A. [Reserved] B. Capitalization and Indebtedness Not applicable. C. Reasons for the Offer and Use of Proceeds Not applicable. D. Risk Factors You should carefully consider the risks described below in addition to the other information contained in this annual report. In addition, most, if not all, of the risks described below must be evaluated bearing in mind that our most important asset is our equity interest in Banco Galicia. Thus, a material change in Banco Galicia’s shareholders’ equity or income statement would also adversely affect our businesses and results of operations. We may also face risks and uncertainties that are not presently known to us or that we currently deem immaterial, which may impair our business. Our operations, property and customers are located in Argentina. Accordingly, the quality of our customer portfolio, loan portfolio, financial condition and results of operations depend, to a significant extent, on the macroeconomic and political conditions prevailing in Argentina. In general, the risk assumed when investing in the securities of issuers from countries such as Argentina is higher than when investing in the securities of issuers from developed countries. Risk Factors Relating to Argentina The current state of the Argentine economy, together with uncertainty regarding the Government, may adversely affect our business and prospects. Grupo Galicia’s results of operations may be affected by inflation, fluctuations in the exchange rate, modifications in interest rates, changes in the Government’s policies and other political or economic developments either internationally or in Argentina. During the course of the last decades, Argentina’s economy has been marked by a high degree of instability and volatility, periods of low or negative economic growth and high fluctuating levels of inflation and currency devaluation. Grupo Galicia’s results of operations, the rights of holders of ADSs (American Depositary Shares), the value of the ADSs and the ability of Grupo Galicia to pay cash distributions to the Depositary for paying the cash dividends or other distributions on the Class B ordinary shares represented by the ADSs, could be materially and adversely affected by a number of possible factors, some of which include Argentina’s inability to achieve a sustainable economic growth path, high inflation rates, Argentina’s ability to obtain financing, a decline in the international prices for Argentina’s main commodity exports, fluctuation in the exchange rates of the currency of other countries (which affects local commercial competitiveness) and the vulnerability of the Argentine economy to external shocks. During the past fifteen years, Argentina experienced economic stagnation as a result of unstable monetary, fiscal and economic regulatory policies. In particular, the Argentine economy has proven to be and continues to be vulnerable to several factors, including: •economic growth rate volatility; •high inflation rates; •exposure to recessionary periods; 6 Table of Contents •interest rate volatility; •regulatory uncertainty for certain economic activities and sectors; •volatility in Argentina’s main export commodities’ prices. The economic recovery has depended in the past, in part, on the high prices of commodities produced by Argentina, which are volatile and beyond the control of the Government; •the stability and competitiveness of the Peso with respect to other currencies; •external financial conditions; •fluctuations in the BCRA’s international reserves; and •uncertainty with respect to exchange and capital controls The Government may implement changes to current policies and regulations or maintain existing ones. Political uncertainty in Argentina regarding both the measures already adopted and those they may adopt in the future could lead to volatility in the market prices of the securities of Argentine entities and, where appropriate, could have a material adverse effect on the economy or on Argentina's ability to meet its obligations, which could affect the Company's financial condition and results of operations. According to estimates made by the IMF in its World Economic Outlook report published in January 2026, Argentina's GDP is projected to grow by 4% in 2026 and another 4% in 2027. However, the Company cannot guarantee growth levels in future years or that the Argentine economy will not suffer a recession. If macroeconomic and political conditions in Argentina become unstable, this could impact the Company's business, its financial results, the price of notes issued by the Company or any of its subsidiaries, and its repayment capacity. Going forward, there can be no assurance that the current or future administrations will refrain from adopting measures that could negatively affect Grupo Galicia´s operations and financial results. Additionally, Grupo Galicia cannot predict the impact that past policies will have on the Argentine economy in general and on the banking sector in particular. Volatility in the regulatory framework, including whether the current administration will implement economic policy reforms, and the impact that these measures and any future measures taken by a new administration will have on the Argentine economy, remains uncertain. From time to time, prior administrations have enacted several laws amending various aspects of regulatory framework governing in an effort to stimulate the economy, some of which have had adverse effects on Grupo Galicia’s