676	(556)	96,120
irrevocable commitments granted	43,234	(81)	3,543	(192)	83	(21)	3	-	46,863	(294)	46,569
Guarantees and sureties granted
Total guarantees and sureties granted, including:	14,658	(19)	631	(30)	86	(15)	303	-	15,678	(64)	15,614
irrevocable commitments granted	12,081	(19)	601	(26)	86	(15)	302	-	13,070	(60)	13,010
performance guarantee	4,062	(3)	329	(19)	20	(5)	114	-	4,525	(27)	4,498
Total	105,291	(173)	6,191	(333)	564	(114)	308	-	112,354	(620)	111,734

31.12.2024
Credit lines and limits	77,096	(163)	10,111	(321)	272	(60)	4	-	87,483	(544)	86,939
real estate	6,570	(18)	142	(10)	4	(2)	-	-	6,716	(30)	6,686
business	60,301	(122)	8,474	(228)	252	(52)	-	-	69,027	(402)	68,625
consumer	10,225	(23)	1,495	(83)	16	(6)	4	-	11,740	(112)	11,628
Other	3,940	-	-	-	-	-	-	-	3,940	-	3,940
Total financial commitments granted, including:	81,036	(163)	10,111	(321)	272	(60)	4	-	91,423	(544)	90,879
irrevocable commitments granted	36,036	(92)	5,407	(199)	91	(15)	2	-	41,536	(306)	41,230
Guarantees and sureties granted
Total guarantees and sureties granted, including:	12,760	(11)	1,345	(37)	99	(28)	337	(1)	14,541	(77)	14,464
irrevocable commitments granted	10,168	(8)	1,312	(36)	98	(28)	337	(1)	11,915	(73)	11,842
performance guarantee	2,900	(4)	740	(28)	28	(13)	120	(1)	3,788	(46)	3,742
Total	93,796	(174)	11,456	(358)	371	(88)	341	(1)	105,964	(621)	105,343

48.2. Change in the gross carrying amount

• Securities (excluding adjustments relating to fair value hedge accounting)

“Other changes” comprise the effect of foreign exchange rate changes, interest, measurement, discount, premium.

SECURITIES MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME – CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	Total
Gross carrying amount at the beginning of the period	93,843	322	10	94,175
Transfer from stage 2 and 3 to stage 1	312	(311)	(1)	-
Transfer from stage 1 and 3 to stage 2	(38)	38	-	-
Granting or purchase of financial instruments	316,424	1	-	316,425
Derecognition, including redemption at maturity	(312,451)	(4)	(1)	(312,456)
Non-substantial modifications	(51)	1	-	(50)
Other changes	5,125	2	-	5,127
Gross carrying amount at the end of the period	103,164	49	8	103,221

2024
Gross carrying amount at the beginning of the period	104,105	304	12	104,421
Transfer from stage 2 and 3 to stage 1	15	(15)	-	-
Transfer from stage 1 and 3 to stage 2	(64)	64	-	-
Granting or purchase of financial instruments	712,408	5	-	712,413
Derecognition, including redemption at maturity	(727,822)	(27)	(2)	(727,851)
Non-substantial modifications	4	-	-	4
Other changes	5,197	(9)	-	5,188
Gross carrying amount at the end of the period	93,843	322	10	94,175

SECURITIES MEASURED AT AMORTISED COST – CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 2	Total
Gross carrying amount at the beginning of the period	108,491	1,236	109,727
Transfer from stage 2 to stage 1	762	(762)	-
Transfer from stage 1 to stage 2	(246)	246	-
Granting or purchase of financial instruments	46,269	34	46,303
Derecognition, including redemption at maturity	(28,068)	(58)	(28,126)
Non-substantial modifications	(22)	-	(22)
Other changes	4,648	38	4,686
Gross carrying amount at the end of the period	131,834	734	132,568

2024
Gross carrying amount at the beginning of the period	85,428	399	85,827
Transfer from stage 2 to stage 1	236	(236)	-
Transfer from stage 1 to stage 2	(872)	872	-
Granting or purchase of financial instruments	37,407	225	37,632
Derecognition, including redemption at maturity	(17,140)	(99)	(17,239)
Non-substantial modifications	(1)	-	(1)
Other changes	3,433	75	3,508
Gross carrying amount at the end of the period	108,491	1,236	109,727

• Loans and advances to customers (excluding adjustment relating to fair value hedge accounting)

Changes in the gross carrying amount are presented as at the end of the reporting period. The item "Other changes" comprises the effect of foreign exchange differences, interest and the cost of legal risk associated with mortgage loans in convertible currencies, and in 2024, transfers from Stages 1, 2 and 3 to POCI.

REAL ESTATE LOANS MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME – CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount at the beginning of the period	8,890	542	31	2	9,465
Transfer from stage 2 and 3 to stage 1	170	(164)	(6)	-	-
Transfer from stage 1 and 3 to stage 2	(198)	209	(11)	-	-
Transfer from stage 1 and 2 to stage 3	(4)	(15)	19	-	-
Transfer from Stage 1, 2 and 3 to POCI	-	-	(1)	1	-
Granting or purchase of financial instruments	194	3	-	1	198
Utilization of limit or disbursement of tranches	66	-	4	-	70
Repayments	(1,134)	(22)	(4)	-	(1,160)
Non-substantial modifications	(8)	-	-	-	(8)
Derecognition, including sale	(344)	(5)	-	(1)	(350)
Write-off	-	-	(3)	-	(3)
Other changes	34	2	1	-	37
Gross carrying amount at the end of the period	7,666	550	30	3	8,249

2024
Gross carrying amount at the beginning of the period	10,132	591	27	1	10,751
Transfer from stage 2 and 3 to stage 1	212	(211)	(1)	-	-
Transfer from stage 1 and 3 to stage 2	(225)	234	(9)	-	-
Transfer from stage 1 and 2 to stage 3	(4)	(18)	22	-	-
Granting or purchase of financial instruments	44	2	-	1	47
Utilization of limit or disbursement of tranches	126	5	3	-	134
Repayments	(1,067)	(30)	(4)	-	(1,101)
Non-substantial modifications	24	-	-	-	24
Derecognition, including sale	(426)	1	-	(2)	(427)
Write-off	-	-	(4)	-	(4)
Other changes	74	(32)	(3)	2	41
Gross carrying amount at the end of the period	8,890	542	31	2	9,465

REAL ESTATE LOANS MEASURED AT AMORTISED COST – CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount at the beginning of the period	88,511	8,526	1,237	71	98,345
Transfer from stage 2 and 3 to stage 1	2,919	(2,819)	(100)	-	-
Transfer from stage 1 and 3 to stage 2	(3,925)	4,032	(107)	-	-
Transfer from stage 1 and 2 to stage 3	(38)	(166)	204	-	-
Transfer from Stage 1, 2 and 3 to POCI	(1)	(15)	(18)	34	-
Granting or purchase of financial instruments	21,739	239	8	25	22,011
Utilization of limit or disbursement of tranches	5,983	165	103	4	6,255
Repayments	(14,786)	(1,758)	(141)	(20)	(16,705)
Changes due to legal risk costs	1,924	-	-	-	1,924
Non-substantial modifications	26	-	(1)	-	25
Derecognition, including sale	(1,744)	(59)	(4)	(32)	(1,839)
Write-off	-	-	(85)	-	(85)
Other changes	(339)	(19)	(19)	(14)	(391)
Gross carrying amount at the end of the period	100,269	8,126	1,077	68	109,540

2024
Gross carrying amount at the beginning of the period	72,201	11,868	1,458	79	85,606
Transfer from stage 2 and 3 to stage 1	3,357	(3,336)	(21)	-	-
Transfer from stage 1 and 3 to stage 2	(2,796)	2,979	(183)	-	-
Transfer from stage 1 and 2 to stage 3	(53)	(192)	245	-	-
Granting or purchase of financial instruments	16,083	417	7	36	16,543
Utilization of limit or disbursement of tranches	8,119	475	197	5	8,796
Repayments	(9,748)	(1,951)	(130)	(25)	(11,854)
Changes due to legal risk costs	640	-	-	-	640
Non-substantial modifications	242	12	5	-	259
Derecognition, including sale	(639)	(25)	(17)	(44)	(725)
Write-off	-	-	(195)	(5)	(200)
Other changes	1,105	(1,721)	(129)	25	(720)
Gross carrying amount at the end of the period	88,511	8,526	1,237	71	98,345

CORPORATE LOANS MEASURED AT AMORTISED COST – CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount at the beginning of the period	84,158	17,735	4,877	400	107,170
Transfer from stage 2 and 3 to stage 1	7,562	(7,469)	(93)	-	-
Transfer from stage 1 and 3 to stage 2	(3,374)	3,409	(35)	-	-
Transfer from stage 1 and 2 to stage 3	(363)	(1,026)	1,389	-	-
Transfer from Stage 1, 2 and 3 to POCI	(3)	(9)	(110)	122	-
Granting or purchase of financial instruments	28,305	1,414	385	163	30,267
Utilization of limit or disbursement of tranches	11,494	1,003	279	33	12,809
Repayments	(28,886)	(1,793)	(984)	(74)	(31,737)
Non-substantial modifications	197	(247)	1	-	(49)
Derecognition, including sale	(1,503)	(358)	(31)	(177)	(2,069)
Write-off	-	-	(408)	(4)	(412)
Other changes	296	(95)	(73)	(1)	127
Gross carrying amount at the end of the period	97,883	12,564	5,197	462	116,106

2024
Gross carrying amount at the beginning of the period	81,933	16,640	3,408	155	102,136
Transfer from stage 2 and 3 to stage 1	2,623	(2,607)	(16)	-	-
Transfer from stage 1 and 3 to stage 2	(7,068)	7,423	(355)	-	-
Transfer from stage 1 and 2 to stage 3	(312)	(2,419)	2,731	-	-
Granting or purchase of financial instruments	15,272	2,276	324	352	18,224
Utilization of limit or disbursement of tranches	16,441	2,669	837	8	19,955
Repayments	(24,956)	(2,862)	(1,071)	(58)	(28,947)
Non-substantial modifications	169	(201)	(6)	-	(38)
Derecognition, including sale	(2,196)	(492)	(70)	(167)	(2,925)
Write-off	-	-	(708)	(3)	(711)
Other changes	2,252	(2,892)	(197)	113	(524)
Gross carrying amount at the end of the period	84,158	17,735	4,877	400	107,170

CONSUMER LOANS MEASURED AT AMORTISED COST – CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
Gross carrying amount at the beginning of the period	31,334	3,288	1,858	90	36,570
Transfer from stage 2 and 3 to stage 1	1,627	(1,518)	(109)	-	-
Transfer from stage 1 and 3 to stage 2	(1,468)	1,540	(72)	-	-
Transfer from stage 1 and 2 to stage 3	(544)	(507)	1,051	-	-
Transfer from Stage 1, 2 and 3 to POCI	(13)	(21)	(73)	107	-
Granting or purchase of financial instruments	30,119	1,000	211	51	31,381
Utilization of limit or disbursement of tranches	920	119	300	6	1,345
Repayments	(22,261)	(491)	(263)	(46)	(23,061)
Non-substantial modifications	(11)	(1)	(1)	-	(13)
Derecognition, including sale	(86)	(68)	(13)	(107)	(274)
Write-off	(6)	-	(759)	(3)	(768)
Other changes	139	-	(3)	1	137
Gross carrying amount at the end of the period	39,750	3,341	2,127	99	45,317

