← Back to GGAL filing summaryOriginal filing text · Part I
Item 11 — Quantitative and Qualitative Disclosures About Market Risk
Grupo Financiero Galicia SA · 20-F · FY 2025 · Period ended Dec 31, 2025
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A. General
Market risks faced by us arise from fluctuations in interest rates and foreign exchange rates. Our market risk primarily stems from the operations of Banco Galicia as a financial intermediary. While our subsidiaries are also subject to market risk, the extent of these risks is not significant and, therefore, not discussed in detail here. Policies regarding these risks are applied at the level of our operating subsidiaries.
In compliance with BCRA regulations and based on best practices and international standards, Banco Galicia has a Risk Management Division responsible for identifying, monitoring, and actively managing the various risks to which it is exposed, including credit, financial, and operational risks. The objective of the Risk Management Division is to ensure that Banco Galicia’s Board of Directors is fully aware of the risks to which the bank is exposed. The Risk Management Division also creates and proposes the policies and procedures necessary to mitigate and control these risks.
The Risk Management Committee of Banco Galicia is composed of six members of the Board of Directors, the Chief Executive Officer, and the Managing Directors of Risk and Finance & Strategic Planning. It is the highest corporate body to which the Board delegates comprehensive risk management. This Committee has executive responsibility for defining and enforcing risk management policies, procedures, and controls. The Risk Management Committee is also responsible for setting specific limits for exposure to each risk, approving temporary excesses over these limits when appropriate, and monitoring each risk position and compliance with policies.
See Item 6. “Directors, Senior Management and Employees”—“Functions of the Board of Directors of Banco Galicia”. Liquidity management is discussed in Item 5 “Operating and Financial Review and Prospects”—B.“Liquidity and Capital Resources”. Credit risk management is discussed in Item 4. “Information on the Company”—B.“Business Overview”—“Selected Statistical Information”—“Credit Review Process” and other sections under Item 4. “Information on the Company”—B.“Business Overview”—“Selected Statistical Information” describing Grupo Galicia’s financial instruments portfolio and financial instruments loss experience.
The following sections contain information on Banco Galicia’s sensitivity to interest-rate risk and exchange-rate risk. These sections include forward-looking statements that involve risks and uncertainties. Actual results could differ from those projected in the forward-looking statements.
B. Interest Rate Risk
A distinctive and natural characteristic of financial brokerage is the existence of interest-earning assets and interest-bearing liabilities with different maturities (or different rate repricing periods) and interest rates that can be fixed or variable. This situation leads to a gap or mismatch that arises from the balance sheet and measures the imbalance between fixed- and variable-rate assets and liabilities, resulting in the so-called interest-rate risk or balance sheet structural risk. A commercial bank can face interest rate risk on both sides of its balance sheet: with regard to the income generated by assets (loans and securities) and the expenses related to the interest-bearing liabilities (deposits and other sources of funds).
The policy currently in force defines this gap as the risk that the financial margin and the economic value of equity may vary as a consequence of fluctuations in market interest rates. The magnitude of such variation is associated with the sensitivity to interest rates of the structure of Banco Galicia's assets and liabilities.
To manage and limit the sensitivity of the economic value and results of Banco Galicia with respect to variations in interest rates inherent to the structure of certain assets and liabilities, the following limits have been determined:
• Limit on the Gross Brokerage Margin (“GBM”) for the first year: This limit helps control the potential impact on the financial margin due to interest rate changes within the first year. For further details, see item i) below
• Limit on the net present value of assets and liabilities: This limit ensures that the overall economic value of the bank's assets and liabilities. remains stable despite fluctuations in interest rates. For further details, see item ii) below.
By adhering to these limits, Banco Galicia aims to mitigate the risks associated with interest rate
fluctuations and maintain financial stability.
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i) Limit on the GBM for the First Year
The effect of interest rate fluctuations on the GBM for the first year is calculated using the methodology known as scenario simulation. On a monthly basis, the GBM for the first year is simulated in a base scenario and in a “+550 bps” scenario for Peso currency, “+100 bps” scenario for dollar currency and “+200 bps” scenario for UVA currency. To prepare each scenario, different criteria are assumed regarding the sensitivity to interest rates of assets and liabilities, based on the historical performance observed for the different balance sheet items. The GBM for the first year in the “+550 bps”, “+100 bps” and “+200 bps” scenarios is compared to the GBM for the first year in the “base” scenario. The resulting difference is related to the annualized accounting GBM for the last calendar trailing quarter available, for Banco Galicia on a consolidated basis.
