Eurobank S.a.ATHEX: EUROB

Financial Reports 2025 Consolidated Pillar 3 Report

Apr 30, 2026 at 1:09 PM UTC · Issued by Eurobank S.a.

CONSOLIDATED PILLAR 3 REPORT

FOR THE YEAR ENDED

31 DECEMBER 2025

8 Othonos Str, Athens 105 57, Greece

eurobank.gr, Tel.: (+30) 210 333 7000 General Commercial Registry No: 154558160000

Introduction - General Information 7
1. Highlights 7
2. Non-Performing exposures (NPE) Operational targets 9
3. Project Sun (ex-"Solar") 9
4. Other loans held for sale (including project "Leon") 9
5. Project "Moon" 9
6. Project "Wave" 10
7. Corporate actions in relation to Hellenic Bank group 10
8. Acquisition of CNP Cyprus Insurance Holdings Limited 11
9. Merger process between Eurobank Holdings and Eurobank S.A. 11
10. Agreement with Fairfax for the acquisition of Eurolife FFH Life Insurance and the partial disposal of ERB Asfalistiki Ltd 11
11. Dividends/Shareholders' remuneration 12
12. Additional Tier 1 capital instruments 12
13. Tier 2 Capital instruments 13
14. Regulatory framework 14
15. Supervisory Review and Evaluation Process (SREP) 18
16. Implementation of Capital Adequacy framework 19
17. 2025 EU - wide stress test 20
18. SSM 2026 Geopolitical Reverse Stress Test 20
19. Scope of Pillar 3 20
20. Pillar 3 Written attestation 21
21. Location, timing and frequency of disclosures 21
22. EBA Pillar 3 Data Hub 22
23. Compliance with CRR 22
24. Governance arrangements 23
25. Prudential versus accounting consolidation 24
26. Impediments to the prompt transfer of capital 30
Capital Management 31
1. Regulatory capital - definition 31
2. Reconciliation of Balance Sheets-financial accounting to prudential scope of consolidation 31
3. Basel 4 implementation 35
4. Key Metrics 36
5. Regulatory capital 37
6. Countercyclical buffer 39
7. Supervisory Review and Evaluation Process (SREP) capital requirements 40
8. Minimum Requirement for Own Funds and Eligible Liabilities (MREL) 41
9. Capital requirements under Pillar 1 45
10. Internal Capital Adequacy Assessment Process (ICAAP) 47
11. Internal Liquidity Adequacy Assessment Process (ILAAP) 48
Risk management overview 49
1. Risk management objectives and policies 49
2. Risk appetite framework 50
3. Types of risk 51
Credit Risk 53
1. Definition of credit risk 53
2. Credit risk organization and processes 53
3. Credit risk reporting 63
4. Credit exposures 64
5. Credit quality of financial assets 64
6. Standardised approach 72
7. Credit risk mitigation 76
8. Asset Backed Securities 81
Market Risk 87
1. Definition and policies 87
2. Internal model - Value at Risk (VaR) model & Credit Risk (IRC) 90
3. Standardised approach for market risk 96
4. Equity exposures not included in the trading book 97
5. Interest rate risk in the Banking Book (IRRBB) 97
Counterparty risk 101
1. Definition 101
2. Mitigation of counterparty risk 101
3. Counterparty risk monitoring 101
4. Wrong way risk 101
5. Implications under rating downgrade 101
6. Credit derivatives 101
7. Counterparty risk based on the calculation methodology employed 102
8. CVA capital charge 103
9. Exposures to CCPs 103
10. Standardised approach - CCR exposures by regulatory portfolio and risk 104
11. RWEAs flow statements of CCR exposures under IMM 105
12. Composition of collateral for exposures to CCR 105
Operational Risk 106
1. Risk management objectives and policies 106
2. Structure and organisation of the operational risk management function 106
3. Scope and nature of the measurement system 107
4. Scope and nature of the operational risk reporting framework 107
5. Policies and strategies of operational risk mitigation 107
6. Operational Risk - Capital requirements 108
Asset Encumbrance 110
1. Information on importance of encumbrance 110
2. Assets 110
3. Collateral received 111
4. Encumbered assets/collateral received and associated liabilities 112
Leverage Ratio 113
Liquidity Risk 116
1. Liquidity Risk Management Framework 116
2. Liquidity Buffer 116
3. Liquidity Coverage Ratio (LCR) calculations 117
4. Net Stable Funding Ratio (NSFR) calculations 118
Environmental, Social and Governance (ESG) Risks 122
1. Qualitative Information on Environmental Risks 122
2. Qualitative Information on Social Risks 151
3. Qualitative Information on Governance Risks 155
4. Quantitative Information on ESG Risks 156

Appendix 1: EU CC1 - Composition of regulatory own funds 177 Appendix 2: Capital instruments' main features disclosure 179 Appendix 3: List of Abbreviations 181 Appendix 4: Guidelines and Regulations mapping on Disclosures Requirements 183 Index of tables

Group's insurance subsidiaries 26
EU LI3 - Outline of the differences in the scopes of consolidation 27
EU CC2 - Reconciliation of regulatory own funds to balance sheet in the audited financial 29
EU LI1 - Differences between accounting and regulatory scopes of consolidation and the mapping of financial
statement categories with regulatory risk categories 32
EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statement 34
EU KM1 - Key Metrics template 36
Composition of regulatory capital 38
EU CCyB1 - Geographical distribution of credit exposures relevant for the calculation of countercyclical buffer 39
EU CCyB2 - Amount of institution-specific countercyclical capital 40
Pillar 2 Requirements 41
EU KM2 - Key metrics - MREL and, where applicable, G-SII requirement for own funds and eligible liabilities 42
EU TLAC1 - Composition - MREL and, where applicable, G-SII Requirement for own funds and eligible liabilities 43
EU TLAC3b - Creditor ranking - resolution entity 44
EU OV1 - Overview of risk weighted exposure amounts 45
EU CMS1 - Comparison of modelled and standardised risk weighted exposure amounts at risk level 46
INS1 - Non deducted participation in insurance undertakings 46
EU CR1-A - Maturity analysis of exposures 64
EU CQ1 - Credit quality of forborne exposures 67
EU CQ3 - Credit quality of performing and non-performing exposures by past due days 68
EU CR1 - Performing and non-performing exposures and related provisions 69
EU CQ4 - Quality of non-performing exposures by geography. 70
EU CQ5 - Credit quality of loans and advances to non-financial corporations by industry. 71
EU CR2 - Changes in the stock of non-performing loans and advances 72
EU CQ7 - Collateral obtained by taking possession and execution processes 72
EU CR4 - Standardised approach - Credit risk exposure and CRM effects 73
EU CR5 - Standardised approach 74
Guarantee and credit derivatives 80
EU CR3 - CRM techniques - Overview: Disclosure of the use of credit risk mitigation techniques 81
EU SEC1 - Securitisation exposures in the non-trading book 83
EU SEC3 - Securitisation exposures in the non-trading book and associated regulatory capital requirements -
institution acting as originator or as sponsor… 84
EU SEC4 - Securitisation exposures in the non-trading book and associated capital requirements - institution acting as
investor… 85
EU SEC5 - Transactions subject to own funds requirements for CVA risk 86
EU MR2-A - Market risk under Internal Model Approach (IMA) 94
EU MR2-B - RWEAs flow of market risk exposures under IMA 94
EU MR3 - IMA values for trading portfolios 95
EU MR4: Comparison of VAR estimates with gains/losses 96
EU MR1 - Market risk under the standardised approach 97
Equity exposures not included in the trading book… 97
Interest rate VaR by risk type (FVOCI) 98
NII Sensitivity impact (± 200 bps) 98
EU IRRBB1 - Interest rate risks of non-trading book activities 99
EU IRRBBA - Qualitative information on interest rate risks of non-trading book activities 100
EU CCR6 - Credit derivatives exposures 102
EU CCR1 - Analysis of CCR exposure by approach 102
EU CVA 1 - Credit valuation adjustment risk under the Reduced Basic Approach (R-BA) 103
EU CCR8 - Exposures to CCPs 103
EU CCR3 - Standardised approach - CCR exposures by regulatory exposure class and risk weights 104
EU CCR7 - RWEA flow statements of CCR exposures under the IMM 105
EU CCR5 - Composition of collateral for CCR exposures 105
EU OR1 - Operational risk own funds requirements and risk-weighted exposure amounts 108
EU OR2 - Business Indicator, components and subcomponents 108
EU OR3 - Operational risk own funds requirements and risk exposure amounts ……………………………………………………. 109
EU AE1 - Encumbered and unencumbered assets 110
EU AE2 - Collateral received and own debt securities issued 111
EU AE3 - Sources of encumbrance 112
EU LR1 - LRSum: Summary reconciliation of accounting assets and leverage ratio exposures 113
EU LR2 - LRCom: Leverage ratio common disclosure 114
EU LR3 - LRSpl: Split-up of on balance sheet exposures (excluding derivatives, SFTs and exempted exposures) 115
EU LIQ1 - Quantitative information of LCR 117
EU LIQ2 - Net Stable Funding Ratio 118
Banking book - Climate Change transition risk: Credit quality of exposures by sector, emissions and residual maturity … 158
Banking book - Climate change transition risk: Loans collateralised by immovable property - Energy efficiency of the
collateral 163
Banking Book - Climate change transition risk: Alignment metrics 164
Banking book - Climate change transition risk: Exposures to top 20 carbon-intensive firms 165
Banking book - Climate change physical risk: Exposures subject to physical risk… 168
Summary of GAR KPIs 170
Mitigating actions: Assets for the calculation of GAR 171
GAR (%) 173
Other climate change mitigating actions that are not covered in the EU Taxonomy… 176
Appendix 1 - EU CC1 - Composition of regulatory own funds 177
Appendix 2: Capital instruments' main features disclosure 179
Appendix 3 - List of Abbreviations 181
Appendix 4 - Guidelines and Regulations mapping on Disclosures Requirements 183

‌Introduction - General Information

On 12 December 2025, the merger by absorption of "Eurobank Ergasias Services and Holdings S.A." (Eurobank Holdings) by Eurobank S.A. (Eurobank or the Bank) was completed and Eurobank S.A. became the ultimate parent company of the Group the Bank along with its subsidiaries (the Group), are active in retail, corporate and private banking, asset management, treasury, capital markets, insurance and other services. The Group operates mainly in Greece, Bulgaria, Cyprus and Luxembourg. The Bank is incorporated in Greece and its shares are listed on the Athens Stock Exchange and the Cyprus Stock Exchange.

Eurobank S.A. is supervised on a standalone and consolidated basis by the European Central Bank (ECB) and the Bank of Greece (BoG).

‌Highlights

31 December 2025 (1) & (2)	31 December 2025 (1)	30 September 2025 (1)	31 December 2024 (1)
€ million	€ million	€ million	€ million
8,132	8,134	8,049	7,718
9,221	9,224	8,544	7,718
10,437	10,439	9,775	9,093

52,245	53,647	51,836	49,977

15.6%	15.2%	15.5%	15.4%
17.7%	17.2%	16.5%	15.4%
20.0%	19.5%	18.9%	18.2%

8.1%	8.1%	7.7%	7.3%

	172.2% 180.4% 188.2% 144.2% 142.7% 144.7%

Risk profile

Available own funds

Common Equity Tier 1 (CET1) capital

Risk-weighted exposure amounts

Tier 1 capital Total capital

Total risk-weighted exposure amount

Capital ratios

Common Equity Tier 1 ratio (%)

Tier 1 ratio (%)

Leverage ratio

Liquidity Ratio

Total capital ratio (%) Leverage ratio

Liquidity coverage ratio (%) Net Stable Funding Ratio (%)

(1) Figures and ratios include profits, as well as the payout accrual (in accordance with the Group shareholders' remuneration policy), subject to Supervisory Authorities' approval.

(2) Pro-forma with the completion of project "Sun (ex-Solar)" and "Wave III" securitization upsize.

18.2%

Evolution of Capital Ratios Evolution of Capital Ratios

Dec. 25 (1) & (2)

Dec. 25 (1)

Sep. 25 (1)

Jun. 25 (1)

Mar. 25 (1)

Dec. 24 (1)

15.6%

14.9%

15.2%

14.6%

15.5%

15.0%

15.3%

14.8%

15.2%

14.8%

15.4%

18.7%

20.0%

19.2%

19.5%

18.9%

18.2%

18.6%

18.1%

18.2%

19.6%

18.9%

CET 1 Phased-in

CAD Phased-in

CET 1 Fully Loaded

CAD Fully Loaded

Dec. 23

15.4%

(1) Figures and ratios include profits, as well as the payout accrual (in accordance with the Group shareholders' remuneration policy), subject to

Supervisory Authorities' approval.

(2) Pro-forma with the completion of project "Sun (ex-Solar)" and "Wave III" securitization upsize.

Evolution of Risk Weighted Exposure Amount

45,203

45,319

47,443

46,042

Dec. 24 (1)

Mar. 25 (1)

Jun 25 (1)

Sep. 25 (1)

Dec. 25 (1)

Dec. 25 (1) & (2)

Operational Risk

Market Risk

Credit Risk

44,884

43,986

€ million

52,245

5,477

727

5,477

727

5,794

723

5,794

723

5,794

861

5,335

656

53,647

51,836

51,720

49,977

51,539

(1) Figures and ratios include profits, as well as the payout accrual (in accordance with the Group shareholders' remuneration policy), subject to

Supervisory Authorities' approval.

(2) Pro-forma with the completion) of project "Sun (ex-Solar)" and "Wave III" securitization upsize.

‌Non-Performing exposures (NPE) Operational targets
As at 31 December 2025 the Group's NPE stock amounting to € 1,434 million (30 September 2025: € 1,531 million. The Group NPE ratio amounted to 2.6% (30 September 2025: 2.8%) while the NPE coverage ratio improved to 95.2% (30
September 2025 94.0%).
‌Project Sun (ex-"Solar")
In the context of its NPE management strategy, the Group had participated, since 2018, in a joint initiative with the other Greek systemic banks, to structure an NPE securitization transaction (project "Solar") under the provisions of Hellenic Asset Protection Scheme (HAPS), that was finally abandoned in the first half of 2025. As Management remains committed to its plan to recover the carrying amount of the respective loan portfolio through its disposal, the Group retained the classification of the underlying loans as held for sale. In December 2025, negotiations with potential investors regarding the sale of the loan portfolio were concluded for a consideration of ca. € 23 million The sale and legal transfer of the abovementioned loan portfolio is expected to be completed within the first half of 2026.
As at 31 December 2025, the carrying amount of Sun loan portfolio reached € 18 million, comprising loans with gross carrying amount of € 240 million and impairment allowance of € 222 million, including the additional impairment loss of
€ 25 million recognized within 2025 and calculated by reference to the expected consideration as adjusted to reflect the
loans' collections from the transaction's reference date up to 31 December 2025 and the estimated selling costs. For further details, please refer to Consolidated Financial Statements, Note 20.
‌Other loans held for sale (including project "Leon")
In December 2023, the Group, in the context of its NPE reduction plan, initiated the sale process of a mixed NPE portfolio that was concluded on 13 September 2024 via a securitization structure (SPV-LEON CAPITAL FINANCE DAC) under the requirements of Hellenic Asset Protection Scheme law. Accordingly, as of the aforementioned date, the Group derecognized the underlying loan portfolio on the basis that it transferred substantially all risks and rewards of the portfolio's ownership and relinquished its control over it, and recognized the retained notes on its balance sheet, i.e. 100% of the senior and 5% of the mezzanine and junior notes of Leon securitization, at fair value. At 31 December 2025 the carrying amount of the retained notes is € 274 million (31 December 2024: € 276 million).
As at 31 December 2025, the remaining loan portfolio designated for sale that was not finally included in the securitization structure, with a gross carrying amount of € 42 million and an equal impairment allowance, was written off in its entirety, as the Group concluded that there was no reasonable expectation of recovering the portfolio's expected cash flows.
For further details, please refer to Consolidated Financial Statements, Note 20.
‌Project "Moon"
In December 2025, the Group, as part of its NPE strategy plan, initiated a structured process for the disposal of a portfolio of secured non-performing retail exposures of gross carrying amount of ca. € 126 million. As at the reporting date, given the Management's commitment to the abovementioned portfolio's disposal plan that is expected to be completed by the end of 2026, the Group classified the respective loans as held for sale. Moreover, in accordance with the Group's accounting policy for the impairment of financial assets, the Group remeasured the portfolio's expected credit losses by reference to the estimated selling price and recognized an impairment loss of ca. € 47 million.
As at 31 December 2025, the carrying amount of the aforementioned loan portfolio reached € 61 million, comprising loans with gross carrying amount of € 126 million, which carried an impairment allowance of € 65 million.
‌Project "Wave"
In the context of the Group's initiatives for the optimization of its regulatory capital, In December 2025, the Bank proceeded with the execution of the upsize of the existing ("Wave III") synthetic risk transfer transaction referencing shipping loans (Project "Wave III Upsize" or "Transaction"). The Transaction provides credit protection over the mezzanine loss in the form of a financial guarantee and is actually an upsize of the original non disclosed reference portfolio of Shipping loan exposures of USD 1.68 billion (closed on 22 December 2022) to USD 2 billion. In order to upsize the reference portfolio to a total USD 2.0 billion, Credit Linked Notes (CLN) of USD 240 million, due 2033, were issued in place of the existing CLNs.
‌Corporate actions in relation to Hellenic Bank group
Hellenic Bank Public Company Ltd ("Hellenic Bank"), a financial institution based in Cyprus was accounted for as a Group's
associate under the equity method from April 2023 until June 2024.
In June 2024, the Bank acquired an additional 26.3% holding in Hellenic Bank and also announced, pursuant to the Takeover Bids Law of 2007 of the Republic of Cyprus ("Law"), the submission of a Mandatory Takeover Bid to all shareholders of Hellenic Bank for the acquisition of up to 100% of its issued share capital. The acceptance period for the Mandatory Takeover Bid expired on 30 July 2024 and the Bank acquired control over Hellenic Bank group within July, despite being the holder of 55.48% of Hellenic Bank's shares as at 30 June 2024. Accordingly, Hellenic Bank and its subsidiaries were included in the Company's consolidated financial statements from the beginning of the third quarter of 2024. The total percentage of acceptance of the Takeover Bid reached 0.481%, giving Eurobank total participation of 55.962% in the issued share capital of Hellenic Bank.
Moreover, in November 2024, the Bank announced that it has entered into share purchase agreements with certain shareholders of the Hellenic Bank, pursuant to which, it has agreed to acquire an additional total holding of 37.51% in the entity.
On 11 February 2025 after the receipt of the relevant regulatory approvals, the acquisition of a total 37.51% stake in Hellenic Bank, was completed resulting in the Bank's total holding in Hellenic Bank at 93.47%. Following that and pursuant to the provisions of the Takeover Bids Law in Cyprus, the Bank also announced the submission of a Mandatory Takeover Bid to the shareholders of Hellenic Bank for the acquisition of up to 100% of the issued share capital of Hellenic Bank.
On 25 April 2025, the Bank announced that the total percentage of acceptance of the Takeover Bid reached 4.525%, resulting in the Bank's total participation of 97.994% in the issued share capital of Hellenic Bank. Moreover, on 28 April 2025, the Bank applied to the Cyprus Securities and Exchange Commission for the exercise of the Squeeze Out right provided by Article 36 of the Takeover Bids Law, for the acquisition of the remaining shares of Hellenic Bank.
On 11 June 2025, the Bank announced the completion of the Squeeze Out procedure. It acquired the remaining 8,279,967 shares of Hellenic Bank, representing 2.006% of its issued share capital. Following this transaction, the Bank's holding in the company's share capital reached 100%.
As of the second quarter of 2025, the fair value exercise performed by the Group to measure the identifiable assets acquired and liabilities incurred from the acquisition of Hellenic Bank has been completed, without any significant differences identified, compared to the acquisition values that were presented in the consolidated financial statements for the year ended 31 December 2024. Moreover, from 1 January 2025, the fair value adjustments that were previously included on a provisional basis within the balance sheet lines 'Other assets' and 'Other liabilities', are presented to the respective balance sheet lines they relate to.
For further details, please refer to Consolidated Financial Statements, Note 23.3.
‌Acquisition of CNP Cyprus Insurance Holdings Limited
On 16 April 2025, Hellenic Bank (currently Eurobank Limited) announced that following the receipt of all relevant regulatory approvals, the acquisition of CNP Cyprus Insurance Holdings Limited from CNP Assurances (the "Transaction") was completed, with a total consideration of € 182 million. As of May 2025, the acquired entity has been renamed ERB Cyprus Insurance Holdings Limited.
The transaction is in line with Eurobank's strategic objective to expand in the Cypriot insurance market. The acquired entity's subsidiaries, hold a leading position in Cyprus in the insurance sector and offer life and general insurance products and services through a large network of independent agents. The Transaction is expected to further expand and strengthen the existing position of Eurobank Limited in the insurance market, increasing significantly its market share in the life and general insurance sectors.
The results of the former CNP Cyprus subgroup were incorporated in the Group's financial statements prospectively, as of 1 April 2025.
For prudential purposes, the aforementioned companies are accounted for as Group's associates and are consolidated under the equity method.
For further details, please refer to Consolidated Financial Statements, Note 23.4.
‌Merger process between Eurobank Holdings and Eurobank S.A.
In respect of the merger process between Eurobank Ergasias Services and Holdings S.A. and Eurobank S.A., on 30 April 2025, the Board of Directors of both companies approved the draft merger agreement. On 19 May 2025, the companies announced the completion of the publicity formalities for the Draft Merger Agreement, pursuant to which Eurobank S.A. will absorb Eurobank Holdings, in accordance with the provisions of the applicable laws. In addition, on 22 October 2025, the General Meeting of Eurobank S.A. approved the above merger.
On 12 December 2025, following the approvals granted by the Extraordinary General Meetings of the shareholders of both Companies and the receipt of all necessary permits and approvals from the competent authorities, Eurobank announced that the merger had been completed.
For further details, please refer to Consolidated Financial Statements, Note 23.1.
‌ Agreement with Fairfax for the acquisition of Eurolife FFH Life Insurance and the partial disposal of ERB Asfalistiki Ltd
On 13 October 2025, Eurobank Holdings and the Bank, announced that Eurobank Holdings has signed a term sheet with Fairfax Financial Holdings Limited ("Fairfax") pursuant to which Eurobank shall acquire 80% of the life insurance business ("Eurolife Life") (the Transaction) for a cash consideration of € 813 million. Following this acquisition, Eurobank will hold 100% of Eurolife Life and will retain its 20% interest in Eurolife Holdings' general insurance business ("Eurolife General Insurance").
In addition to the aforementioned Transaction, Fairfax shall procure that certain affiliates of Fairfax will acquire 45% of the share capital of ERB Asfalistiki ("ERBA"), the non-life (property and casualty) insurance company of Eurobank Limited in Cyprus, for a cash consideration of € 59 million. Fairfax will also have the right to acquire the remaining 55% of the share capital of ERBA over time. This strategic partnership will allow both companies to combine their strengths in underwriting, risk management, and product development, driving greater operational efficiency and unlocking new market opportunities in Greece and Cyprus.
The signing of both share purchase agreements is expected within the first quarter of 2026, whilst their completion within the second quarter of 2026 is subject to the required approvals from the relevant authorities and the process for related party transactions.
For further details, please refer to Consolidated Financial Statements, Note 23.2.
‌Dividends/Shareholders' remuneration
On 29 April 2025, the Company received the approval from the ECB to remunerate its shareholders with an amount of € 674 million for the financial year 2024, with a combination of cash and share buyback, corresponding to a 50% payout ratio of the Group's net profit for 2024 excluding the gain on acquisition of a shareholding in Hellenic Bank of € 99.5 million.
In May 2025, the Bank, further to the distribution of € 240 million in December 2024, proceeded with the distribution of an additional amount of € 405 million from its non-mandatory reserves, as part of the Bank's overall contribution to its sole shareholder, Eurobank Holdings, in order to enable the latter to remunerate its shareholders out of the profits for the financial year 2024.
In October 2025, the BoD of Eurobank Holdings approved, in accordance with the provisions of paragraph 3 of article 162 of Law 4548/ 2018 and in line with its shareholders' remuneration policy, the distribution of an interim cash dividend of
€ 170 million for the financial year 2025 from its non-mandatory reserves. Eurobank Holdings obtained the necessary approval from the ECB in late October and proceeded with the payment of the interim dividend to its shareholders on 12 November 2025.
Based on the Group's financial performance for the financial year 2025, the Bank intends to remunerate its shareholders with a total amount of € 717 million, of which € 170 million has already been distributed in the form of an interim dividend, as noted above. This corresponds to a 55% payout ratio of the Group's net profit for 2025 less the € 58 million gain on acquisition of the CNP Cyprus subgroup and is subject to approval of the Annual General Meeting (AGM) of its shareholders and the regulatory authorities. The final remuneration will be delivered through a combination of a cash dividend and a share buyback programme.
For further details, please refer to Consolidated Financial Statements, Note 39.
‌Additional Tier 1 capital instruments
On 4 June 2025, Eurobank Holdings issued fixed rate reset Additional Tier 1 perpetual contingent temporary write-down notes (the "Notes") of nominal value € 500 million. On the same date, the Bank issued notes of equivalent terms, which are held by Eurobank Holdings until its merger with the Bank in December 2025. Upon completion of the merger, these notes were cancelled, and the Bank assumed the corresponding Notes held by third parties. The Notes, subject to their terms and conditions, are redeemable in full at the Bank's sole and full discretion on any interest payment date falling on or after 4 June 2031 (the first reset date) or at any time following the occurrence of certain events. They bear non-cumulative interest, which is cancellable subject to conditions, at a fixed rate of 6.625% per annum until the first reset date, and thereafter at a reset rate based on the aggregate of 5-year mid-swap rate plus a margin of 445.4 bps. The interest is payable semi-annually in arrears, commencing on 4 December 2025.
On 10 November 2025, Eurobank Holdings issued fixed rate reset Additional Tier 1 perpetual contingent temporary write down notes (the "Notes" - second issuance) with a nominal value of € 600 million. On the same date, the Bank issued notes of equivalent terms, which were held by Eurobank Holdings until its merger with the Bank in December 2025. Upon completion of the merger, these notes were cancelled, and the Bank assumed the corresponding Notes held by third parties. The said Notes are callable by the Bank, subject to their terms and conditions, on any interest payment date falling on or after 10 November 2033 and bear non-cumulative interest at a fixed rate of 6.250% per annum until the first reset
date, and thereafter at a reset rate based on the aggregate of 5-year mid-swap rate plus a margin of 379 bps, payable semi-annually in arrears, commencing on 10 May 2026.
The issued Notes are listed on the Euro MTF market of the Luxembourg Stock Exchange.
Based on their terms, such as the fully discretionary and non-cumulative nature of interest, perpetual maturity, and loss-absorbing features that relate to specific regulatory requirements or trigger events, the Notes have been classified as equity instruments with coupon payments, if any, to be recognized as dividends in accordance with the principles of IAS
32. The Notes also qualify as Additional Tier 1 capital instruments under the CRR. For the year ended 31 December 2025, the coupon payment to AT1 capital holders amounted to € 16.5 million (€ 12 million after tax).
The issuances are in line with the Group's strategy to further optimize its capital structure and enhance its capacity to support future strategic initiatives.
Further information is available on the Company's website.
‌Tier 2 Capital instruments
In January 2018, Eurobank Ergasias S.A. issued Tier 2 capital instruments of face value of € 950 million, in replacement of the preference shares which had been issued in the context of the first stream of Hellenic Republic's plan to support liquidity in the Greek economy under Law 3723/2008. The aforementioned instruments had a maturity of ten years (until 17 January 2028) and paid fixed nominal interest rate of 6.41%, payable semi-annually. In September 2025 Eurobank Holdings proceeded with the early redemption of the above Tier 2 capital instruments of face value of € 950 million.
On 30 November 2022, the Company announced the issuance of a € 300 million subordinated Tier 2 debt instrument which matures in December 2032, is callable in December 2027 offering a coupon of 10% per annum and is listed on the Luxembourg Stock Exchange's Euro MTF market. On the same date, the Bank issued a subordinated instrument of equivalent terms, held by the Company.
On 19 January 2024, the Company announced the issuance of a € 300 million subordinated Tier 2 debt instrument which matures in April 2034, is callable at par in April 2029 offering a coupon of 6.25% per annum and is listed on the Luxembourg Stock Exchange's Euro MTF market. On the same date, the Bank issued a subordinated instrument of equivalent terms, held by the Company.
As at 31 December 2024, Tier 2 subordinated instruments include notes issued by Hellenic Bank with nominal value € 200 million, out of which € 33 million were held by Group entities. The notes were issued in March 2023 at par offering a coupon of 10.25% per annum, mature in 14 June 2033, are callable at par for a 3-month period commencing on 14 March 2028 and are listed on the Luxembourg Stock Exchange's Euro MTF market.
In January 2025, Eurobank Holdings announced that it has successfully priced the issuance of € 400 million subordinated Tier 2 debt instruments (New Instruments) which mature in April 2035, are callable at par from 30 January 2030 until 30 April 2030, offering a coupon of 4.25% per annum and are listed on the Luxembourg Stock Exchange's Euro MTF market. In addition, Eurobank Holdings announced an any-and-all exchange offers for Hellenic Bank's outstanding € 200 million Tier 2 notes, out of which € 33 million were held by Group entities, with additional Eurobank Holdings Tier 2 subordinated notes, issued under a single series and with same terms with the € 400 million subordinated notes. The offer period was set from 21 January 2025 until 27 January 2025.
On 28 January 2025, Eurobank Holdings announced that it has decided to accept all existing notes offered for exchange,
pursuant to the exchange offer, with nominal value of € 157 million. The nominal value of new instruments issued is €
188.5 million, which form a single series with the New Instruments with a combined aggregate nominal amount of € 589
million. As a result of the aforementioned exchange, the Group recognized a buy-back loss of approximately € 9 million, in the income statement line "Other income/(expenses)".
Following the merger of Eurobank Holdings with the Bank the latter assumed the above mentioned instruments.
The purpose of the Exchange Offer and the issuance of the Eurobank Holdings subordinated notes is to optimize the
regulatory efficiency of Eurobank Holdings' capital base while the proceeds will be used for general financing purposes.