2024
Gross carrying amount at the beginning of the period	25,338	3,408	2,310	70	31,126
Transfer from stage 2 and 3 to stage 1	958	(925)	(33)	-	-
Transfer from stage 1 and 3 to stage 2	(1,622)	1,702	(80)	-	-
Transfer from stage 1 and 2 to stage 3	(386)	(410)	796	-	-
Granting or purchase of financial instruments	19,415	491	206	63	20,175
Utilization of limit or disbursement of tranches	1,337	175	327	7	1,846
Repayments	(14,439)	(504)	(275)	(33)	(15,251)
Non-substantial modifications	(10)	(2)	(2)	-	(14)
Derecognition, including sale	129	(34)	(696)	(124)	(725)
Write-off	-	-	(659)	(14)	(673)
Other changes	614	(613)	(36)	121	86
Gross carrying amount at the end of the period	31,334	3,288	1,858	90	36,570

• Other financial assets:

OTHER FINANCIAL ASSETS - CHANGE IN THE GROSS CARRYING AMOUNT DURING THE PERIOD 2025	Stage 1	Stage 3	Total
Gross carrying amount at the beginning of the period	2,318	128	2,446
Transfer from stage 3 to stage 1	1	(1)	-
Transfer from stage 1 to stage 3	(1)	1	-
Granting or purchase of financial assets	2,300	-	2,300
Repayments	(2,683)	-	(2,683)
Write-off	-	(48)	(48)
Other changes	(20)	7	(13)
Gross carrying amount at the end of the period	1,915	87	2,002

2024
Gross carrying amount at the beginning of the period	1,306	137	1,443
Granting or purchase of financial assets	2,318	62	2,380
Repayments	(1,306)	(63)	(1,369)
Write-off	-	(8)	(8)
Gross carrying amount at the end of the period	2,318	128	2,446

48.3. Changes in allowances for expected credit losses

The line "Net allowances for expected credit losses" includes the following items:

• “Increase due to recognition and purchase”,

• "Changes in credit risk (net)", which includes the effect on the allowance amount of an increase or decrease in the amount of financial assets due to accrued and paid interest income, the effect of the passage of time on expected credit losses, changes in estimates due to an update or review of risk parameters, and changes in forecasted macroeconomic data,

• “Decrease due to derecognition”,

• “Changes due to modification without derecognition (net)”.

Items of transfers between Stages 1, 2 and 3 are presented in the amount of allowances for expected credit losses at the end of the reporting period in correspondence with the item "Changes in credit risk (net)". In 2024, items of transfers between Stages 1, 2 and 3 were presented in the amount of allowances for expected credit losses at the end of the reporting period in correspondence with the item "Change in credit risk - transfers".

The item “Other adjustments” includes the effect of foreign exchange differences and, in the case of financial assets measured at fair value through other comprehensive income, the effect of measurement at fair value.

• securities

SECURITIES MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME – CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES IN THE PERIOD 2025	Stage 1	Stage 2	Total
As at the beginning of the period	-	-	-
Transfer from stage 2 to stage 1	(4)	4	-
Increase due to recognition and purchase	(6)	-	(6)
Changes in credit risk (net)	17	-	17
Other adjustments	(7)	(4)	(11)
As at the end of the period	-	-	-

2024
As at the beginning of the period
Transfer from stage 1 to stage 2	1	(1)	-
Change in credit risk – transfers	(1)	1	-
Increase due to recognition and purchase	(7)	-	(7)
Changes in credit risk (net)	8	-	8
Other adjustments	(1)	-	(1)
As at the end of the period	-	-	-

SECURITIES MEASURED AT AMORTISED COST – CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES DURING THE PERIOD 2025	Stage 1	Stage 2	Total
As at the beginning of the period	(68)	(26)	(94)
Transfer from stage 2 to stage 1	(10)	10	-
Transfer from stage 1 to stage 2	1	(1)	-
Increase due to recognition and purchase	(32)	-	(32)
Changes in credit risk (net)	49	1	50
Changes due to modification without derecognition (net)	1	-	1
Other adjustments	1	-	1
As at the end of the period	(58)	(16)	(74)

2024
As at the beginning of the period	(54)	(18)	(72)
Transfer from stage 2 and 3 to stage 1	(1)	1	-
Transfer from stage 1 and 3 to stage 2	16	(16)	-
Change in credit risk – transfers	(15)	15	-
Increase due to recognition and purchase	(22)	(3)	(25)
Changes in credit risk (net)	8	(5)	3
Other adjustments	-	-	-
As at the end of the period	(68)	(26)	(94)

• Loans and advances to customers

REAL ESTATE LOANS MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME – CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES IN THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
As at the beginning of the period	-	-	-	-	-
Transfer from stage 2 and 3 to stage 1	(19)	17	2	-	-
Transfer from stage 1 and 3 to stage 2	-	(4)	4	-	-
Transfer from stage 1 and 2 to stage 3	-	7	(7)	-	-
Transfer from Stage 1, 2 and 3 to POCI	-	-	1	(1)	-
Increase due to recognition and purchase	-	-	-	(1)	(1)
Changes in credit risk (net)	19	(12)	4	1	12
Decrease due to derecognition	1	-	-	1	2
Write-off	-	-	3	-	3
Other adjustments	(1)	(8)	(7)	-	(16)
As at the end of the period	-	-	-	-	-

2024
As at the beginning of the period	-	-	-	-	-
Transfer from stage 1 and 3 to stage 2	27	(28)	1	-	-
Transfer from stage 1 and 2 to stage 3	2	7	(9)	-	-
Change in credit risk – transfers	(29)	21	8	-	-
Increase due to recognition and purchase	-	-	-	(1)	(1)
Changes in credit risk (net)	4	(4)	(1)	(1)	(2)
Decrease due to derecognition	1	-	-	1	2
Write-off	-	-	4	-	4
Other adjustments	(5)	4	(3)	1	(3)
As at the end of the period	-	-	-		-

REAL ESTATE LOANS MEASURED AT AMORTISED COST – CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
As at the beginning of the period	(59)	(823)	(717)	13	(1,586)
Transfer from stage 2 and 3 to stage 1	(200)	155	45	-	-
Transfer from stage 1 and 3 to stage 2	5	(51)	46	-	-
Transfer from stage 1 and 2 to stage 3	-	64	(64)	-	-
Transfer from Stage 1, 2 and 3 to POCI	-	3	9	(12)	-
Increase due to recognition and purchase	(16)	(1)	-	(11)	(28)
Changes in credit risk (net)	215	(202)	84	12	109
Decrease due to derecognition	10	4	1	11	26
Changes due to modification without derecognition (net)	-	-	2	-	2
Write-off	-	-	85	-	85
Other adjustments	9	24	(79)	(3)	(67)
As at the end of the period	(54)	(827)	(588)	10	(1,459)

2024
As at the beginning of the period	(71)	(977)	(1,057)	(5)	(2,110)
Transfer from stage 2 and 3 to stage 1	(5)	5	-	-	-
Transfer from stage 1 and 3 to stage 2	214	(237)	23	-	-
Transfer from stage 1 and 2 to stage 3	19	85	(104)	-	-
Change in credit risk – transfers	(228)	147	81	-	-
Increase due to recognition and purchase	(36)	(3)	(2)	(27)	(68)
Changes in credit risk (net)	-	(88)	117	4	33
Decrease due to derecognition	39	4	2	24	69
Changes due to modification without derecognition (net)	1	(2)	-	-	(1)
Write-off	-	-	195	5	200
Other adjustments	8	243	28	12	291
As at the end of the period	(59)	(823)	(717)	13	(1,586)

CORPORATE LOANS MEASURED AT AMORTISED COST – CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
As at the beginning of the period	(535)	(1,345)	(2,064)	(17)	(3,961)
Transfer from stage 2 and 3 to stage 1	(351)	301	50	-	-
Transfer from stage 1 and 3 to stage 2	46	(59)	13	-	-
Transfer from stage 1 and 2 to stage 3	10	79	(89)	-	-
Transfer from Stage 1, 2 and 3 to POCI	-	1	44	(45)	-
Increase due to recognition and purchase	(269)	(61)	(115)	(106)	(551)
Changes in credit risk (net)	693	(260)	(383)	47	97
Decrease due to derecognition	14	19	13	50	96
Changes due to modification without derecognition (net)	(2)	10	-	-	8
Write-off	-	-	408	4	412
Other adjustments	(48)	3	(309)	79	(275)
As at the end of the period	(442)	(1,312)	(2,432)	12	(4,174)

2024
As at the beginning of the period	(481)	(1,679)	(1,998)	4	(4,154)
Transfer from stage 2 and 3 to stage 1	(24)	24	-	-	-
Transfer from stage 1 and 3 to stage 2	272	(274)	2	-	-
Transfer from stage 1 and 2 to stage 3	119	717	(836)	-	-
Change in credit risk – transfers	(367)	(467)	834	-	-
Increase due to recognition and purchase	(206)	(125)	(86)	(218)	(635)
Changes in credit risk (net)	184	429	(537)	(29)	47
Decrease due to derecognition	14	56	1	44	115
Changes due to modification without derecognition (net)	(3)	2	59	-	58
Write-off	-	-	708	3	711
Other adjustments	(43)	(28)	(211)	179	(103)
As at the end of the period	(535)	(1,345)	(2,064)	(17)	(3,961)

CONSUMER LOANS MEASURED AT AMORTISED COST – CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES DURING THE PERIOD 2025	Stage 1	Stage 2	Stage 3	POCI	Total
As at the beginning of the period	(503)	(723)	(1,134)	100	(2,260)
Transfer from stage 2 and 3 to stage 1	(296)	254	42	-	-
Transfer from stage 1 and 3 to stage 2	40	(59)	19	-	-
Transfer from stage 1 and 2 to stage 3	25	189	(214)	-	-
Transfer from Stage 1, 2 and 3 to POCI	1	9	39	(49)	-
Increase due to recognition and purchase	(327)	(28)	(61)	(74)	(490)
Changes in credit risk (net)	466	(455)	(211)	34	(166)
Decrease due to derecognition	-	9	2	51	62
Changes due to modification without derecognition (net)	(1)	(4)	-	-	(5)
Update of the applied estimation method (net)	3	-	3	5	11
Write-off	6	-	759	3	768
Other adjustments	(1)	(1)	(475)	36	(441)
As at the end of the period	(587)	(809)	(1,231)	106	(2,521)

2024
As at the beginning of the period	(437)	(711)	(1,450)	57	(2,541)
Transfer from stage 2 and 3 to stage 1	(16)	16	-	-	-
Transfer from stage 1 and 3 to stage 2	341	(352)	11	-	-
Transfer from stage 1 and 2 to stage 3	215	204	(419)	-	-
Change in credit risk – transfers	(540)	132	408	-	-
Increase due to recognition and purchase	(260)	(18)	(98)	(93)	(469)
Changes in credit risk (net)	187	9	(356)	4	(156)
Decrease due to derecognition	-	7	1	60	68
Changes due to modification without derecognition (net)	(1)	(3)	(1)	-	(5)
Update of the applied estimation method (net)	3	-	4	21	28
Write-off	-	-	659	14	673
Other adjustments	5	(7)	107	37	142
As at the end of the period	(503)	(723)	(1,134)	100	(2,260)

• Other financial assets:

CHANGES IN ALLOWANCES FOR EXPECTED CREDIT LOSSES IN THE PERIOD – Stage 3	2025	2024
As at the beginning of the period	(127)	(134)
Changes in credit risk (net)	(3)	3
Decrease due to derecognition	1	-
Write-off	48	8
Other adjustments	(5)	(4)
As at the end of the period	(86)	(127)

48.4. Other disclosures

For financial instruments measured at fair value through profit or loss, i.e., derivative instruments, securities, and loans and advances granted to customers, the maximum exposure to credit risk is equal to their carrying amount presented in the statement of financial position.

FINANCIAL ASSETS SUBJECT TO MODIFICATION	2025		2024
Financial assets subject to modification during the period:	Stage 2	Stage 3	Stage 2	Stage 3
valuation amount at amortized cost before modification	679	571	616	483
gain (loss) on modification	11	-	13	(1)
Financial assets subject to modification since initial recognition:	31.12.2025		31.12.2024
gross carrying amount of financial assets subject to modification for which expected losses were calculated over the lifetime and which are classified as Stage 1 after modification	290		98

The table below presents the outstanding amounts of financial assets to be repaid, which were written down during the reporting period and which are still subject to debt recovery activities.

RECEIVABLES WRITTEN OFF	2025		2024
RECEIVABLES WRITTEN OFF	Partly written off	Entirely written off	Partly written off	Entirely written off
real estate loans	12	4	21	127
business loans	24	101	41	833
consumer loans	80	45	85	543
Total	116	150	147	1,503

The Bank adopted the following criteria for writing off receivables:

• the receivable has fully matured and is the consequence of a loan, advance, contractual overdraft, guarantee, surety, or bond;

• in accordance with IFRS, the allowance for expected credit losses covers 100% of the gross carrying amount of the asset, or exceeds 90% of this amount and:

• debt recovery actions taken did not lead to the recovery of the receivable, and the assessment of the probability of recovery (taking into account the findings of the bailiff or the receiver, transferability of collateral, level of satisfaction, mortgage position) indicates that the entire receivable cannot be recovered, or

• in the last 12 months, repayments did not cover currently accrued interest.

PAST DUE FINANCIAL ASSETS SUBJECT TO IMPAIRMENT OR IMPAIRED (net) – loans and advances to customers	up to 30 days	30 to 90 days	over 90 days	TOTAL
31.12.2025	up to 30 days	30 to 90 days	over 90 days	TOTAL
Stage 1	821	8	-	829
Stage 2	716	201	104	1,021
Stage 3	340	178	1,751	2,269
Total	1,877	387	1,855	4,119

31.12.2024
Stage 1	1,401	4	-	1,405
Stage 2	685	228	132	1,045
Stage 3	183	348	1,336	1,867
Total	2,269	580	1,468	4,317

To specify whether a loan is overdue, the Bank applies the following minimum thresholds:

• PLN 400 – for retail exposures,

• PLN 2,000 – for other credit exposures, and

• 1% – with reference to the debtor’s entire credit exposure in the balance sheet of the Bank.

• Quality of the portfolio covered by the rating model for loans and advances to customers at gross carrying amount

CREDIT RISK EXPOSURES BY PD PARAMETER	Stage 1	Stage 2	Stage 3	POCI	TOTAL
31.12.2025	Stage 1	Stage 2	Stage 3	POCI	TOTAL
REAL ESTATE LOANS	107,935	8,676	1,107	71	117,789
0.00 - 0.02%	12,183	64	-	-	12,247
0.02 - 0.07%	59,191	461	-	2	59,654
0.07 - 0.11%	14,329	193	-	1	14,523
0.11 - 0.18%	9,385	312	-	2	9,699
0.18 - 0.45%	6,142	1,963	-	6	8,111
0.45 - 1.78%	1,631	3,218	-	5	4,854
1.78 - 99.99%	497	2,448	-	7	2,952
100%	-	-	1,107	48	1,155
no internal rating	4,577	17	-	-	4,594
BUSINESS LOANS	97,883	12,564	5,197	462	116,106
0.00 - 0.45%	38,583	9	-	-	38,592
0.45 - 0.90%	8,549	69	-	-	8,618
0.90 - 1.78%	15,292	604	-	3	15,899
1.78 - 3.55%	18,830	3,193	-	-	22,023
3.55 - 7.07%	9,946	4,839	-	45	14,830
7.07 - 14.07%	5,693	2,391	-	-	8,084
14.07 - 99.99%	247	1,414	-	5	1,666
100%	-	-	5,197	408	5,605
no internal rating	743	45	-	1	789
CONSUMER LOANS	39,750	3,341	2,127	99	45,317
0.00 - 0.45%	12,632	96	-	1	12,729
0.45 - 0.90%	6,946	130	-	2	7,078
0.90 - 1.78%	7,037	262	-	3	7,302
1.78 - 3.55%	5,798	441	-	4	6,243
3.55 - 7.07%	3,263	505	-	4	3,772
7.07 - 14.07%	1,231	466	-	4	1,701
14.07 - 99.99%	329	1,197	-	6	1,532
100%	-	-	2,127	72	2,199
no internal rating	2,514	244	-	3	2,761
TOTAL	245,568	24,581	8,431	632	279,212

CREDIT RISK EXPOSURES BY PD PARAMETER	Stage 1	Stage 2	Stage 3	POCI	TOTAL
31.12.2024	Stage 1	Stage 2	Stage 3	POCI	TOTAL
REAL ESTATE LOANS	97,401	9,068	1,268	73	107,810
0.00 - 0.02%	10,874	69	-	-	10,943
0.02 - 0.07%	53,034	479	-	3	53,516
0.07 - 0.11%	12,863	202	-	1	13,066
0.11 - 0.18%	8,211	497	-	1	8,709
0.18 - 0.45%	5,933	2,185	-	3	8,121
0.45 - 1.78%	2,023	3,174	-	7	5,204
1.78 - 99.99%	221	2,445	-	8	2,674
100%	-	-	1,268	50	1,318
no internal rating	4,242	17	-	-	4,259
BUSINESS LOANS	84,158	17,735	4,877	400	107,170
0.00 - 0.45%	34,954	22	-	-	34,976
0.45 - 0.90%	6,817	342	-	-	7,159
0.90 - 1.78%	14,967	2,676	-	-	17,643
1.78 - 3.55%	15,312	3,998	-	-	19,310
3.55 - 7.07%	7,219	5,408	-	5	12,632
7.07 - 14.07%	4,061	3,770	-	4	7,835
14.07 - 99.99%	217	1,496	-	4	1,717
100%	-	-	4,877	386	5,263
no internal rating	611	23	-	1	635
CONSUMER LOANS	31,334	3,288	1,858	90	36,570
0.00 - 0.45%	10,488	89	-	1	10,578
0.45 - 0.90%	5,655	138	-	1	5,794
0.90 - 1.78%	5,433	311	-	2	5,746
1.78 - 3.55%	4,173	526	-	2	4,701
3.55 - 7.07%	2,324	578	-	2	2,904
7.07 - 14.07%	909	506	-	2	1,417
14.07 - 99.99%	220	1,084	-	4	1,308
100%	-	-	1,858	72	1,930
no internal rating	2,132	56	-	4	2,192
TOTAL	212,893	30,091	8,003	563	251,550

• Quality of the portfolio covered by the rating model for off-balance sheet liabilities at nominal value

CREDIT RISK EXPOSURES BY PD PARAMETER 31.12.2025	Stage 1	Stage 2	Stage 3	POCI	TOTAL
0.00 - 0.45%	26,504	67	-	1	26,572
0.45 - 0.90%	16,748	325	-	1	17,074
0.90 - 1.78%	15,923	631	-	1	16,555
1.78 - 3.55%	18,636	1,766	-	-	20,402
3.55 - 7.07%	9,493	1,118	-	-	10,611
7.07 - 14.07%	3,097	822	-	294	4,213
14.07 - 99.99%	34	256	-	-	290
100%	-	-	564	11	575
no internal rating	14,856	1,206	-	-	16,062
TOTAL	105,291	6,191	564	308	112,354

31.12.2024
0.00 - 0.45%	21,017	91	-	1	21,109
0.45 - 0.90%	14,120	586	-	1	14,707
0.90 - 1.78%	13,834	2,002	-	-	15,836
1.78 - 3.55%	14,333	2,812	-	-	17,145
3.55 - 7.07%	5,134	2,727	-	1	7,862
7.07 - 14.07%	2,028	1,833	-	337	4,198
14.07 - 99.99%	50	172	-	-	222
100%	-	-	371	1	372
no internal rating	23,280	1,233	-	-	24,513
TOTAL	93,796	11,456	371	341	105,964

• Quality of the portfolio covered by the rating model for amounts due from banks at gross carrying amount

AMOUNTS DUE FROM BANKS	31.12.2025		31.12.2024
AMOUNTS DUE FROM BANKS	Stage 1	TOTAL	Stage 1	TOTAL
EXTERNAL RATINGS
AA	284	284	1,064	1,064
A	6,000	6,000	7,227	7,227
BBB	74	74	75	75
BB	4	4	1	1
B	-	-	1	1
TOTAL	6,362	6,362	8,368	8,368

• Quality of the portfolio covered by the rating model for debt securities at gross carrying amount

DEBT SECURITIES 31.12.2025	Stage 1	Stage 2	Stage 3		TOTAL

EXTERNAL RATINGS
AAA	13,601	-		-	13,601
AA	1,990	-		-	1,990
A	198,764	34		-	198,798
BBB	2,780	-		-	2,780
BB	650	208		-	858
INTERNAL RATINGS
0.00-0.45%	8,302	-		-	8,302
0.45-0.90%	6,627	220		-	6,847
0.90-1.78%	305	257		-	562
1.78-3.55%	1,885	60		-	1,945
7.07-14.07%	80	4		-	84
100%	-	-		8	8
no internal rating	14	-		-	14
TOTAL	234,998	783		8	235,789

31.12.2024
EXTERNAL RATINGS
AAA	11,658	-	-	11,658
AA	9,108	-	-	9,108
A	163,986	-	-	163,986
BBB	1,994	-	-	1,994
BB	560	485	-	1,045
INTERNAL RATINGS
0.00-0.45%	6,873	-	-	6,873
0.45-0.90%	6,200	791	-	6,991
0.90-1.78%	89	82	-	171
1.78-3.55%	1,844	66	-	1,910
3.55-7.07%	3	-	-	3
7.07-14.07%	19	1	-	20
100%	-	-	10	10
no internal rating	-	133	-	133
TOTAL	202,334	1,558	10	203,902

49. Offsetting financial assets and financial liabilities

The Bank offsets and presents financial assets and liabilities in the statement of financial position on a net basis if it has a legally enforceable right to set off the amounts and intends either to settle on a net basis, or to realize the assets and settle the liabilities simultaneously.

Most often, positive and negative fair values of interest rate derivative instruments are offset against margin deposits (Variation Margin) where the counterparty is a clearing house (CCP) or a clearing broker.

The Bank enters into ISDA (International Swaps and Derivatives Association Master Agreements) and GMRA (Global Master Repurchase Agreement) agreements, which make it possible to offset assets and liabilities (close-out netting) in the event of a breach of the agreement. These agreements mitigate settlement and pre-settlement risks, but they do not meet the requirements of IAS 32 because the set-off is conditional and depends on the occurrence of a specific event.

Exposures arising from derivatives are further secured by margin deposits provided by counterparties as part of CSAs (Credit Support Annex).

OFFSETTING ASSETS - Hedging and other derivative instruments	31.12.2025	31.12.2024
Recognized financial assets, gross	6,839	6,423
Financial liabilities subject to offsetting, gross	(4,246)	(4,061)
Financial assets recognized in the statement of financial position, net	2,593	2,362
Amounts subject to enforceable framework agreement or similar agreement concerning offsetting, including related to:	1,146	881
(i) recognized financial instruments which do not meet the offsetting criteria	330	447
(ii) financial collateral (including cash)	816	434
Net amount	1,447	1,481

OFFSETTING LIABILITIES - Hedging and other derivative instruments	31.12.2025	31.12.2024
Recognized financial liabilities, gross	5,825	7,048
Financial assets subject to offsetting, gross	(2,996)	(4,337)
Financial liabilities recognized in the statement of financial position, net	2,829	2,711
Amounts subject to enforceable framework agreement or similar agreement concerning offsetting, including related to:	579	743
(i) recognized financial instruments which do not meet the offsetting criteria	330	447
(ii) financial collateral (including cash)	249	296
Net amount	2,250	1,968

50. Managing credit concentration risk in the Bank

Credit concentration risk is the risk arising from a large exposure to individual customers or related groups whose repayment capacity depends on a common risk factor. The Bank analyzes concentration, inter alia, as regards the largest customers and related groups, industries, regions, currencies and exposures secured with a mortgage.

The objective of managing this risk is to maintain a safe structure of the portfolio by mitigating excessive concentrations that may generate material losses. The measurement consists of examining the actual aggregate exposure to a customer or a group of related customers and the actual aggregate exposure in individual groups of loan portfolios, in accordance with the definition of exposure in the CRR (comprising assets, off-balance sheet items and indirect exposures).

The identification of concentration risk involves recognizing the factors affecting the emergence or change in the amount of the Bank's exposure. In this process, the Bank identifies a group of related customers constituting a single risk for the Bank) and determines the total exposure to each group of customers, and applies exemptions from the concentration limit and risk mitigation techniques consistent with the CRR.

The tolerance level for concentration risk is determined by external limits and the Bank's internal limits (strategic limits and other limits defining the risk appetite). To measure the concentration of exposures, the Bank uses, among other things, the concentration ratio resulting from Art. 395(1) of the CRR and Art. 79a of the Banking Law, the Gini coefficient and the Lorenz curve. The Bank forecasts changes in the level of concentration risk as part of its analyses and reviews of internal limits and the concentration risk management policy and in the process of stress testing concentration risk.

Concentration risk is an element of comprehensive stress tests which enables the evaluation of the forecast effect of correlated credit, interest rate, currency, operating and liquidity risks and concentration risk on the expected credit loss of the Bank. The monitoring of the Bank's exposure concentration takes place in the financing decision-making process and systemically, among other things, through daily control of limits, identification of large exposures, and monthly/quarterly control of internal limits and early warning indicators.

• Concentration by the largest entities (customers)

The Bank monitors the risk of concentration towards individual customers and related groups in accordance with the CRR. It does not allow exposures exceeding 25% of the Tier 1 capital of the Bank after taking into account risk mitigation techniques (Arts. 399–403 of the CRR).

As at 31 December 2025 and 31 December 2024, the concentration limits were not exceeded. The largest exposure to a single entity (excluding governments and banks) accounted for 55.45% of Tier 1 capital in 2025 and 53.43% in 2024, respectively.

The total exposure to the five largest customers (excluding governments and banks) comprises the sum of gross balance sheet exposures from loans, advances, debt securities, purchased debt claims, off-balance sheet exposures, derivative transactions (according to Art. 274(2) of the CRR) and shares – details are presented in the table below.

31.12.2025				31.12.2024
No.	The Bank's exposure	Share of the portfolio	Concentration ratio1	No.	The Bank's exposure	Share of the portfolio	Concentration ratio1
12	24,175	5.59%	55.45%	12	22,616	5.44%	53.43%
22	8,020	1.85%	18.40%	22	14,187	3.41%	33.52%
32	4,166	0.96%	9.56%	32	8,021	1.93%	18.95%
4	3,151	0.73%	7.23%	42	3,390	0.82%	8.01%
5	3,106	0.72%	7.12%	5	3,181	0.76%	7.52%
Total	42,618	9.85%	97.75%	Total	51,395	12.36%	121.43%

1 The Bank's exposure to the Bank's Tier 1 capital ratio

2 Exposure exempt from the exposure concentration limit under the CRR

• Concentration by the largest groups of related customers

The Bank's largest exposure to a single group of related customers was 8.40% of the financial instrument portfolio as at 31 December 2025 (8.18% in 2024).

Excluding exposures to governments and banks and without the effect of credit risk mitigation, the largest concentration towards a group of related customers was 83.40% of Tier 1 capital in 2025 (80.40% in 2024).

The total exposure to the five largest groups of related customers comprises the sum of gross balance sheet exposures (loans, advances, debt securities, purchased debt claims), off-balance sheet exposures, derivative transactions (according to Art. 274(2) of the CRR) and shares – details are presented in the table below.

31.12.2025					31.12.2024
No.	The Bank's exposure	Share of the portfolio	Concentration ratio1	No.		The Bank's exposure	Share of the portfolio	Concentration ratio1
12	36,362	8.40%	83.40%	12		34,030	8.18%	80.40%
2	5,377	1.24%	12.33%	22		15,241	3.67%	36.01%
3	4,115	0.95%	9.44%	3		4,256	1.02%	10.06%
4	3,491	0.81%	8.01%	4		3,246	0.78%	7.67%
5	3,196	0.74%	7.33%	5		3,189	0.77%	7.54%
Total	52,541	12.14%	120.51%	Total		59,962	14.42%	141.68%

1 The Bank's exposure to the Bank's Tier 1 capital ratio

2 Exposure exempt from the exposure concentration limit under the CRR

• Concentration by industry

The Bank's portfolio of corporate exposures is diversified across industry sectors. The table below presents the structure of the gross loan and securities portfolio to corporate entities by industry section.

SECTION SYMBOL	SECTION NAME	31.12.2025		31.12.2024
SECTION SYMBOL	SECTION NAME	EXPOSURE	Share of the portfolio	EXPOSURE	Share of the portfolio
L	Financial and insurance activities	26.39	1.04	26.62	1.09
C	Industrial processing	14.64	9.17	14.73	9.13
M	Real estate market administration	8.77	18.21	7.91	18.57
G	Wholesale and retail trade	8.85	17.90	7.86	19.84
P	Public administration and national defense, compulsory social security	16.74	2.72	18.98	3.26
Other exposures		24.61	50.96	23.90	48.11
Total		100.00	100.00	100.00	100.00

• Concentration by geographical regions

The Bank’s loan portfolio is diversified in terms of geographical concentration. The geographical structure of the gross loan portfolio is identified depending on the Bank's customer area:

CONCENTRATION OF CREDIT RISK BY GEOGRAPHICAL REGION FOR RETAIL CUSTOMERS	31.12.2025	31.12.2024
Warsaw region	16.45	16.45
Katowice region	11.11	11.08
Wrocław region	10.71	10.75
Poznań region	10.27	10.35
Gdańsk region	10.18	10.14
Łódź region	8.86	8.77
Kraków region	8.85	8.77
Szczecin region	8.28	8.21
Lublin region	7.79	7.54
Białystok region	6.96	6.70
Head Office	0.41	0.67
Other	0.13	0.57
Total	100.00	100.00

CONCENTRATION OF CREDIT RISK BY GEOGRAPHICAL REGION FOR INSTITUTIONAL CUSTOMERS	31.12.2025	31.12.2024
Head Office	5.16	4.74
central macroregion	45.67	45.86
northern macroregion	7.20	7.54
western macroregion	9.10	9.67
southern macroregion	9.80	10.56
south-eastern macroregion	8.83	9.00
north-eastern macroregion	3.51	3.41
south-western macroregion	7.31	6.57
foreign branches	3.42	2.65
Total	100.00	100.00

• Concentration of credit risk by currency

CONCENTRATION OF CREDIT RISK BY CURRENCY	31.12.2025	31.12.2024
PLN	87.54	87.29
Foreign currencies, of which:	12.46	12.71
CHF	0.38	0.85
EUR	11.27	10.90
USD	0.54	0.87
UAH	0.00	0.00
GBP	0.02	0.02
Other	0.25	0.07
Total	100.00	100.00

• Other types of concentration

The Bank analyses the structure of its housing loan portfolio by LTV levels.

THE BANK’S HOUSING LOAN PORTFOLIO STRUCTURE BY LTV	31.12.2025	31.12.2024
0% - 40%	40.15	44.73
41% - 60%	23.42	25.51
61% - 80%	26.00	20.08
81% - 90%	6.85	7.49
91% - 100%	3.35	1.99
over 100%	0.23	0.20
Total	100.00	100.00

AVERAGE LTV FOR:	31.12.2025	31.12.2024
- portfolio of housing loans in CHF	43.55	40.94
- portfolio of housing loans	49.66	46.84

51. Exposure to the counterparty credit risk

CONCENTRATION OF CREDIT RISK – INTERBANK MARKET AND NON-WHOLESALE MARKET – EXPOSURE*
Counterparty	Country	Rating	Interbank market – wholesale				Non-wholesale market			Cash on NOSTRO and LORO accounts		Total
Counterparty	Country	Rating	Deposits (nominal value)	Derivatives (market value, excluding collateral if positive)	Securities (nominal value)	Nominal balance sheet exposure		Nominal off-balance sheet exposure
31.12.2025
Counterparty 1	Luxembourg	AAA	-	-	13,700	-		-	-		13,700
Counterparty 2	Poland	A	-	23	20	4,588		6,912	2		11,545
Counterparty 3	Poland	A	10	-	7,766	-		-	-		7,776
Counterparty 4	Belgium	A	286	(5)	-	-		-	65		351
Counterparty 5	Ukraine	none	-	-	-	-		277	-		277
Counterparty 6	Germany	A	-	201	-	-		-	4		205
Counterparty 7	Germany	A	-	154	-	-		-	-		154
Counterparty 8	Poland	A	-	-	-	150		-	-		150
Counterparty 9	France	A	-	119	-	-		-	-		119
Counterparty 10	France	A	-	98	-	-		-	-		98
31.12.2024
Counterparty 1	Luxembourg	AAA	-	-	11,799	-		-	-		11,799
Counterparty 2	Poland	A	-	207	6	5,843		5,126	2		11,184
Counterparty 3	Poland	A	-	18	9,693	-		-	-		9,711
Counterparty 93	Switzerland	AA	598	-	-	-		-	-		598
Counterparty 4	Belgium	A	427	(9)	-	-		-	105		532
Counterparty 5	Ukraine	none	-	-	-	-		316	-		316
Counterparty 94	Switzerland	AA	299	-	-	-		-	-		299
Counterparty 15	Germany	AA	-	128	-	-		32	4		164
Counterparty 12	France	A	-	161	-	-		-	-		161
Counterparty 8	Poland	A	-	6	-	150		-	-		156

* Excluding exposures to the State Treasury and the National Bank of Poland

The Bank mitigates credit risk by concluding framework agreements with counterparties (PBA, ISDA, ICMA), which enable offsetting of liabilities and the use of the close-out netting mechanism in the event of termination of the agreement. In addition, collateral agreements (CSA – Credit Support Annex) are applied, imposing the obligation to establish collateral upon meeting specific conditions. Exceptions are transactions between the Group entities (PKO Bank Polski S.A. and PKO Bank Hipoteczny S.A.), which are exempted from the EMIR requirements regarding the exchange of collateral.

The Bank clears interest rate derivative transactions through two clearing houses (CCP) in accordance with EMIR. For transactions not cleared at a CCP, the Bank concludes agreements on initial margins (IM) based on the ISDA standard. Deposits are placed with a depositary in the form of accepted securities or cash after the IM threshold is exceeded, and until then the level of the IM requirement is monitored.

52. Forbearance practices

The Bank treats as forbearance actions agreed with a debtor in a difficult financial situation, consisting in changing the terms of the agreement in order to restore repayment capacity and maximize recoveries while minimizing costs. They may include, among other things: dividing the debt into instalments, changing the repayment schedule, extending the lending period, changing the interest rate or margin, as well as reducing the debt.

Exposures subject to forbearance are classified into the portfolio of impaired exposures. Return to the performing portfolio takes place not earlier than after 12 months of timely repayment of arrears and at least 6 instalments, provided that there are no threats in the Bank's assessment.

The forbearance status expires 24 months after inclusion in the performing portfolio if the customer has no overdue debt >30 days and has repaid at least 12 full instalments. Throughout the period of the status, the impairment allowance corresponds to the expected loss over the lifetime of the exposure.

Non-performing exposures are those which are past due by >90 days and their value exceeds 20% of all exposures to the debtor.

31.12.2025	Instruments with modified terms and conditions	Refinancing	Total, gross	Allowances for expected credit losses	Total, net
Performing exposures
Loans and advances to customers	671	2	673	30	703
Non-performing exposures
Securities	8	-	8	-	8
Loans and advances to customers	3,136	15	3,151	(1,179)	1,972
TOTAL EXPOSURES SUBJECT TO FORBEARANCE	3,815	17	3,832	(1,149)	2,683

31.12.2024
Performing exposures
Securities	100	-	100	-	100
Loans and advances to customers	1,065	2	1,067	(7)	1,060
Non-performing exposures
Securities	10	-	10	-	10
Loans and advances to customers	3,159	17	3,176	(861)	2,315
TOTAL EXPOSURES SUBJECT TO FORBEARANCE	4,334	19	4,353	(868)	3,485

LOANS AND ADVANCES TO CUSTOMERS SUBJECT TO FORBEARANCE	2025	2024
Recognized interest income on forborne loans and advances to customers	317	365

53. Information on package sale of receivables

In 2025, the Group Bank package sales of about 48 thousand receivables (balance sheet and off-balance sheet) from retail and business customers amounting to a total of PLN 2,070 million (in 2024: 74 thousand receivables for PLN 1,756 million). As at 31 December 2025, the value of the provisions for potential claims on the sale of receivables amounted to PLN 6 million (as at 31 December 2024: PLN 5 million). As a result of the sale, all risks and rewards were transferred, hence the Bank derecognized these assets.

54. Interest rate risk management

Interest rate risk is a risk of losses being incurred on the balance sheet and off-balance sheet items sensitive to interest rate fluctuations. The Bank mitigates it by appropriately structuring its assets and liabilities and applying limits and thresholds tailored to the scale of operations.

The following are used to measure the risk:

• sensitivity of interest income,

• sensitivity of economic value,

• VaR,

• stress tests and repricing gap analysis.

The Bank monitors the level of risk and the utilization of strategic and internal limits.

As at 31 December 2025 and 31 December 2024, the exposure to interest rate risk remained within the adopted limits; the main source of risk was the PLN interest rate.

Interest rate risk is generated primarily in the banking book (items from core activities), while in the trading book it is kept at a limited level. In order to mitigate it, the Bank, in particular, uses limits, performs sensitivity analyses and concludes hedging transactions (IRS/CIRS) as part of the approved hedge accounting strategies. Note “Hedge accounting and other derivative instruments”.

• Sensitivity of interest income

This measure determines the potential impact of an abrupt shift in the yield curve on interest income in a specific time horizon. The result arises mainly from the mismatch between repricing dates of assets, liabilities and off-balance sheet liabilities (including derivative instruments) sensitive to interest rate fluctuations.

Sensitivity of interest income in the banking book of the Bank to the shift in the yield curve of 200 bp down in a one-year horizon for all currencies is shown in the table below:

NAME OF THE MEASURE	31.12.2025	31.12.2024
Sensitivity of interest income (PLN million)	(1,616)	(1,343)

• Sensitivity of economic value

This measure reflects the fair value change of the portfolio arising from the parallel shift of the yield curves by 200 bp up or down (the more unfavorable scenario is taken into account). The table below presents the stress test results for the banking book of the Bank in all currencies as at 31 December 2025 and 31 December 2024.

NAME OF THE MEASURE	31.12.2025	31.12.2024
Sensitivity of economic value (PLN million)	(3,511)	(3,239)

The Bank monitors interest rate risk in the trading book by applying, in particular, the VaR measure.

• Value at risk

IR VaR determines a potential loss under normal market conditions in a specific time horizon and with an assumed level of probability, resulting from changes in interest rate curves. The table below presents the IR VaR for the Bank's trading book.

NAME OF THE MEASURE IR VaR for a 10-day time horizon at a confidence level of 99% (PLN million):	31.12.2025	31.12.2024
Average value	5	7
Maximum value	12	15
Value at the end of the period	5	5

55. Currency risk management

Currency risk is the risk of loss resulting from changes in foreign exchange rates, generated by maintaining open currency positions. The Bank mitigates it by appropriately structuring the currency structure of assets and liabilities and applying limits and thresholds tailored to the scale of operations.

The following measures are used for risk measurement: value at risk (VaR) and stress tests. Control includes setting strategic tolerance limits and monitoring the level of risk, utilization of limits and thresholds. The Bank has set limits for, among other things, currency positions, VaR for a 10-day time horizon and potential loss on the currency market.

• Sensitivity measures

FX VaR determines a potential loss under normal market conditions in a specific horizon and with an assumed level of probability, resulting from changes in foreign exchange rates. Stress tests are used to estimate losses in the event of abrupt changes on the currency market which are not included in the standard statistical measures.

NAME OF SENSITIVITY MEASURE	31.12.2025	31.12.2024
VaR for a 10-day time horizon at a confidence level of 99% (in PLN million) jointly for all currencies	17	3

• Foreign currency position

FOREIGN CURRENCY POSITION1	31.12.2025	31.12.2024
EUR	(490)	39
CHF	(153)	(122)
Other (Global, Net)	(36)	6

1 The positions do not include structural positions in UAH (PLN 1,072.3 million) and in EUR (PLN 23.5 million), for which the Bank obtained approval from the PFSA to exclude them from the calculation of the currency positions.

Currency positions (in addition to volatility of foreign exchange rates) are a key factor determining the level of currency risk to which the Bank is exposed. Their level is affected by the concluded on-balance sheet and off-balance sheet currency transactions, with the exception of the structural position in UAH and EUR excluded from the calculation of the currency positions with the approval of the PFSA.

• Financial assets and liabilities by currency

FINANCIAL ASSETS	Currency translated to PLN
31.12.2025	PLN	CHF	EUR	USD	Other	Total
Cash and balances with the Central Bank	20,849	23	483	107	182	21,644
Amounts due from banks	5,003	96	964	104	184	6,351
Hedging derivatives	128	-	19	-	-	147
Other derivative instruments	2,260	-	149	37	-	2,446
Securities	218,394	-	11,450	6,601	-	236,445
Reverse repo transactions	701	-	1,309	-	-	2,010
Loans and advances to customers	238,784	1,024	31,576	809	798	272,991
Other financial assets	1,818	1	58	23	16	1,916
Total financial assets	487,937	1,144	46,008	7,681	1,180	543,950

31.12.2024	PLN	CHF	EUR	USD	Other	Total
Cash and balances with the Central Bank	22,426	19	487	142	189	23,263
Amounts due from banks	5,689	1	2,364	148	147	8,349
Hedging derivatives	323	-	20	1	-	344
Other derivative instruments	1,791	-	186	41	-	2,018
Securities	184,975	-	9,680	10,222	-	204,877
Reverse repo transactions	892	-	-	-	-	892
Loans and advances to customers	214,866	2,153	27,377	1,267	245	245,908
Other financial assets	2,094	2	164	35	24	2,319
Total financial assets	433,056	2,175	40,278	11,856	605	487,970

FINANCIAL LIABILITIES AND OFF-BALANCE SHEET LIABILITIES	Currency translated to PLN
31.12.2025	PLN	CHF	EUR	USD	Other	Total
Amounts due to Central bank	10	-	-	-	-	10
Amounts due to banks	2,147	14	1,036	113	67	3,377
Hedging derivatives	105	-	-	-	-	105
Other derivative instruments	2,338	-	326	59	1	2,724
Repo transactions	22	-	-	-	-	22
Amounts due to customers	397,716	1,454	38,617	14,060	3,815	455,662
Liabilities in respect of debt securities in issue	1,021	-	15,013	-	-	16,034
Subordinated liabilities	6,309	-	-	-	-	6,309
Other financial liabilities	2,620	5	1,048	202	38	3,913
Provisions for financial liabilities and guarantees granted	532	5	76	5	2	620
Total financial liabilities	412,820	1,478	56,116	14,439	3,923	488,776
Financial liabilities and guarantees granted	89,520	49	15,883	5,604	1,298	112,354

31.12.2024	PLN	CHF	EUR	USD	Other	Total
Amounts due to Central bank	11	-	-	-	-	11
Amounts due to banks	1,200	58	827	45	141	2,271
Hedging derivatives	301	-	1	-	-	302
Other derivative instruments	2,104	-	252	53	-	2,409
Amounts due to customers	358,773	1,321	37,142	13,913	3,771	414,920
Liabilities in respect of debt securities in issue	1,025	-	10,974	-	-	11,999
Subordinated liabilities	4,291	-	-	-	-	4,291
Other financial liabilities	2,528	2	1,104	184	93	3,911
Provisions for financial liabilities and guarantees granted	529	8	77	3	4	621
Total financial liabilities	370,762	1,389	50,377	14,198	4,009	440,735
Financial liabilities and guarantees granted	87,073	75	11,943	6,076	797	105,964

56. Liquidity risk management

Liquidity risk is the risk of the inability to settle liabilities as they become due because of a shortage of liquid assets, resulting, among other things, from a mismatch of cash flows, withdrawal of funds by customers or loss of sources of financing. The Bank also manages financing risk, which includes the inability to renew or obtain funds.

The risk is mitigated by appropriately structuring assets and liabilities and maintaining stable sources of financing.

The following are used for measurement, among other things:

• contractual and adjusted liquidity gap;

• liquidity surplus;

• liquidity coverage ratio (LCR);

• net stable funding ratio (NSFR);

• liquidity reserve;

• the ratio of stable funds to illiquid assets;

• measures of stability of the deposit and loan portfolios;

• liquidity stress tests.

The control covers strategic and internal limits, monitoring of supervisory standards, concentration of sources of financing and early warning indicators. The Bank prepares liquidity forecasts which take into account stress-test scenarios.

The main tools are: procedures and contingency plans, short-term, medium-term and long-term limits, deposit and investment transactions, transactions in securities and derivative instruments, and transactions ensuring long-term financing. The policy is based on maintaining a liquidity surplus, a stable deposit base and liquid securities, using money market instruments, including NBP open market operations.

• Liquidity gap

It is a statement of balance sheet and off-balance sheet items by their adjusted maturities.

	on demand	0 – 1 month	1 – 3 months	3 – 6 months	6 – 12 months	12 – 24 months	24 – 60 months	more than 60 months
31.12.2025
Adjusted periodic gap	19,397	154,108	(16,770)	(1,454)	(7,374)	14,298	33,026	(195,231)
Adjusted cumulative periodic gap	19,397	173,505	156,735	155,281	147,907	162,205	195,231	-
31.12.2024
Adjusted periodic gap	18,164	124,128	(15,197)	(2,130)	(9,643)	19,991	27,326	(162,639)
Adjusted cumulative periodic gap	18,164	142,292	127,095	124,965	115,322	135,313	162,639	-

In all time horizons, the liquidity gap was positive, which means a surplus of assets receivable over liabilities payable.

• Supervisory liquidity measures

The Bank regularly calculates and monitors the ratios specified by the EU provisions:

• LCR (Liquidity Coverage Ratio) - the ratio of high-quality liquid assets to net outflows in the 30-day horizon in stress conditions,

• NSFR (Net Stable Funding Ratio) - the ratio of items providing stable funding to items requiring stable funding.

SUPERVISORY LIQUIDITY MEASURES	31.12.2025	31.12.2024
NSFR - net stable funding ratio	160.2%	156.8%
LCR - liquidity coverage ratio	254.9%	231.1%

The values of the supervisory measures ratios remained above the supervisory limits.

• Core deposit base

As at 31 December 2025, the core deposit base constituted approx. 94.3% of all deposits placed with the Bank (excluding the interbank market), which represents a decrease of around 0.4 p.p. compared with the end of 2024.

• Structure of the sources of financing

STRUCTURE OF THE BANK’S SOURCES OF FINANCING	31.12.2025	31.12.2024
Total deposits (excluding interbank market)	86.47%	86.13%
Interbank market deposits	0.73%	0.51%
Equity	8.63%	9.90%
Market financing	4.17%	3.46%
Total	100.00%	100.00%

• Contractual cash flows from the financial liabilities, excluding derivative financial instruments

The amounts comprise non-discounted future cash flows in respect of principal and interest in accordance with the agreement, up to the maturity date of the liability. The earliest possible settlement deadline was assumed, and in the case of liabilities repaid in instalments – each instalment was allocated to the earliest period in which the obligation to pay may arise. For liabilities with variable instalment amounts, the terms binding as at the reporting date were applied.

31.12.2025	Up to 1 month (inclusive)	1 to 3 months (inclusive)	More than 3 months up to 1 year (inclusive)	More than 1 year up to 5 years (inclusive)	More than 5 years	Contractual amount	Carrying amount
Amounts due to Central bank	10	-	-	-	-	10	10
Repo transactions	22	-	-	-	-	22	22
Amounts due to banks	3,346	-	31	-	-	3,377	3,377
Amounts due to customers	379,975	41,598	24,283	8,756	3,472	458,084	455,662
Liabilities in respect of debt securities in issue	-	126	3,675	9,773	4,380	17,954	16,034
Subordinated liabilities	-	85	302	3,847	4,532	8,766	6,309
Lease liabilities	24	46	184	620	219	1,093	1,093
Other financial liabilities	2,820	-	-	-	-	2,820	2,820
Total	386,197	41,855	28,475	22,996	12,603	492,126	485,327
Off-balance sheet liabilities:
financing granted	7,096	4,738	34,678	29,580	20,584	96,676
guarantees granted	15,678	-	-	-	-	15,678

31.12.2024
Amounts due to Central bank	11	-	-	-	-	11	11
Amounts due to banks	2,271	-	-	-	-	2,271	2,271
Amounts due to customers	343,498	35,225	24,412	8,666	6,337	418,138	414,920
Liabilities in respect of debt securities in issue	-	351	220	12,958	-	13,529	11,999
Subordinated liabilities	-	100	217	5,057	-	5,374	4,291
Lease liabilities	22	43	175	586	287	1,113	1,112
Other financial liabilities	2,799	-	-	-	-	2,799	2,799
Total	348,601	35,719	25,024	27,267	6,624	443,235	437,403
Off-balance sheet liabilities:
financing granted	16,879	5,663	27,955	28,956	11,970	91,423	-
guarantees granted	14,541	-	-	-	-	14,541	-

Contractual cash flows from liabilities in respect of derivative financial instruments for which the valuation as at the balance sheet date was negative (a liability) and which are settled on a gross basis

31.12.2025	Up to 1 month (inclusive)	1 to 3 months (inclusive)	More than 3 months up to 1 year (inclusive)	More than 1 year up to 5 years (inclusive)	More than 5 years	Contractual amount
outflows (principal and interest)	(15,072)	(5,814)	(10,183)	(19,321)	(2,200)	(52,590)
inflows (principal and interest)	14,909	5,546	9,641	18,254	2,149	50,499

31.12.2024
outflows (principal and interest)	(12,195)	(8,032)	(7,690)	(6,338)	(1)	(34,256)
inflows (principal and interest)	11,923	5,706	7,292	6,308	-	31,229

31.12.2025	Up to 1 month (inclusive)	1 to 3 months (inclusive)	More than 3 months up to 1 year (inclusive)	More than 1 year up to 5 years (inclusive)	More than 5 years	Contractual amount
IRS	(3)	(75)	(362)	(43)	(91)	(574)
other derivatives: options, FRA, NDF	(144)	(342)	(869)	(723)	(1)	(2,079)

31.12.2024
IRS	(19)	(22)	(169)	81	(6)	(135)
other derivatives: options, FRA, NDF	(147)	(205)	(952)	(709)	-	(2,013)

• other information - financial liabilities, including past due liabilities

FINANCIAL LIABILITIES	31.12.2025	31.12.2024
Financial liabilities, including:	488,776	440,735
Past due	4	4

57. Assets pledged as collateral for liabilities and transferred financial assets

Collateral for liabilities in respect of derivative instruments

ASSETS PLEDGED AS COLLATERAL FOR LIABILITIES in respect of derivative instruments	31.12.2025	31.12.2024	31.12.2025	31.12.2024
	Derivative instruments (Initial Margin agreement)		Derivative instruments (other agreements)
Carrying amount of the collateral	1,544	2,018	492	113
Nominal value of the collateral	1,564	2,051	504	123
Type of collateral	Securities measured at fair value through other comprehensive income
Carrying amount of liabilities secured	160	1,846	492	113

funds securing liabilities in respect of contributions to the Bank Guarantee Fund (BGF)

Funds securing liabilities in respect of contributions to the Bank Guarantee Fund (BGF)	31.12.2025	31.12.2024
Value of the contribution made in the form of payables	1,052	896
Nominal value of the assets in which funds corresponding to payables were invested	1,392	1,172
Type of collateral*	treasury bonds	treasury bonds
Maturity of collateral	2026-2031	2026-2031
Carrying amount of the collateral	1,351	1,107

* Securities measured at fair value through other comprehensive income.

Since 2017, the value of contributions made in the form of payment commitments has not exceeded 30% of the contributions to the deposit guarantee fund or the resolution fund. These liabilities are secured by treasury bonds pledged for the benefit of the BGF in an amount which ensures that the ratio of the collateral value to the amount of liabilities is maintained at a level of at least 110%.

• legal limitations relating to the Bank’s title

In 2025 and 2024, there were no intangible assets or property, plant and equipment to which the Bank’s legal title was restricted or which were pledged as collateral for liabilities.

CAPITAL MANAGEMENT AT THE BANK

58. Capital adequacy

Capital adequacy means the Bank's ability to cover the risk associated with its business activities with its capital, whose level and structure are compliant with supervisory requirements, risk tolerance and the adopted time horizon.

Adequacy management comprises compliance with regulations, capital planning, determining capital targets, measuring internal capital, setting thresholds, monitoring own funds, balance sheet management, stress tests, and emergency measures.

Capital adequacy measures include:

• total capital ratio (TCR);

• the ratio of own funds to internal capital;

• Tier 1 core capital ratio (CET1);

• Tier 1 capital ratio (T1);

• leverage ratio;

• MREL ratio - TREA;

• MREL ratio - TEM.

The objective of monitoring is to assess compliance with supervisory standards and to identify situations requiring corrective actions.

The Bank's capital adequacy management is described in detail in the “Report on capital adequacy and other information subject to publication by the PKO Bank Polski S.A. Group”.

Minimum level of capital ratios maintained by the Bank in accordance with Art. 92 of the CRR Regulation
total capital ratio (TCR)	8.0%
Tier 1 capital ratio (T1)	6.0%
Tier 1 core capital ratio (CET1)	4.5%

Obligation to maintain a combined buffer above the minimum amounts specified in Art. 92 of the CRR, representing the sum of the applicable buffers	31.12.2025	31.12.2024
Total:	5.5%	4.56%
conservation buffer	2.5%	2.5%
Countercyclical buffer	1%	0.06%
due to identifying the Bank as another systemically important institution (“O-SII”)1	2%	2%
Combined minimum capital adequacy ratio together with the combined buffer requirement	13.5%	12.56%

1 The buffer represents a share of total risk exposure amount calculated in accordance with the CRR. On 11 December 2024, an announcement was published by the PFSA on the review of the adequacy of the Other Systemically Important Institution (O-SII) buffer ratio, according to which the O-SII buffer amount for individual banks was maintained at the level resulting from the previous review conducted in 2023.

Capital adequacy	31.12.2025	31.12.2024 restated	31.12.2024 published
Equity	55,635	49,767	49,767
capital: share capital, supplementary capital, other reserves, and general risk reserve	35,494	33,194	33,194
retained earnings	9,437	9,437	9,437
net profit or loss for the year	10,240	9,150	9,150
other comprehensive income	464	(2,014)	(2,014)
Exclusions from equity:	10,481	8,045	8,045
net profit or loss for the year	10,240	9,150	9,150
cash flow hedges	241	(1,105)	(1,105)
Other fund reductions:	2,575	2,610	2,614
goodwill	755	755	755
other intangible assets	1,415	1,504	1,504
securitization items	11	-	-
additional asset adjustments (AVA, DVA, NPE, capital exposures and DTA above the thresholds specified in Art. 48 of the CRR)	394	351	355
Provisional treatment of unrealized gains and losses on securities measured at fair value through OCI according to Art. 468 of the CRR	(303)	927	927
Temporary reversal of IFRS 9 impact2	-	560	739
Net profit or loss for the year, included by permission from the PFSA3	1,322	2,300	1,550
Tier 1 capital	43,598	42,899	42,324
Tier 2 capital (subordinated debt)	4,499	3,039	3,039
Own funds	48,097	45,938	45,363
Requirements for own funds	20,445	17,284	17,392
Credit risk4	17,116	14,817	14,925
Operational risk5	3,207	2,317	2,317
Market risk	61	114	114
Credit valuation adjustment risk	61	36	36
Total capital ratio	18.82	21.26	20.87
Tier 1 capital ratio	17.06	19.86	19.47

1 AVA – additional valuation adjustment, DVA – debt valuation adjustment, NPE – non-performing exposures, DTA – deferred tax assets.

2 The temporary reversal of the IFRS 9 impact on own funds was applicable until the end of 2024.

3 The amount of PLN 1,550 million relates to the portion of the profit for 2024 included in own funds with the approval of the PFSA, and the amount of PLN 2,300 million relates to the amount of the profit for 2024 following approval of the profit distribution by the AGM. In line with the European Banking Authority’s guidance on when to recognise annual and interim profits in capital adequacy data, from the point at which the institution formally meets the criteria to include the profit for the period in Tier 1 capital, it is considered that the profit should be included on a retrospective date and an adjustment to own funds should be made to the date to which the profit relates. Consequently, the value of the credit risk requirement, NPE adjustments and the transitional IFRS 9 reversal has also been recalculated. The amount of PLN 1,322 million in the figures as at 31 December 2025 relates to the portion of the profit for 2025 included in own funds with the approval of the PFSA.

4 In 2025, the requirement for own funds in respect of credit risk increased, which was driven mainly by the growth in the Bank's loan portfolio.

5 In 2025, the capital requirement related to operational risk increased due to the new CRR3 regulations. The Bank discontinued the use of the AMA approach, which had allowed it to take into account its individual risk profile.

The minimum requirement for own funds and eligible liabilities (MREL) in % determined by the BGF	31.12.2025	31.12.2024 restated	31.12.2024 published
MREL (TREA) ratio	17.78%	20.05%	19.56%
MREL (TREA) ratio without restrictions1	23.38%	24.74%	24.25%
MREL (TREA) – subordinated	16.68%	18.74%	18.26%
subordinated MREL (TREA) ratio (without restrictions)1	22.28%	23.43%	22.95%
MREL (TEM)	10.76%	10.97%	10.80%
MREL (TEM) subordinated	10.25%	10.39%	10.23%

Minimum MREL level	31.12.2025	31.12.2024 restated	31.12.2024 published
MREL (TREA)	15.36%	15.36%	15.36%
MREL (TREA) – subordinated	13.53%	13.90%	13.90%
MREL (TEM)	5.91%	5.91%	5.91%
MREL (TEM) – subordinated	5.50%	5.62%	5.62%

1 without deduction of Common Equity Tier 1 instruments held by the entity to meet the combined buffer requirement

The capital adequacy measures of the Bank in 2025 and 2024 remained at a safe level, well above the supervisory requirements. The minimum capital requirements were satisfied over the entire period.

Details regarding internal capital (Pillar II), disclosures (Pillar III) and publication rules are provided in the "PKO Bank Polski S.A. Information Policy" available on the Bank's website (www.pkobp.pl).

59. Dividends and distribution of retained earnings

In accordance with the decision of 13 June 2025 of the Annual General Meeting on distribution of profit for 2024:

• PLN 6,850 million was allocated for distribution among shareholders (the gross dividend per share was PLN 5.48 and was paid on 14 August 2025)

• PLN 2,300 million was transferred to the reserve capital for the payment of dividend, including interim dividend in accordance with § 30 of the Bank's Articles of Association.

The AGM passed a resolution to leave the Bank's retained earnings undistributed.

The dividend policy and the PFSA's recommendations regarding the distribution of dividends in 2026 are described in detail in Section 7.3 "DIVIDEND AND PROFIT DISTRIBUTION" of the Directors’ Report.

OTHER NOTES

60. Notes to the cash flow statement

Significant accounting policies:

Cash and cash equivalents comprise cash in hand, cash on nostro accounts with the NBP, current amounts due from banks, and other cash equivalents with maturities up to 3 months from the date of acquisition.

financial information

CASH AND CASH EQUIVALENTS	31.12.2025	31.12.2024
Cash, current account with the Central Bank	21,644	23,263
Current amounts due from banks	1,426	2,847
Total	23,070	26,110

INTEREST INCOME ON:	2025	2024
reported under operating activities	21,532	20,889
Loans and other amounts due from banks and balances with the Central Bank and pooling.	1,290	2,046
Debt securities	46	47
Loans and advances to customers	20,136	18,776
Repo transactions	60	20
reported under investing activities	8,293	7,204
Debt securities measured at fair value through other comprehensive income	4,128	4,376
Debt securities measured at amortized cost	4,165	2,828
Total	29,825	28,093

INTEREST EXPENSES – PAID:	2025	2024
reported under operating activities	(7,548)	(10,397)
Amounts due to banks	(91)	(72)
Amounts due to customers	(5,747)	(7,309)
Leases	(46)	(37)
Hedging derivatives	(1,451)	(2,202)
Debt securities	(202)	(764)
Repo transactions	(11)	(13)
reported under financing activities	(936)	(436)
Subordinated liabilities	(316)	(209)
Issues of securities	(620)	(227)
Total	(8,484)	(10,833)

• Reconciliation of items presented in the statement of financial position with financing activities in the cash flow statement

2025	As at the beginning of the period	Reported under financing activities				Reported under operating activities	As at the end of the period
2025	As at the beginning of the period	Incurred	Repaid	Repayment of interest on financial liabilities	(including: interest accrued, foreign exchange differences and other)		As at the end of the period
Liabilities in respect of debt securities in issue	11,999	7,407	(3,173)	(620)	421		16,034
Subordinated liabilities - subordinated bonds	4,291	2,000	-	(316)	334		6,309
Lease liabilities	1,112	-	(269)	-	250		1,093
Total	17,402	9,407	(3,442)	(936)	1,005		23,436

2024
Liabilities in respect of debt securities in issue	3,421	8,524	-	(227)	281	11,999
Subordinated liabilities - subordinated bonds	2,774	1,500	-	(209)	226	4,291
Lease liabilities	1,034	-	(277)	-	355	1,112
Total	7,229	10,024	(277)	(436)	862	17,402

OTHER INFLOWS FROM INVESTING ACTIVITIES INCLUDING DIVIDENDS	2025	2024
from subsidiaries, associates and joint ventures	919	1,024
from financial assets held for trading	1	2
from financial instruments not held for trading, measured at fair value through profit or loss	12	13
sale of shares in VISA and BOŚ reported under investing activities	36	48
Total	968	1,087

61. Transactions with the State Treasury and related entities

• Transactions with the State Treasury

The State Treasury holds a 29.43% interest in the Bank’s share capital.

Pursuant to the Act of 30 November 1995 on the state support in repayment of certain housing loans, reimbursement of guarantee bonuses paid, and amendments to certain Acts, PKO Bank Polski S.A. receives payments from the State budget as the repurchase of interest receivable on housing loans.

TRANSACTIONS WITH THE STATE TREASURY	2025	2024
Income recognized on an accruals basis	65	64
Income recognized on a cash basis	3	7
Income from temporary redemption by the State Treasury of interest on housing loans in the “old portfolio”	62	57

Biuro Maklerskie PKO BP plays the role of an agent for the issue of retail Treasury bonds under the agreement signed with the Ministry of Finance on 11 February 2003. Under this agreement, Biuro Maklerskie PKO BP receives a fee for providing the services of an agent for the issue of bonds – in 2025 in the amount of PLN 257 million, and in 2024 in the amount of PLN 332 million.

• Significant transactions with the State Treasury’s related entities

The table presents the Bank's exposure and liabilities to 10 entities related to the State Treasury with the highest total exposure.

SIGNIFICANT TRANSACTIONS WITH THE STATE TREASURY’S RELATED ENTITIES	BALANCE SHEET EXPOSURE, INCLUDING EXPOSURE TO LOANS AND DEBT INSTRUMENTS		OFF-BALANCE SHEET EXPOSURE		LIABILITIES IN RESPECT OF DEPOSITS
	31.12.2025	31.12.2024	31.12.2025	31.12.2024	31.12.2025	31.12.2024
Counterparty 1	-	-	3,150	3,150	2,106	2,735
Counterparty 2	469	517	2,290	1,920	366	357
Counterparty 3	603	226	2,503	2,968	1	1
Counterparty 4	556	871	2,112	1,884	126	95
Counterparty 5	-	-	1,502	1,501	868	365
Counterparty 6	689	823	1,493	1,465	1	-
Counterparty 7	1,571	1,627	204	163	69	197
Counterparty 8	120	229	1,522	2,471	141	180
Counterparty 9	1,716	13,677	31	31	28	532
Counterparty 10	907	1,006	531	419	-	-

	2025	2024
Interest and commission income	379	506
Interest and commission expense	95	82

As at 31 December 2025, the allowance for expected credit losses for the above exposures amounted to PLN 790 million (as at 31 December 2024 it amounted to PLN 574 million).

In the opinion of the Bank, transactions with entities related to the State Treasury are concluded on an arm’s-length basis.

The transactions were concluded on an arm’s-length basis. Repayment terms are within a range of from one month to eighteen years.

	Receivables	of which loans	Liabilities	Off-balance sheet liabilities granted
SUBSIDIARIES
31.12.2025	36,418	35,149	773	11,557
31.12.2024	35,128	34,389	603	9,716
JOINT VENTURES AND ASSOCIATES
31.12.2025	144	33	340	133
31.12.2024	147	85	195	446

TOTAL SUBSIDIARIES	Total income	of which interest and commission income	Total expense	of which interest and commission expense
SUBSIDIARIES
2025	3,277	2,377	46	38
2024	3,407	2,454	51	40
JOINT VENTURES AND ASSOCIATES
2025	977	935	203	175
2024	965	900	245	191

As at 31 December 2025 and 31 December 2024, seven entities remained related to the Bank through the key management personnel or their close family members. In 2025-2024, no transactions were conducted between the Bank and those entities.

62. Benefits for the PKO Bank Polski S.A. key management

Significant accounting policies:

The members of the Management Board and Supervisory Board of the Bank are considered to be the Bank's key management personnel.

Short-term employee benefits include the basic salary and the non-deferred part of the variable remuneration component paid in cash, and long-term benefits include the deferred part of the variable remuneration component paid in cash. Share-based payments settled in cash include non-deferred and deferred variable remuneration components granted in the form of phantom shares, converted into cash after an additional period of retention, in accordance with the principles described below.

• Variable remuneration components of key management personnel in the Bank

Variable remuneration components are granted at the Bank in two parts:

• non-deferred – in the first year after the appraisal period,

• deferred – for the next five years.

Both parts are divided in the Bank into a cash form (45%) and an instrument (55%) – phantom shares, which are converted into cash after a retention period. The conversion is carried out according to the median of the daily average prices of the Bank’s shares (Volume Weighted Average Price) for the first quarter of the relevant year, based on data from Thomson Reuters or Bloomberg.

The deferred remuneration may be reduced in the event of a deterioration in the financial performance of the Bank, a loss or other negative factors revealed after the appraisal period.

For a more extensive description, see chapter “BENEFITS FOR MANAGERS AND SUPERVISORS” of the Directors’ Report.

Financial information

COST OF REMUNERATION OF THE BANK’S MANAGEMENT AND SUPERVISORY BOARDS (in PLN thousand)	2025	2024
Management Board of the Bank
Short-term employee benefits	15,769	12,550
Long-term employee benefits	2,255	2,488
Share-based payments settled in cash1	6,891	9,736
Benefits to the Bank’s Management Board members who ceased to perform their functions before the reporting date	-	5,155
Total	24,915	29,929
Supervisory Board of the Bank - Short-term employee benefits	2,003	1,990
Total	2,003	1,990

1 This item includes both the cost of provisions for variable remuneration components in the form of an instrument for the current period, as well as the effect of revaluation of provisions for variable remuneration components in the form of an instrument for previous years based on the current price of the Bank's shares.

LOANS AND ADVANCES GRANTED BY THE BANK TO THE MEMBERS OF THE MANAGEMENT AND SUPERVISORY BOARDS (in PLN thousand)	31.12.2025	31.12.2024
Management Board of the Bank	325	332
Total	325	332

In accordance with the Banking Law, credit transactions (loans, cash advances, guarantees, sureties) with members of the Management Board, the Supervisory Board, persons holding managerial positions and entities related to them are carried out based on the Regulations adopted by the Supervisory Board. The Regulations specify the rules and decision-making levels, including the requirement for a transaction with a member of the Management Board or the Supervisory Board to be approved by both these bodies.

Members of the Management Board and the Supervisory Board use loan products on standard terms and conditions, without preferential interest rates. The interest rates and repayment terms are consistent with arm's-length conditions.

The Bank provides the key management personnel, members of the Supervisory Board and their families with standard financial services (accounts, deposits, loans) on an arm’s-length basis.

In 2025, members of the Management Board and the Supervisory Board in office as at 31 December received remuneration from related entities in the amount of PLN 255 thousand (in 2024 – PLN 53 thousand).

• variable remuneration components

The provision for variable remuneration components is presented under other liabilities in the item “provision for other employee benefits."

PROVISION FOR VARIABLE REMUNERATION COMPONENTS	31.12.2025	31.12.2024
PROVISION FOR VARIABLE REMUNERATION COMPONENTS	(for 2021-2025)	(for 2020-2024)
Management Board (including members of the Bank’s Management Board who ceased to perform their functions before the reporting date)	48	40
Other Risk Takers (persons holding managerial positions other than members of the Bank’s Management Board)	136	104
Total provision	184	144
REMUNERATION PAID DURING THE YEAR	2025	2024
REMUNERATION PAID DURING THE YEAR	(for 2020-2024)	(for 2019-2023)
- granted in cash	15	15
Management Board (including members of the Bank’s Management Board who ceased to perform their functions before the reporting date)	2	1
Other Risk Takers (persons holding managerial positions other than members of the Bank’s Management Board)	13	14
- granted in the form of an instrument	18	28
Management Board (including members of the Bank’s Management Board who ceased to perform their functions before the reporting date)	2	3
Other Risk Takers (persons holding managerial positions other than members of the Bank’s Management Board)	16	25
Total remuneration paid	33	43

63. Leases

Significant accounting policies:

The Bank classifies agreements as a lease when it obtains the right to use an asset in return for consideration. The Bank does not recognize assets and liabilities for short-term leases (up to 12 months, without a purchase option) and low-value leases (asset value < PLN 20,000), excluding rental of space.

The lease liability is initially measured at the present value of the lease payments, taking into account fixed payments, index-dependent payments, residual guarantees expected, the exercise price of a purchase option (if the probability > 50%) and penalties for termination. The Bank does not include variable lease payments depending on external factors.

After initial recognition, the liability is measured at amortized cost, and adjustments affect the carrying amount of the right-of-use. The excess of the remeasurement after the asset is reduced to zero is recognized as a profit or loss. Liabilities are presented in the note “Other liabilities”, line “Lease liabilities”.

Right-of-use assets are recognized in the note “Property, plant and equipment” and measured at cost comprising the initial amount of the liability, payments made before the commencement of the lease, less incentives, and direct costs. Subsequently, the assets are depreciated using the straight-line method and adjusted for impairment and modifications to the liability.

To discount the lease payments, the Bank applies rates based on yield curves, reflecting the cost of financing in a given currency and the tenor of the agreement (1–99 years). The rates are updated quarterly and applied to the portfolio of car and real estate lease agreements, taking into account the collateral.

Payments for short-term and low-value leases are recognized as an expense on a straight-line basis over the lease term, and the differences are accounted for as prepayments or accruals.

Financial information

LESSEE - LEASE AMOUNTS RECOGNIZED IN THE INCOME STATEMENT	2025	2024
Costs related to short-term lease contracts	(18)	(17)
Costs related to lease contracts for low-value assets (other than short-term), non-deductible VAT expenses and service charges	(111)	(102)
Total	(129)	(119)

Land and buildings account for 97% of tangible right-of-use assets.

NON-CURRENT right-of-use assets	2025	2024
Gross carrying amount at the beginning of the period	2,408	2,080
Increases	213	333
Scrapping and sale	(1)	(5)
Gross carrying amount at the end of the period	2,620	2,408
Accumulated amortization as at the beginning of the period	(1,331)	(1,073)
Amortization charge for the period	(254)	(259)
Other	-	1
Accumulated amortization as at the end of the period	(1,585)	(1,331)
Impairment losses as at the beginning of the period	(4)	(4)
Impairment losses as at the end of the period	(4)	(4)
Carrying amount as at the beginning of the period, net	1,073	1,003
Carrying amount as at the end of the period, net	1,031	1,073

64. Information on the audit firm authorized to audit the financial statements

On 15 December 2022, the Supervisory Board, pursuant to § 15 clause 1 point 2 of the Bank’s Articles of Association, selected KPMG Audyt Spółka z ograniczoną odpowiedzialnością sp.k. (KPMG) as the audit firm to audit and review the financial statements of the Bank and of the Bank’s Group for the years 2024-2026. KPMG Audyt Spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warsaw, ul. Inflancka 4A, is entered in the list of audit firms kept by the Polish Agency for Audit Oversight under number 3546. On 14 February 2024, the Bank concluded an agreement with KPMG for the audit and review of the financial statements of the Bank and the Bank's Group for the years 2024-2026.

Furthermore, on 15 December 2025, the Supervisory Board, pursuant to § 15 clause 1 point 2 of the Bank’s Articles of Association, selected KPMG as the audit firm to audit and review the financial statements of the Bank and of the Bank’s Group for the years 2027-2031.

TOTAL AMOUNT OF NET REMUNERATION DUE TO THE AUDIT FIRM AUDITING THE FINANCIAL STATEMENTS FOR SERVICES PROVIDED TO THE BANK IN RESPECT OF: (in PLN thousand)	2025	2024
audit of financial statements of the Bank and consolidated financial statements of the Group	2,164	2,089
assurance services, including reviews of the financial statements	2,502	1,963
Total	4,666	4,052

65. Interest rate benchmarks reform

The BMR Regulation (EU 2016/1011) is in force in the European Union, which regulates the development and use of benchmarks in financial instruments and contracts.

WIBOR benchmark reform

The Act of 7 July 2022 initiated the process of replacing WIBOR. The National Working Group on Benchmark Reform (NWG), with the participation of public institutions and the financial sector, coordinates the work under the supervision of the Steering Committee (SC).

• 2022 – selection of WIRON as an alternative benchmark, adoption of the Roadmap.

• 2023 – WIRON recognized as an interest rate benchmark.

• 2024 – the SC commenced a review of RFR-type benchmarks; following consultations, WIRF (based on unsecured deposits) was selected as the ultimate benchmark. The administrator will be GPW Benchmark S.A. The reform is scheduled to be completed by the end of 2027. WIRF will become a critical benchmark in financial contracts, instruments and funds.

• January 2025 – the SC decided to select the ultimate name POLSTR (Polish Short Term Rate) for the proposed index, as the ultimate interest rate benchmark to replace the WIBOR benchmark.

• March 2025 - the SC approved the updated Roadmap for the process of replacing the WIBOR and WIBID benchmarks. The reform is scheduled to be completed by the end of 2027.

• June 2025 - official determination of the POLSTR Interest Rate Index and indices from the POLSTR Compound Index Family commenced. The administrator of POLSTR is GPW Benchmark SA – an entity holding authorization from the Polish Financial Supervision Authority and entered in the register of benchmark administrators maintained by the European Securities and Markets Authority (ESMA).

• September 2025 – the SC announced that the first application of the POLSTR interest rate index in the domestic financial market took place on 1 September 2025. Therefore, POLSTR gained a status of a benchmark in accordance with the requirements of the EU Benchmark Regulation. The SC announced the adoption of recommendations for new banking, leasing and factoring products based on POLSTR. GPW Benchmark SA issued a statement on the discontinuation of the calculation of WIBID and WIBOR reference rates for selected fixing tenors.

• November 2025 - the Ministry of Finance carried out the first pilot issue of treasury bonds based on the POLSTR benchmark during a sales auction.

• December 2025 - the SC of the NWG adopted the Recommendation for the legacy portfolio in PLN in the business customer segment, specifying the rules for replacing references to the WIBOR/WIBID benchmarks with the POLSTR benchmark or benchmarks from the POLSTR Compound Index Family.

Adaptation of the Bank

Changes resulting from the BMR Regulation affect contracts, instrument valuations and IT processes. Since the third quarter of 2020, the Bank has been implementing an adjustment project comprising:

• contingency plans in contracts and regulations,

• adjustment of products, systems and hedge accounting,

• annexing contracts and implementing market standards,

• cooperation with the sector regarding the interpretation of regulations.

The project involves many Bank units and subsidiaries (PKO Bank Hipoteczny S.A., PKO Leasing, PKO Faktoring). The Bank monitors the risks, but at the current stage it is not possible to estimate the financial impact of the reform. The withdrawal of products based on WIBOR/WIBID and the introduction of products with the new benchmark will take place gradually.

Exposures with interest rate based on WIBOR – financial and off-balance sheet assets and liabilities	31.12.2025	31.12.2024
Amounts due from banks	1,602	3,078
Securities	20,780	18,275
Reverse repo transactions	565	589
Loans and advances to customers	191,000	174,296
Total assets	213,947	196,238
Repo transactions	22	-
Amounts due to banks	4	-
Amounts due to customers	8,395	7,829
Subordinated liabilities	6,309	4,291
Liabilities in respect of debt securities in issue	1,021	1,025
Provisions for financial liabilities and guarantees granted	259	254
Total liabilities	16,010	13,399
Financial liabilities and guarantees granted	47,640	37,679
Hedging derivatives - nominal value	87,170	86,337

For new variable interest loans in foreign currencies, the Bank applies risk-free rates (RFRs), e.g. SARON for CHF, SOFR for USD, SONIA for GBP. Interest is calculated on a daily basis or using compound interest rates “in advance” (based on historical rates) or “in arrears” (at the end of the interest period).

In financial market transactions, the Bank applies the ISDA Protocol standard, executing and settling transactions using compound risk-free rates.

• hedge accounting

The amendments to IFRS allow for the assumption that future cash flows – although subject to changes in the future as a result of the transition to alternative reference rates – are still highly probable and thus the existing hedging relationships can be maintained.

66. Events that occurred after the date on which the financial statements are prepared

• On 20 January 2026, the Extraordinary General Shareholders' Meeting of the Bank, pursuant to Article 385 § 1 of the Commercial Companies Code, appointed Mr. Grzegorz Mazurek to the Supervisory Board.

• On 3 February 2026, the Bank adopted a resolution to increase the maximum amount of the Bank's own bond issuance programme on the domestic market from PLN 5 billion to PLN 9 billion or the equivalent of this amount in other currencies.

• On 27 February 2026, an entry was made in the National Court Register regarding the merger of Masterlease sp. z o.o. and Prime Car Management S.A. (subsidiaries of PKO Leasing S.A.). The company's name was changed from Prime Car Management S.A. to PKO Masterlease S.A.

• On 3 March 2026, the Bank received an individual recommendation from the Polish Financial Supervision Authority (KNF), in which the KNF confirmed that the Bank meets the requirements to pay a dividend of up to 75% of the profit for 2025, provided that the maximum payment amount does not exceed the annual profit reduced by the portion of the 2025 profit already included in own funds. The Bank included in own funds part of the net profit earned in the first half of 2025 in the amount of PLN 1,322,271,645 at the standalone level. At the same time, the KNF recommended that the Bank limit the risks arising in its operations by refraining—without prior consultation with the supervisory authority—from undertaking other actions, in particular those outside the scope of its ongoing business and operational activities, that could result in a reduction of own funds, including any potential dividend payments from undistributed profits from previous years as well as buybacks or redemptions of own shares.

SIGNATURES OF ALL MEMBERS OF THE BANK’S MANAGEMENT BOARD

Szymon Midera	President of the Management Board
Krzysztof Dresler	Vice-President of the Management Board
Ludmiła Falak-Cyniak	Vice-President of the Management Board
Piotr Mazur	Vice-President of the Management Board
Tomasz Pol	Vice-President of the Management Board
Marek Radzikowski	Vice-President of the Management Board
Michał Sobolewski	Vice-President of the Management Board
Mariusz Zarzycki	Vice-President of the Management Board

SIGNATURE OF A PERSON WHO IS RESPONSIBLE FOR MAINTAINING THE ACCOUNTING RECORDS

Danuta Szymańska Director of the accounting division

The original Polish document is signed with a qualified electronic signatures

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