Group public disclosure – Pillar III as at 31 March 2026

FINECOBANK GROUP PUBLIC DISCLOSURE - PILLAR III

Contents

"FinecoBank Banca Fineco S.p.A."

in abbreviated form "FinecoBank S.p.A.", or "Banca Fineco S.p.A." or "Fineco Banca S.p.A.".

Bank enrolled in the Register of Banks and Parent Company of the FinecoBank Banking Group - enrolled in the Register of Banking Groups at No. 3015, Member of the National Guarantee Fund and National Interbank Deposit Guarantee Fund.

Tax Code and Milan-Monza-Brianza-Lodi Companies Register no. 01392970404 - R.E.A. (Economic and Administrative Index) no. 1598155, VAT No. 12962340159

Introduction

The Group FinecoBank public disclosure Pillar III - (hereafter "Disclosure") has been prepared in accordance with the prudential rules for banks and investment firms, which came into force on January 1, 2014 and are contained in Directive 2013/36/EU (Capital Requirements Directive, CRD IV) and in Regulation 575/2013/EU (Capital Requirements Regulation, CRR), and subsequent Directives and Regulations amending its content. In particular, reference is made to Regulation (EU) 2024/1623 and Directive (EU) 2024/1619, which introduced significant amendments to the CRR Regulation and the CRD Directive, applicable from 1 January 2025. In the rest of this document, the term "CRR" refers to Regulation no. 575/2013/EU as subsequently amended, while the term "Directive" refers to the Capital Requirements Directive as subsequently amended.

The Directive and the Regulation transpose into European Union legislation the framework known as Basel III, defined by the Basel Committee on Banking Supervision to strengthen banks' ability to absorb shocks arising from financial and economic tensions, regardless of their origin, to improve risk management and governance of banks, as well as to strengthen their transparency and disclosure.

The CRR requires Institutions to publish the information set out in Title II and III of Part Eight in conjunction with the financial statements. The purpose of this disclosure requirement is to integrate the minimum capital requirements (Pillar 1) and the prudential control process (Pillar 2), by identifying a set of disclosure transparency requirements that allow market participants to have relevant, complete and reliable information about capital adequacy, risk exposure and the general characteristics of the systems in place to identify, measure and manage those risks.

FinecoBank S.p.A. (hereinafter also FinecoBank or Fineco or Bank) qualifies as a "Large Institution" under Part Eight of the CRR and, therefore, all information required to them on a quarterly basis has been published in this Public Disclosure as at 31 March 2026.

In line with the CRR, FinecoBank S.p.A., as the Parent Company of the FinecoBank Banking Group (hereinafter the "Group"), publishes its Public Disclosure at a consolidated level.

With the aim of improving transparency and comparability of information disclosed to the public, through the use of specific IT solutions, structured data exchange formats and automated validation methods that can also ensure greater efficiency in the management and publication of public disclosures, an initiative launched by EBA under the direct mandate of Article 434bis of CRR3, the so-called Pillar 3 Data Hub (P3DH), is being finalized, aimed at centralizing and making available Pillar 3 disclosures through a single electronic access point on the EBA website. According to the timeline reported in the Final Draft ITS (EBA/ITS/2025/01), a gradual transition to this new system is planned, with large institutions (including Fineco) expected to adopt it as of June 30, 2025, the first reference date for P3DH implementation. This transitional period for the reference dates of June 30, September 30, and December 31, 2025, allows institutions to publish their Pillar 3 disclosures on their websites and subsequently comply with the requirement to submit the information to the EBA in the technical format required by ITS. As of 31 March 2026, the initiative is fully operational; therefore, from that date onwards, the reports must instead be submitted first to the EBA, although the EBA has granted banks the option to continue publishing them on their websites as well.

In addition to the European Union regulations before mentioned, there are also the provisions issued by the Bank of Italy, in particular Circular no. 285 "Supervisory provisions for banks" of December 17, 2013 (and subsequent updates), which in Chapter 13 of Part Two (public disclosure) governs the matter. The aforementioned circular does not lay down specific rules for the preparation and publication of Pillar III but refers to the provisions for this purpose provided by CRR, by the Regulations of the European Commission whose preparation may be delegated to the EBA (European Banking Authority) and by the EBA Guidelines.