In January 2026, the Bank announced that it has successfully completed the pricing of € 400 million subordinated Tier II debt instruments which mature in April 2037, are callable at par from 29 January 2032 until 29 April 2032, offering a coupon of 4.125% per annum and are listed on the Luxembourg Stock Exchange's Euro MTF market. The proceeds from the issues will support Eurobank Group's strategy to ensure ongoing compliance with its MREL requirements and will be used for Eurobank's general funding purposes.
‌Regulatory framework
The general Basel IV regulatory framework is structured around three mutually reinforcing pillars:
- Pillar 1 defines the minimum regulatory capital requirements, based on principles, rules and methodologies specifying and measuring credit, market and operational risk. These requirements are covered by regulatory own funds, according to the rules and specifications of CRR. The Basel IV revisions introduce substantial enhancements to Pillar 1, aiming to improve the consistency and comparability of risk-weighted asset calculations.
- Pillar 2 addresses the internal processes for assessing overall capital and liquid asset holdings are adequate in relation to risk profile (Internal Capital Adequacy Assessment Process - ICAAP and Internal Liquidity Assessment Process -ILAAP). Moreover, Pillar 2 introduces the Supervisory Review & Evaluation Process (SREP), which assesses the risks banks face and checks that banks are equipped to manage those risks properly. The Basel IV framework indirectly reinforces Pillar 2 by elevating supervisory expectations regarding model governance, stress testing practices, and the integration of revised risk metrics into ICAAP methodologies.
- Pillar 3 intends to enhance market discipline by developing a set of quantitative and qualitative disclosure requirements, which allow market participants to assess key pieces of information on the scope of application, capital, risk exposures, risk assessment processes and hence the capital adequacy and the internal liquidity adequacy of credit institutions. Basel IV further strengthens Pillar 3 by expanding transparency obligations enhancing comparability and accountability across institutions.
  According to the CRD IV provisions:
- Minimum Common equity Tier 1 (CET1) ratio: 4.5%;
- Minimum Tier 1 ratio: 6%; and
- Minimum Total Capital ratio: 8%.
  Furthermore, banks are required to maintain in addition to the above minimum ratios, a Capital Conservation Buffer (CCB) equal to 2.5% of their total risk exposure amount calculated.
  As a result, the minimum ratios which must be met, including the CCB are:
- Minimum CET1 capital ratio 7%; and
- Total capital adequacy ratio 10.5%.
Additional capital buffers that CRD IV introduces are the following:
1. Countercyclical buffer (CCyB)
  The purpose of this buffer is to counteract the effects of the economic cycle on banks' lending activity, thus making the supply of credit less volatile and possibly even reduce the probability of credit bubbles or crunches. Credit institutions may be required under the CRD IV to build up an additional buffer up to 2.5% of CET1 capital during periods of excess credit growth, according to national circumstances. According to BoG Executive Committee Act No 202/1/11.03.2022, which lays down the procedure for applying the CCyB rate in Greece and the relevant calibration methodology, BoG assesses, on a quarterly basis, the intensity of cyclical systemic risk and the appropriateness of the CCyB rate, taking into account the standardised credit-to-GDP (Gross Domestic Product) gap, the buffer guide and, in particular, additional indicators for monitoring the build-up of cyclical systemic risk.
  Under Executive Committee Act 235/2/07.10.2024, the CCyB rate that credit institutions are required to maintain is 0.25% for the period from 1.10.2025 to 30.09.2026. From 1 October 2026, under Executive Committee Act 248/1/06.10.2025, the BoG has decided to set the CCyB rate for Greece at 0.5%, i.e. to the level of the target positive neutral CCyB rate, applicable. The positive neutral CCyB is activated at an early stage in the economic and financial cycle, when cyclical systemic risks are neither elevated nor subdued.
2. Global systemic institution buffer
  CRD IV includes a mandatory Systemic Risk Buffer (SyRB) of CET1 for banks that are identified by the relevant authority as globally systemically important, which is not applicable to Greek banks.
3. Other systemically important institutions buffer (O-SIIs)
  On 22 December 2022, ECB published the November 2022 Governing Council statement on macroprudential policies regarding the revised floor methodology for assessing capital buffers for O-SIIs. The revised floor methodology increases the number of buckets to which O-SIIs are allocated from four to six and raises the floor level for the highest bucket to 1.50% while keeping the floor of the lowest bucket unchanged at 0.25% The ECB uses the revised floor methodology to assess O-SII buffers proposed by national authorities as of 1 January 2024.
  From 1 January 2024, the O-SII buffer for the Group increased to 1.25% (from 1.00% in 2023), in accordance with the Executive Committee Act 221/1/17.10.2023 of BoG, following the above change in the floor methodology. Based on the Executive Committee Act 234/23.09.2024, BoG decided that would keep O-SIIs buffer for the Group unchanged at 1.25% for 2025. On 15 September 2025, BoG published the Executive Act 246/15.9.2025 for the determination of O-SIIs and the O-SII buffer thereof for 2026. BoG has decided that it would keep O-SIIs buffer for the Group unchanged at 1.25% for 2026 with effect from 1 January 2026.
4. Systemic Risk Buffer (SyRB)
According to article 133 of CRD, SyRB can be used to address a broad range of systemic risks, which may also stem from exposures to specific sectors, as long as they are not already covered by the Capital Requirements Regulation or by the CCyB or the G-SII/O-SII buffers. The level of the SyRB may vary across institutions or sets of institutions as well as across subsets of exposures. There is no maximum limit for this buffer. Competent authority is in charge of setting the SyRB and of identifying the sets of institutions to which it applies. According to BoG Executive Committee Act No 197/2/21.12.2021, BoG decided to adopt the European Banking Authority (EBA) guidelines on the appropriate subsets of exposures to which the competent authority or the designated authority may apply a SyRB based on paragraph 5 of article 133 of CRD.
The SyRB consists of CET1 capital and is expressed as a percentage of the total risk exposure amount of credit institutions. It can be set in multiples of 0.5% and may exceed 3% provided that the relevant procedures laid down in EU law are respected. The BoG has set neither a sectoral nor a broader SyRB rate as yet.
1. Regulatory Developments
  On 20 December 2023, the EBA published its final draft ITS on amendments to disclosure and reporting of the minimum requirement for MREL and TLAC. These amendments reflect the new requirement to deduct investments in eligible liabilities instruments of entities belonging to the same resolution group, the so called 'daisy chain' framework, and other
  changes to the prudential framework. The amendments apply for the reference date as of end-June 2024 for banks subject to the obligation to meet the final MREL target.
  On 9 April 2024, EBA published its final Guidelines on the resubmission of historical data under the EBA reporting framework. The Guidelines provide a common approach to the resubmission of historical data by the financial institutions to the competent and resolution authorities in case of errors, inaccuracies or other changes in the data reported, in accordance with the supervisory and resolution reporting framework developed by the EBA.
  The Guidelines set out a general approach for the resubmission of historical data with the aim of limiting the number of historical periods. Under this general approach, financial institutions are expected to resubmit the corrected data for the current reporting date, and historical data for past reference dates, going back at least one calendar year (except for the data with monthly reporting frequency). The Guidelines also clarify the general circumstances under which the resubmission may not be required. The new precision requirement is applicable from 1 April 2025.
  On 19 June 2024, the following were published in the Official Journal of the EU:
  - Directive (EU) 2024/1619 of the European Parliament and of the Council of 31 May 2024 amending the Capital Requirements Directive IV as regards supervisory powers, sanctions, third-country branches, and environmental, social and governance risks (CRD 6).
  - Regulation (EU) 2024/1623 of the European Parliament and of the Council of 31 May 2024 amending the Capital Requirements Regulation as regards requirements for credit risk, credit valuation adjustment risk, operational risk, market risk and the output floor (CRR 3).
    Member States will have 18 months to transpose CRD 6 into national legislation, whilst CRR 3 applied from 1 January 2025.
    In addition, following its publication in the Official Journal of the European Union, the Commission Implementing Regulation (EU) 2024/1872 of 1 July 2024, amended the implementing technical standards laid down in Implementing Regulation (EU) 2016/1799 as regards the mapping tables specifying the correspondence between the credit risk assessments of external credit assessment institutions and the credit quality steps set out in Regulation (EU) No 575/2013 of the European Parliament and of the Council.
    On 8 January 2025, EBA published the final guidelines on the management of environmental, social and governance (ESG) risks. The guidelines specify requirements regarding the internal processes and ESG risk management arrangements that institutions should have in place in accordance with the Capital Requirements Directive (CRD6). These guidelines, which will apply from 11 January 2026, establish requirements for institutions' internal processes and ESG risk management arrangements, including embedding ESG risks into their risk appetite, internal controls, and the ICAAP, as well as developing specific transition plans to manage the impact of ESG factors over short, medium, and long-term horizons.
    On 12 February 2025, EBA published its final draft ITS on the Pillar 3 data hub for large and other institutions, which will centralise prudential disclosures by institutions through a single electronic access point on the EBA website. This project is part of the Banking Package laid down in the CRR3 and CRD6. The ITS detail the IT solutions and processes to be followed by large and other institutions when submitting their respective Pillar 3 disclosures. This includes the IT solutions to be used, the data exchange formats to be considered and the technical validations to be performed by the EBA.
    On 22 May 2025, EBA published an onboarding plan for large and other institutions, setting out the steps required for accessing and submitting information to the new Pillar 3 Data Hub (P3DH) - the EBA's centralised platform for public disclosures under CRR3.
    The onboarding plan outlines the procedural steps that institutions need to follow to ensure timely and accurate submissions of Pillar 3 information. The onboarding plan provides a step-by-step guide for the identification of institutions and to give them access to the EBA's EUCLID Regulatory Reporting Platform, through which the Pillar 3 data will be
    submitted. It also spells out the timeline for the process, which will follow a phased-in approach. This means that institutions will be able to continue to fulfil their Pillar 3 disclosure obligations during 2025 as usual, and the submissions to the P3DH will occur only at a later stage. This approach will give institutions enough time to complete the onboarding process and align their internal processes, without impacting the compliance with the CRR requirements. P3DH information is available to the public from December 2025.
    On 22 May 2025, EBA launched a public consultation on proposed amendments to the European Commission's Implementing Regulation on Pillar 3 disclosures under the CRR3. The proposal specifies enhanced and proportionate disclosure requirements related to ESG-related risks, equity exposures and aggregate exposure to shadow banking entities. It also implements the new codes for the statistical classification of economic activities in the EU (NACE). The consultation paper was published for a three-month consultation period i.e. until 22 August 2025.
    On 16 June 2025, EBA published three final draft technical standards that are crucial for the implementation of the EU Banking Package and will allow supervisors to monitor institutions' compliance. In particular, the EBA is publishing the following Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS):
  - RTS concerning the calculation and adjustments of the Business Indicator (BI), which is central to the standardised and harmonised application of the operational risk capital requirements.
  - ITS on the mapping to FINREP, which will ensure consistency and reduce implementation, administrative and operational costs.
  - Amending ITS on operational risk reporting, which will keep the supervisory reporting framework relevant, meaningful and aligned with the amended regulation.
    After the submission of the final draft ITS to the Commission for adoption, the EBA published on the website the IT tools, including binding instructions. The EBA has published a technical package, including the Data Point Model (DPM), validation rules and taxonomy, that shall be used by institutions to submit this supervisory reporting information to supervisors. The first applicable reference date for reporting under the draft ITS is 31 March 2026.
    On 5 November 2025, EBA published its final guidelines on environmental scenario analysis, clarifying supervisory expectations on how institutions should incorporate physical and transition climate risks into both short-term stress-testing exercises and longer-term resilience assessments. The Guidelines complement the broader ESG risk management framework and set out high-level criteria for selecting scenarios, identifying transmission channels and integrating the results into risk management and strategic planning. The guidelines will apply from 1 January 2027.
    On 3 December 2024, the SRB published a consultation paper on the 'Operational guidance for banks on resolvability self-assessment', outlining the capabilities that banks are expected to maintain over time in order to be deemed resolvable. The final document was published on 7 August 2025. On 17 March 2025, the SRB launched a public consultation on 'Operational Guidance on Resolvability Testing for Banks' that seeks to promote a harmonized approach for the implementation of the multi-annual testing programme across the main resolvability dimensions. The final document was published on 26 September 2025. Lastly, on 2 April 2025, the SRB started a public consultation on 'Expectations on Valuation Capabilities' that introduces an updated, comprehensive set of information necessary for performing valuations, the minimum functionalities expected for Data Repositories for resolution, as well as establishing expectations on the content and structure of the valuation playbooks (consultation ended on 2 July 2025).
    On 4 November 2025, EBA released several updates to ensure consistency with the latest regulatory and reporting framework developments. These include an updated Mapping Tool reflecting recent amendments to the Pillar 3 disclosure and supervisory reporting frameworks.
‌Supervisory Review and Evaluation Process (SREP)
Since November 2014, within the context of the SSM, the ECB has been responsible for the supervision of the largest and most significant banks located in the euro area and other EU countries wishing to participate in the SSM (e.g. Bulgaria). National supervisory authorities in close cooperation with the ECB, remain responsible for the supervision of the less significant banks.
Among others, the ECB conducts annually a Supervisory Review and Evaluation Process (SREP) assessment, in order to assess banks' risk profiles and determine quantitative and qualitative requirements for banks. The key purpose of SREP is to ensure that banks have adequate arrangements, strategies, processes and mechanisms, as well as capital and liquidity to ensure a sound management and coverage of their risks, to which they are or might be exposed, including those revealed by stress testing and risks the institution may pose to the financial system. The methodology followed provides for a holistic and forward-looking assessment of the viability of the supervised institution.
The common SREP framework is built around:
- a business model and profitability assessment;
- an internal governance and risk management assessment;
- an assessment of risks to capital on a risk-specific basis (i.e. credit risk, market risk, operational risk, interest rate risk in the banking book (IRRBB) and credit spread risk in the banking book CSRBB), of the institution's internal capital adequacy assessment process (ICAAP) and of capital adequacy; and
- an assessment of risks to liquidity and funding on a risk-specific basis (i.e. short-term funding, long-term funding and banks' internally identified risks in normal scenarios and under stressed conditions), of the banks' internal liquidity adequacy assessment process (ILAAP) and of the adequacy of liquidity.
  On the basis of the ECB's assessment of the Groups' risk profile (through SREP), the following apply:
- The minimum required CET1 ratio and the minimum required Total capital adequacy ratio (Total SREP Capital Requirement or TSCR) that the Group must meet at all times;
- The Pillar 2 Requirement (P2R) is a bank specific capital requirement included in the TSCR, which typically covers risks which are underestimated or not covered by the minimum capital requirements (Pillar 1). The P2R is binding and its breach can have direct legal consequences. The P2R is determined via the SREP.
- The Overall Capital Requirement (OCR), which includes, in addition to the TSCR, the combined buffer requirement, and which in case of breach, leads to the trigger of the Maximum Distributable Amount (MDA) restrictions; and
- The Pillar 2 Guidance (P2G), which is an additional capital buffer recommended by the ECB to be kept at consolidated level over and above the OCR. The P2G indicates the level of capital that the ECB expects the Group to maintain in order to ensure it can absorb potential losses resulting from adverse scenarios.
Capital Stack
Pillar 2 Guidance Systemic Buffers Countercyclical Buffer
Capital Conservation Buffer
OCR
Pillar 2 Requirements
TSCR
Pillar 1 (min requirements)
1. Requirements for excessive Leverage
  Apart from the capital requirements, a bank may be subject to a Pillar 2 requirement (P2R) with regard to the leverage ratio, in addition to the 3% minimum requirement, if ECB determines that the bank has an elevated risk of excessive leverage. This is intended to capture contingent leverage risk originating from a bank extensively using derivatives, securities financing transactions and off-balance sheet items, as well as engaging in regulatory arbitrage and providing step-in support. Similarly, to the P2R for capital requirements, the leverage ratio Pillar 2 Requirement is legally binding.
  Additionally, a bank may be subject to leverage ratio Pillar 2 Guidance (P2G), which is a bank-specific recommendation that indicates the level of capital a bank has to maintain in addition to their binding leverage ratio requirements. Based on the latest SREP Decision, the Group is not subject to a P2R or P2G with regard to the leverage ratio.