business. Although the current administration has eliminated certain measures implemented by previous administrations, political and social pressures could inhibit the Government’s implementation of new policies designed to generate growth and enhance consumer and investor confidence. In addition, as of the date of this annual report, the impact that the reforms adopted by the current Government will have on the Argentine economy as a whole, and the financial sector in particular, remains uncertain and cannot be predicted. It is also currently unclear what additional measures the current Government may implement in the future and what the effects such measures may have on the Argentine economy. Measures already adopted by the Government or future measures implemented may be disruptive to the economy and may fail to benefit, or may harm, our business. In particular, Grupo Galicia has no control over the implementation of reforms to the regulatory framework that governs its operations and cannot guarantee that these reforms, if implemented, will be beneficial. The failure of these measures to achieve their intended goals could adversely affect the Argentine economy and Grupo Galicia’s business, financial position and results of operations. The Argentine economy and Grupo Galicia’s financial position and business could be adversely affected if the inflation rate were to accelerate again. Argentina’s National Institute of Statistics and Censuses (INDEC), the country’s sole institution legally authorized to produce official national statistics, underwent a period of institutional deterioration between 2007 and 2015 that gave rise to concerns regarding the reliability of its data. Although the inflation indicators produced by INDEC have been broadly accepted since the reforms implemented beginning in 2016, the possibility of future disputes over data quality cannot be ruled out, which could have implications for the broader economy and, in particular, for the financial sector. Historically, inflation has adversely affected the Argentine economy and the government's ability to establish conditions conducive to sustained economic growth. Moreover, the high degree of uncertainty surrounding key economic 7 Table of Contents variables and persistent inflationary instability could negatively impact economic activity and, in turn, materially and adversely affect the Company's business, results of operations, and financial position. A high inflation rate affects Argentina's competitiveness abroad and generates macroeconomic instability, which could negatively impact economic activity, employment, real wages, consumption, and interest rates. Uncertainty regarding these economic variables and unstable inflation levels can shorten contractual terms and affect the ability to plan and make decisions. All of this could have a negative impact on economic activity, income, and the purchasing power of consumers, all of which would adversely affect Grupo Galicia's financial position, business, and its ability to make payments on its debts and obligations. While the measures implemented by the current administration have resulted in a slowdown in inflation during its tenure, in the past inflation has undermined the Argentine economy and the government's ability to create conditions that drive economic growth. In particular, high inflation rates or a high level of volatility with respect to the same may materially and adversely affect the business volume of the financial system and prevent the growth of financial intermediation activity. This, in turn, could adversely affect economic activity and employment levels in Argentina. Combined with high inflation rates, Argentina has also displayed high volatility in its currency valuation, as a consequence of local imbalances and external shocks. Both high inflation rates and high levels of volatility in the inflation rate impact Argentina’s competitiveness abroad, as well as real salaries, employment rates, consumption rates and interest rates. A high level of uncertainty regarding these economic variables, and the lack of stability in terms of inflation, could lead to shortened contractual terms and affect the ability for corporations and individuals to plan and make decisions in the future. This may have a negative impact on economic activity and on the income of consumers and their purchasing power. All of the above could materially and adversely affect Grupo Galicia’s financial position, results of operations and business. Argentina’s and Argentine companies’ ability to obtain financing and to attract direct foreign investment is limited and may adversely affect Grupo Galicia’s financial position, results of operations and business. In the past, Argentina has had and continues to have limited access to external financing and has had different debt restructuring processes with foreign bondholders, multilateral financial institutions and other financial institutions. In more recent developments, in April 2025 Argentina entered into an Extended Fund Facility arrangement with the International Monetary Fund, which established a set of macroeconomic and policy targets for the country. Despite this agreement, significant structural imbalances persist that could impair Argentina’s ability to comply with its commitments. Any failure to meet the conditions of the IMF program or to service other external obligations could restrict or prevent access by the Republic of Argentina and the private sector to