Decision of BGF regarding MREL requirements

The Management Board of Bank Millennium S.A. ("Bank") announces that it received a letter from the Banking Guarantee Fund ("BGF") regarding a joint decision of the resolution authorities, i.e. the Single Resolution Board (SRB) and BGF obliging the Bank to meet the communicated MREL (minimum level for own funds and eligible liabilities) requirements at the consolidated level, excluding Millennium Bank Hipoteczny, i.e.

1. MRELtrea calculated as a percentage of the total risk exposure amount (TREA), and

2. MRELtem calculated as a percentage of the total exposure measure (TEM).

The decision sets updated minimum requirements that must be met immediately after its receipt at the level of 15.36% - consolidated MRELtrea (previously 15.36% in the decision of 28.05.2025) and 5.91% - consolidated MRELtem (the same level as in the decision dated 28.05.2025). Respectively, taken a subordination criteria, the Bank is obliged to meet the minimum MRELtrea requirement of 14.14% (versus 14.15% in the decision dated 28.05.2025) and MRELtem of 5.54% (versus 5.54% in the decision dated 28.05.2025).

Additionally, MRELtrea requirement calculated for the Bank and increased by the combined buffer requirements expressed in nominal terms is lower than the amount of 8% of Total Liabilities and Own Funds (“TLOF”). Due to that, based on paragraph 4 in article 45c(3) of BRRD, BGF has set the MRELtem at the level not lower than 8% of TLOF. As result, from 1 st of January 2027 the MRELtrea requirement was set at the level of 15.36% and the MRELtem at the level of 7.70% on consolidated basis.

Taken a subordination criteria, from 1st of January 2027 the Bank will be obliged to meet the minimum MRELtrea requirement of 14.14% and MRELtem of 7.7%.

Pursuant to Article 97a(1)(2) of the Act on the Bank Guarantee Fund (BFG Act), liabilities shall be included in the amount of own funds and eligible liabilities only where they meet the eligibility criteria referred to in Articles 72a and 72b of the CRR, excluding the subordination requirement referred to in Article 72b(2)(d) of the CRR, after taking into account amortisation in accordance with Article 72c of the CRR and deductions in accordance with Article 72k of the CRR.

At the same time, in accordance with Article 19(2)(3), Article 21(3)(3), Article 42(3) and Article 48(3) of the Act on macro-prudential supervision, which transposes Article 128 of the CRD, CET1 instruments held by the Bank for the purpose of the combined buffer requirement are not eligible for the MREL requirement expressed as a percentage of the total risk exposure. This rule does not apply to the MREL requirement expressed as a percentage of the total exposure measure (MREL TEM).

The Bank fulfils above requirements at the moment of publication of this report.

Legal basis: art. 17 sec. 1 of MAR - confidential information