The limit on a potential loss was established at 20% of the GBM for the first year, as defined above. At fiscal year-end, the negative difference between the GBM for the first year corresponding to the “+400/100/200 bps” scenario and that corresponding to the “base” scenario accounted for -2.4% of the GBM for the first year.
The tables below show as of December 31, 2025 in absolute and percentage terms, the change in Banco Galicia’s consolidated GBM for the first year, as compared to the GBM of the “base” scenario corresponding to various interest-rate scenarios in which interest rates change 50, 100, 150 and 200 bps from those in the “base” scenario. Banco Galicia’s net portfolio is broken down into trading and non-trading. The trading net portfolio primarily represents securities issued by the Government.
Net Portfolio
Gross Brokerage Margin (1)
December 31, 2025
(In millions of Pesos, except percentages)
Change in Interest Rates in bps Variation % Change in the GBM
200 134,411 2.39 %
150 108,802 1.94 %
100 83,267 1.48 %
50 57,805 1.03 %
Static
(50) (1,709) (0.03) %
(100) (21,868) (0.39) %
(150) (42,150) (0.75) %
(200) (62,379) (1.11) %
(1)Net interest of the first year
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Net Trading Portfolio
Gross Brokerage Margin (1)
December 31, 2025
(In millions of Pesos, except percentages)
Change in Interest Rates in bps Variation % Change in the GBM
200 8,827 0.16 %
150 6,610 0.12 %
100 4,400 0.08 %
50 2,197 0.04 %
Static
(50) (2,190) (0.04) %
(100) (4,374) (0.08) %
(150) (6,551) (0.12) %
(200) (8,721) (0.16) %
(1)Net interest of the first year
Net Non -Trading Portfolio
Gross Brokerage Margin (1)
December 31, 2025
(In millions of Pesos, except percentages)
Change in Interest Rates in bps Variation % Change in the GBM
200 125,584 2.24 %
150 102,192 1.82 %
100 78,867 1.40 %
50 55,608 0.99 %
Static
-50 482 0.01 %
-100 (17,494) (0.31) %
-150 (35,599) (0.63) %
-200 (53,658) (0.95) %
(1)Net interest of the first year
ii) Limit on the Net Present Value of Assets and Liabilities
The net present value of assets and liabilities is also calculated on a monthly basis and taking into account the assets and liabilities of Banco Galicia’s consolidated balance sheet. The methodology used for calculating interest rate risk is based on the net present value of the underlying assets and liabilities.
The net present value of the consolidated assets and liabilities is calculated for a “base” scenario, where the listed securities portfolio is discounted using interest rates derived from yield curves based on the market yields of various reference bonds denominated in Pesos, foreign currency and adjusted by CER/UVA. Yield curves for unlisted assets and liabilities are also created using market interest rates. Additionally, the net present value of assets and liabilities is calculated for a “critical” scenario. This scenario is derived from a significant number of statistical simulations of historical interest rate data, representing the interest rate risk exposure presented by the balance sheet structure.
The economic capital is obtained from the difference between the “critical” scenario and the net present value of assets and liabilities in the “base” scenario, considering a 99.5% degree of accuracy.
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The limit on interest rate risk exposure, expressed as the difference between the net present value of assets and liabilities in the “base” scenario and the “critical” scenario cannot exceed 12% of the consolidated Tier 1 capital. As of December 31, 2025, the “Value at Risk” was -4.6% of the Tier 1 capital.
C. Foreign Exchange Rate Risk
Exchange-rate sensitivity is the relationship between the fluctuations of exchange rates and Banco Galicia’s net financial income resulting from the revaluation of Banco Galicia’s assets and liabilities denominated in foreign currency. The impact of variations in the exchange rate on Banco Galicia’s net financial income depends on whether Banco Galicia has a net asset foreign currency position (the amount by which foreign currency denominated assets exceed foreign currency denominated liabilities) or a net liability foreign currency position (the amount by which foreign currency denominated liabilities exceed foreign currency denominated assets). In the first case an increase/decrease in the exchange rate results in a gain/loss, respectively. In the second case, an increase/decrease results in a loss/gain, respectively. Banco Galicia has established limits for its consolidated foreign currency mismatches for the asset and liability positions of +30% of Banco Galicia’s RPC. At the end of the fiscal year 2025, Banco Galicia’s net asset position in foreign currency represented -0.9% (minus 0.9%).