international capital markets, adversely affecting the Argentine economy as a whole. New or more onerous regulations limiting access to capital investments and further restrictions that limit access to international financing for the private sector could arise again in the future. Such an event could have a negative impact on Grupo Galicia’s business, financial condition and results of operations. In addition, Argentina may be unable to service its debt, may again be unable to access the international markets or other sources of financing or may need to go through a debt restructuring process again. All of such scenarios could have an adverse effect on the Argentine economy and, consequently, on Grupo Galicia’s operations. Argentine economy and its goods, financial services and securities markets remain vulnerable to external factors, which could affect Argentina’s economic growth and Grupo Galicia’s prospects. The financial and securities markets in Argentina are influenced, to varying degrees, by economic and market conditions in other countries. Although such conditions may vary from country to country, investor reactions to events occurring in one country may affect capital flows to issuers in other countries, and consequently affect the trading prices of their securities. Decreased capital inflows and lower prices in the stock market of a country may have a material adverse effect on the real economy of those countries in the form of higher interest rates and foreign exchange volatility. During periods of uncertainty in international markets, investors generally choose to invest in high-quality assets (flight to quality) at the expense of emerging market assets. This has had and could have a negative impact on the Argentine economy, and could continue to negatively impact the country's economy in the near future. 8 Table of Contents The monetary and fiscal policies implemented by the world’s leading economies, such as the U.S., China and the European Union have an effect on the Argentine economy through impacts on its interest rates, commodity prices and economic growth rates. Higher interest rates in leading economies negatively affect emerging markets such as Argentina. The economic activity of Brazil, one of Argentina’s main trade partners, also has an impact on Argentina’s economy. A depreciation of the Brazilian Real against the Dollar has in the past and would again in the future put additional pressure on the exchange rate for the Argentine Peso against the Dollar. Likewise, a weak economic performance from Brazil would affect Argentine exports, particularly in the case of industrial goods, many of which Argentina exports to Brazil. Adverse climate conditions and events may also affect Argentina’s economy, either by negatively impacting the local harvest and thus reducing export volumes, or by impacting other competing countries and affecting international commodities’ prices, which determine Argentine agricultural exports’ value. Additionally, increases in various interest rates could imply lower economic growth in any of Argentina's main trading partners (including Brazil, the European Union, China, and the United States). A new global economic and/or financial crisis, or the effects of a deterioration in the current international context, could affect the Argentine economy and, consequently, the results and operations of the Parties, which could substantially adversely affect their ability to meet their payment obligations. A potential devaluation of the Peso may hinder or potentially prevent Grupo Galicia from being able to honor its foreign currency denominated obligations. If the Peso depreciated against the Dollar, as has occurred in the past and which could occur again in the future, this could have an adverse effect on the ability of Argentine companies to make timely payments on their debts denominated in or indexed or otherwise connected to a foreign currency, generate very high inflation rates, reduce real salaries significantly, and have an adverse effect on companies focused on the domestic market, such as public utilities and the financial industry. Such a potential devaluation could also adversely affect the Argentine government’s capacity to honor its foreign debt, with adverse consequences for the Company’s businesses, which could affect the capacity of the Company or any of its subsidiaries to meet obligations denominated in U.S. Dollars. Additionally, the BCRA and the Treasury may intervene in the foreign exchange market to influence exchange rates. Purchases of Pesos by the entities could result in a decrease of its international reserves. A significant decrease in the BCRA international reserves may have an adverse impact on Argentina’s ability to withstand external shocks to the economy, and any adverse effects to the Argentine economy could, in turn, adversely affect the financial position and business of Grupo Galicia and its subsidiaries. Growing capital controls have been enforced since 2019 and remain in place until today, although some foreign exchange restrictions have been lifted since the current administrations took office. Any further depreciation of the Peso could adversely affect the Argentine economy and could negatively impact Grupo Galicia's business and its ability to service its existing debt obligations. Moreover, an acceleration of inflation caused by an exchange rate crisis would raise the costs associated with Grupo Galicia's subsidiaries servicing of their foreign