The subject is therefore directly regulated:

• by the Part Eight of CRR, "Disclosure by institutions" (art. 431 - 455);

• by the Regulations of the European Commission, the preparation of which may be delegated to the EBA, containing the regulatory or implementing technical standards to govern the uniform models for publishing the various types of information. In particular, reference is made to the following guidelines and regulations:

  • Commission Implementing Regulation (EU) 2024/3172 of 29 November 2024 laying down implementing technical standards for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council with regard to public disclosures by institutions of the information referred to in Part Eight, Titles II and III, of that Regulation, and repealing Commission Implementing Regulation (EU) 2021/637 (EBA/ITS/2024/25 transposed by the Implementing Regulation 2024/3172);

  • Commission Implementing Regulation (EU) 2021/763 of 23 April 2021 laying down implementing technical rules for the application of Regulation (EU) No 575/2013 of the European Parliament and of the Council and Directive 2014/59/EU of the European Parliament and of the Council (Bank Recovery and Resolution Directive - BRRD) with regard to supervisory reporting and public disclosure of minimum own funds requirement and eligible liabilities (MREL);

  • guidelines on materiality, proprietary and confidentiality and on disclosure frequency under Articles 432(1), 432(2) and 433 of Regulation (EU) No 575/2013 (EBA/GL/2014/14).

    Please note that the disclosure of the Group is prepared in accordance with a formal policy (Internal Regulation) adopted in the application of the CRR Article 431 (3) that sets out the internal controls and procedures.

    The key elements of this policy are:

• identification of roles and responsibilities of the corporate bodies, departments and Legal Entities involved in the process of producing the disclosure;

• identification of the information to be published (in accordance with EBA GL/2014/14 and CRR Article 432 and 433 in relation with the requirements applicable as of 31 March 2026);

• approval by the Board of Directors;

Introduction

• publication on the disclosure. In line with the aforementioned P3DH, the Disclosure as of March 31, 2026, will first be submitted to the EBA in electronic format in accordance with the deadlines set out in the regulations and will be subsequently made available on the FinecoBank website.

  This document has been prepared in accordance with the indications of the EBA guidelines in compliance with the proportionality principle and publishing only information that is material and not exclusive or confidential in accordance with Article 432 of the CRR. In this regard, it should be noted that for the publication of qualitative and quantitative information, FinecoBank has adopted, firstly, the models provided by the EU Regulations or by the applicable EBA Guidelines mentioned above, secondly, free models. The tables below report references to the location, in this document, of the required information.

  Any discrepancies between data disclosed in this document are due to the effect of rounding. All amounts, unless otherwise specified, are expressed in thousands of euros.

  Reference to regulatory reporting requirements on a quarterly basis: Implementing Regulation (EU) 3172/2024

  The table below shows the templates required on quarterly basis, applicable to FinecoBank Group. Therefore, the following tables are excluded:

• EU CMS1 and EU CMS2 since the Group does not use internal models to calculate risk-weighted exposure amounts;

• EU CR8 since the Group does not use internal models (IRB) to calculate risk-weighted exposure amounts for credit risk;

• EU CCR7 since the Group does not use internal models (IMM) to calculate risk-weighted exposure amounts for counterparty credit risk;

• EU MR2-B since the Group does not use internal models (IMA) to calculate risk-weighted exposure amounts for market risk;

• EU CVA4 since the Group does not use the standardized model to calculate risk-weighted exposure amounts for credit valuation adjustments.

  TABLE	TOPIC	CHAPTER
  EU OV1	Overview of total risk exposure amounts	Own funds requirements and risk-weighted exposure amounts
  EU KM1	Key metrics	Key metrics
  EU LIQ1	Quantitative information of LCR	Liquidity requirements
  EU LIQB	Qualitative information on LCR, which complements template EU LIQ1	Liquidity requirements

  Reference to the information required by Part Eight of CRR

  The table shows the information required, on a quarterly basis, by CRR.

  ARTICLE	TOPIC	CHAPTER
  438 letters	Disclosure of own funds requirements and risk-weighted	Own funds requirements and risk-weighted exposure
  d), da) and h)	exposure amounts	amounts
  447	Disclosure of key metrics	Key metrics
  451a paragraph 2	Disclosure of liquidity requirements	Liquidity requirements

  It should be noted that the information referred to in the sections of the articles listed above for which a quarterly frequency is required to large institutions, as detailed in 433a of the CRR, is subject to publication in this document.