As of December 31, 2025, Banco Galicia had a net assets foreign currency position of Ps.253,687 million (US$173.8 million) after adjusting its on-balance sheet net assets position of Ps.51,208 million (US$35.1 million) by net forward purchases of foreign currency without delivery of the underlying liability, for Ps.202,479 million (US$138.7 million), recorded off-balance sheet.
The table below show the effects of changes in the exchange rate of the Peso vis-à-vis the Dollar on the value of Banco Galicia’s foreign currency net asset position as of December 31, 2025. As of these dates, the breakdown of Banco Galicia’s foreign currency net asset position into trading and non-trading is not presented, as Banco Galicia’s foreign currency trading portfolio was not material.
Value of Foreign Currency Net Position As of December 31,
2025
Percentage Change in the Value of the Peso Relative to the Dollar (1) Amount Absolute Variation % Change
(in millions of Pesos, except percentages)
40% (355,162) (101,475) 40
30% (329,793) (76,106) 30
20% (304,424) (50,737) 20
10% (279,056) (25,369) 10
Static (2) (253,687) — —
-10% (228,318) 25,369 (10)
-20% (202,950) 50,737 (20)
-30% (177,581) 76,106 (30)
-40% (152,212) 101,475 (40)
____________________
(1)Devaluation / (Revaluation).
(2)Adjusted to reflect forward purchases and sales of foreign currency without delivery of the underlying asset, registered in memorandum accounts.
D. Currency Mismatches
The funding and the use of funds in loans and/or investments can be carried out in assets and liabilities denominated in different currencies. As such, there is the potential for a currency mismatch between liabilities and the use thereof on assets, generating a risk. Currency risk is defined as the risk of incurring equity losses as a result of variations in the foreign currency exchange rates in which assets and liabilities are denominated.
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The management of the Bank’s currency risk mismatch involves the monitoring of foreign currency-denominated assets and liabilities that may change in the short- and or mid-term. One of the available market instruments for the management of currency mismatches of assets and liabilities are “currency futures” transactions, which are traded on the A3 Mercados.
The policy framework currently in force establishes limits in terms of maximum net asset positions (assets denominated in a currency which are higher than the liabilities denominated in such currency) and net liability positions (assets denominated in a currency which are lower than the liabilities denominated in such currency) for mismatches in foreign currency, as a proportion of the Bank’s computable regulatory capital (RPC), on a consolidated basis.
The table below shows the composition of the Grupo Financiero Galicia’s Shareholders’ Equity as of December 31, 2025, by currency and type of adjustment:
December 31, 2025
Assets Liabilities Gap
(in millions of Pesos)
Financial Assets and Liabilities 43,261,274 36,519,538 6,741,736
Pesos - Adjusted by UVA 2,761,525 118,004 2,643,521
Pesos - Unadjusted 25,289,611 21,502,021 3,787,590
Foreign Currency (1) 15,210,138 14,899,513 310,625
Other Assets and Liabilities 2,483,861 1,458,766 1,025,095
Total Gap 45,745,135 37,978,304 7,766,831
Adjusted for Forward Transactions Recorded in Memo Accounts
Financial Assets and Liabilities 43,261,274 36,519,538 6,741,736
Pesos - Adjusted by the UVA 2,761,525 118,004 2,643,521
Pesos - Unadjusted, Including Shareholders’ Equity (2) 23,541,414 19,769,498 3,771,916
Foreign Currency (1) (2) 16,958,335 16,632,036 326,299
Other Assets and Liabilities 2,483,861 1,458,766 1,025,095
Total Adjusted Gap 45,745,135 37,978,304 7,766,831
(1)In Pesos, at an exchange rate of Ps.1,459.4167 per US$1.
(2)Adjusted for forward sales and purchases of foreign exchange, without delivery of underlying assets and recorded in Memorandum Accounts.
As of December 31, 2025, considering the adjustments from forward transactions recorded under memorandum accounts, Grupo Financiero Galicia had net asset positions in foreign currency and Pesos adjusted and non-adjusted.
The paragraphs below describe the composition of the different currency mismatches of assets and liabilities as of December 31, 2025:
i) Assets and Liabilities Denominated in Foreign Currency
As of December 31, 2025, Grupo Financiero Galicia’s assets denominated in foreign currency were mainly comprised of the following: (i) Ps. 7,627,036 million in cash and balances with the Central Bank of Argentina (BCRA) and correspondent banks; (ii) Ps. 6,390,520 million in loans to the non-financial private sector and residents abroad (principal plus interest, net of allowances), and other financing, including Ps. 2,081 million in receivables from financial leases; (iii) Ps. 540,420 million in government and private securities; (iv) Ps. 428,239 million in debt securities; (v) Ps. 178,006 million in other financial assets, including Ps. 6,105 million related to Prisma; (vi) Ps. 22,065 million in investments, including equity instruments and investments in subsidiaries, associates and joint ventures; and (vii) Ps. 16,490 million in assets pledged as collateral, including forward purchases of government securities.
The liabilities denominated in foreign currency consisted mainly of: (i) Ps. 12,192,242 million in deposits (principal, interest and exchange rate differences); (ii) Ps. 1,686,615 million in subordinated and non-subordinated notes issued by Banco Galicia and Naranja; (iii) Ps. 698,929 million in other financial liabilities, mainly collections on behalf of
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third parties, including Ps. 329,493 million related to such collections, Ps. 30,470 million in lease liabilities, Ps. 14,012 million related to securities transactions, and amounts related to sales of government securities and foreign currency pending settlement; (iv) Ps. 278,117 million in borrowings from banks and international credit organizations; and (v) Ps. 43,611 million recorded under “Other Non-financial Liabilities”.
A net assets position of Ps.310,625 million stemmed from the consolidated balance sheet. Furthermore, forward transactions in foreign currency without delivery of the underlying asset were recorded in memorandum accounts, which, in terms of their notional value, were equal to a net liability position of Ps.10,740 million. Therefore, as of that date, the net position in foreign currency adjusted to reflect these transactions was a net asset position of Ps 326,299 million, equivalent to US$223.6 million.
Grupo Financiero Galicia has set limits as regards foreign currency mismatches at -9% of the computable regulatory capital (RPC) for the Bank's net liability position and +30% for net asset positions. At the fiscal year-end, Banco Galicia’s net liability position in foreign currency represented 4.4% of its RPC.
ii) Non-Adjusted Peso-Denominated Assets and Liabilities
Grupo Financiero Galicia’s non-adjusted Peso-denominated assets at December 31, 2025 were mainly comprised of the following: (i) Ps. 15,032,600 million for loans (principal plus interest, net of allowances), including Ps. 47,045 million for receivables from financial leases and Ps. 34,346 million for miscellaneous receivables; (ii) Ps. 5,724,954 million for the holding of government and private securities, including Ps. 45,200 million for BOTE 2027; (iii) Ps. 2,234,133 million for cash and balances held at the BCRA and correspondent banks (including the balance of escrow accounts); and (iv) Ps. 989,314 million for assets pledged as collateral, including forward purchases of government securities.
Grupo Financiero Galicia’s non-adjusted Peso-denominated liabilities at December 31, 2025 were mainly comprised of the following: (i) Ps. 15,358,694 million for deposits (principal plus interest); (ii) Ps. 3,048,987 million for liabilities payable to stores related to credit card transactions of Banco Galicia and regional credit card companies; (iii) Ps. 970,548 million for liabilities arising from insurance contracts; (iv) Ps. 733,823 million for other financial liabilities; (v) Ps. 603,628 million for debt incurred with local financial institutions (almost entirely related to regional credit card companies); (vi) Ps. 357,331 million for repurchase agreement transactions; (vii) Ps. 311,916 million for notes issued by Banco Galicia and regional credit card companies; (viii) Ps. 58,320 million for amounts payable for transactions pending settlement and forward transactions; and (ix) Ps. 40,431 million for obligations payable to third parties arising from securities transactions.
The net asset position in non-adjusted Peso-denominated assets and liabilities was Ps. 3,771,916 million on December 31, 2025.
iii) Peso-Denominated Assets and Liabilities Adjusted by UVA
At December 31, 2025, the net asset position amounted to Ps. 2,643,521 million, which is primarily comprised of Ps.1,925,073 million for loans, mainly UVA mortgage loans, Ps.793,209 million for the holding of adjustable government securities (LECER) and Ps.43,243 million for miscellaneous receivables, mainly employee loans and receivables arising from the sale of Prisma.
With respect to liabilities, Ps.73,958 million related to balances of the unemployment fund of construction workers and Ps.44,046 million was related to UVA‑adjusted time deposits.
iv) Other Assets and Liabilities
As of December 31, 2025, “Other Assets—Liabilities” mainly included the following:(i) Ps. 1,695,980 million for property, plant and equipment, miscellaneous and intangible assets; (ii) Ps. 436,984 million for miscellaneous receivables; (iii) Ps. 229,812 million recorded in “Other Non‑financial assets”; and (iv) Ps. 9,564 million for non‑current assets held for sale.
As of December 31, 2025, liabilities mainly included the following: (i) Ps. 1,082,795 million recorded in “Other Non‑financial Liabilities”; (ii) Ps. 260,562 million for provisions for other contingencies; and (iii) Ps. 115,409 million for current income tax liabilities.
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E. Market Risk
The exposure of portfolios consisting of listed financial instruments, whose values vary according to the movements in their market prices, is subject to a specific policy framework. This framework regulates the risk of incurring a loss due to variations in the market price of financial assets whose values are subject to negotiation.
Brokerage transactions and/or investments in government securities, currencies, notes, derivative products and debt instruments issued by the BCRA are governed by the policy that limits the maximum tolerable losses in a given fiscal year.
To gauge and monitor this source of risk, the Value at Risk (VaR) model, among others, is used. Banco Galicia measures risk by means of a parametric VaR model, assuming that returns follow a multivariate normal distribution. This model determines on an intra-daily basis the potential losses that could be generated for Banco Galicia individually according to its portfolio, under certain parameters. This model provides the expected loss in the bank's returns with a 99% confidence level.
The parameters considered are as follows:
(i) Confidence level: A 99% confidence level is used for the VaR model analysis..
(ii) Holding Periods: Holding periods of one day and “n” days, where “n” is defined as the number of days necessary to settle the position in each security.
(iii) Volatilities: Volatilities are calculated as the standard deviation of returns in the available trading days. If there are new issuances, or if there are not enough trading days or quotations, the volatility of bonds from domestic issuers with similar risk and characteristics are used.
Banco Galicia’s policy requires that the Risk Management and Treasury Divisions agree on the parameters under which the models operate. The policy also establishes the maximum losses authorized for equity securities, foreign-currency, BCRA’s debt instruments and derivative products in a fiscal year. Maximum losses were established in:
Risk Policy on Limits
(in millions of Pesos)
Total risk (currency + fixed-income instruments + interest rate derivatives) 174,337
Furthermore, the policy includes the regular undertaking of stress tests, with the goal to assess the risk positions and their results under adverse market conditions. Finally, “contingency plans” were designed for each transaction, which include the actions to be implemented in a critical scenario.
F. Cross-Border Risk
Cross-border risk represents the risk of incurring equity losses due to the impairment or failure to collect on foreign credit exposures (loans, securities holdings, equity investments, and cash) abroad. This risk includes exposures arising from transactions with public or private counterparties domiciled outside of Argentina.
To regulate risk exposures in international jurisdictions, limits were established based on the jurisdiction’s credit rating, the type of transaction, and the maximum acceptable exposure for each counterparty.
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Banco Galicia has defined their policy by setting maximum exposure limits, measured as a percentage of their RPC (Regulatory Capital), and considering whether the counterparty is deemed investment grade:
Risk Required Credit Rating Investment Grade Not Investment Grade
- Jurisdictional Risk - International Rating Agency - No limit - No limit
- Counterparty Risk - International Banking Relations - Credit Division - Maximum limit: 25% - The limit is distributed between financial and foreign trade transactions, thus absorbing local counterparty margin '- Maximum Limit per Economic Group: 5%- Only foreign trade transactions
G. Overseas Foreign Currency Transfer Risk
With a view towards mitigating the risk resulting from potential changes in domestic laws that may affect overseas foreign currency transfers and to meet incurred liabilities, a policy was devised to set a limit for liabilities transferred abroad, as a proportion to total consolidated liabilities. This ratio was fixed at 15%.
As of December 31, 2025, such exposure was 5.13% of total liabilities.
H. Risk Exposures in the Non-Financial Public Sector
The BCRA imposes restrictions on financing for the non-financial public sector and establishes limits regarding the agencies that can be aided, the types of permitted loans and maximum amounts that can be granted. These maximum amounts are set based on Banco Galicia' RPC (Regulatory Capital).
Banco Galicia provides two types of financial assistance to this sector:
(i) Assistance through the issuance of government securities: this involves purchasing or underwriting government-issued securities; and
(ii) Direct assistance: this includes loans, leasing, corporate securities, discounted notes, overdrafts, guarantees granted, foreign trade transactions, payroll loans, credit cards, and other financial products.
Risk exposures on loans granted to the non-financial public sector in national, provincial and municipal jurisdictions are governed by a specific policy. This policy applies to agencies within these jurisdictions, decentralized entities, companies and trust funds with underlying cash flows from the non-financial public sector.