currency-denominated debt. Any of these factors could increase Grupo Galicia’s costs thereby having a material adverse effect on Grupo Galicia’s financial condition and consequently, the trading value of its ADSs. Changes or new regulations in the Argentine foreign exchange market may adversely affect the ability and the manner in which Grupo Galicia repays its obligations denominated in, indexed to or otherwise connected to a foreign currency. During the last two decades, different government administrations have established and implemented various restrictions on foreign currency transfers (both in respect of transfers into and out of Argentina). The impact that these measures or potential future measures will have on the Argentine economy and Grupo Galicia is uncertain. Grupo Galicia cannot assure you that the regulations will not be amended, or that no new regulations will be enacted in the future imposing greater limitations on funds flowing into and out of the Argentine foreign exchange market. Any such new measures, as well as any additional controls and/or restrictions, could materially affect Grupo Galicia's ability to access the international capital markets and may undermine its ability to make payments of principal and/or interest on its obligations denominated in a foreign currency or transfer funds abroad (in total or in part) to make payments on its obligations, including debt securities issued by Grupo Galicia or any of its subsidiaries. These regulations (and their amendments) can limit access to the foreign exchange market. In the future, Grupo Galicia may be prevented 9 Table of Contents from making payments in U.S. Dollars and/or making payments outside of Argentina due to the restrictions in place at that time in the foreign exchange market and/or due to the restrictions on the ability of companies to transfer funds abroad. In April 2025, the Argentine Central Bank (BCRA) announced the launch of a new phase of the Economic Program, introducing a managed float regime with moving exchange‑rate bands, alongside a partial easing of existing foreign‑exchange regulations. The Bank also communicated a monetary policy framework centered on the monitoring of monetary aggregates. As of the date of this annual report, it is not possible to predict with certainty the impact that these measures may have on the Argentine economy in general or on the situation of Grupo Galicia in particular, especially with regard to their effective implementation and continuity over time. It is possible that the National Government, together with the BCRA, will adopt new provisions that modify the current conditions of the foreign exchange market. In this regard, there is no guarantee that current regulations will not be altered or replaced by others that reinforce or introduce new limitations on access to the MLC (official exchange rate market). Any such measure could restrict Grupo Galicia's ability to access international capital markets, affect its ability to meet the principal and interest payments on its foreign currency obligations, or hinder the transfer abroad of the funds necessary to meet these commitments. As a result, both non-resident investors and residents with assets held abroad should carefully consider these risks when evaluating an investment in the ADSs. The measures adopted by the Argentine government and the claims filed by workers on an individual basis or as part of a labor union action may lead to pressures to increase salaries or additional benefits, which would increase companies’, including Grupo Galicia’s, operating costs. Additionally, labor union activity could lead to strikes or work stoppages, which may materially and adversely affect Grupo Galicia’s results of operations. In the past, the Argentine government has passed laws and regulations requiring private sector companies to maintain certain salary levels and provide their employees with additional work-related benefits. Furthermore, employers, both in the public sector and in the private sector, have been experiencing intense pressure from their personnel, or from the labor unions representing such personnel, demanding salary increases and certain benefits for the workers, given the prevailing high inflation rates. For example, in the recent history of Argentina there have been strikes promoted by the union representing Argentine bank employees. Some of these strikes did not have a direct effect on banks (including our principal subsidiary, Banco Galicia) but did impact banks’ clients who were not able to access branches. Such strikes can also lower the perception the public has of banks, which could have a reputational cost for Banco Galicia (the main subsidiary of Grupo Galicia) and, consequently, for Grupo Galicia. Labor movements are active in Argentina and can potentially lead to further strikes or work stoppages if demands are not satisfied, which could have a material and adverse effect on our operations and operating costs. There can be no assurance that the Argentine government will not adopt measures in the future mandating salary increases or the provision of additional employee benefits or that employees or their unions will not exert pressure on companies, such as Grupo Galicia, in demanding the implementation of such measures. The implementation of any such measures could have a material and adverse effect on Grupo Galicia’s expenses and business, results of operations and financial condition and, thus, on the trading prices