‌Implementation of Capital Adequacy framework

Credit risk
The Group is applying since Q1 2023 the Common Reports requirements of EU Regulation 575/2013 ('CRR') under Title II, Chapter 2 ('Standardised approach') and its subsequent amendments for all credit risk exposures. The Group utilizes its advanced risk management capabilities for internal purposes such as credit approvals, risk adjusted pricing, IFRS9 provisions where applicable and risk monitoring.
Market risk
The Bank uses its own internal Value at Risk (VaR) model to calculate capital requirements for market risk in its trading book, for the Bank's activities in Greece. The Bank received the official validation of its model for market risk by the BoG in July 2005. The model is subject to periodic review by the regulator.
In 2011, the Bank updated its models and systems in order to fully comply with the BoG Governor's Act 2646/2011 for the trading book capital. The Bank calculates the capital for stressed VaR and Incremental Risk Charge (IRC) since 31.12.2011.
For the measurement of market risk exposure and the calculation of capital requirements for the Bank's subsidiaries in Greece and in International operations, the Standardised Approach (STD) is applied.
Furthermore, the Bank calculates and monitors the market risk of the banking book for its operations in Greece and international subsidiaries on a daily basis using the internal VaR model, further supplemented by sensitivity analysis and stress testing, historical simulation and other market risk metrics (e.g., expected shortfall).
Interest Rate risk in the Banking Book (IRRBB) and Credit Spread risk in the Banking Book (CSRBB)
Interest Rate Risk in the Banking Book (IRRBB) is part of the SREP and refers to the current or prospective risk to the Bank's capital and to its earnings, arising from the impact of adverse movements in interest rates in its banking book. The Bank has updated its infrastructure to reflect changes in the market and supervisory practices so as to effectively manage and control such risks. This includes the implementation of a specialised software, so as to identify, measure and monitor IRRBB.
The established software tools are under continuous evolution in order to cover any part of the Bank's balance sheet. They offer a wide range of modelling capabilities for demand deposits, pre-payable loans, mortgage pipelines, revolving facilities and off-balance sheet items.
The Bank uses sensitivity analysis to monitor risk on earnings (NII) and on economic value of equity (EVE) on a continuous basis, covering both supervisory and internal monitoring reporting needs.
In addition to the above, the Bank in response to the regulatory developments and requirements (EBA/GL/2022/14), has further enhanced its infrastructure, governance and limit structure accordingly, so as to measure and monitor its CSRBB.

Operational risk

‌Basel IV introduces a single Standardised Approach for operational risk, replacing previous methods and simplifying the framework. Capital requirements are driven solely by the Business Indicator, which reflects the scale of an institution's activities based on selected income and expense components averaged over three years. Following the transition to the new framework, the Group applies this methodology for calculating its operational risk capital requirements from 2025 onwards.1.17 2025 EU - wide stress test

The EU-wide stress test exercise was carried out on a sample of banks covering broadly 75% of the banking sector in the euro area, each non-euro area EU Member State and Norway, as expressed in terms of total consolidated assets as of end 2023. To be included in the sample, banks have to have a minimum of € 30 billion total assets.

As per the 2025 EU-Wide Stress Test Methodological Note (published on 11 November 2024, footnote 92), Eurobank Holdings has been excluded from the sample of the EU-wide stress test exercise because of a major acquisition (Hellenic Bank).

‌SSM 2026 Geopolitical Reverse Stress Test
The European Central Bank (ECB) has conducted in 2026 a geopolitical risk reverse stress test on 110 directly supervised banks, including Eurobank S.A. The stress test was launched on 16 December 2025, while a publication summarizing aggregate findings will be published at the end of July 2026. No bank individual results will be published.
In line with previous ECB thematic stress tests conducted to comply with Article 100 of the Capital Requirements Directive (CRD), the geopolitical risk reverse stress test is not intended to have any implications for Pillar 2 Guidance (P2G).
The outcome will be used to inform and complement the Supervisory Review and Evaluation Process (SREP) in a qualitative way and in line with the broader 2026 ICAAP.
‌Scope of Pillar 3
The purpose of Pillar 3 report is to provide updated information on the Group's risk management practices, risk assessment processes and regulatory capital adequacy ratios.
Pillar 3 disclosures consist of both qualitative and quantitative information and are provided on a consolidated basis. They have been prepared in accordance with Part 8 of the Capital Requirements Regulation within CRD IV (Regulation 2013/575/EU) and according to the prudential consolidation framework, which is described in the following section.
In December 2016, EBA published EBA/GL/2016/11 guidelines on revised Pillar 3 disclosures requirements to improve the consistency and comparability of institutions' regulatory disclosures. These guidelines harmonised the frequency of disclosures and updated the list of requirements to be considered for more frequent disclosures.
According to the above guidelines, for templates that require the disclosure for current and previous reporting periods, the previous reporting period is always referred to as the last data disclosed according to the frequency of the template. When the disclosure is being reported for the first time, the data of the previous period is not required.
In December 2018 EBA published EBA/GL/2018/10 guidelines, which include enhanced disclosure formats for credit institutions for disclosures related to non-performing exposures, forborne exposures and foreclosed assets. Some templates are applicable to significant credit institutions that have a gross NPL ratio of 5% or above. Considering that Group's NPEs ratio remained consistently below 5% for five consecutive quarters, templates CQ2, CQ6, CQ8 and CR2a of the EBA Disclosure ITS are not published from 31 December 2024 and onwards.
In June 2019, the EP and the Council published the Regulation (EU) No 876/2019 or CRR2 amending the CRR, regarding among others the reporting and disclosure framework. The CRR2 rules follow a phased implementation with significant elements entering into force in 2021.
In June 2020, EBA published new ITS on public disclosures by institutions and revised final draft ITS on supervisory reporting that implements changes introduced in the revised CRR2 and the Prudential Backstop Regulation. The two ITS aim to promote market discipline through enhanced and comparable public disclosures for stakeholders and to keep the reporting requirements in line with the evolving needs for Supervisory Authorities' risk assessments.
On 6 August 2021, EBA published an updated tool, which specifies the mapping between quantitative disclosure data points and the relevant supervisory reporting data points. This tool aims at facilitating institutions' compliance with disclosure requirements and improving the consistency and quality of the information disclosed.
On 24 May 2022, EBA published an updated mapping between quantitative disclosure data points and the relevant supervisory reporting data points. The amendments mainly address issues raised by competent authorities and the industry. The updated mapping applies to the reporting framework 3.0 and the ITS on institutions' Pillar 3 public disclosures.
On 19 December 2022, the Commission Implementing Regulation (EU) 2022/2453 of 30 November 2022 was published in the Official Journal. The ITS amending the ITS laid down in Implementing Regulation (EU) 2021/637 as regards the uniform disclosure formats for the disclosure of ESG risks. This Implementing Regulation was entered into force on 8 January 2023.
On 20 June 2024, EBA published a new draft ITS on Pillar 3 framework in order to cover all disclosures requirements for institutions under the new legislative CRR3 which is applicable from 01 January 2025. As the relevant disclosures are published for the first time in their entirety, the data of the previous periods are not reported as the templates are not comparable.
‌Pillar 3 Written attestation
Pursuant to article 431(3) of Part Eight of CCR2, the Group has issued an internal approved by the BoD "Consolidated Pillar 3 Disclosures Policy" in order to ensure consistent and continuous compliance with the Pillar 3 disclosures requirements, as these have been specified in the existing regulatory framework.
The Pillar 3 governance process ensures that both the Group's Management and the Board are given sufficient opportunity to debate and challenge the disclosures before their publication, hence, to examine that these have been subject to adequate verification, and they comply with applicable regulatory framework.
The information contained in the Pillar 3 Disclosures has been verified by the Audit Committee and was approved by the BoD on 29 April 2026 prior to their publication on the Group's website.
It should be noted that:
- data refers to the prudential (regulatory) scope of consolidation;
- the amounts reported are consistent with the recent submissions of the regulatory reporting for each period.
‌Location, timing and frequency of disclosures
Pillar 3 disclosures are provided on a quarterly basis in electronic format, after taking into consideration the relevant recommendation of EBA Guidelines 2016/11, which include the list of requirements to be considered for more frequent, than annual basis, disclosures.
Pillar 3 disclosures are provided with reference date (corresponding period) the close of the previous quarter and in conjunction with the date of publication of the financial statements. Equivalent disclosures made by the Group under accounting, listing or other requirements are deemed to constitute compliance with the requirements of the aforementioned Regulation (EU) No 575/2013 (Part Eight) taking into consideration any existing relevant implementing Regulations as well as the EBA guidelines.
Based on the internal "Consolidated Pillar 3 Disclosures Policy" the Group ensures consistent and continuous compliance with the Pillar 3 disclosures requirements. In addition, the Group puts in place and maintains internal processes, systems and controls to verify that the disclosures are appropriate and in compliance with the aforementioned regulatory framework.
Pillar 3 disclosures are a standalone document that provides a readily accessible source of prudential information for users and is available on a designated location on the Company's website https://www.eurobank.gr/en/group/investor-relations/oikonomika-apotelesmata-eurobank in chronological order and cover both quantitative and qualitative information.
Quantitative information, which is included in the Group's Consolidated Financial Statements, is also provided at the above location. In this way, the Company secures easy access of the market participants to continuous and complete information without cross-reference to other locations or media of communication.
Regarding the timing of disclosures, CRR clarifies that disclosures shall be published on the same date as the date on which the institution publishes its financial reports or as soon as possible thereafter. The Group's Pillar 3 disclosures report will be published in accordance with EBA expectations the latest, as follows:
- Year-end Pillar 3 reports (reference date December): by end-June, with the exception of the remuneration policies information that would be expected by end-August;
- Quarterly and Semi- annual Pillar 3 reports: by "reference date + 4 months".
‌EBA Pillar 3 Data Hub
The EBA Pillar 3 Data Hub (P3DH), established under CRR 3 (Regulation (EU) 2024/1623) and CRD 6 (Directive (EU) 2024/1619), constitutes a centralised digital platform aimed at enhancing the transparency, accessibility and comparability of prudential disclosures across EU credit institutions.
In accordance with the applicable regulatory framework, large and other relevant institutions are required to submit their Pillar 3 disclosures to the EBA in XBRL-CSV format starting from the reporting reference date of December 2025. The submitted information is published centrally by the EBA and made publicly available through the EBA Data Access Portal (EDAP).
Submissions are expected to take place on the same date as the publication of the financial statements or shortly thereafter, depending on the reporting frequency and the nature of the disclosures. Institutions may continue to publish the required prudential disclosures on their own websites. In this context, the Bank may also provide a reference or link to the EBA Data Access Portal, where the Pillar 3 information is available in a centralised manner.
‌Compliance with CRR
The Group operates as follows:
- Pillar 3 disclosures are provided on a consolidated basis;
- The data refers to the prudential (regulatory) scope of consolidation;
- The amounts reported are consistent with the submissions of the regulatory reporting for each period;
- The Group includes in its disclosures all information deemed necessary to provide users with a clear, complete and accurate view of the Group's structure, capital management, risk management system, unencumbered assets and remuneration policy and corporate governance principles. During this procedure the Bank also identifies information that is material, confidential and proprietary;
- Τhe Group has opted to present the full set of Pillar 3 disclosures in a separate document "Consolidated Pillar 3 Report", which is published at least annually on the Bank's website, in conjunction with the date of publication of its financial statements. The Remuneration and Corporate Governance disclosures are published as separate documents;
- The Group re-examines the extent and type of information provided at each disclosure date and revises its policy as necessary;
- The Group assesses the need to publish some or all disclosures more frequently than annually, taking into consideration factors such as scale of operations, range of activities, presence in different countries, involvement in different financial sectors, participation in international financial markets and payment, settlement and clearing systems and paying particular attention to information on own funds, capital requirements, risk exposure and other items prone to rapid change; and
- The Audit Committee of the Group is responsible to review and assess the process for the preparation of the Pillar 3 report, while the BoD of the Bank is responsible to approve it.
The aforementioned responsibilities are equivalent to those in respect of the Bank's Consolidated Financial Statements.
‌Governance arrangements
Eurobank is headed by a Board of Directors (Board or BoD) which is collectively responsible for the long-term success of the Bank. The Board exercises its responsibilities effectively and in accordance with the Greek legislation and international best practices, while its role is to provide entrepreneurial leadership to the Bank and its subsidiaries (Group) within a framework of prudent and effective controls which enables risk to be assessed and managed.
The Board is assisted in carrying out its duties by Board Committees. The Board delegates some of its responsibilities to the Board Committees, approves their composition and mandates and receives regular and ad hoc reports from them.
The Bank has adopted the Board Nomination Policy which sets out the guidelines and formal process for the identification, selection and nomination of candidates for the Board and ensures that the appointments are made: (a) in accordance with legal and regulatory requirements; (b) with due regard to the expectations of the major shareholders, and (c) on the basis of individual merit and ability, following a best practice process.
In addition, the Bank has adopted the Directors Diversity Policy which sets out the approach to diversity on the Board and it is in accordance with international best practices and the EU and Greek banking law provisions. According to this Policy, Nomination and Corporate Governance Committee's priority is to ensure that the Board continues to have strong leadership and the right mix of skills to deliver the business strategy. Within this context and in regard to the less represented gender in the Board, Nomination and Corporate Governance Committee ensures that at least 25% (rounded to the previous integer) of the Board is composed of members of the less represented gender, with a target to increase this representation to a minimum of 33% (rounded to the nearest integer) as soon as practicable, and in any case no later than mid 2026. This target aligns with legal and regulatory requirements and industry best practices and shall be maintained at all times, reflecting evolving legal frameworks and market trends. Additionally, if the Board includes three
(3) or more executive members, at least one (1) executive member of the less represented gender must be included in the aforementioned 33% percentage. Compliance with this requirement is expected upon the first, after mid 2026, expiration of a term or of the next term in case of one renewal or upon a replacement of an already serving executive member of the Board of Directors for any reason after mid 2026.
More information concerning the Corporate Governance Arrangements is also available in the Board of Director's Report, in the 2025 Annual Financial Report https://www.eurobank.gr/en/group/investor-relations/oikonomika-apotelesmata-eurobank/financial-year-2025.

‌Prudential versus accounting consolidation

The Pillar 3 disclosures are different from the disclosures presented in the Consolidated Financial Statements, which have been prepared in accordance with the International Financial Reporting Standards (IFRS) issued by the International Accounting Standards Board (IASB), as endorsed by the European Union (EU). This is mainly due to differences between the prudential consolidation and the accounting consolidation used by the Group. Following the changes introduced in the CRR, Article 18(7) has been amended in order to regulate the treatment of subsidiaries which are excluded from the scope of prudential consolidation since they are different from institutions. The Pillar 3 disclosures are based on disclosure requirements set out in Regulation EU 575/2013 (CRR) as amended and pertain to the conditions of the Group's prudential consolidation, which excludes insurance subsidiaries.

Accounting consolidation
The accounting consolidation of the Group is based on the International Financial Reporting Standards (IFRS) and specifically IFRS 10 Consolidated Financial Statements, IAS 28 Investments in Associates and Joint Ventures and IFRS 11 Joint Arrangements.
Subsidiaries are all entities controlled by the Group. The Group controls an entity when it is exposed, or has rights to, variable returns from its involvement with the entity and has the ability to affect those returns through its power over the entity. The Group consolidates an entity only when all the above three elements of control are present.
Power is considered to exist when the Group's existing rights give it the current ability to direct the relevant activities of the entity, i.e. the activities that significantly affect the entity's returns and the Group has the practical ability to exercise those rights. Power over the entity may arise from voting rights granted by equity instruments such as shares or, in other cases, may result from contractual arrangements.
Where voting rights are relevant, the Group is deemed to have control where it holds, directly or indirectly, more than half of the voting rights over an entity, unless there is evidence that another investor has the practical ability to unilaterally direct the relevant activities.
The Group may have power even when it holds less than a majority of the voting rights of the entity through a contractual arrangement with other vote holders, rights arising from other contractual arrangements, substantive potential voting rights, ownership of the largest block of voting rights in a situation where the remaining rights are widely dispersed ('de facto power'), or a combination of the above. In assessing whether the Group has de facto power, it considers all relevant facts and circumstances including the relative size of the Group's holding of voting rights and dispersions of holdings of other vote holders to determine whether the Group has the practical ability to direct the relevant activities.
The Group is exposed or has rights to variable returns from its involvement with an entity when these returns have the
potential to vary as a result of the entity's performance.
In assessing whether the Group has the ability to use its power to affect the amount of returns from its involvement with an entity, the Group determines whether in exercising its decision-making rights it is acting as an agent or as a principal. The Group acts as an agent when it is engaged to act on behalf and for the benefit of another party and as a result does not control an entity. Therefore, in such cases, the Group does not consolidate the entity. In making the above assessment, the Group considers the scope of its decision-making authority over the entity, the rights held by other parties, the remuneration to which the Group is entitled from its involvement and its exposure to variability of returns from other interests in that entity.
The Group has interests in certain entities which are structured so that voting rights are not the dominant factor in deciding who controls the entity, such as when any voting rights relate to administrative tasks only and the relevant activities are directed by means of contractual rights. In determining whether the Group has control over such structured entities, it considers the following factors:
- The purpose and design of the entity;
- Whether the Group has certain rights that give it the ability to direct the relevant activities of the entity unilaterally, as a result of existing contractual arrangements that give it the power to govern the entity and direct its activities;
- In case another entity is granted decision making rights, the Group assesses whether this entity acts as an agent of the Group or another investor;
- The existence of any special relationships with the entity; and
- The extent of the Group's exposure to variability of returns from its involvement with the entity, including its exposure in the most subordinated securitised notes issued by the entity as well as subordinated loans or other credit enhancements that may be granted to the entity, and if the Group has the power to affect such variability.
The Group reassesses whether it controls an entity if facts and circumstances indicate that there are changes to one or more elements of control. This includes circumstances in which the rights held by the Group and intended to be protective in nature become substantive upon a breach of a covenant or default on payments in a borrowing arrangement and lead to the Group having power over the investee.
Subsidiaries are fully consolidated from the date on which control is transferred to the Group and are no longer consolidated from the date that control ceases. Total comprehensive income is attributed to the owners of the parent and to the non-controlling interests even if this results in the non-controlling interests having a deficit balance.
Investments in joint ventures (the contractually agreed sharing of control of an arrangement, which exists only when decisions about the relevant activities require the unanimous consent of the parties sharing control and, under which, the parties have rights to the net assets of the arrangement) and investments in associates (investments in which the Group has a significant influence, but which it does not control) , are also part of the accounting consolidation scope, but are accounted for using the equity method.
Business combinations involving entities under common control
Pursuant to IAS 8 'Accounting Policies, Changes in Accounting Estimates and Errors', since business combinations between entities under common control are excluded from the scope of IFRS 3 'Business Combinations', such transactions are accounted for in the Group's financial statements by using the pooling of interests method (also known as merger accounting), with reference to the most recent pronouncements of other standard-setting bodies that use a similar conceptual framework and comply with the IFRSs general principles, as well as accepted industry practices.
Under the pooling of interests method, the Group incorporates the assets and liabilities of the acquiree at their pre-combination carrying amounts, as derived from the highest level of common control unless the substance of the transaction and the underlying facts and circumstances indicate a different value, without any fair value adjustments. Any difference between the cost of the transaction and the carrying amount of the net assets acquired is recorded in Group's equity.
The Group accounts for the cost of such business combinations at the fair value of the consideration given, being the amount of cash or shares issued or if that cannot be reliably measured, the consideration received.
Common control transactions that involve the formation of a new Group entity to effect a business combination by bringing together two or more previously uncombined businesses under the new Group entity are also accounted for by using the pooling of interests method.
Under a capital reorganization, the acquiring entity incorporates the assets and liabilities of the acquired entity at their carrying amounts, as presented in the books of that acquired entity, rather than those from the highest level of common control. Any difference between the cost of the transaction and the carrying amount of the net assets acquired is recognized in the equity of the new entity. Capital reorganization transactions do not have any impact on the Group's consolidated financial statements.
For further details, please refer to Consolidated Financial Statements, Note 2.2.1.

Prudential consolidation

The prudential consolidation applied for reporting to regulatory authorities follows the principles used for the accounting consolidation with the following difference: participation in insurance companies is excluded from prudential consolidation and are accounted for using the equity method.

According to CRD IV, holdings in insurance companies and financial institutions that the Bank has a significant investment, must be deducted from CET1 in case the total investment exceeds 10% of the aggregate amount of CET1. Amount, which is not deducted, is risk weighted by 250%.

The following table presents a list of the Group's subsidiaries at 31 December 2025 for which prudential consolidation is different compared to the accounting consolidation:

Table 1: Group's insurance subsidiaries

c & g

Name of the entity

Method of

accounting consolidation

Method of prudential consolidation

Description of the entity

Hellenic Bank Insurance Holding Ltd⁽¹⁾	Full consolidation	Equity consolidation	Insurance services
ERB Cyprus Insurance Holdings Ltd (2)	Full consolidation	Equity consolidation	Holding company
Cyprialife Greece Single Member S.A.(3)	Full consolidation	Equity consolidation	Life Insurance
ERB Cyprialife Ltd (3)	Full consolidation	Equity consolidation	Life Insurance
ERB Asfalistiki Ltd⁽²⁾	Full consolidation	Equity consolidation	General Insurance
Cyprialife Insurance Brokers Ltd⁽²⁾	Full consolidation	Equity consolidation	Insurance Brokerage
Laiki Brokers (Insurance & Consultancy Services) Ltd⁽²⁾	Full consolidation	Equity consolidation	Insurance Brokerage
Laiki Insurance Agencies Ltd⁽²⁾	Full consolidation	Equity consolidation	Insurance agency services

(1) Entities of former Hellenic Bank group, which were consolidated as of the third quarter of 2024.

(2) CNP Cyprus Insurance Holdings Limited and its subsidiaries (former "CNP Cyprus subgroup") were acquired by Hellenic Bank in April 2025.

(3) Merger of Group's Cypriot insurance companies: In October 2025, the merger of the Group's Cypriot insurance companies was completed. This involved the transfer of all insurance portfolios, assets, and liabilities of Hellenic Life Insurance Company Ltd and Pancyprian Insurance Ltd to ERB Cyprialife Ltd and ERB Asfalistiki Ltd, respectively.

Table 2: EU LI3 - Outline of the differences in the scopes of consolidation

The following table presents a list of all Company's subsidiaries based on the method of accounting and prudential

consolidation.

a	b	c & g	h
Name of the entity	Method of accounting consolidation	Method of prudential consolidation	Description of the entity

Be Business Exchanges Single Member Societe Anonyme of Business Exchanges Networks and Accounting and Tax Services

Eurobank Asset Management Mutual Fund Mngt Company Single Member S.A.

Full consolidation Full consolidation Business-to-business e-commerce,

accounting, tax and sundry services

Full consolidation Full consolidation Mutual fund and asset management

Eurobank Equities Investment Firm Single Member S.A. Full consolidation Full consolidation Capital markets and advisory services Eurobank Leasing Single Member S.A. Full consolidation Full consolidation Leasing

Eurobank Factors Single Member S.A. Full consolidation Full consolidation Factoring

Herald Greece Single Member Real Estate development and services S.A. 1

Full consolidation Full consolidation Real estate

Piraeus Port Plaza 1 Single Member Development S.A. Full consolidation Full consolidation Real estate

(Under liquidation) Anchor Hellenic Investment Holding Single Member S.A.

Full consolidation Full consolidation Real estate

Athinaiki Estate Investments Single Member S.A. Full consolidation Full consolidation Real estate Piraeus Port Plaza 2 Single Member Development S.A. Full consolidation Full consolidation Real estate Piraeus Port Plaza 3 Single Member Development S.A. Full consolidation Full consolidation Real estate Tenberco Real Estate Single Member S.A. Full consolidation Full consolidation Real estate Value Touristiki Single Member Development S.A. Full consolidation Full consolidation Real estate Insignio Single Member S.A. Full consolidation Full consolidation Real estate

Anaptyxeis Plagias Single Member S.A.⁽²⁾ Full consolidation Full consolidation Real estate

Eurobank Ananeosimes Single Member S.A. Full consolidation Full consolidation Production and distribution of solar

generated electric energy

Eurobank Bulgaria AD Full consolidation Full consolidation Banking

			business
Berberis Investments Ltd	Full consolidation	Full consolidation	Holding company
Eurobank Limited⁽¹⁾	Full consolidation	Full consolidation	Banking

PB Personal Finance EAD Full consolidation Full consolidation Pension assurance intermediary

			and brokerage
HB Data Analytics Ltd⁽¹⁾	Full consolidation	Full consolidation	Auxiliary services
Ezmero Holdings Ltd⁽¹⁾	Full consolidation	Full consolidation	Real estate
Anolia Industrial Ltd⁽¹⁾	Full consolidation	Full consolidation	Real estate
Drypto Holdings Ltd⁽¹⁾	Full consolidation	Full consolidation	Real estate
Arzetio Holdings Ltd⁽¹⁾	Full consolidation	Full consolidation	Real estate
Katlero Holdings Ltd⁽¹⁾	Full consolidation	Full consolidation	Real estate
ERB Cyprus Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Holding company
ERB Cyprus Tower Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
LCYL Karpenisiou Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
LCYL Kiti Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
LCYL Dramas Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
LCYL Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
CL Archangelos Anaptyxis Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
CL Archangelos Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate

Hellenic Bank (Investments) Ltd⁽¹⁾ Full consolidation Full consolidation Investment banking, asset management

	a	b	c & g		h
Name of the entity		Method of accounting consolidation	Method of prudential consolidation	Description of the entity
Montper Enterprises Ltd⁽²⁾	Full consolidation		Full consolidation	Holding company

CL (Mesa Geitonia) Properties Ltd⁽²⁾	Full consolidation	Full consolidation	Real estate
Foramonio Ltd	Full consolidation	Full consolidation	Real estate
Lenevino Holdings Ltd	Full consolidation	Full consolidation	Real estate
Rano Investments Ltd	Full consolidation	Full consolidation	Real estate
Neviko Ventures Ltd	Full consolidation	Full consolidation	Real estate
Zivar Investments Ltd	Full consolidation	Full consolidation	Real estate
Amvanero Ltd	Full consolidation	Full consolidation	Real estate
Revasono Holdings Ltd	Full consolidation	Full consolidation	Real estate
Volki Investments Ltd	Full consolidation	Full consolidation	Real estate
Adariano Investments Ltd	Full consolidation	Full consolidation	Real estate
Elerovio Holdings Ltd	Full consolidation	Full consolidation	Real estate
Ovedrio Holdings Ltd	Full consolidation	Full consolidation	Real estate
Primoxia Holdings Ltd	Full consolidation	Full consolidation	Real estate
Severdor Ltd	Full consolidation	Full consolidation	Holding company
Eurobank Private Bank Luxembourg S.A.	Full consolidation	Full consolidation	Banking
Eurobank Fund Management Company (Luxembourg) S.A.	Full consolidation	Full consolidation	Fund management
ERB Lux Immo S.A.	Full consolidation	Full consolidation	Real estate
ERB New Europe Funding B.V.	Full consolidation	Full consolidation	Finance company
ERB New Europe Funding II B.V.	Full consolidation	Full consolidation	Finance company
ERB IT Shared Services S.A.	Full consolidation	Full consolidation	Informatics data processing
Seferco Development S.A.	Full consolidation	Full consolidation	Real estate
ERB Leasing A.D. Beograd-in Liquidation	Full consolidation	Full consolidation	Leasing
IMO Property Investments A.D. Beograd	Full consolidation	Full consolidation	Real estate services
Karta II Plc	Full consolidation	Full consolidation	Special purpose financing vehicle
Astarti Designated Activity Company	Full consolidation	Full consolidation	Special purpose financing vehicle
ERB Recovery Designated Activity Company	Full consolidation	Full consolidation	Special purpose financing vehicle
Femion Ltd	Equity consolidation	Equity consolidation	Special purpose investment vehicle
Global Finance S.A.	Equity consolidation	Equity consolidation	Investment financing
Odyssey GP S.a.r.l.	Equity consolidation	Equity consolidation	Special purpose investment vehicle
Eurolife FFH Insurance Group Holdings S.A.	Equity consolidation	Equity consolidation	Holding company
Alpha Investment Property Commercial Stores S.A.	Equity consolidation	Equity consolidation	Real estate
Peirga Kythnou P.C.	Equity consolidation	Equity consolidation	Real estate
doValue Greece Loans and Credits Claim Management S.A.	Equity consolidation	Equity consolidation	Loans and Credits Claim Management
Perigenis Business Properties S.A.	Equity consolidation	Equity consolidation	Real estate

(1) Entities of the former Hellenic Bank group, which was consolidated as of the third quarter of 2024. As of November 2024, following the share purchase agreements with certain shareholders of Hellenic Bank and Eurobank's squeeze-out right to acquire the remaining shares of Hellenic Bank, the entity is included in the Group's financial statements with 100% consolidation percentage. As of June 2025, following the completion of the Squeeze Out procedure, the Bank's holding in the company's share capital reached 100%.

(2) CNP Cyprus Insurance Holdings Limited and its subsidiaries (former "CNP Cyprus subgroup") were acquired by Hellenic Bank in April 2025.

The following table shows a comparison between the Balance Sheet included in the Consolidated Financial Statements and the Balance Sheet prepared under the prudential scope of consolidation as at 31 December 2025 and 30 September 2025.

31 December 2025

Balance sheet per published financial

statements

Deconsolidation of insurance and consolidation by the

equity method

Balance sheet per prudential scope of

consolidation

€ million

Table 3: EU CC2 - reconciliation of regulatory own funds to balance sheet in the audited financial statements


						Assets	Ref. (1)
Cash and Balances with central banks		15,628	-		15,628
Due from credit institutions (2)		2,356	(184)		2,172
Securities held for trading		516	-		516
Derivative financial instruments		780	-		780
Loans and advances to customers (2)		54,663	157		54,820
Investment securities		24,884	(857)		24,027
Investments in associaties and joint ventures	a	251	279		530
Property, plant and equipment		1,067	(25)		1,042
Investment property		1,331	(55)		1,276
Intangible assets	b	511	(8)		503
Deferred tax asset		3,629	(2)		3,627
of which deferred tax assets that rely on future profitability and do not arise from temporary differences	c	1	-		1
of which deferred tax assets that do not rely on future profitability		2,832	-		2,832
of which deferred tax assets that rely on future profitability and arise from temporary differences	d	794	-		794
Other assets		2,032		(56)	1,976
Assets of disposal group classified as held for sale		328		-	328
Total assets		107,976		(751)	107,225
Liabilities		-		-	-
Due to central banks		1,001		-	1,001
Due to credit institutions (2)		2,850		(322)	2,528
Derivative financial instruments		915		-	915
Due to customers (2)		82,704		360	83,064
Debt securities in issue		7,352		-	7,352
of which tier 2 instruments	e	1,220		-	1,220
Other liabilities		2,531		(789)	1,742
Total liabilities		97,353		(751)	96,602
Equity		-		-	-
Ordinary share capital	f	799		-	799
Share premium	g	1,140		-	1,140
Reserves and retained earnings	h	7,594		-	7,594
of which cash flow hedge reserves	i	(16)		-	(16)
AT1 Capital Instruments	j	1,090		-	1,090
Total equity		10,623		-	10,623
Total equity and liabilities		107,976		(751)	107,225

30 September 2025

Balance sheet per published financial

statements

Deconsolidation of insurance and consolidation by the

equity method

Balance sheet per prudential scope of

consolidation

€ million

Assets
Cash and Balances with central banks	13,339	-	13,339
Due from credit institutions	2,250	(146)	2,104
Securities held for trading	364	-	364
Derivative financial instruments	785	-	785
Loans and advances to customers	52,881	125	53,006
Investment securities	24,270	(880)	23,390
Investments in associaties and joint ventures	237	321	558
Property, plant and equipment	1,047	(33)	1,014
Investment property	1,327	(54)	1,273
Intangible assets	484	(8)	476
Deferred tax asset	3,633	(2)	3,631
of which deferred tax assets that rely on future profitability and do not arise from temporary differences of which deferred tax assets that do not rely on future profitability	1 2,880	- -	1 2,880
of which deferred tax assets that rely on future profitability and arise from temporary differences Other assets	752 2,039	(2) (56)	750 1,983
Assets of disposal group classified as held for sale	313	-	313
Total assets	102,969	(733)	102,236
Liabilities
Due to central banks	-	-	-
Due to credit institutions	3,073	(284)	2,789
Derivative financial instruments	976	-	976
Due to customers	78,999	324	79,323
Debt securities in issue	7,423	-	7,423
of which tier 2 instruments	1,234	-	1,234
Other liabilities	2,590	(773)	1,817
Liabilities of disposal group classified as held for sale	-	-	-
Total liabilities	93,061	(733)	92,328
Equity
Ordinary share capital	811	-	811
Share premium	1,145	-	1,145
Reserves and retained earnings	7,457	-	7,457
of which cash flow hedge reserves	(16)	-	(16)
Preferred securities	-	-	-
AT1 Capital Instruments	495	-	495
Total equity	9,908	-	9,908
Total equity and liabilities	102,969	(733)	102,236

(1) References provide the mapping of items of the statement of financial position prepared under the regulatory scope of consolidation used to calculate

regulatory capital as reflected in column "References" in Section 2.5 "Composition of regulatory capital".

(2) According to Annex V "Reporting on Financial Information", specific amounts are categorised as Credit Institutions in Financial Statements while in Regulatory scope of consolidation as Other Financial Corporations (Loans and advances to customers or Due to customers).

‌Impediments to the prompt transfer of capital

Subordinated loans given by Eurobank S.A. to its subsidiaries, financial institutions operating outside Greece, are subject to local regulations and subsequently restrictions set by local laws and supervisory authorities. The most common of all restrictions is minimum duration (5 to 7 years in most cases) with no possibility of prepayment without prior permission by the respective supervisory authority.

‌Capital Management

The amount and quality of the capital held by the Group is subject to certain rules and guidelines. The composition of the Group's available regulatory capital under Pillar 1 is as follows:

‌Regulatory capital - definition
The Pillar 1 regulatory capital of the Group at consolidated level is calculated on the basis of IFRS figures and according to the rules set by Regulation (EU) No 575/2013 as amended.
According to the CRR, the available regulatory capital is classified under two main categories: Tier 1 and Tier 2 capital. Tier 1 consists of Common Equity (CET1) and Additional Tier 1 (AT1) capital.
CET1 capital is composed of ordinary shareholders' equity, and minority interest allowed in consolidated CET1, after the following deductions:
- Fair value reserves related to gains or losses of cash flow hedges;
- Gains and losses on market valuation of liabilities designated as fair-value-through-profit-or-loss attributable to own credit risk;
- Goodwill and intangible assets adjusted based on the requirements for prudent valuation of software assets;
- Deferred tax assets that rely on future profitability excluding those arising from temporary differences (unused tax losses);
- Participating interests and subordinated loans (and other capital instruments qualifying as own funds) of more than 10% in not fully consolidated credit or other financial institutions, including insurance companies;
- Deferred tax assets arising from temporary differences, which exceed 10% threshold of CET1 capital before certain deductions;
- The sum of deferred tax asset arising from temporary differences and participating interests and subordinated loans to financial institutions of more than 10% that are less than 10% of CET 1 capital and in total exceed the 17.65% threshold of adjusted CET1 capital; and
- Value adjustments due to the requirements for prudent valuation for all fair valued financial instruments and commodities (AVA).
Tier 1 capital comprises CET1 capital plus AT1 capital including preferred securities subject to phase out. In case deductions of Tier 1 capital exceed positive amounts of Tier 1 capital, then the difference is deducted from CET1 capital.
Tier 2 capital comprises long term subordinated liabilities that meet certain regulatory specified criteria. In case deductions of Tier 2 capital exceed positive amounts of Tier 2 capital, then the difference is deducted from Tier 1 capital.

‌Reconciliation of Balance Sheets-financial accounting to prudential scope of consolidation

As noted in section "1.25 Prudential versus accounting consolidation", the prudential consolidation is different compared to the accounting consolidation. As a result, the table below presents the Balance Sheet separately as per published financial statements and prudential consolidation broken down into different risk types. Certain assets and liabilities can be subject to multiple risk frameworks.

Table 4: EU LI1 - Differences between accounting and regulatory scopes of consolidation and the mapping of financial statement categories with regulatory risk categories

	a	b	c	d	e	f	g
	31 December 2025
			Carrying values of items
							Not subject to
							capital
	Balance sheet						requirements
	per published	Balance sheet	Subject to the		Subject to the	Subject to the	or subject to
	financial	per regulatory	credit risk	Subject to the	securitisation	market risk	deduction from
	statements	consolidation	framework	CCR framework	framework	framework	capital
Ref.	€ million	€ million	€ million	€ million	€ million	€ million	€ million
Assets
Cash and Balances with central banks	15,628	15,628	15,628	-	-	-	-
Due from credit institutions	2,356	2,172	1,710	462	-	-	-
Securities held for trading	516	516	-	-	-	516	-
Derivative financial instruments	780	780	-	780	-	780	-
Loans and advances to customers	54,663	54,820	48,056	4,542	6,443	-	279
Investment securities	24,884	24,027	22,266	879	1,761	-	-
Investments in associate and joint ventures a	251	530	524	-	-	-	6
Property and equipment	1,067	1,042	1,042	-	-	-	-
Investment property	1,331	1,276	1,276	-	-	-	-
Goodwill and other intangible assets b	511	503	153	-	-	-	350
Deferred tax asset	3,629	3,627	3,618	-	-	-	9
of which deferred tax assets that rely on future profitability c excluding those arising from temporary differences	1	1	-	-	-	-	1
of which deferred tax credit	2,832	2,832	2,832	-	-	-	-
of which deferred tax assets arising from temporary differences d	794	794	786	-	-	-	8
Other assets	2,032	1,976	1,947	-	-	-	29
Assets of disposal group classified as held for sale	328	328	328	-	-	-	-
Total assets	107,976	107,225	96,547	6,663	8,204	1,296	673
Liabilities
Due to central banks	1,001	1,001	-	1,001	-	-	-
Due to credit institutions	2,850	2,528	-	1,905	-	-	623
Derivative financial instruments	915	915	-	915	-	915	-
Due to customers	82,704	83,064	-	-	-	-	83,064
Debt securities in issue	7,352	7,352	-	-	-	-	7,352
Other liabilities	2,531	1,742	50	-	-	-	1,692
Total liabilities	97,353	96,602	50	3,821	-	915	92,731
of which tier 2 instruments e	1,220	1,220	-	-	-	-	1,220
Equity
Ordinary share capital f	799	799	-	-	-	-	799
Share premium g	1,140	1,140	-	-	-	-	1,140
Reserves and retained earnings h	7,594	7,594	-	-	-	-	7,594
of which cash flow hedge reserves	(16)	(16)	-	-	-	-	(16)
of which own credit risk	-	-	-	-	-	-	-
Preference shares	-	-	-	-	-	-	-
Total equity attributable to shareholders of the Bank	9,533	9,533	-	-	-	-	9,533
Preferred securities	-	-	-	-	-	-	-
Non controlling interests	1,090	1,090	-	-	-	-	1,090
Total equity i	10,623	10,623	-	-	-	-	10,623
Total equity and liabilities	107,976	107,225	50	3,821	-	915	103,354

	a	b	c	d	e	f	g
	31 December 2024
			Carrying values of items
	Balance sheet per published financial statements	Balance sheet per regulatory consolidation	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 capital requirements or subject to deduction from capital
	€ million	€ million	€ million	€ million	€ million	€ million	€ million
Assets
Cash and Balances with central banks	16,131	16,131	16,131	-	-	-	-
Due from credit institutions	2,196	2,025	1,991	34	-	-	-
Financial instruments at fair value through profit or loss	285	285	-	-	-	285	-
Derivative financial instruments	838	838	-	838	-	838	-
Loans and advances to customers	50,953	51,120	43,386	2,120	6,934	-	746
Investment securities	22,184	22,070	20,066	687	2,004	-	-
Investments in associate and joint ventures	203	258	258	-	-	-	-
Property and equipment	975	969	969	-	-	-	-
Investment property	1,404	1,403	1,403	-	-	-	-
Intangible assets	415	413	127	-	-	-	286
Deferred tax asset	3,780	3,780	3,780	-	-	-	-
of which deferred tax assets that rely on future profitability	-	-	-	-	-	-	-
excluding those arising from temporary differences of which deferred tax credit	3,022	3,022	3,022	-	-	-	-
of which deferred tax assets arising from temporary differences	758	758	758	-	-	-	-
Other assets	1,695	1,666	1,637	-	-	-	29
Assets of disposal group classified as held for sale	91	91	91	-	-	-	-
Total assets	101,150	101,049	89,838	3,679	8,938	1,123	1,061
Liabilities
Due to central banks	-	-	-	-	-	-	-
Due to credit institutions	2,800	2,584	-	1,952	-	-	632
Derivative financial instruments	1,120	1,120	-	1,120	-	1,120	-
Due to customers	78,593	78,819	-	-	-	-	78,819
Debt securities in issue	7,056	7,056	-	-	-	-	7,056
Other liabilities	2,682	2,571	43	-	-	-	2,528
Total liabilities	92,251	92,150	43	3,072	-	1,120	89,035
of which tier 2 instruments	1,759	1,759	-	-	-	-	1,759
Equity
Ordinary share capital	809	809	-	-	-	-	809
Share premium	1,145	1,145	-	-	-	-	1,145
Reserves and retained earnings	6,945	6,945	-	-	-	-	6,945
of which cash flow hedge reserves	(15)	(15)	-	-	-	-	(15)
of which own credit risk	-	-	-	-	-	-	-
Preference shares	-	-	-	-	-	-	-
Total equity attributable to shareholders of the Bank	8,899	8,899	-	-	-	-	8,899
Preferred securities	-	-	-	-	-	-	-
Non controlling interests	-	-	-	-	-	-	-
Total equity	8,899	8,899	-	-	-	-	8,899
Total equity and liabilities	101,150	101,049	43	3,072	-	1,120	97,934

Note: The amounts shown in column "Balance sheet per published financial statements and per prudential consolidation" do not equal to the sum of the

amounts shown in the remaining columns, as some assets are subject to multiple risk frameworks.

The table below provides a reconciliation of the consolidated regulatory balance sheet to the Exposure at Default (EAD), allocated to different risk frameworks.

Table 5: EU LI2 - Main sources of differences between regulatory exposure amounts and carrying values in financial statements

a	b	c	d	e
31 December 2025
	Items subject to
Total € million	Credit risk framework € million	CCR framework € million	Securitisation framework € million	Market risk framework € million

Assets carrying value amount under the scope of 1 regulatory consolidation (as per template EU LI1) (1)	106,552	96,547	6,663	8,204	1,296
Liabilities carrying value amount under the regulatory 2 scope of consolidation (as per template EU LI1) (1)	3,871	50	3,821	-	915
Total net amount under the regulatory scope of	102,681	96,497	2,842	8,204	381
4 Off-balance-sheet amounts	19,707	19,707	-	-	-
5 Differences in valuations	-	-	-	-	-
6 Differences due to different netting rules, other than	1	1	(2,158)	915
7 Differences due to consideration of provisions	(75)	(75)	-	-	-
8 Differences due to the use of credit risk mitigation techniques (CRMs)	(2,014)	1,060	-	(3,074)
9 Differences due to credit conversion factors	(15,864)	(15,864)	-
10 Differences due to Securitisation with risk transfer	-	-	-	-	-
11 Other differences	-	-	2,032	-	-
12 Exposure amounts considered for regulatory purposes	104,436	101,326	2,716	5,130	1,296

3 consolidation

those already included in row 2

a	b	c	d	e
31 December 2024
	Items subject to
Total € million	Credit risk framework € million	CCR framework € million	Securitisation framework € million	Market risk framework € million

Assets carrying value amount under the scope of	99,988	89,838	3,679	8,938	1,123
Liabilities carrying value amount under the regulatory 2 scope of consolidation (as per template EU LI1)	3,115	43	3,072	-	1,120
Total net amount under the regulatory scope of	96,873	89,795	607	8,938	3
4 Off-balance-sheet amounts	13,940	13,940	-	-	-
6 Differences due to different netting rules, other than	44	44	(590)		1,120
7 Differences due to consideration of provisions	-	-	-	-	-
8 Differences due to the use of credit risk mitigation techniques (CRMs)	(1,844)	1,237	-	(3,081)
9 Differences due to credit conversion factors	(10,183)	(10,183)	-
10 Differences due to Securitisation with risk transfer	-	-	-	-	-
11 Other differences	-	-	1,909	-	-
12 Exposure amounts considered for regulatory purposes	98,830	94,833	1,926	5,857	1,123

1 regulatory consolidation (as per template EU LI1)

3 consolidation

those already included in row 2

(1) Excludes amounts subject to deduction from capital or not subject to regulatory capital requirements.

‌Basel 4 implementation
On 19 June 2024, Regulation 2024/1623/EU and Directive 2024/1619/EU of the European Parliament and of the Council of 31 May 2024, amending Regulation 575/2013/EU and Directive 2013/36/EU, respectively, were published in the Official Journal of the European Union. The revised CRR (CRR3 Basel IV) became, in general, applicable from 1 January 2025, with a transitional period envisaged for certain rules set out therein.
The main changes that affect the Group's RWEAs under the new framework are described below:
1. Credit risk
  - Unconditionally cancellable limits previously at 0% CCF will gradually receive a 10% CCF (transition period 2030-2032);
  - Exposures to natural persons with unhedged currency mismatch (i.e. CHF mortgage loans) are penalized with an RWEAs multiplier of 1.5x;
  - Acquisition of Land, Development & Construction (ADC) loans are distinguished from the secured by real estate asset class and receive 150% Risk Weighting Factor (RWF) (or 100% under specific conditions for RRE property);
  - In the secured by real estate exposures class, the RWF/LTV mapping is changing, providing benefit to the very low LTVs of loans secured by RRE and increased RWEAs for the remaining exposure. Income Producing Real Estate (IPRE) exposures are also distinguished from the secured by real estate asset class and their risk weight factor is linked to the LTV and the collateral type (RRE/CRE) resulting in more punitive risk weights;
  - For externally rated corporates/institutions the Credit Quality Step (CQS)/RWF mapping is changing, providing a lower RW in certain cases;
  - Unrated Project Finance clients are categorized in 3 segments based on the project phase (pre-operational at 130%; operational at 100%) and specific conditions (high quality operational at 80% RWF);
  - Shipping clients may benefit of 80% RWF subject to specific conditions; and
  - Retail asset class is segmented to transactors (revolving accounts acting as a transactional rather than a credit facility) which receive a lower risk weight (45% instead of 75%) and to non-transactors.
2. Counterparty and Issuer Risk
  - Change of the applicable risk weights on exposures from Corporates and Financial Institutions (subordinated, senior preferred / non-preferred);
  - Revised treatment on exposures from unrated Institutions and impact from the application of original maturity (removal of the residual maturity);
  - Change in the calculation of exposure from SFTs under master netting agreements concerning the Financial Collateral Comprehensive Method;
  - Revision of the credit valuation adjustment (CVA) framework, including the removal of the existing exceptions following specific criteria (mainly corporate clients) and the application of the reduced version of the basic approach (BA-CVA); and
  - Change of the applicable risk weight for Equities (new prevailing RWF mainly at 250% vs 100%-150%-250%), subject to transition period (full application from 2030).
3. Market Risk
  In light of ongoing delays in the international implementation of the Basel FRTB standards-particularly by the United States and the United Kingdom-the European Commission adopted a Delegated Regulation to defer by one year the application of the revised market risk capital requirements under Regulation (EU) No 575/2013. This decision, supported by the majority of stakeholders during a public consultation held between March and April 2025, aims to preserve a level playing field for EU institutions. According to this Regulation the FRTB framework is scheduled to apply from 1 January 2027.
  2.3.3 Operational Risk
  Basel IV introduces a new Standardised Approach (SA) for calculating operational risk capital requirements. This method is a single, non-model-based approach and replaces all previous methods, including the Basic Indicator, Standardised, and Advanced Measurement Approaches.
  The capital requirement is now based on a Business Indicator (BI) reflecting the scale of business operations through income and expense components. BI is calculated as the average over the past three years.

‌Key Metrics

The following table provides an overview of Group's prudential regulatory metrics.

a	b	c	d	e
31 December 2025	30 September 2025	30 June 2025	31 March 2025	31 December 2024
€ million	€ million	€ million	€ million	€ million
8,134	7,874	7,932	7,692	7,718
9,224	8,369	8,427	7,692	7,718
10,439	9,600	10,132	9,444	9,093

53,647	51,756	51,720	51,471	49,977
53,647	51,756	51,720	51,471

15.2%	15.2%	15.3%	14.9%	15.4%
15.2%	15.2%	15.3%	14.9%
17.2%	16.2%	16.3%	14.9%	15.4%
17.2%	16.2%	16.3%	14.9%
19.5%	18.5%	19.6%	18.3%	18.2%
19.5%	18.5%	19.6%	18.3%

2.85%	2.85%	2.85%	2.85%	2.85%
1.60%	1.60%	1.60%	1.60%	1.60%
2.14%	2.14%	2.14%	2.14%	2.14%
10.85%	10.85%	10.85%	10.85%	10.85%

2.50%	2.50%	2.50%	2.50%	2.50%
0.00%	0.00%	0.00%	0.00%	0.00%
0.68%	0.55%	0.55%	0.54%	0.56%
0.00%	0.00%	0.00%	0.00%	0.00%
0.00%	0.00%	0.00%	0.00%	0.00%
1.25%	1.25%	1.25%	1.25%	1.25%
4.43%	4.30%	4.30%	4.29%	4.31%
15.28%	15.15%	15.15%	15.14%	15.16%
8.61%	7.70%	8.15%	7.32%	7.30%

113,523	108,295	107,100	105,673	106,049
8.1%	7.7%	7.9%	7.3%	7.3%

0.00%	0.00%	0.00%	0.00%	0.00%
0.00%	0.00%	0.00%	0.00%	0.00%
3.00%	3.00%	3.00%	3.00%	3.00%

Table 6: EU KM1 - Key Metrics template

Available own funds (amounts)

Common Equity Tier 1 (CET1) capital
Tier 1 capital
Total capital
Risk-weighted exposure amounts
Capital ratios (as a percentage of risk-weighted exposure amount)
Total risk exposure amount 4a Total risk exposure pre-floor
Common Equity Tier 1 ratio (%)
5b Common Equity Tier 1 ratio considering unfloored TREA (%)
Tier 1 ratio (%)
6b Tier 1 ratio considering unfloored TREA (%)
Total capital ratio (%)
7b Total capital ratio considering unfloored TREA (%)
Additional own funds requirements to address risks other than the risk of excessive leverage (as a percentage of risk-weighted exposure amount)
EU 7d Additional own funds requirements to address risks other than the risk of excessive leverage (%) EU 7e of which: to be made up of CET1 capital (percentage points)
Combined buffer requirement (as a percentage of risk-weighted exposure amount)
EU 7f of which: to be made up of Tier 1 capital (percentage points) EU 7g Total SREP own funds requirements (%)
Capital conservation buffer (%)
Conservation buffer due to macro-prudential or systemic risk identified at the level of a Member
EU 8a
State (%)
Institution specific countercyclical capital buffer (%) EU 9a Systemic risk buffer (%)
Global Systemically Important Institution buffer (%) EU 10a Other Systemically Important Institution buffer
Combined buffer requirement (%) EU 11a Overall capital requirements (%)
CET1 available after meeting the total SREP own funds requirements (%)
Leverage ratio
Leverage ratio total exposure measure

Leverage ratio

Additional own funds requirements to address risks of excessive leverage (as a percentage of leverage ratio total exposure amount)

EU 14a Additional own funds requirements to address the risk of excessive leverage (%) EU 14b of which: to be made up of CET1 capital (percentage points)

EU 14c Total SREP leverage ratio requirements (%)

Leverage ratio buffer and overall leverage ratio requirement (as a percentage of total exposure measure)

EU 14d Leverage ratio buffer requirement (%) 0.00% 0.00% 0.00% 0.00% 0.00%

EU 14e Overall leverage ratio requirements (%) 3.00% 3.00% 3.00% 3.00% 3.00%

Liquidity Coverage Ratio

a	c	d	e	e
31 December 2025	30 September 2025	30 June 2025	31 March 2025	31 December 2024
€ million	€ million	€ million	€ million	€ million
22,307	22,674	22,191	21,259	20,159
14,313	14,055	13,643	12,968	12,324
2,073	2,073	1,963	1,717	1,546
12,240	11,982	11,680	11,251	10,778
182.6%	189.3%	190.1%	188.7%	186.6%
172.2%	180.4%	194.4%	182.8%	188.2%

83,136	80,021	79,366	77,797	77,562
57,650	56,067	55,301	54,452	53,612
144.2%	142.7%	143.5%	142.9%	144.7%

Total high-quality liquid assets (HQLA) (Weighted value - average) EU 16a Cash outflows - Total weighted value
EU 16b Cash inflows - Total weighted value
Total net cash outflows (adjusted value)
Liquidity coverage ratio (%) (adjusted value) (1)
Liquidity coverage ratio (%)
Net Stable Funding Ratio
Total available stable funding
Total required stable funding
NSFR ratio (%)

(1) Average figures based on previous monthly data points.

Notes:

Figures and ratios presented are as per the final regulatory reporting submissions which include semi-annual and year-end audited profits, as well as the payout accrual (in accordance with the Group shareholders' remuneration policy), following permission granted by the Supervisory Authorities and the AGM of the shareholders.
Pro-forma CET1, Tier 1 and Total Capital Adequacy ratios as at 31 December 2025 with the completion of project "Sun (ex-Solar)" and "Wave III" securitization upsize would be 15.6%, 17.7% and 20.0%, respectively.

‌Regulatory capital

The Group has sought to maintain an actively managed capital base to cover risks inherent in the business. The adequacy of the Group's capital is monitored using, among other measures, the rules and ratios established by the Basel Committee on Banking Supervision and adopted by the European Union and the SSM in supervising the Group.

The following table shows the composition of the Group's regulatory capital as at 31 December 2025 and 30 September 2025 which is calculated according to CRD IV as amended.

Table 7: Composition of regulatory capital

a & b

Ref.

31 December

2025 (1)

30 September

2025 (1)

€ million

Total equity	f, g, h	9,533	9,413
Regulatory adjustments
Interim or year-end profit not eligible (1)		(657)	(633)
Minority interest not allowed in CET1		-	-
Cash flow hedge reserves	i	16	16
Intangible assets	b	(350)	(379)
of which Goodwill		(42)	(42)
Deferred tax assets that rely on future profitability and do not arise	c	(1)	(1)
from temporary differences
Deferred tax assets that rely on future profitability and arise from temporary differences (amount above 10% threshold)	d	-	-
Prudent Valuation Adjustments (2)		(5)	(4)
Other regulatory adjustments		(389)	(338)
Amount exceeding the 17.65% threshold	a, d	(13)	(24)
Common Equity Tier 1 capital		8,134	8,049
Additional Tier 1 capital (3)	j	1,090	495
Total Tier 1 capital		9,224	8,544
Tier 2 capital - subordinated debt	e	1,215	1,231

Total Regulatory Capital 10,439 9,775

Risk Weighted Assets 53,647 51,836

Ratios
Common Equity Tier 1 (4)	15.2%	15.5%
Tier 1	17.2%	16.5%
Total Capital Adequacy Ratio	19.5%	18.9%

(1) Figures and ratios include profits for the financial year 2025 and 9M 2025 accordingly, less the payout accrual (in accordance with the Group

shareholders' remuneration policy), subject to Supervisory Authorities and AGM approval.

(2) The Additional Value Adjustments calculation is based on the simplified approach according to Commission Delegated Regulation (EU) No 101/2016. The total AVAs are deducted from CET1 capital, in accordance with Article 34 of the CRR.

(3) Additional Tier 1 capital increased mainly due to the issuance of € 600 million fixed rate reset Additional Tier 1 perpetual contingent temporary write-down notes.

(4) CET1 ratio decreased mainly due to increased RWEAs from the new production of loans, the termination of synthetic securitizations ("Wave I" & "Wave III"), the payout accrual and the acceleration of DTC amortization, which is partially offset by the Group's organic profitability and the decrease in RWEAs of Operational Risk.

Note: The pro-forma CET1, Tier 1 and Total Capital Adequacy ratios as at 31 December 2025 with the completion of project "Sun (ex-Solar)" and "Wave III" securitization upsize would be 15.6%, 17.7% and 20.0%, respectively.

The CET1 ratio is defined as CET1 capital divided by RWEAs, the Tier 1 ratio is defined as Tier 1 capital divided by RWEAs and Total Capital Adequacy ratio is defined as Total Regulatory Capital divided by RWEAs.

As at 31 December 2025, pursuant to the Law 4172/2013, as in force, the Bank's eligible Deferred Tax Assets/Deferred Tax Credits (DTCs) against the Greek State amounted to € 2,832 million (30 September 2025 € 2,880 million). DTCs are accounted for on: (a) the unamortised losses from the Private Sector Involvement and the Greek State Debt Buyback Program, which are subject to amortization over a thirty-year period and (b) on the sum of (i) the unamortised part of the DTC eligible crystallized tax losses arising from write-offs and disposals of loans, which are subject to amortization over a twenty-year period, (ii) the accounting debt write-offs and (iii) the remaining accumulated provisions and other losses in general due to credit risk recorded up to 30 June 2015. The DTCs will be converted into directly enforceable claims (tax credit) against the Greek State provided that the Bank's after tax accounting result for the year is a loss.

According to Regulation (EU) No. 575/2013, article 39, deferred tax assets that can be replaced with a tax credit, shall not be deducted from CET1, but instead be risk weighted by 100%.

In line with the Bank's initiative to enhance the quality of its regulatory capital, the amortisation of DTC has been accelerated for regulatory purposes starting from 01.01.2025, by an amount equal to 29% of accrued shareholders remuneration, aiming at its elimination by 2033 or earlier. Following this, the DTC included in the calculation of the Group's capital ratios stands at € 2,624 million (30 September 2025 € 2,738 million) accounting for 32.3% of CET 1 capital.

‌Countercyclical buffer

The CCyB will be applied when the authorities deem that lending growth is giving rise to an unacceptable accumulation of systemic risks. This buffer is specifically calculated for each bank or group and consists of the weighted average of percentages of countercyclical buffers applied in regions in which the bank's credit exposures are located.

The following table presents the geographical distribution of the Group's credit exposures relevant for the calculation of

its countercyclical capital buffer, which includes all private sector exposures according to Regulation (EU) 1152/2014.

a b c d e f g h i j k l m
31 December 2025
Relevant credit exposures - Securitisation General credit exposures Market risk exposures			Own funds requirements
Exposure Exposure Sum of long Value of Exposure value Total Relevant Relevant Relevant credit Total Risk-weighted Own funds Counter-cyclical value under value under and short trading book for non-trading exposure credit risk credit exposures - exposure requirements capital buffer the the IRB positions of exposure for book value exposures - exposures - Securitisation amounts weights rate standardised approach trading book internal Credit risk Market risk positions in the approach exposures for models non-trading SA book € million € million € million € million € million € million € million € million € million € million € million (%) (%)

Table 8: EU CCyB1 - Geographical distribution of credit exposures relevant for the calculation of countercyclical buffer

010 Breakdown by country:

Greece (1)	35,451	- 16	- 1,161	36,628	1,967	1	17	1,985	24,813	61%	0.25%
Romania	99	- -	- -	99	5	-	-	5	63	0.2%	1.00%
Bulgaria (2)	9,178	- -	- -	9,178	457	-	-	457	5,713	14%	2.00%
United Kingdom	1,096	- -	- 180	1,276	59	-	3	62	775	2%	2.00%
Cyprus	6,512	- -	- 35	6,547	390	-	3	393	4,913	12%	1.00%
Luxemburg	282	- -	- -	282	23	-	-	23	288	1%	0.50%
Ireland	11	- -	- 5,285	5,296	1	-	91	92	1,150	3%	1.50%
Other Countries	4,769	- 1	- 1,543	6,313	209	-	26	235	2,938	7%	0.49%
020 Total	57,398	- 17	- 8,204	65,619	3,111	1	140	3,252	40,653	100%	0.68%

i j

30 June 2025

General credit exposures

Relevant credit exposures -

Market risk

Securitisation exposures

Total exposure value

Own funds requirements

Risk-weighted Own funds Counter-exposure requirements cyclical capital amounts weights buffer rate

Exposure value under

the standardised approach

Exposure value under the IRB approach

Sum of long and short positions of trading book exposures for

Value of trading book exposure for internal models

Exposure value for non-trading

book

Relevant credit risk exposures -Credit risk

Relevant credit exposures -Market risk

Relevant credit Total

exposures -Securitisation positions in the non-trading

book

€ million

€ million € million

€ million

(%)





Breakdown by country:
Greece	33.146	- 7	- 3	33.156	1.802	- -	1.802	22.525	59%	0,00%
Romania	87	- -	- -	87	4	- -	4	50	0,1%	1,00%
Bulgaria	8.428	- -	- -	8.428	429	- -	429	5.363	14%	2,00%
United Kingdom	1.097	- -	- 139	1.236	62	- 2	64	800	2%	2,00%
Cyprus	6.218	- -	- 74	6.292	384	- 8	392	4.900	13%	1,00%
Luxemburg	262	- -	- -	262	22	- -	22	275	1%	0,50%
Ireland	16	- -	- 6.578	6.594	1	- 105	106	1.325	3%	1,50%
Other Countries	4.501	- 1	- 1.692	6.194	190	- 28	218	2.725	7%	0,50%

010

020 Total 53.755 - 8 - 8.486 62.249 2.894 - 143 3.037 37.963 100% 0,55%

(1) For the period from 1.10.2025 to 30.09.2026, the CCyB rate is increased to 0.25%, in accordance with Executive Committee Act 235/2/07.10.2024. Under Executive Committee Act 248/1/06.10.2025, the BoG has decided to set the CCyB rate for Greece at 0.5%, applicable from 1 October 2026.

(2) The increase in the exposure value under the stansardised approach is mainly due to the credit growth of Greece and Bulgaria and in the securitization exposures in Greece is due to the Wave VI securitization.

Note: The tables above exclude exposures on Central governments or Central banks, Regional governments or local authorities, Public sector entities, Multilateral development banks, International organisations and Institutions asset classes.

The following table presents an overview of Group's specific countercyclical capital risk exposure and buffer

requirements.

Table 9: EU CCyB2 - Amount of institution-specific countercyclical capital buffer

30 June

2025

31 December

2025

1 Total risk exposure amount (€ million)	53,647	51,720
2 Institution specific countercyclical capital buffer rate (1)	0.68%	0.55%
3 Institution specific countercyclical capital buffer requirement (€ million)	365	284

(1) The increase in the specific countercyclical capital buffer rate is mainly due to credit growth of Greece and Bulgaria and the CCyB rate of Greece which is 0.25% from 1.10.2025.

‌Supervisory Review and Evaluation Process (SREP) capital requirements

According to the 2024 SREP decision, from December 2024 the P2R for the Group is set at 2.85% in terms of total capital (or at 1.60% in terms of CET1 capital). The change in the P2R is the outcome of the consolidation of Hellenic Bank. Based on the ECB's 'Guide on the supervisory approach to consolidation in the banking sector', in case of M&As, the P2R of the combined entity/group is determined based on the weighted average of the P2R (based on RWEAs) of the two entities (i.e. Eurobank Group: 2.75%, Hellenic Bank: 3.45%). Based on the 2025 SREP decision, from 1 January 2026 the P2R is reduced to 2.75% (or 1.55% in terms of CET1 capital), reflecting the Group's progress in the areas assessed by the ECB, and particularly in the integration of Hellenic Bank into the Group.