  Key metrics

  Below is reported the EU KM1 table on key metrics, the details and qualitative information of which are reported within the document, if requested on quarterly basis, in the specific dedicated sections.

  The following table EU KM1 reports information required by article 447 letters from a) to g) of CRR, in particular:

  • the composition of own funds and own funds requirements;

  • the total amount of risk exposure;

  • the amount and composition of additional own funds that institutions are required to hold;

  • the combined buffer requirement that institutions are required to hold;

  • the leverage ratio and exposure measure;

  • information in relation to liquidity coverage ratio;

  • information in relation to net stable funding requirement.

    All minimum requirements applicable to the FinecoBank Group as at 31 March 2026 are met. The calculation of Own Funds, and in particular of CET1 capital as at 31 March 2026, took into account foreseeable dividends and charges for a total amount of 131,269 euro thousand, assuming the conditions of Article 26(2) of the CRR are met.

    EU KM1 - Key metrics

    (Amounts in € thousand)

    		a	b	c	d	e
    		03.31.2026	12.31.2025	09.30.2025	06.30.2025	03.31.2025
    Available own funds (amounts)
    1	Common Equity Tier 1 (CET1) capital	1,470,351	1,445,203	1,391,422	1,362,025	1,341,370
    2	Tier 1 capital	1,970,351	1,945,203	1,891,422	1,862,025	1,841,370
    3	Total capital	1,970,351	1,945,203	1,891,422	1,862,025	1,841,370
    Risk-weighted exposure amounts
    4	Total risk exposure amount	6,299,479	6,201,582	5,814,637	5,805,481	5,590,726
    4a	Total risk exposure pre-floor	6,299,479	6,201,582	5,814,637	5,805,481	5,590,726
    Capital ratios (as a percentage of risk-weighted exposure amount)
    5	Common Equity Tier 1 ratio (%)	23.34%	23.30%	23.93%	23.46%	23.99%
    5b	Common Equity Tier 1 ratio considering unfloored TREA (%)	23.34%	23.30%	23.93%	23.46%	23.99%
    6	Tier 1 ratio (%)	31.28%	31.37%	32.53%	32.07%	32.94%
    6b	Tier 1 ratio considering unfloored TREA (%)	31.28%	31.37%	32.53%	32.07%	32.94%
    7	Total capital ratio (%)	31.28%	31.37%	32.53%	32.07%	32.94%
    7b	Total capital ratio considering unfloored TREA (%)	31.28%	31.37%	32.53%	32.07%	32.94%
    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 (%)	2.00%	2.00%	2.00%	2.00%	2.00%
    EU 7e	of which: to be made up of CET1 capital (percentage points)	1.13%	1.13%	1.13%	1.13%	1.13%
    EU 7f	of which: to be made up of Tier 1 capital (percentage points)	1.50%	1.50%	1.50%	1.50%	1.50%
    EU 7g	Total SREP own funds requirements (%)	10.00%	10.00%	10.00%	10.00%	10.00%
    Combined buffer and overall capital requirement (as a percentage of risk-weighted exposure amount)
    8	Capital conservation buffer (%)	2.50%	2.50%	2.50%	2.50%	2.50%
    EU 8a	Conservation buffer due to macro-prudential or systemic risk identified at the level of a Member State (%)	-	-	-	-	-
    9	Institution specific countercyclical capital buffer (%)	0.15%	0.15%	0.14%	0.14%	0.13%
    EU 9a	Systemic risk buffer (%)	0.38%	0.38%	0.40%	0.41%	0.21%
    10	Global Systemically Important Institution buffer (%)	-	-	-	-	-
    EU 10a	Other Systemically Important Institution buffer (%)	-	-	-	-	-
    11	Combined buffer requirement (%)	3.03%	3.03%	3.04%	3.05%	2.84%
    EU 11a	Overall capital requirements (%)	13.03%	13.03%	13.04%	13.05%	12.84%
    12	CET1 available after meeting the total SREP own funds requirements (%)	17.71%	17.67%	18.30%	17.83%	18.36%

    Key metrics

    continued EU KM1 - Key metrics

    (Amounts in € thousand)

    		a	b	c	d	e
    		03.31.2026	12.31.2025	09.30.2025	06.30.2025	03.31.2025
    Leverage ratio
    13	Total exposure measure	38,326,346	38,355,223	37,032,524	35,812,644	34,460,784
    14	Leverage ratio (%)	5.14%	5.07%	5.11%	5.20%	5.34%
    Additional own funds requirements to address the risk of excessive leverage (as a percentage of total exposure measure)
    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 (%)	3.00%	3.00%	3.00%	3.00%	3.00%
    Leverage ratio buffer and overall leverage ratio requirement (as a percentage of total exposure measure)
    EU 14d	Leverage ratio buffer requirement (%)	-	-	-	-	-
    EU 14e	Overall leverage ratio requirement (%)	3.00%	3.00%	3.00%	3.00%	3.00%
    Liquidity Coverage Ratio
    15	Total high-quality liquid assets (HQLA) (Weighted value -average)	24,508,340	24,064,395	23,567,530	22,873,792	22,118,611
    EU 16a	Cash outflows - Total weighted value	3,889,014	3,885,782	3,883,046	3,818,173	3,792,887
    EU 16b	Cash inflows - Total weighted value	1,371,901	1,368,347	1,347,830	1,306,074	1,295,140
    16	Total net cash outflows (adjusted value)	2,517,113	2,517,435	2,535,217	2,512,099	2,497,748
    17	Liquidity coverage ratio (%)	976.06%	957.85%	931.02%	912.15%	887.96%
    Net Stable Funding Ratio
    18	Total available stable funding	32,095,710	32,162,813	31,320,887	30,558,801	29,732,236
    19	Total required stable funding	7,781,569	7,701,917	7,153,990	7,580,479	7,629,755
    20	NSFR ratio (%)	412.46%	417.59%	437.81%	403.12%	389.69%

    Please note that the information on the Liquidity Coverage Ratio refers to the weighted average values, consistent with the representation provided in the EU LIQ1 template.

    Own funds requirements and risk-weighted exposure amounts

    The Group deems as a priority the activities of capital management and allocation based on the risk assumed in order to expand its operations and create value. These activities involve the various planning and control stages and, specifically, the planning, budgeting and monitoring processes (analysis of expected and actual performance, analysis and monitoring of limits, performance analysis and monitoring of capital ratios).

    In the dynamic management of capital, the Group draws up the capital plan and monitors the regulatory capital requirements, anticipating the appropriate actions to achieve the targets.

    On the basis of the EU regulations set out in CRD and CRR, collated and implemented by the Bank of Italy through Circular No. 285 of December 17, 2013 "Supervisory Regulations for Banks" as amended, the Bank must satisfy the following own funds requirements established in Article 92 of the CRR, expressed as a percentage of the total risk exposure amount (RWA - Risk Weighted Assets):

  • a Common Equity Tier 1 capital ratio of at least 4.5%;

  • a Tier 1 capital ratio of at least 6%;

  • a Total capital ratio of at least 8%.

    Furthermore, in addition to these minimum requirements, banks are required to meet the combined buffer requirement, according to the article 128(6) of EU Directive 2013/36/EU. Failure to comply with such combined buffer requirement triggers restrictions on distributions, requiring the calculation of the Maximum Distributable Amount (MDA), and the need to adopt a capital conservation plan.

    The combined buffer requirement applicable to FinecoBank includes the following buffers:

  • Capital Conservation Buffer (CCB) according to the article 129 of CRDIV, which is equal to 2.5% of the total Group risk weighted assets;

  • Institution specific countercyclical capital buffer (CCyB) to be applied in periods of excessive credit growth, coherently with the article 160 of CRDIV (paragraphs 1 to 4) which for the Bank is equal to 0.15% as of 31 March 2026. This buffer is calculated depending on the geographical distribution of the relevant Group's credit exposures and on the national authorities' decisions, which define country-specific buffers;

  • Systemic Risk Buffer (SyRB) defined by the Bank of Italy for all banks authorised in Italy to be applied to a rate of 1% to credit and counterparty risk-weighted exposures to Italian residents, which for the Group is equal to 0.38% as of 31 March 2026.