for its ADSs. Exposure to multiple provincial and municipal tax legislation and regulations could adversely affect Grupo Galicia’s business or results of operations. Argentina has a federal system of government with 23 provinces and the Autonomous City of Buenos Aires. Each of these, under the Argentine National Constitution, has full power to enact legislation concerning taxes. Likewise, within each province, municipal governments have broad powers to regulate said matters. Given that the bank branches of our primary subsidiary, Banco Galicia, are located in multiple provinces, we are subject to various provincial and municipal legislation and regulations that may vary from time to time. Future developments in provincial and municipal legislation concerning taxes, provincial regulations or other matters could materially and adversely affect Grupo Galicia’s expenses, business, results of operations and financial condition and thus the trading price for its ADSs could decrease. Epidemics and pandemics, could have an adverse effect on the Argentine economy and consequently, in our business operations. 10 Table of Contents An outbreak of another pandemic, or epidemic disease or similar public health threat could have material adverse effects on global economic, financial and business conditions, which could materially and adversely affect our business, financial condition and results of operations. The long-term effects to the global economy and to Grupo Galicia of epidemics, pandemics and other public health crises, are difficult to assess or predict, and may include risks to employee’s health and safety, and reduce our business operations. Also, such long-term effects depend on several other factors which are uncertain (such circumstances may include further waves of infection, further variants of the Covid-19 virus, the lasting effects of vaccines, the global roll out of vaccination programs, the percentage of vaccinated population, possible lockdowns or other restrictions, and the speed and stability of the economic recovery, among others). Epidemics, pandemics and other health crises, may negatively impact the business and operations of third-party service providers who perform services critical for our business. Furthermore, in such cases, the Government may impose certain measures such as travel restrictions, border closures and lockdowns, which may force us to set in place work from home arrangements for our employees and may also have a material impact on our ability to operate and achieve our business goals. If the global and Argentine economies are unable to sustain the post-pandemic recovery, we may also experience higher default rates on our customer financing, liquidity shortfalls, and difficulties in our ability to service our debt and other financial obligations. We may also encounter difficulties in accessing the debt and capital markets and be forced to refinance pre-existing financing arrangements. Although the actual impact is impossible to assess, the occurrence of any of these events could have a material adverse effect on our operations. Finally, it is unclear whether these challenges and uncertainties will increase or diminish, and what effects they may have on long-term global political and economic conditions. The impact of health crises could have a material and adverse effect on Grupo Galicia’s business, results of operations, and financial condition and, therefore, on the trading prices of its ADSs. Failure to adequately address actual and perceived risks arising from institutional deterioration and corruption could adversely affect Argentina’s economy and financial position and the ability of Argentine companies to attract foreign investment. The lack of a solid institutional framework regulating contracts entered into by the Argentine government and its agencies, as well as allegations of corruption, have affected and continue to affect Argentina. The Transparency International Corruption Perceptions Index, which measures corruption in 180 countries, ranked Argentina 99th in 2024, with a score of 37 out of a possible 100. Furthermore, as of the date of this annual report, Argentina has been invited to join the Organization for Economic Cooperation and Development (OECD). However, if the country fails to implement the reforms and make the commitments required by this organization, its membership could be rejected. On January 29, 2024, the OECD took note of the letter from the Republic of Argentina accepting the invitation to the organization. As of the date of this annual report, although OECD membership is a national objective, pursuant to Decree No. 591/2024, and the technical accession process has been underway since the submission of the initial memorandum in November 2025, Argentina's accession to this organization is still pending. While measures have been taken in the past to improve practices and reduce the incidence of corruption in government, failure by the Government to continue addressing these issues could increase the risk of political instability and distort the process of adopting measures, affecting Argentina's international reputation and the ability of its companies to attract foreign investment. Fluctuations in the value of the Peso could adversely affect the Argentine economy and Grupo Galicia's financial condition and results of operations. The devaluation of the Peso may negatively impact the ability of certain Argentine companies to repay their foreign currency debts, generate inflation, substantially reduce real wages, and jeopardize the stability of companies, such as the Company, whose success depends on domestic market demand. Lastly, it could adversely affect the ability of the National Government to meet its external debt obligations. Both a significant depreciation and appreciation of the Peso could have a materially adverse effect on the Argentine economy, as well as on Grupo Galicia's financial position, business, and ability to repay its debts. 11 Table of Contents As of the date of this annual report supplement, there are different implicit exchange rates related to foreign currency rates, such as the “contado con liquidación,” the MEP or “dólar bolsa,” and the “dólar tarjeta,” among others. While this does not have a direct impact on the Company’s operations and business, a widening gap between these exchange rates and the official rate could affect Grupo Galicia and its subsidiaries' financial conditions and results of operations. The credibility of certain Argentine economic indexes has been called into question, which may lead to a lack of confidence in the Argentine economy Between 2007 and 2015, the INDEC, which is the only institution in Argentina with the statutory authority to produce official national statistics, experienced a period of institutional deterioration that gave rise to controversy regarding the reliability of the information that it produces, including inflation, GDP and unemployment data, with allegations that the inflation rate in Argentina and the other rates calculated by INDEC could be substantially different from what’s indicated in official reports. Reports published by the IMF stated that their staff used alternative measures of inflation for macroeconomic surveillance, including data produced by private sources, which showed inflation rates considerably higher than those published by the INDEC from 2007-2015. The IMF also censured Argentina for failing to make sufficient progress, as required under the Articles of Agreement of the IMF, in adopting remedial measures to address the quality of official data, including inflation and GDP data. In January 2016, the Macri administration declared a state of administrative emergency in respect of the national statistical system and the INDEC. The INDEC suspended the publication of certain statistical data until it completed a reorganization of its technical and administrative structure to recover its ability to produce sufficient and reliable statistical information. As a result, the INDEC released certain revised foreign trade, balance of payment and GDP data for the years 2011-2015. In November 2016, the executive directors of the IMF lifted the motion of censure, noting that Argentina had resumed the publication of data in a manner consistent with its obligations under the IMF’s Articles of Agreement, enabling Argentina to borrow from the IMF again. We cannot assure you that the Government will not vary or introduce other measures that may affect the national statistics system and, consequently, the Argentine economy, in particular by undermining consumer and investor confidence, which ultimately could have a material adverse effect on Grupo Galicia´s business, results of operations and financial condition. The current geopolitical and economic landscape presents significant challenges for global financial markets operating in a context of high uncertainty. Rising trade tensions and geopolitical conflicts may generate uncertainty in international markets and influence investment flows toward emerging economies. Notable among these are the economic measures implemented between China and the United States, along with recent territorial and strategic disputes in the North Atlantic regarding the sovereignty of Greenland. The latter has introduced unexpected friction in relations between the United States and the European Union, which could lead to new tariff barriers and increased volatility in fixed income and foreign exchange markets. Furthermore, unrest in the Middle East and regional conflicts in countries such as Iran, Ukraine, Russia, and Israel create persistent instability in global financial asset prices. Likewise, political crises in Latin America represent critical factors that must be cautiously assessed by investors within the framework of a historically volatile region. In particular, the uncertain transition in Venezuela following recent changes in its power structure raises questions regarding institutional stability and the future configuration of the regional energy market. Regarding military conflicts in Eastern Europe and the Middle East, the primary concern lies in the potential effects on hydrocarbon supply and the security of international trade routes. A military escalation could severely restrict global energy exports, given that these regions account for the world's major oil producers. Consequently, geopolitical tensions have had and will likely continue to have a profound impact on international energy prices. Due to the inherent uncertainties regarding the scale and duration of these events and their direct and indirect effects, it is not possible to reasonably estimate the impact that these conflicts may have on the global economy and its financial markets, on the Argentine economy, and, consequently, on the Company’s financial condition. Risk Factors Relating to the Argentine Financial System 12 Table of Contents The stability of the Argentine financial system is dependent upon the ability of financial institutions, including Banco Galicia, the main subsidiary of Grupo Galicia, to maintain and increase the confidence of depositors. The measures implemented by the Government in late 2001 and early 2002, in particular the restrictions imposed on depositors to withdraw money freely from banks and the “pesification” and restructuring of their deposits, were strongly opposed by depositors due to the losses on their savings and undermined their confidence in the Argentine financial system and in all financial institutions operating in Argentina. If depositors once again withdraw their money from banks in the future, there may be a substantial negative impact on the manner in which financial institutions, including Banco Galicia (our main subsidiary), conduct their business, and on their ability to operate as financial intermediaries. Loss of confidence in the international financial markets may also adversely affect the confidence of Argentine depositors in local banks. An adverse economic situation, even if it is not related to the financial system, could trigger a massive withdrawal of capital from local banks by depositors, as an alternative to protect their assets from potential crises. Any massive withdrawal of deposits could cause liquidity issues in the financial sector and, consequently, a contraction in credit supply. The occurrence of any of the above could have a material and adverse effect on Grupo Galicia’s expenses and business, results of operations and financial condition and, thus, on the trading prices for its ADSs. If financial intermediation activity volumes relative to GDP are not restored to significant levels, the capacity of financial institutions, including Banco Galicia, the main subsidiary of Grupo Galicia, to generate profits may be negatively affected. As a result of several economic crises, financial intermediation activity has declined in Argentina; private sector loans and deposits have reached lows, both in terms of volume and as a percentage of GDP. Although they have recovered over the last years, the ratio of private‑sector loans and deposits to GDP in the financial system remains low compared to other Latin American countries. There is no assurance that financial intermediation activities will continue in a manner sufficient to reach the necessary volumes to provide financial institutions, including Banco Galicia, with sufficient capacity to generate income, or that that those actions will be sufficient to prevent Argentine financial institutions, such as Banco Galicia, from having to assume excessive risks in terms of maturity mismatches. Under these circumstances and for an undetermined period of time, the (i) scale of the operations of Argentine-based financial institutions operating in Argentina, including Banco Galicia, (ii) volume of their business, (iii) size of their assets and liabilities or (iv) their ability to generate results, could be limited and/or restricted, would may, in turn, impact the results of operations of Banco Galicia and potentially the trading price for Grupo Galicia's ADSs. The Argentine financial system’s growth and income, including that of Banco Galicia, the main subsidiary of Grupo Galicia, depend in part on the development of medium- and long-term funding sources. In spite of the fact that the financial system and Banco Galicia’s deposits continue to grow, they are mostly demand or short-term time deposits and the sources of medium- and long-term funding for financial institutions are currently limited. If Argentine financial institutions, such as Banco Galicia, are unable to access adequate sources of medium and long-term funding or if they are required to pay high costs in order to obtain the same and/or if they cannot generate profits and/or maintain their current volume and/or scale of their business, this may adversely affect Grupo Galicia’s ability to honor its debts. Additionally, this could negatively affect the trading prices for its ADSs. Argentine financial institutions (including Banco Galicia) continue to have exposure to public sector debt (including securities issued by the BCRA) and its repayment capacity, which in periods of economic recession, may negatively affect their results of operations. Argentine financial institutions continue to be exposed, to some extent, to public sector debt and the public sector’s repayment capacity. The Government’s ability to honor its financial obligations is dependent on, among other things, its ability to establish economic policies that succeed in fostering sustainable growth and development in the long term, generating tax revenues and controlling public expenditures, which could, either partially or totally, fail to take place. 13 Table of Contents Banco Galicia’s (our main subsidiary) exposure to the public sector as of December 31, 2025 was Ps.6,693,902 million, representing approximately 18% of total assets and 111% of net worth. As a result, Grupo Galicia’s income-generating capacity may be materially impacted or may be particularly affected by the Argentine public sector’s repayment capacity and the performance of public sector bonds, which, in turn, is dependent on the factors referred to above. The Grupo Galicia and its subsidiaries’ ability to honor their respective financial obligations may be adversely affected by the Government’s repayment capacity or its failure to meet its obligations in respect of Government obligations owed to Grupo Galicia which may, in turn, adversely affect the trading prices for Grupo Galicia's ADSs. The asset quality of financial institutions could be deteriorated if the Argentine private sector is affected by economic events in Argentina or international macroeconomic conditions. The ability of Argentine private sector debtors to repay their loans has deteriorated significantly in the past years as a result of certain economic events in Argentina and challenging macroeconomic conditions. This trend may impact the asset quality of financial institutions, including our own. We cannot assure that the current economic situation and the international context will be favorable and that private sector debtors will improve the private sector’s ability to pay. Despite the current quality of its portfolio, we may not be successful in recovering substantial portions of outstanding loans. If Argentina’s economic growth were to slow down or if the financial condition of the private sector were to deteriorate, there could be a substantial increase in the incidence of non-performing loans, which could have a material and adverse effect on our business, results of operations and financial condition. The Consumer Protection Law may limit some of the rights afforded to Grupo Galicia and its subsidiaries. Law No. 27,265 and Law No. 27,266, the “Consumer Protection Law”) sets forth a series of rules and principles designed to protect consumers, which include Banco Galicia's customers. Additionally, Law No. 25,065 (as amended by Law No. 26,010, Law No. 26,361 and the Decree of Necessity and Urgency No. 70/2023, the “Credit Card Law”) also sets forth public policy regulations designed to protect credit card holders. Additionally, the Civil and Commercial Code captured the principles of Consumer Protection Law and established their application to banking agreements. Furthermore, Law No. 26,993 created the “System to Solve Disputes in Consumer Relationships” (“COPREC” for its Spanish acronym), an administrative and legal procedure within the framework of the Consumer Protection Law; namely, an administrative and a judicial regime for such matters. By virtue of the Decree of Necessity and Urgency No. 55/2025, the National Executive Branch has dissolved COPREC, effective as of February 1, 2025. Notwithstanding the foregoing, local (Provincial and Municipal) regulations governing consumer relationships, as well as the administrative procedures applicable to consumer claims, shall remain in force. Furthermore, as of the date of this report, a unified federal system for the filing and processing of consumer claims, known as the Federal Single Window for Consumer Protection Claims (Ventanilla Única Federal de Reclamos de Defensa del Consumidor), is in effect, as formalized by Disposition No. 890/2025 of the Undersecretariat of Consumer Protection and Fair Trade. One of its primary functions is to receive consumer claims filed nationwide and refer them to the competent local authority, provided such authority has previously adhered to the applicable framework. Additionally, the Central Bank has issued various regulations providing broad protection to financial services users, establishing limits on the fees and charges that financial institutions may validly impose on their clients, which are consolidated under the “Financial Services Users Protection” regulations. The application of both the Consumer Protection Law and the Credit Card Law by administrative authorities and courts at the federal, provincial and municipal levels has increased. This trend has led to an increase in general consumer protection levels. In the event that the Company is found to be liable for violations of any of the provisions of the Consumer Protection Law or the Credit Card Law, the potential penalties could limit some of the Company’s rights, for example, with respect to their ability to collect payments due from services and financing provided by the Company, and adversely affect their financial results of operations. There can be no assurance that court and administrative rulings based on the regulation or measures adopted by the enforcement authorities will not increase the degree of protection given to its debtors and other customers in the future, or that they will not favor the claims brought by consumer groups or associations. 14 Table of Contents The implementation of the Consumer Protection Law, the Credit Card Law and other applicable regulations by administrative authorities and courts may prevent or hinder the collection of payments resulting from services rendered and financing granted by Grupo Galicia's subsidiaries including Banco Galicia, which may have an adverse effect on their results and operations and, in turn, on the trading price for the ADSs. The maintenance or implementation of measures regarding the charging of fees and regulated rates could materially and adversely affect Grupo Galicia’s consolidated financial condition and results of operations The BCRA has various regulations regarding the fees and interest rates that entities can charge in the banking business. One of Grupo Galicia’s primary subsidiaries, Banco Galicia, is required to comply with the applicable regulations. Caps on the rates and fees an entity can charge its customers could affect the interest rates and fees earned by Banco Galicia, potentially resulting in a reduction in Grupo Galicia’s consolidated income or a decrease in customer demand for Banco Galicia’s loan or deposit products. