Capital Adequacy and Other Information Subject to Disclosure of the Alior Bank Spółka Akcyjna Capital Group as at 31 December 2025 List of Tables
Introduction 5
EU OV1 - Overview of total risk exposure amounts 6
EU KM1 - Key metrics template 7
EU KM2 - Key metrics - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities 9
EU TLAC1 - Composition - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities 10
EU TLAC3b - Creditor ranking - resolution entity 12
EU INS1 - Insurance participations 13
EU INS2 - Financial conglomerates information on own funds and capital adequacy ratio 13
EU OVA - Institution risk management approach 13
EU OVB - Disclosure on governance arrangements 19
EU OVC - ICAAP information 21
EU LI1 - Differences between the accounting scope and the scope of prudential consolidation and mapping of financial statement categories with regulatory risk categories 22
EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements 24
EU LI3 - Outline of the differences in the scopes of consolidation (entity by entity) 25
EU LIA - Explanations of differences between accounting and regulatory exposure amounts 27
EU LIB - Other qualitative information on the scope of application 27
EU PV1 - Prudent valuation adjustments (PVA) 28
EU CC1 - Composition of regulatory own funds 29
EU CC2 - Reconciliation of regulatory own funds to balance sheet in the audited financial statements 33
EU CCA - Main features of regulatory own funds instruments and eligible liabilities instruments 35
IFRS 9-FL - Comparison of institutions' own funds and capital and leverage ratios with and without the application of transitional arrangements for IFRS 9 or analogous ECLs 38
EU CCyB1 - Geographical distribution of credit exposures relevant for the calculation of the countercyclical buffer 39
EU CCyB2 - Amount of institution-specific countercyclical capital buffer 40
EU LR1 - LRSum: Summary reconciliation of accounting assets and leverage ratio exposures 40
EU LR2 - LRCom: Leverage ratio common disclosure 41
EU LR3 - LRSpl: Split-up of on balance sheet exposures (excluding derivatives, SFTs and exempted exposures) 44
EU LRA - Disclosure of LR qualitative information 45
EU LIQA - Liquidity risk management 45
Recommendation P - regarding the management of banks' financial liquidity risk 50
Analysis of maturity / payment of assets and liabilities for the Alior Bank Group, according to contractual deadlines at the end of 2025 51
Analysis of maturity / payment of assets and liabilities for the Alior Bank Group, according to the dates real to the end of 2025
. 52
EU LIQ1 - Quantitative information of LCR 53
EU LIQB on qualitative information on LCR, which complements template EU LIQ1 54
EU LIQ2 - Net Stable Funding Ratio 56
Disclosure period - 31.12.2025 56
Disclosure period - 30.06.2025 58
EU CRA - General qualitative information about credit risk 60
EU CRB - Additional disclosure related to the credit quality of assets 63
Recommendation R - regarding the rules for classifying credit exposures, estimating and recognizing expected credit losses and credit risk management 65
Business Client exposure portfolio 31.12.2025 67
Retail Client exposure portfolio - Mortgage 31.12.2025 69
Retail client exposure portfolio - Other 31.12.2025 71
Portfolio of exposures from the Leasing Activity 31.12.2025 73
EU CR1 - Performing and non-performing exposures and related provisions 75
EU CR1-A - Maturity of exposures 76
EU CR2 - Changes in the stock of non-performing loans and advances 76
EU CR2a - Changes in the stock of non-performing loans and advances and related net accumulated recoveries 76
EU CQ1 - Credit quality of forborne exposures 77
EU CQ2 - Quality of forbearance 77
EU CQ3 - Credit quality of performing and non-performing exposures by past due days 78
EU CQ4 - Quality of non-performing exposures by geography 79
EU CQ5 - Credit quality of loans and advances to non-financial corporations by industry 80
EU CQ6 - Collateral valuation - loans and advances 81
EU CQ7 - Collateral obtained by taking possession and execution processes 82
EU CQ8 - Collateral obtained by taking possession and execution processes - vintage breakdown 83
EU CRC - Qualitative disclosure requirements related to CRM techniques 84
EU CR3 - CRM techniques overview: Disclosure of the use of credit risk mitigation techniques 85
EU CRD - Qualitative disclosure requirements related to standardised approach 85
EU CR4 - Standardised approach - Credit risk exposure and CRM effects 86
EU CR5 - Standardised approach 87
EU CCRA - Qualitative disclosure related to CCR 89
EU CCR1 - Analysis of CCR exposure by approach 90
EU CCR3 - Standardised approach - CCR exposures by regulatory exposure class and risk weights 91
EU CCR5 - Composition of collateral for CCR exposures 92
EU CCR6 - Credit derivatives exposures 93
EU CCR8 - Exposures to CCPs 93
EU SECA - Qualitative disclosure requirements related to securitisation exposures 94
EU MRA - Qualitative disclosure requirements related to market risk 94
EU MR1 - Market risk under the standardised approach (ASA) 97
EU CVAA - Qualitative disclosure requirements related to credit valuation adjustment risk 98
EU CVA 1 - Credit valuation adjustment risk under the Reduced Basic Approach 98
EU CVAB - Qualitative disclosure requirements related to CVA risk for institutions using the Standardised Approach 99
EU IRRBBA - Qualitative information on interest rate risks of non-trading book activities 99
EU IRRBB1 - Interest rate risks of non-trading book activities 100
EU ORA - Qualitative information on operational risk 100
Recommendation M - concerning operational risk management in banks 102
Operating risk costs in the Alior Bank SA Group in 2025 by category 102
EU OR1 - Operational risk own funds requirements and risk-weighted exposure amounts 103
EU OR2 - Business Indicator, components and subcomponents 104
EU OR3 - Operational risk own funds requirements and risk exposure amounts 105
EU REMA - Remuneration policy 105
Guidelines EBA/GL/2022/06 and EBA/GL/2021/04 109
Table 1 - Representation of staff of different genders per quartile of remuneration level 109
Table 2 - Gender pay pap based on the total gross remuneration 110
Recommendation Z - concerning the rules of internal governance in banks 111
EU REM1 - Remuneration awarded for the financial year 112
EU REM2 - Special payments to staff whose professional activities have a material impact on institutions' risk profile (identified staff) 113
EU REM3 - Deferred remuneration 114
EU REM4 - Remuneration of 1 million EUR or more per year 116
EU REM5 - Information on remuneration of staff whose professional activities have a material impact on institutions' risk profile (identified staff) 117
EU AE1 - Encumbered and unencumbered assets 118
EU AE2 - Collateral received and own debt securities issued 119
EU AE3 - Sources of encumbrance 119
EU AE4 - Accompanying narrative information 120
ESG - Environmental, Social and Corporate Governance 120
Management Board's statement 121
Introduction
Alior Bank Spółka Akcyjna with its registered office in Warsaw (hereinafter referred to as the "Bank") is obliged, under Part Eight of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012, as amended (hereinafter referred to as the "CRR Regulation") and the Banking Law Act of 29 August 1997, as amended (hereinafter referred to as the "Banking Law"), to publish quantitative and qualitative information within the scope of Pillar III in a generally accessible manner, excluding insignificant, proprietary or confidential information.
The information is published in accordance with Commission Implementing Regulation (EU) 2024/3172 of 29 November 2024 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to public disclosure by institutions of information referred to in Titles II and III of Part Eight of that Regulation and repealing Commission Implementing Regulation (EU) 2021/637, as amended (hereinafter "Regulation 2024/3172"), and is also published in accordance with Guidelines EBA/GL/2020/12 amending Guidelines EBA/GL/2018/01 and Guidelines EBA/GL/2021/04, EBA/GL/2022/08 and EBA/GL/2022/06 on remuneration policy, as well as supplemented with the provisions resulting from Recommendations M, P, R and Z of the Polish Financial Supervision Authority.
The report is an implementation of the adopted "Information Policy regarding capital adequacy and other information to be published at Alior Bank S.A." (hereinafter "Information Policy"). The information policy was implemented by a resolution of the Bank's Management Board and approved by the Bank's Supervisory Board, and is published on the Bank's website.
The presented scope of information is consistent with the requirements of Art. 433 and 433c of the CRR Regulation. Taking into account the scale of its operations, the bank does not meet the conditions described in Art. 4 points 145 and 146 of the CRR Regulation.
The published scope of information is intended to provide market participants with a comprehensive picture of the risk profile of Alior Bank SA and the Alior Bank SA Capital Group.
As at December 31, 2025, the Alior Bank SA Capital Group consists of: Alior Bank SA, as the parent company, and subsidiaries in which the Bank holds majority shares. For the purposes of calculations in the area of capital adequacy, prudential consolidation was used - in accordance with Article 19 of the CRR Regulation - therefore, the consolidation included Alior Bank SA and Alior Leasing Sp. z o. o.