    With reference to the capital requirements applicable to the FinecoBank Group, it should be noted that, at the end of the Supervisory Review and Evaluation Process (SREP), on 3 November 2025 the the Competent Authority communicated that the Pillar 2 Requirement (P2R) applicable to the Group remains unchanged: 2.00% in terms of Total Capital ratio, of which 1.13% in terms of Common Equity Tier 1 ratio and 1.50% in terms of Tier 1 Ratio.

    Below is a summary of the capital requirements and reserves applicable to the FinecoBank Group which also highlights the 'Total SREP Capital Requirement' (TSCR) and the 'Overall Capital Requirement' (OCR) requirements.

    Capital requirements and buffers for FinecoBank Group

    Requirements	CET1	T1	TOTAL CAPITAL
    A) Pillar 1 requirements	4.50 %	6.00 %	8.00 %
    B) Pillar 2 requirements	1.13 %	1.50 %	2.00 %
    C) TSCR (A+B)	5.63 %	7.50 %	10.00 %
    D) Combined Buffer requirement, of which:	3.03 %	3.03 %	3.03 %
    1. Capital Conservation Buffer (CCB)	2.50 %	2.50 %	2.50 %
    2. Institution-specific Countercyclical Capital Buffer (CCyB)	0.15 %	0.15 %	0.15 %
    3. systemic risk buffer for FinecoBank (SyRB)	0.38 %	0.38 %	0.38 %
    E) Overall Capital Requirement (C+D)	8.66 %	10.53 %	13.03 %

    As at 31 March 2026, FinecoBank ratios are compliant with the above requirements.

    The Group assesses capital adequacy by managing and allocating (regulatory and economic) capital according to the risks assumed and with the aim of directing its operations towards the creation of value. The Group has the goal of generating income in excess of that necessary to remunerate risk (cost of equity). This purpose is pursued by allocating capital according to specific risk profiles and ability to generate sustainable earnings, measured as EVA (Economic Value Added) and ROAC (Return on Allocated Capital), which are the main risk-related performance indicators.

    Capital and its allocation are therefore extremely important in defining strategies, since on the one hand it represents the shareholders' investment in the Group, which must be adequately remunerated, while on the other hand it is a scarce resource on which there are external limitations imposed by supervisory regulations.

    Own funds requirements and risk-weighted exposure amounts

    The definitions of capital used in the allocation process are as follows:

• Risk or employed capital: this is the equity component provided by shareholders (employed capital) for which a return that is greater than or equal to expectations (cost of equity) must be provided;

• Capital at risk: this is the portion of capital and reserves that is used (the budgeted amount or allocated capital) or was used to cover (at period-end - absorbed capital) risks assumed to pursue the objective of creating value.

Capital at risk is measured according to risk management techniques, for which risk capital is defined as internal capital, on the one hand, and supervisory regulations, for which risk capital is defined as regulatory capital, on the other.

Internal capital and regulatory capital differ in terms of their definition and the categories of risk covered. The former is based on the actual measurement of exposure assumed, while the latter is based on templates specified in regulatory provisions. Economic capital is set at a level that will cover adverse events with a certain probability (confidence interval), while regulatory capital is quantified based on a target ratio higher than that required by the supervisory regulations in force.

The process of capital allocation is based on a "dual track" logic, considering both economic capital, measured through the full evaluation of risks via risk management models, and regulatory capital, quantified applying internal capitalisation targets to regulatory capital requirements.

The Group dynamically manages its capital base by monitoring regulatory capital ratios, anticipating the appropriate changes necessary to achieve its defined targets, and optimising the composition of its assets and equity. The capital monitoring and planning is performed by the Group in relation to regulatory capital (Common Equity Tier 1, Additional Tier 1 and Tier 2 Capital and Own funds), and in relation to risk-weighted assets (RWAs). Planning is also carried out taking into account other dimensions relevant to the Group, such as exposure for leverage purposes.

The monitoring is accompanied by an efficient and appropriate communications system, both for management purposes and communications with the supervisory authorities.

The following EU OV1 template shows the information required under Article 438 letter d) of the CRR. It shows the total amount of risk-weighted exposure and the corresponding total own funds requirement, broken down by the different risk categories.