Unless otherwise stated, the information disclosed in this document is based on data from the consolidated financial statements of the Alior Bank S.A. Capital Group for the year ended December 31, 2025. The risk profile of the Bank's Capital Group is primarily influenced by Alior Bank S.A., therefore, some of the information contained in the report relates to individual data of Alior Bank S.A.
Figures are drawn up in Polish zlotys (PLN) and are rounded up to one million zlotys (M).
This version of our report is a translation from the original, which was prepared in Polish language. All possible care has been taken to ensure that the translation is an accurate representation of the original. However, in all matters of interpretation of information, views or opinions, the original language version of our report takes precedence over this translation.
EU OV1 - Overview of total risk exposure amounts
PLN m
Total risk exposure amounts (TREA) | Total own funds requirements | |||||
31.12.2025 | 31.12.2024 | 31.12.2025 | ||||
a | b | c | ||||
0010 | 0020 | 0030 | ||||
1 | Credit risk (excluding CCR) | 0010 | 52 603 | 45 451 | 4 208 | |
2 | Of which the standardised approach | 0020 | 52 603 | 45 451 | 4 208 | |
3 | Of which the Foundation IRB (F-IRB) approach | 0030 | ||||
4 | Of which slotting approach | 0040 | ||||
EU-4a | Of which equities under the simple risk weighted approach | 0050 | ||||
5 | Of which the Advanced IRB (A-IRB) approach | 0060 | ||||
6 | Counterparty credit risk - CCR | 0070 | 810 | 627 | 65 | |
7 | Of which the standardised approach | 0080 | 237 | 142 | 19 | |
8 | Of which internal model method (IMM) | 0090 | ||||
EU-8a | Of which exposures to a CCP | 0100 | 567 | 483 | 45 | |
9 | Of which other CCR | 0110 | 6 | 2 | ||
10 | Credit valuation adjustments risk - CVA risk | 0120 | 30 | 21 | 2 | |
EU-10a | Of which the standardised approach (SA) | 0130 | ||||
EU 10b | Of which the basic approach (F-BA and R-BA) | 0140 | 30 | 21 | 2 | |
EU 10c | Of which the simplified approach | 0150 | ||||
11 | not applicable | 0160 | ||||
12 | not applicable | 0170 | ||||
13 | not applicable | 0180 | ||||
14 | not applicable | 0190 | ||||
15 | Settlement risk | 0200 | ||||
16 | Securitisation exposures in the non-trading book (after the cap) | 0210 | ||||
17 | Of which SEC-IRBA approach | 0220 | ||||
18 | Of which SEC-ERBA (including IAA) | 0230 | ||||
19 | Of which SEC-SA approach | 0240 | ||||
EU-19a | Of which 1250% / deduction | 0250 | ||||
20 | Position, foreign exchange and commodities risks (Market risk) | 0260 | 357 | 217 | 29 | |
21 | Of which the Alternative standardised approach (A-SA) | 0270 | ||||
EU 21a | Of which the Simplified standardised approach (S-SA) | 0280 | 357 | 217 | 29 | |
22 | Of which Alternative Internal Model Approach (A-IMA) | 0290 | ||||
EU-22a | Large exposures | 0300 | ||||
23 | Reclassifications between the trading and non-trading books | 0310 | ||||
24 | Operational risk | 0320 | 5 843 | 4 895 | 467 | |
EU 24a | Exposures to crypto-assets | 0330 | ||||
25 | Amounts below the thresholds for deduction (subject to 250% risk weight) | 0340 | ||||
26 | Output floor applied (%) | 0350 | ||||
27 | Floor adjustment (before application of transitional cap) | 0360 | ||||
28 | Floor adjustment (after application of transitional cap) | 0370 | ||||
29 | Total | 0380 | 59 643 | 51 211 | 4 772 | |
EU KM1 - Key metrics template
PLN m
31.12.2025 | 30.06.2025* | 31.12.2024** | ||||
a. | c. | e. | ||||
0010 | 0030 | 0050 | ||||
Available own funds (amounts) | 0005 | |||||
1 | Common Equity Tier 1 (CET1) capital | 0010 | 10 515 | 10 499 | 9 742 | |
2 | Tier 1 capital | 0020 | 10 515 | 10 499 | 9 742 | |
3 | Total capital | 0030 | 10 515 | 10 499 | 9 742 | |
Risk-weighted exposure amounts | 0035 | |||||
4 | Total risk exposure amount | 0040 | 59 643 | 57 961 | 51 211 | |
4a | Total risk exposure pre-floor | 0041 | 59 643 | 57 961 | ||
Capital ratios (as a percentage of risk-weighted exposure amount) | 0045 | |||||
5 | Common Equity Tier 1 ratio (%) | 0050 | 17.63% | 18.11% | 19.02% | |
5b | Common Equity Tier 1 ratio considering unfloored TREA (%) | 0051 | ||||
6 | Tier 1 ratio (%) | 0060 | 17.63% | 18.11% | 19.02% | |
6b | Common Equity Tier 1 ratio considering unfloored TREA (%) | 0061 | ||||
7 | Total capital ratio (%) | 0070 | 17.63% | 18.11% | 19.02% | |
7b | Total capital ratio considering unfloored TREA (%) | 0081 | ||||
Additional own funds requirements to address risks other than the risk of excessive leverage (as a percentage of risk-weighted exposure amount) | 0075 | |||||
EU 7d | Additional own funds requirements to address risks other than the risk of excessive leverage (%) | 0080 | ||||
EU 7e | of which: to be made up of CET1 capital (percentage points) | 0090 | ||||
EU 7f | of which: to be made up of Tier 1 capital (percentage points) | 0100 | ||||
EU 7g | Total SREP own funds requirements (%) | 0110 | 8.00% | 8.00% | 8.00% | |
Combined buffer and overall capital requirement (as a percentage of risk-weighted exposure amount) | 0115 | |||||
8 | Capital conservation buffer (%) | 0120 | 2.50% | 2.50% | 2.50% | |
EU-8a | Conservation buffer due to macro-prudential or systemic risk identified at the level of a Member State (%) | 0130 | ||||
9 | Institution specific countercyclical capital buffer (%) | 0140 | 1.00% | 0.01% | 0.01% | |
EU-9a | Systemic risk buffer (%) | 0150 | ||||
10 | Global Systemically Important Institution buffer (%) | 0160 | ||||
EU-10a | Other Systemically Important Institution buffer (%) | 0170 | ||||
11 | Combined buffer requirement (%) | 0180 | 3.50% | 2.51% | 2.51% | |
EU-11a | Overall capital requirements (%) | 0190 | 11.50% | 10.51% | 10.51% | |
12 | CET1 available after meeting the total SREP own funds requirements (%) | 0200 | 9.63% | 10.11% | 11.02% | |
Leverage ratio | 0205 | |||||
13 | Total exposure measure | 0210 | 111 444 | 108 989 | 99 220 | |
14 | Leverage ratio (%) | 0220 | 9.44% | 9.63% | 9.82% | |
Additional own funds requirements to address the risk of excessive leverage (as a percentage of total exposure measure) | 0225 | |||||
EU-14a | Additional own funds requirements to address the risk of excessive leverage | 0230 | ||||
EU-14b | of which: to be made up of CET1 capital (percentage points) | 0240 | ||||
EU-14c | Total SREP leverage ratio requirements (%) | 0250 | 3.00% | 3.00% | 3.00% | |
Leverage ratio buffer and overall leverage ratio requirement (as a percentage of | 0255 | |||||
EU-14d | Leverage ratio buffer requirement (%) | 0260 | ||||
EU-14e | Overall leverage ratio requirement (%) | 0270 | 3.00% | 3.00% | 3.00% | |
Liquidity Coverage Ratio | 0275 | |||||
15 | Total high-quality liquid assets (HQLA) (Weighted value -average) | 0280 | 26 192 | 24 173 | 22 632 | |
EU-16a | Cash outflows - Total weighted value | 0290 | 13 406 | 13 684 | 14 191 | |
EU-16b | Cash inflows - Total weighted value | 0300 | 1 623 | 2 081 | 2 081 | |
31.12.2025 | 30.06.2025* | 31.12.2024** | |||
a. | c. | e. | |||
0010 | 0030 | 0050 | |||
16 | Total net cash outflows (adjusted value) | 0310 | 11 783 | 11 603 | 12 110 |
17 | Liquidity coverage ratio (%) | 0320 | 222% | 208% | 187% |
Net Stable Funding Ratio | 0325 | ||||
18 | Total available stable funding | 0330 | 82 570 | 78 943 | 76 180 |
19 | Total required stable funding | 0340 | 55 473 | 53 585 | 51 518 |
20 | NSFR ratio (%) | 0350 | 149% | 147% | 148% |
* On September 18, 2025, the Polish Financial Supervision Authority (KNF) approved the inclusion of part of the net profit of the prudentially consolidated Alior Bank S.A. Capital Group for the first half of 2025 in the consolidated Common Equity Tier 1 capital of the Alior Bank S.A. Capital Group. Data as at June 30, 2025 were recalculated to include in own funds the net profit generated for the first half of 2025, for which the KNF approved it. Therefore, the table above presents changed data compared to the information published for 2025 in the report "Interim Disclosures in Respect of Pillar III of the Alior Bank Spółka Akcyjna Capital Group for the half-year ended June 30, 2025".
*On April 11, 2025, the Polish Financial Supervision Authority (KNF) approved the inclusion of a portion of the prudentially consolidated net profit of the Alior Bank SA Capital Group for 2024 in the prudentially consolidated Common Equity Tier 1 capital of the Alior Bank SA Capital Group. Data as at December 31, 2024, were recalculated to include the net profit generated for 2024 in own funds, for which the KNF approved it. Therefore, the table above presents changed data compared to the information published for 2024 in the report "Capital Adequacy and Other Information Subject to Disclosure of the Alior Bank Spółka Akcyjna Capital Group for the year ended December 31, 2024".
On 16 June 2025, the Annual General Meeting of the Bank adopted resolution No. 7/2025 on the method of distributing the Bank's profit for the financial year 2024
.
EU KM2 - Key metrics - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities
PLN m
Minimum requirement for own funds and eligible liabilities MREL | G-SII Requirement for own funds and eligible liabilities TLAC | ||||||||
a. 31.12.2025 | b. 31.12.2025 | c. 30.09.2025 | d. 30.06.2025 | e. 31.03.2025 | f. 31.12.2024 | ||||
0010 | 0020 | 0030 | 0040 | 0050 | 0060 | ||||
Own funds and eligible liabilities, ratios and components | 0009 | ||||||||
1 | Own funds and eligible liabilities | 0010 | 12 784 | N/A | N/A | N/A | N/A | N/A | |
EU-1a | Of which own funds and subordinated liabilities | 0020 | 11 778 | ||||||
2 | Total risk exposure amount of the resolution group TREA | 0030 | 59 643 | N/A | N/A | N/A | N/A | N/A | |
3 | Own funds and eligible liabilities as a percentage of the TREA | 0040 | 21,43% | N/A | N/A | N/A | N/A | N/A | |
EU-3a | Of which own funds and subordinated liabilities | 0050 | 19.75% | ||||||
4 | Total exposure measure TEM of the resolution group | 0060 | 111 444 | N/A | N/A | N/A | N/A | N/A | |
5 | Own funds and eligible liabilities as percentage of the TEM | 0070 | 11.47% | N/A | N/A | N/A | N/A | N/A | |
EU-5a | Of which own funds or subordinated liabilities | 0080 | 10.57% | ||||||
6a | Does the subordination exemption in Article 72b 4 of Regulation EU No 575/2013 apply? 5% exemption | 0090 | N/A | N/A | N/A | N/A | N/A | ||
6b | Aggregate amount of permitted non-subordinated eligible liabilities instruments if the subordination discretion in accordance with Article 72b 3 of Regulation EU No 575/2013 is applied max 3.5% exemption | 0100 | N/A | N/A | N/A | N/A | N/A | ||
6c | If a capped subordination exemption applies in accordance with Article 72b 3 of Regulation EU No 575/2013, the amount of funding issued that ranks pari passu with excluded liabilities and that is recognised under row 1, divided by funding issued that ranks pari passu with excluded liabilities and that would be recognised under row 1 if no cap was applied % | 0110 | N/A | N/A | N/A | N/A | N/A | ||
Minimum requirement for own funds and eligible liabilities MREL | 0119 | ||||||||
EU-7 | MREL expressed as a percentage of the TREA | 0120 | 15.36% | ||||||
EU-8 | Of which to be met with own funds or subordinated liabilities | 0130 | 15.36% | ||||||
EU-9 | MREL expressed as a percentage of the TEM | 0140 | 5.91% | ||||||
EU-10 | Of which to be met with own funds or subordinated liabilities | 0150 | 5.91% | ||||||
Alior Bank SA is not a global systemically important institution (G-SII), therefore it is obliged to meet the minimum requirement in terms of own funds and eligible liabilities MREL.
EU TLAC1 - Composition - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities
PLN m
Minimum requirement for own funds and eligible liabilities MREL | G-SII requirement for own funds and eligible liabilities TLAC | Memo item: Amounts eligible for the purposes of MREL, but not of TLAC | ||||
a | b | c | ||||
0010 | 0020 | 0030 | ||||
Own funds and eligible liabilities, ratios and components | 0009 | |||||
1. | Common Equity Tier 1 capital CET1 | 0010 | 10 515 | N/A | ||
2. | Additional Tier 1 capital AT1 | 0020 | N/A | |||
3. | Empty set in the EU | 0030 | ||||
4. | Empty set in the EU | 0040 | ||||
5. | Empty set in the EU | 0050 | ||||
6. | Tier 2 capital T2 | 0060 | N/A | |||
7. | Empty set in the EU | 0070 | ||||
8. | Empty set in the EU | 0080 | ||||
11. | Own funds for the purpose of Articles 92a of Regulation EU No 575/2013 and 45 of Directive 2014/59/EU | 0090 | 10 515 | N/A | ||
Own funds and eligible liabilities: Non-regulatory capital elements | 0099 | |||||
12. | Eligible liabilities instruments issued directly by the resolution entity that are subordinated to excluded liabilities not grandfathered | 0100 | 1 262 | N/A | ||
EU-12a. | Eligible liabilities instruments issued by other entities within the resolution group that are subordinated to excluded liabilities not grandfathered | 0110 | N/A | |||
EU-12b. | Eligible liabilities instruments that are subordinated to excluded liabilities issued prior to 27 June 2019 subordinated grandfathered | 0120 | N/A | |||
EU-12c. | Tier 2 instruments with a residual maturity of at least one year to the extent they do not qualify as Tier 2 items | 0130 | N/A | |||
13. | Eligible liabilities that are not subordinated to excluded liabilities not grandfathered pre-cap | 0140 | 1 007 | N/A | ||
EU-13a. | Eligible liabilities that are not subordinated to excluded liabilities issued prior to 27 June 2019 pre-cap | 0150 | N/A | |||
14. | Amount of non subordinated eligible liabilities instruments, where applicable after application of Article 72b 3 CRR | 0160 | 1 007 | N/A | 1 007 | |
15. | Empty set in the EU | 0170 | ||||
16. | Empty set in the EU | 0180 | ||||
17. | Eligible liabilities items before adjustments | 0190 | 2 269 | N/A | ||
EU-17a. | Of which subordinated liabilities items | 0200 | 1 262 | N/A | ||
Own funds and eligible liabilities: Adjustments to non-regulatory capital elements | 0209 | |||||
18. | Own funds and eligible liabilities items before adjustments | 0210 | 12 784 | N/A | ||
Minimum requirement for own funds and eligible liabilities MREL | G-SII requirement for own funds and eligible liabilities TLAC | Memo item: Amounts eligible for the purposes of MREL, but not of TLAC | ||||
a | b | c | ||||
0010 | 0020 | 0030 | ||||
19. | Deduction of exposures between multiple point of entry (MPE) resolution groups | 0220 | N/A | |||
20. | (Deduction of investments in other eligible liabilities instruments) | 0230 | N/A | |||
21. | Empty set in the EU | 0240 | ||||
22. | Own funds and eligible liabilities after adjustments | 0250 | 12 784 | N/A | ||
EU-22a. | Of which: own funds and subordinated liabilities | 0260 | 11 778 | |||
Risk-weighted exposure amount and leverage exposure measure of the resolution group | 0269 | |||||
23. | Total risk exposure amount TREA | 0270 | 59 643 | N/A | 59 643 | |
24. | Total exposure measure TEM | 0280 | 111 444 | N/A | 111 444 | |
Ratio of own funds and eligible liabilities | 0289 | |||||
25. | Own funds and eligible liabilities as a percentage of TREA | 0290 | 21,43% | N/A | 21.43% | |
EU-25a. | Of which own funds and subordinated liabilities | 0300 | 19.75% | |||
26. | Own funds and eligible liabilities as a percentage of TEM | 0310 | 11.47% | N/A | 11.47% | |
EU-26a. | Of which own funds and subordinated liabilities | 0320 | 10.57% | |||
27. | CET1 as a percentage of the TREA available after meeting the resolution group's requirements | 0330 | 9.63% | N/A | ||
28. | Institution-specific combined buffer requirement | 0340 | N/A | |||
29. | of which capital conservation buffer requirement | 0350 | N/A | |||
30. | of which countercyclical buffer requirement | 0360 | N/A | |||
31. | of which systemic risk buffer requirement | 0370 | N/A | |||
EU-31a. | of which Global Systemically Important Institution G-SII or Other Systemically Important Institution O-SII buffer | 0380 | N/A | |||
Memorandum items | 0389 | |||||
EU-32. | Total amount of excluded liabilities referred to in Article 72a 2 of Regulation EU No 575/2013 | 0390 | N/A | |||
Alior Bank SA is not a global systemically important institution (G-SII), therefore it is obliged to meet the minimum requirement in terms of own funds and eligible liabilities MREL.
EU TLAC3b - Creditor ranking - resolution entity
PLN m
Insolvency ranking Insolvency ranking 1 2 3 4 5 6 7 8 9 10 Sum of 1 to 10 (most junior) (most senior)1 | Description of insolvency rank (free text) | Receivables due to liabilities included in the bank's own funds, referred to in Art. 26 of Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013, as amended, including interest and enforcement costs | Receivables due to liabilities included in the bank's own funds, referred to in Art. 51 of Regulation No. 575/2013, along with interest and enforcement costs | Receivables due to liabilities included in the bank's own funds, referred to in Art. 62 of Regulation No. 575/2013, along with interest and enforcement costs | Receivables from subordinated liabilities not included in the bank's own funds, along with interest and enforcement costs | Receivables under bonds, together with interest and enforcement costs, excluding receivables in category 9, under other debt instruments that have the characteristics of negotiable receivables, or under instruments giving rise to the legal effects of debt financial instruments | Receivables of partners or shareholders arising from a loan or other legal transaction with similar effects, in particular the delivery of goods with deferred payment date, together with interest, if they are not subject to satisfaction in lower categories | Interest on receivables included in higher categories in the order in which the capital is satisfied, as well as judicial and administrative fines and receivables for donations and bequests | Other liabilities, if they cannot be satisfied in other categories, in particular taxes and other public levies and other liabilities due to social security contributions | Receivables from natural persons, micro-entrepreneurs, small and medium-sized enterprises in respect of funds covered by guarantee protection other than guaranteed funds within the meaning of Art. 2 point 65 of the Act of 10 June 2016 on the Bank Guarantee Fund | Receivables referred to in Art. 39 section 1 of the Act of 10 June 2016 on the Bank Guarantee Fund | |
2 | Empty set in the EU | |||||||||||
3 | Empty set in the EU | |||||||||||
4 | Empty set in the EU |
5 potentially eligible for 10 515 meeting MREL | 1 262 | 7 | 1 053 | 33 | 12 870 |
6 of which residual maturity | 451 | 53 | 32 | 536 | |
7 of which residual maturity | 811 | 7 | 1 000 | 1 | 1 819 |
≥ 1 year < 2 years
≥ 2 year < 5 years
of which residual maturity
≥ 5 years < 10 years
of which residual maturity
≥ 10 years, but excluding
perpetual securities
of which perpetual securities
10 515 10 515
EU INS1 - Insurance participations
PLN m
Exposure value | Risk exposure amount | ||
a | b | ||
0010 | 0020 | ||
Own fund instruments held in insurance or re-insurance undertakings or insurance holding company not deducted from own funds | 0010 | ||
Alior Bank SA does not hold equity interests in insurance companies.
EU INS2 - Financial conglomerates information on own funds and capital adequacy ratio
PLN m
31.12.2025 | |||
a | |||
0010 | |||
1 | Supplementary own fund requirements of the financial conglomerate (amount) | 0010 | |
2 | Capital adequacy ratio of the financial conglomerate (%) | 0020 | |
Alior Bank SA is part of a financial conglomerate headed by PZU SA, the Bank itself does not calculate additional requirements for the financial conglomerate's own funds.
EU OVA - Institution risk management approach
Legal basis Row number Details Point (f) of Article 435(1) CRRAs part of the risk appetite, the Bank's Management Board approved the expected levels of the Bank's key capital ratios for 2025 at the level of: total capital ratio - 12.00 % and Tier 1 capital ratio - 10.00%. The expected internal capital coverage ratio by own funds was approved at 1.5. Risk appetite levels for capital ratios remained at the same level as in 2024.
The bank is still not identified as a systemically important institution, therefore there is no buffer of another systemically important institution (O-SII).
In November 2025, the Polish Financial Supervision Authority (KNF) imposed an additional capital charge (P2G) on the Bank to absorb potential losses resulting from stress events. The total capital charges recommended under Pillar II (P2G) offset by the capital conservation buffer requirement are
2.73 percentage points at the individual level and 2.26 p.p. at the consolidated level.
The structure of the assessed risk exposure measured by the capital requirement for individual types of risk throughout 2025 remained at a level consistent with the structure of the risk exposure in the entire banking sector in Poland.
The structure of the assessed risk exposure confirms the dominance of credit risk exposure in the total risk exposure. In accordance with its policy, the Bank does not maintain significant exposure to market risk, therefore its share in the exposure structure is small. The share of operational risk exposure was close to the average for the Polish banking sector.
Point (b) of Article 435(1) CRRIn order to efficiently and effectively manage the risk system at Alior Bank SA, the supervision, control
and responsibility for the operation of this system have been entrusted to:
the Supervisory Board,
the Risk Committee of the Supervisory Board,
the Bank's Management Board,
DetailsCommittees (Capital, Assets and Liabilities Management Committee - CALCO, Operational Risk Committee, Credit Risk Committee and Business Initiatives Committee, Model Risk Committee, Bank Credit Committee),
organizational units responsible for particular types of risk.
The risk management system in place at the Bank is based on three independent lines of defense. Its framework is set by standards applicable in the banking sector and guidelines contained in regulations, including supervisory recommendations, which are reflected in the applicable internal regulations.
The Supervisory Board oversees the Group's risk management system, the compliance of the Group's risk-taking policy with the Group's strategy and financial plan, and assesses the adequacy and effectiveness of this system, in particular through:
approval of the risk appetite defined by the Bank's Management Board for a given year and monitoring of its compliance,
approval of the risk management strategy adopted by the Bank's Management Board and monitoring of its compliance,
supervision over the development, adoption and implementation of policies and procedures on the basis of which the risk management system is to function in the Group,
defining the rules for reporting to the Supervisory Board on the types and size of risk in the activity in a way that allows the supervision of the risk management system in the Group,
annual assessment of the adequacy and effectiveness of the risk management system.
The Risk Committee of the Supervisory Board supports the Supervisory Board in supervision over the Group's risk management system. The Committee operates based on the Rules of Procedure of the Risk Committee of the Supervisory Board of Alior Bank approved by the Supervisory Board. The most important tasks of the Risk Committee of the Supervisory Board include in particular:
supporting the Bank's Supervisory Board in supervising the risk management system at the Bank,
giving opinions on the Bank's overall, current and future readiness to take risk,
giving opinions on the Bank's risk management strategy and analyzing the information submitted by the Management Board regarding the implementation of this strategy,
monitoring issues related to the implementation of the audit plan and recommendations issued by the Audit Department,
issuing opinions/conclusions on materials regarding the risk management system, including with regard to the annual report of the Risk Strategy Department, Compliance Department, Audit Department, in order for the Bank's Supervisory Board to assess the adequacy and effectiveness of the internal control system and risk management system,
supporting the Bank's Supervisory Board in overseeing the implementation of the Bank's risk management strategy by senior management,
verification of compliance of the price of liabilities and assets offered to clients with the Bank's business model and its risk strategy; in the event of non-compliance, presenting to the Bank's Management Board proposals to ensure the adequacy of the prices of liabilities and assets to these types of risk,
issuing opinions on regulations defining the Bank's strategy and approach to risk-taking,
analysis of periodic reports on the implementation of the above strategies and policies.
In 2025, 11 meetings of the Risk Committee of the Supervisory Board and 1 combined meeting of the Risk Committee of the Supervisory Board and the Audit Committee of the Supervisory Board were held.
Legal basis Row number DetailsThe Management Board of the Bank designs, implements and ensures the operation of a coherent risk management system in the Group, adjusted to the risk profile, including the rules for managing individual risk types of the Group, ensuring their consistency with the Group's risk management strategy, and determining the risk appetite. Moreover, the Management Board determines the organizational structure of the Bank, including foreign branches, taking care to properly divide the roles that are key to risk management. In the effective management of individual risks, the Board is supported by Committees established for this purpose. The Committees take decisions and make recommendations at standing meetings or by circulation.
The objective of the Capital, Assets and Liabilities Management Committee (CALCO) is to support the Bank's Management Board in effective management of market risk, liquidity risk, counterparty risk, business risk, capital risk and excessive leverage risk, as well as to supervise the operation of the Recovery Plan.
In 2025, the CALCO Committee held 42 meetings.
The Operational Risk Committee (KRO) was established to support the Bank's Management Board in the effective management of operational risk, including issues related to the maladjustment or unreliability of processes, the operation of people and systems or resulting from external threats, including significant subsidiaries. The Committee monitors the level of exposure to operational risk and assesses the situation in the area of operational risk throughout the Bank.
In 2025 the Operational Risk Committee held 12 meetings.
The objective of the Credit Risk Committee and Business Initiatives Committee is to support the Bank's Management Board in effective management of the Bank's credit risk, including credit concentration risk.
In 2025, the Credit Risk and Business Initiatives Committee held 14 meetings.
The Model Risk Committee supports the Bank's Management Board in the effective management of model risk, taking into account significant subsidiaries where model risk has been recognized as material under the Internal Capital Adequacy Assessment Process (ICAAP).
In 2025, the Model Risk Committee held 14 meetings.
The subject of the Bank's Credit Committee is to approve credit decisions on the Bank's on-balance sheet and off-balance sheet exposure, to make decisions on the introduction of special offers and to make decisions on all matters not regulated in the Credit Competence Rules, which involve the Bank taking credit risk, up to the limit of competences granted to Bank's Credit Committee, and recommending to the Bank's Management Board credit decisions for exposures exceeding the limit granted to the committee.
In 2025, the Bank's Credit Committee held 107 meetings.
The Bank supervises the functioning of the subsidiaries of the Bank's Capital Group. The Bank supervises the risk management systems in these entities and takes into account the level of risk related to the activities of individual entities as part of the risk monitoring and reporting system at the level of the Bank's Group.
The Risk Materiality Group is responsible for the risk review at Alior Bank SA. The Group is composed of representatives of individual divisions and areas of the Bank's operations, having appropriate knowledge of the current and potential risk. In particular, they are representatives of units responsible for managing credit risk, market risk and operational risk.
Due to the variety of phenomena accompanying particular types of risk, each of them is managed by the appropriate leading unit. In the case of credit risk, individual functions related to identification, measurement, assessment and monitoring have been divided among several organizational units.
The detailed scope of tasks of individual units is presented when discussing each type of risk.
Legal basis | Row number | Details |
The Audit Department conducts independent audits to provide the Supervisory Board and the | ||
Management Board of the Bank with objective information regarding the assessment of the | ||
effectiveness and adequacy of the risk management system in the Bank's Capital Group. | ||
Point (e) of Article 435(1) CRR | c) | The implemented and applied risk management system in the Group is appropriate from the point of view of the Group's profile and strategy. |
Point (c) of Article | d) | Risk measurement and assessment includes the determination of risk measures adequate to the materiality of a given type of risk and risk quantification using the established measures, as well as |
435(1) CRR | risk assessment consisting in determining the level of risk that may pose a threat to the achievement | |
of the Group's strategic goals. As part of the risk measurement, stress tests are carried out on the | ||
basis of assumptions ensuring reliable risk assessment, which include an analysis of the impact of | ||
changes in the environment and functioning of the Group on its financial and capital position. The | ||
measurement results are regularly reported to the Bank's authorities and designated organizational | ||
units. | ||
Point (c) of Article | e) | Risk reporting consists in regularly providing the Supervisory Board, the Management Board, committees and organizational units of the Bank indicated by the Management Board with reliable |
435(1) CRR | and regular information on changes in the size and profile of the Group's risk, as well as on the | |
undertaken and recommended actions in the field of risk management. The scope, frequency and form | ||
of reporting are adjusted to the management level of the recipients, which is regulated in detail in the | ||
Bank's internal regulations. | ||
Point (a) of Article | f) | Credit risk Credit risk management and keeping it at a safe level, defined in the risk appetite, is of fundamental |
importance for the Bank's stable operation and development. Credit risk is controlled by the credit risk management system in place at the Bank, which is comprehensive and integrated with the Bank's operational processes.
The description of the risk control system operation is reflected in the regulations in force at the Bank, in particular in the lending methodologies and risk valuation models tailored to the client's segment, product and transaction type, rules for establishing and monitoring legal loan collateral, and monitoring and debt collection processes.
By managing the risk (both on an individual and portfolio basis), the Bank takes actions that lead to:
minimizing the level of credit risk of a single loan with the assumed profitability level,
reduction of the total credit risk resulting from the Bank's specific loan portfolio.
As part of minimizing the risk of a single exposure, the Bank assesses each time when granting a loan product:
credibility and creditworthiness of the client, taking into account, inter alia, detailed analysis of the source of exposure repayment,
credibility of the accepted collateral, including verification of their formal, legal and economic status, taking into account, inter alia, LTV adequacy
undertakes effective monitoring and debt collection activities adequately defined at the level of a single client thanks to the segmentation models used.
In order to maintain the credit risk at the level defined in the risk appetite, the Bank takes the following actions:
sets and controls concentration limits,
monitors the structure and quality of a new credit exposure in relation to the defined objectives and signals of EWS,
analyzes changes in internal factors as well as market and geopolitical factors and the sensitivity of the loan portfolio, particularly with regard to negative events identified as potential risks,
regularly monitors the loan portfolio, controlling all significant parameters of credit risk (including SRC,PD, LGD, LTV, DTI, COR, NPE, NPL),
regularly carries out stress tests.
DetailsIn addition to individual organizational units in the credit risk management process, an active role is played by the Supervisory Board, the Bank's Management Board, the Credit Risk Committee and Business Initiatives Committee and the Bank's Credit Committee.
Operational riskThe Bank has a formal operational risk management system that prevents the occurrence of operational events and limits losses in the event of risk materialization.
Operational risk management includes the identification, measurement and assessment of operational risk, management activities and risk monitoring and control at all levels, from organizational units responsible for operational risk management in their areas, operational risk coordinators, through the Operational Risk Management Department, the Operational Risk Committee, to Management Board and Supervisory Board. An element of operational risk management is also reporting the level of this risk, both for internal and external purposes. The recipients, frequency and type of management information in operational risk reports are described in the Management Information System Principles (approved at the level of the Bank's Management Board).
As part of the identification of operational risk, the Bank recognizes risk factors that significantly influence its level. At the identification stage, various methods of obtaining information are used, including:
collecting data on events and losses at the Bank,
identifying risks in products, processes, systems, contracts and business reports (projects, initiatives),
analysis of external operational risk events.
Measurement and assessment of operational risk are carried out using quantitative and qualitative measures and include, among others:
the new standardised approach (SMA) is used to determine the own funds requirements for operational risk for Alior Bank S.A. and at the consolidated level of the Alior Bank S.A. Capital Group,
estimation of the Bank's internal capital for operational risk using the results of the internal model,
scenario analyses,
self-assessment of operational risk of products, processes, systems, contracts and business notifications,
setting an internal target and a limit for operational risk costs,
determining the level of target utilization and the limit for operational risk costs,
setting business goals for operational risk costs,
KRI,
valuation of actual and potential losses related to identified operational events,
conducting Stress Tests.
From 2025, for the purposes of determining own funds requirements for operational risk for Alior Bank S.A. and at the consolidated level of the Alior Bank S.A. Capital Group a new standard approach (SMA) is used, in accordance with the guidelines of the Regulation of the European Parliament and of the Council (EU) of 31 May 2024 amending Regulation (EU) No. 575/2013 with regard to requirements regarding credit risk, risk related to credit valuation adjustments, operational risk, market risk and the minimum capital threshold (Resolution No. 459/2024 of the Management Board of Alior Bank S.A. of December 30, 2024).
Market riskThe following types of market risk have been identified in the Bank and are subject to management:
interest rate risk in the banking book,
market risk in the trading book (including interest rate risk in the trading book, currency risk and commodity price risk).
The objective of market risk management is to limit potential losses due to changes in market risk factors to an acceptable level by appropriately shaping the structure of the balance sheet and off-balance sheet items. The Bank distinguishes the following market risk factors:
exchange rates,
interest rate indices,
stock / index prices,
prices of goods,
credit spread related to the rating of a given issuer,
options volatility parameters.
The Bank has a clear division of competences in the area of market risk management, including:
concluding treasury transactions,
measurement, monitoring and reporting of market risk,
transaction settlement process,
operational service and operational support for business processes.
Supervision over the above-mentioned activities related to concluding transactions as well as independent measurement and reporting of risk at the Bank has been distributed to the level of a Management Board Member, which guarantees full independence of their operations.
Points (a) and
(d) of Article 435(1)
CRR
g) Credit risk
Collaterals are established in relation to the credit risk incurred by the Bank and in a flexible manner to the client's abilities. Its establishment does not release the Bank from the obligation to examine the customer's creditworthiness.
The purpose of securing the loan is to provide the Bank with the repayment of the granted loan together with the interest and costs due, if the borrower fails to pay the amounts due within the time limits specified in the loan agreement and the restructuring activities do not bring the expected results. Details in points b and c of EU CRC - Qualitative disclosure requirements related to CRM techniques.
Operational riskIn order to limit the risk of materializing the effects of rare but potentially severe operational events, the Bank purchased a number of insurance policies. The above-mentioned policies included, among others: insurance in the field of: property (including electronic equipment), civil liability, fiscal penal liability and professional liability. The terms of individual policies are adapted to the scale and scope of the risk incurred.
An important element of operational risk management at Alior Bank is business continuity management (BCM). As part of BCM, the Bank implements the BCM system and strategies in accordance with the Business Continuity Management Policy and the ICT Business Continuity Management Strategy approved by the Bank's Management Board.
The above aspect is also regulated by the "ICT Business Continuity Management Policy" introduced by the Decision of the Vice-President of the Bank responsible for the IT Area.
As part of the BCM Bank system, periodically:
analyzes business processes / operational activities,
reviews and updates the strategy for action in emergency and crisis situations,
develops and implements emergency solutions and Business Continuity Plans (BCP),
performs tests, updates and self-assessment of the BCM system,
builds awareness in the organization in the field of BCM.
The implementation of the agreed BCM system and strategy is intended to ensure the implementation of critical business processes in the event of an unplanned disruption.
The bank has periodically tested emergency solutions for the implementation of critical processes (including replacement locations) and disaster recovery solutions.
Legal basis Row number Market risk DetailsMarket risk is limited by a system of limits and warning thresholds as well as an appropriate number of regulations defining the framework of the Bank's operations in terms of exposure to market risk. The limits are defined in particular in the form of the market risk appetite at the level of the Bank's Supervisory Board. Moreover, the CALCO Committee additionally limits the market risk with supplementary limits.
Market risk is hedged by appropriate shaping of the Bank's balance sheet structure (natural hedge) and by concluding appropriate hedging transactions. Some of the hedging transactions are designated for hedge accounting, both for cash flow volatility and fair value volatility.
EU OVB - Disclosure on governance arrangements
As at December 31, 2025, members of the Bank's Management Board: Piotr Żabski (President of the Bank's Management Board), Marcin Ciszewski (Vice-President of the Bank's Management Board), Zdzisław Wojtera (Vice-President of the Bank's Management Board), Jacek Iljin (Vice-President of the Bank's Management Board), Wojciech Przybył (Vice-President of the Bank's Management Board) Beata Stawiarska (Vice-President of the Bank's Management Board).
Members of the Bank's Management Board, in addition to their positions at Alior Bank S.A., held the following positions:
Piotr Żabski, Polski Standard Płatności sp. z o.o. - Member of the Supervisory Board, Jacek Iljin, Alior TFI S.A. - Chairman of the Supervisory Board,
Wojciech Przybył, Alior Leasing sp. z o.o. - Chairman of the Supervisory Board,
Zdzisław Wojtera, System Ochrony Banków Komercyjnych S.A. - Member of the Supervisory Board.
Point (b) of Article 435(2) CRRThe following applies at Alior Bank Spółka Akcyjna: Policy for the selection and assessment of
suitability of members of the Management Board of Alior Bank S.A. and Policy for selection and assessment of suitability of members of the Supervisory Board of Alior Bank S.A. , taking into account, among others, the provisions of the Methodology for assessing the suitability of bodies of entities supervised by the Polish Financial Supervision Authority (hereinafter referred to as the "Methodology").
In relation to members of the Management Board, its purpose is to fulfill obligations arising from legal provisions and support the implementation of the Bank's strategy by ensuring that the functions of members of the Management Board are performed by persons with knowledge, skills and experience appropriate to the functions they perform and the duties entrusted to them, and provide a guarantee proper performance of these duties.
In order to ensure the individual suitability of the Management Board members, the Nomination and Remuneration Committee of the Supervisory Board and then the Supervisory Board assess the initial suitability of the candidates and, based on this assessment, decides on appointment to the Management Board. The collective suitability of the body is also assessed.
The Nomination and Remuneration Committee of the Supervisory Board and the Supervisory Board periodically (once a year) verify the suitability of the Management Board members, making a secondary assessment of the individual suitability of individual Management Board members and assessing the collective suitability of the Management Board. Secondary evaluation of Management
Legal basis
Row
number
Details
Board members also takes place in the event of changes in the areas subject to evaluation according
to the Methodology.
Point (c) of Article 435(2)
c)
The Bank makes efforts to ensure diversity of the Management Board, in particular in terms of
education and professional experience, specialist knowledge, gender and age of the Management
CRR
Board members, to the extent that ensures a broad spectrum of views of the management body.
When selecting the composition of the Management Board, the Bank aims to achieve a balance in
terms of gender representation in this body, the total number of positions in the Management Board
and the Supervisory Board of the Bank held by persons of the underrepresented gender at a level no
lower than the number closest to 33% of all positions in both bodies, in a situation where at least one
person of the underrepresented gender holds a position in the Management Board of the Bank. In
order to achieve the assumed target share of both genders in the Management Board, the Nomination
and Remuneration Committee ensures the participation of both sexes in the process of selecting
Management Board members and equal treatment of candidates regardless of gender. In cases where
the selection process for a position on the Bank's Management Board involves a choice between
candidates with equivalent qualifications, priority is given to the candidate of the gender that is
underrepresented in the Bank's bodies, unless other diversity principles specified in legal provisions,
based on non-discriminatory criteria, justify the selection of a candidate of the opposite gender.
When assessing the diversity of the Bank's Management Board Members in terms of education and
professional experience, the following criteria may be taken into account: place (country, region) of
obtaining education or professional experience, educational profile, field of study, specialization in a
specific field, type of entities in which the candidate for a Bank's Management Board Member held a
position or was employed, and length of service. The Bank recruits Members of the Bank's
Management Board taking into account, first of all, the criteria specified above - necessary for the
proper functioning and suitability of the Bank's Management Board as a whole. As part of its annual
review of the composition of the Bank's Management Board, the Nomination Committee assesses its
compliance with the objectives and target values referred to above. If these are not met, it should
document the reasons for non-compliance, the measures that will be taken, and the deadlines for
their implementation to ensure the objectives and values are met. The composition of the Bank's
Management Board should not be shaped solely for the purpose of increasing diversity at the expense
of the functioning and suitability of the Management Board as a whole or the suitability of individual
members of the Bank's Management Board.
Point (d) of Article 435(2)
d)
The Risk Committee of the Supervisory Board of Alior Bank S.A. was established on 22 December
2015 by Resolution No. 81/2015 of the Supervisory Board to support the Supervisory Board in
CRR
overseeing the risk management process at the Bank.
The Committee operates based on the Rules of Operation of the Risk Committee of the Supervisory
Board of Alior Bank S.A. approved by the Supervisory Board.
Meetings of the Committee are held in accordance with the work plan adopted by the Committee,
generally on a monthly basis.
Point (e) Article 435(2)
e)
Reporting to the management body is carried out in accordance with the principles described in the
Regulation of the Management Information System (approved at the level of the Bank's Management
Board).
Management reporting is carried out in the following cycles:
Monthly:
the monthly information for the Bank's Management Board is to present to the Bank's Management Board the aggregated results of the implementation of the Bank's strategy in terms of individual risks in relation to the adopted risk appetite,
the implementation of key risk indicators, including the risk appetite in the credit portfolio of the Alior Bank Group, involves presenting the aggregated results of the implementation
of the Bank's strategy in terms of individual risks in relation to the adopted risk appetite to the Bank's Management Board and the Risk Committee of the Supervisory Board.
Quarterly:quarterly information for the Bank's Management Board, the Risk Committee of the Supervisory Board and the Supervisory Board is the presentation to the Management Board of the Bank, the Risk Committee of the Supervisory Board and the Supervisory Board of the aggregated results of the implementation of the Bank's strategy in terms of individual risks in relation to the adopted risk appetite.
Semi-annual:report on the assessment of outsourcing and sensitive services in terms of operational risk for the Bank's Management Board and Supervisory Board,
Annual:summary of annual risk results, including accounting for risk appetite and risk policy implementation for the previous year,
report on information technology risk at Alior Bank for the Bank's Management Board and the Risk Committee of the Supervisory Board,
annual report - Operational risk management in the Alior Bank S.A. Group. for the Bank's Management Board, the Risk Committee of the Supervisory Board and the Supervisory Board, includes a summary of the implementation of the operational risk management strategy and policy.
EU OVC - ICAAP information
Alior Bank SA has an internal capital adequacy assessment process (ICAAP) in line with the Regulation of the Minister of Finance, Funds and Regional Policy of 3 August 2021 on the detailed method of internal capital estimation and bank reviews.
The purpose of the internal capital adequacy assessment process is to ensure that all risks to which the Bank is exposed are analyzed in terms of materiality and that the Bank has an adequate amount of capital to cover the risks deemed material.
The process includes the following phases:
identification of material risks - performed as part of the process review on an annual basis, or more frequently in justified cases,
quantification of individual risks and total internal capital - performed on an ongoing basis,
stress testing - performed on an annual basis or more frequently in justified cases,
reporting and monitoring of capital goals, including available capital allocation limits -cyclically,
capital management and capital planning - performed on an ongoing basis in order to ensure the adequacy of internal capital,
process review - performed on an annual basis, or more often in justified cases.
Article 438(c) CRR
The Bank did not have any additional regulatory requirements with regard to own funds and their structure based on the supervisory review process referred to in Art. 104 sec. 1 lit. a) Directive 2013/36/EU.
EU LI1 - Differences between the accounting scope and the scope of prudential consolidation and mapping of financial statement categories with regulatory risk categories
PLN m
Carrying values as reported in published financial statements | Carrying values under scope of prudential consolidation | Carrying values of items | ||||||
Subject to the credit risk framework | Subject to the CCR framework | Subject to the securitisation framework | Subject to the market risk framework | Not subject to own funds requirements or subject to deduction from own funds | ||||
a | b | c | d | e | f | g | ||
0010 | 0020 | 0030 | 0040 | 0050 | 0060 | 0070 | ||
Breakdown by asset clases according to the balance sheet in the published financial | ||||||||
1 | Cash and cash equivalents | 4 063 | 4 058 | 4 058 | ||||
2 | Amounts due from banks | 2 203 | 2 203 | 877 | 1 326 | |||
3 | Debt securities and derivatives | 26 510 | 26 492 | 26 244 | 248 | 189 | ||
measured at fair value through other comprehensive income | 22 543 | 22 540 | 22 540 | |||||
measured at fair value through profit or loss | 371 | 356 | 108 | 248 | 189 | |||
measured at amortized cost | 3 596 | 3 596 | 3 596 | |||||
4 | Derivative hedging instruments | 660 | 660 | 660 | ||||
5 | Loans and advances to customers | 65 451 | 65 451 | 65 036 | 415 | |||
6 | Property. plant and equipment | 829 | 829 | 829 | ||||
7 | Intangible assets | 551 | 551 | 101 | 450 | |||
8 | Investments in associates | 0 | 75 | 75 | ||||
9 | Income tax asset | 724 | 723 | 685 | 38 | |||
10 | Other assets | 784 | 780 | 780 | ||||
Total assets | 101 775 | 101 822 | 98 685 | 2 649 | 189 | 488 | ||
Carrying values as reported in published financial statements | Carrying values under scope of prudential consolidation | Carrying values of items | ||||||
Subject to the credit risk framework | Subject to the CCR framework | Subject to the securitisation framework | Subject to the market risk framework | Not subject to own funds requirements or subject to deduction from own funds | ||||
a | b | c | d | e | f | g | ||
0010 | 0020 | 0030 | 0040 | 0050 | 0060 | 0070 | ||
Breakdown by liability classes according to the balance sheet in the published | ||||||||
1 | Amounts due to banks | 589 | 589 | |||||
2 | Amounts due to customers | 82 621 | 82 679 | |||||
3 | Financial liabilities | 327 | 327 | 268 | 167 | |||
4 | Derivative hedging instruments | 69 | 69 | 69 | ||||
5 | Fair value changes of the hedged items in portfolio hedge of interest rate risk | 202 | 202 | |||||
6 | Provisions | 404 | 404 | |||||
7 | Other liabilities | 2 040 | 2 033 | |||||
8 | Income tax liabilities | 218 | 217 | |||||
9 | Debt securities issued | 2 322 | 2 322 | |||||
Total liabilities | 88 792 | 88 842 | 337 | 167 | ||||
EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements
PLN m
Total | Items subject to | ||||||
Credit risk framework | Securitisation framework | CCR framework | Market risk framework | ||||
a | b | c | d | e | |||
0010 | 0020 | 0030 | 0040 | 0050 | |||
1 | Assets carrying value amount under the scope of prudential consolidation (as per template LI1) | 0010 | 101 822 | 98 865 | 2 649 | 189 | |
2 | Liabilities carrying value amount under the scope of prudential consolidation (as per template LI1) | 0020 | 88 842 | 337 | 167 | ||
3 | Total net amount under the scope of prudential consolidation | 0030 | 12 980 | 98 685 | 2 312 | 22 | |
4 | Off-balance-sheet amounts | 0040 | 17 123 | 17 123 | |||
5 | Differences in valuations | 0050 | |||||
6 | Differences due to different netting rules, other than those already included in row 2 | 0060 | |||||
7 | Differences due to consideration of provisions | 0070 | -102 | -102 | |||
8 | Differences due to the use of credit risk mitigation techniques (CRMs) | 0080 | -169 | -169 | |||
9 | Differences due to credit conversion factors | 0090 | 8 904 | 8 904 | |||
10 | Differences due to Securitisation with risk transfer | 0100 | |||||
11 | Other differences | 0110 | 916 | 958 | -42 | ||
12 | Exposure amounts considered for regulatory purposes | 0120 | 109 861 | 107 591 | 2 270 | 25 | |
EU LI3 - Outline of the differences in the scopes of consolidation (entity by entity)
Name of the entity | Method of prudential consolidation | Method of accounting consolidation | Description of the entity | |||||
Full consolidation | Proportional consolidation | Equity method | Neither consolidated nor deducted | Deducted | ||||
a | b | c | d | e | f | g | ||
0009 | 0010 | 0020 | 0030 | 0040 | 0050 | 0060 | 0070 | |
1 | Alior Services Sp. z o.o. | Full consolidation | x | The company operates as an insurance agent for 7 insurance companies (contract administration). | ||||
2 | Alior Leasing Sp. z o.o. | Full consolidation | x | The company provides fixed asset financing through operational and financial leasing, as well as lease loans. The company has its own sales network of Leasing Advisors responsible for servicing Alior Bank clients and collaborating with external partners - vehicle, machinery, and equipment dealers. The company's strategic goal is to expand its cooperation with Alior Bank in the corporate client segment, continue its dynamic growth among SME and sole proprietorship clients, and increase its presence among machinery and equipment dealers by tailoring its offerings to the needs of clients in the industrial and medical sectors. The Alior Leasing Capital Group also includes:
| ||||
3 | Meritum Services ICB SA | Full consolidation | x | The company conducts service activities in the field of information and computer technologies and provides IT software services. | ||||
4 | Alior TFI SA | Full consolidation | x | The company's core business is asset management. The bank's collaboration with its subsidiary, Alior TFI, primarily involves the distribution of ALIOR SFIO units. The company continues to hold a license to manage portfolios comprising one or more financial instruments. | ||||
Name of the entity | Method of prudential consolidation | Method of accounting consolidation | Description of the entity | |||||
Full consolidation | Proportional consolidation | Equity method | Neither consolidated nor deducted | Deducted | ||||
a | b | c | d | e | f | g | ||
0009 | 0010 | 0020 | 0030 | 0040 | 0050 | 0060 | 0070 | |
5 | Corsham Sp. z o.o. | Full consolidation | x | A company dedicated to implementing venture capital investments. Pursuant to Resolution No. 434/2023 of the Bank's Management Board dated 13 December 2023, the Bank's Management Board decided to discontinue further investment activities. | ||||
6 | RBL_VC Sp. z o.o. | Full consolidation | x | A company dedicated to managing companies making venture capital investments has been entered into the register of Alternative Investment Company Managers (ZASI). | ||||
7 | RBL_VC Sp. z o.o. ASI spółka komandytowo-akcyjna | Full consolidation | x | It is an investment vehicle used by Alior Bank SA to make venture capital investments. Pursuant to Resolution No. 434/2023 of the Bank's Management Board dated 13 December 2023, the Bank's Management Board decided to discontinue further investment activities. By Resolution No. 469/2025 of 16 December 2025, the Bank's Management Board granted directional consent to the liquidation of the company as part of the simplification of the structure of the Bank's Capital Group. | ||||
Detailed information on the structure of the Alior Bank SA Capital Group is included in the Consolidated Financial Statements of the Alior Bank Group for the year ended 31 December 2025.
EU LIA - Explanations of differences between accounting and regulatory exposure amounts
Annex No. 1 to Resolution No. 53/2026 of the Management Board of Alior Bank SA
Details Article 436(b) CRRThe scope of companies subject to prudential consolidation differs from the scope of companies subject to financial consolidation carried out in accordance with the International Financial Reporting Standards.
In 2025, Alior Bank SA and Alior Leasing sp. z o.o. were covered by prudential consolidation. In the opinion of the Bank's Management Board, other subsidiaries were not subject to prudential consolidation due to their insignificant scale of operations in the Bank's Capital Group.
The differences between the accounting and prudential scope of consolidation result from the financial data of other companies not included in the prudential consolidation, and from accounting consolidation exclusions.
Article 436(d) CRRThe main difference between the accounting and prudential scope of consolidation is "Investments
in associates", the Bank's shares in subsidiaries not prudentially consolidated.
EU LIB - Other qualitative information on the scope of application
Legal basis | Row number | Details |
Article 436(f) CRR | a) | In the case of other entities belonging to the Alior Bank SA Capital Group, the Bank does not identify any significant obstacles to the transfer of funds for recapitalization of entities and the repayment of |
their liabilities. | ||
Article 436(g) CRR | b) | The Bank does not have subsidiaries not covered by consolidation, whose own funds are lower than required. |
Article 436(h) CRR | c) | The Bank does not apply the derogations referred to in Art. 7 of CRR, or the individual consolidation method specified in Art. 9 of CRR. |
Article 436(g) CRR | d) | Due to the above, this disclosure does not apply to the Alior Bank Group. |
EU PV1 - Prudent valuation adjustments (PVA)
PLN m
Risk category | Category level AVA -Valuation uncertainty | Total category level post-diversification | ||||||||||
Equity | Interest Rates | Foreign exchange | Credit | Commodities | Unearned credit spreads AVA | Investment and funding costs AVA | Of which: Total core approach in the trading book | Of which: Total core approach in the banking book | ||||
a | b | c | d | e | EU e1 | EU e2 | f | g | h | |||
Category level AVA | 0009 | 0010 | 0020 | 0030 | 0040 | 0050 | 0060 | 0070 | 0080 | 0090 | 0100 | |
1 | Market price uncertainty | 0010 | ||||||||||
2 | Not applicable | 0020 | ||||||||||
3 | Close-out cost | 0030 | ||||||||||
4 | Concentrated positions | 0040 | ||||||||||
5 | Early termination | 0050 | ||||||||||
6 | Model risk | 0060 | ||||||||||
7 | Operational risk | 0070 | ||||||||||
8 | Not applicable | 0080 | ||||||||||
9 | Not applicable | 0090 | ||||||||||
10 | Future administrative costs | 0100 | ||||||||||
11 | Not applicable | 0110 | ||||||||||
12 | Total Additional Valuation Adjustments | 0120 | 24 | |||||||||
To calculate a prudent valuation adjustment (AVA), the bank uses the simplified method, in accordance with Art. 4, Commission Delegated Regulation (EU) 2016/101 of 26 October 2015 supplementing Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to prudent regulatory technical standards in accordance with Art. 105 paragraph. 14, the sum of the absolute value of assets and liabilities measured at fair value as reported in the institution's financial statements in accordance with the applicable accounting framework is less than EUR 15 billion.
EU CC1 - Composition of regulatory own funds
PLN m | Amounts | Source based on reference numbers/letters of the balance sheet under the regulatory scope of consolidation | |||
a | b | ||||
0010 | 0020 | ||||
Common Equity Tier 1 (CET1) capital: instruments and reserves | 0009 | ||||
1 | Capital instruments and the related share premium accounts | 0010 | 5 182 | EU CC2 pos. P10 +P11.1 | |
Series A | |||||
Series B | |||||
Series C | |||||
Series D,E, F | |||||
Series G | |||||
Series H | |||||
Series I, J | |||||
2 | Retained earnings | 0050 | 78 | EU CC2 pos. P14.1 | |
3 | Accumulated other comprehensive income (and other reserves) | 0060 | 5 354 | EU CC2 pos. P11+P.12+P13 | |
EU-3a | Funds for general banking risk | 0070 | |||
4 | Amount of qualifying items referred to in Article 484 (3) CRR and the related share premium accounts subject to phase out from CET1 | 0080 | |||
5 | Minority interests (amount allowed in consolidated CET1) | 0090 | |||
EU-5a | Independently reviewed interim profits net of any foreseeable charge or dividend | 0100 | 558 | EU CC2 pos. P14.3 | |
6 | Common Equity Tier 1 (CET1) capital before regulatory adjustments | 0110 | 11 173 | ||
Common Equity Tier 1 (CET1) capital: regulatory adjustments | 0119 | ||||
7 | Additional value adjustments (negative amount) | 0120 | -24 | ||
8 | Intangible assets (net of related tax liability) (negative amount) | 0130 | -450 | EU CC2 pos. A7 | |
10 | Deferred tax assets that rely on future profitability excluding those arising from temporary differences (net of related tax liability where the conditions in Article 38 (3) CRR are met) (negative amount) | 0140 | |||
11 | Fair value reserves related to gains or losses on cash flow hedges of financial instruments that are not valued at fair value | 0150 | -126 | ||
12 | Negative amounts resulting from the calculation of expected loss amounts | 0160 | |||
13 | Any increase in equity that results from securitised assets (negative amount) | 0170 | |||
14 | Gains or losses on liabilities valued at fair value resulting from changes in own credit standing | 0180 | |||
15 | Defined-benefit pension fund assets (negative amount) | 0190 | |||
16 | Direct, indirect and synthetic holdings by an institution of own CET1 instruments (negative amount) | 0200 | |||
17 | Direct, indirect and synthetic holdings of the CET 1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount) | 0210 | |||
18 | Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution does not have a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount) | 0220 | |||
PLN m | Amounts | Source based on reference numbers/letters of the balance sheet under the regulatory scope of consolidation | |||
a | b | ||||
0010 | 0020 | ||||
19 | Direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities (amount above 10% threshold and net of eligible short positions) (negative amount) | 0230 | |||
EU-20a | Exposure amount of the following items which qualify for a RW of 1250%, where the institution opts for the deduction alternative | 0240 | |||
EU-20b | of which: qualifying holdings outside the financial sector (negative amount) | 0250 | |||
EU-20c | of which: securitisation positions (negative amount) | 0260 | |||
EU-20d | of which: free deliveries (negative amount) | 0270 | |||
21 | Deferred tax assets arising from temporary differences (amount above 10% threshold, net of related tax liability where the conditions in Article 38 (3) CRR are met) (negative amount) | 0280 | |||
22 | Amount exceeding the 17,65% threshold (negative amount) | 0290 | |||
23 | of which: direct, indirect and synthetic holdings by the institution of the CET1 instruments of financial sector entities where the institution has a significant investment in those entities | 0300 | |||
25 | of which: deferred tax assets arising from temporary differences | 0310 | |||
EU-25a | Losses for the current financial year (negative amount) | 0320 | |||
EU-25b | Foreseeable tax charges relating to CET1 items except where the institution suitably adjusts the amount of CET1 items insofar as such tax charges reduce the amount up to which those items may be used to cover risks or losses (negative amount) | 0330 | |||
27 | Qualifying AT1 deductions that exceed the AT1 items of the institution (negative amount) | 0340 | |||
27a | Other regulatory adjustments | 0350 | -57 | ||
28 | Total regulatory adjustments to Common Equity Tier 1 (CET1) | 0360 | -657 | ||
29 | Common Equity Tier 1 (CET1) capital | 0370 | 10 515 | ||
Kapitał dodatkowy Tier I: instrumenty | 0379 | ||||
30 | Capital instruments and the related share premium accounts | 0380 | |||
31 | of which: classified as equity under applicable accounting standards | 0390 | |||
32 | of which: classified as liabilities under applicable accounting standards | 0400 | |||
33 | Amount of qualifying items referred to in Article 484 (4) CRR and the related share premium accounts subject to phase out from AT1 | 0410 | |||
EU-33a | Amount of qualifying items referred to in Article 494a(1) CRR subject to phase out from AT1 | 0420 | |||
EU-33b | Amount of qualifying items referred to in Article 494b(1) CRR subject to phase out from AT1 | 0430 | |||
34 | Qualifying Tier 1 capital included in consolidated AT1 capital (including minority interests not included in row 5) issued by subsidiaries and held by third parties | 0440 | |||
35 | of which: instruments issued by subsidiaries subject to phase out | 0450 | |||
36 | Additional Tier 1 (AT1) capital before regulatory adjustments | 0460 | |||
Additional Tier 1 (AT1) capital: regulatory adjustments | 0469 | ||||
37 | Direct, indirect and synthetic holdings by an institution of own AT1 instruments (negative amount) | 0470 | |||
38 | Direct, indirect and synthetic holdings of the AT1 instruments of financial sector entities where those entities have reciprocal cross holdings with the institution designed to inflate artificially the own funds of the institution (negative amount) | 0480 | |||
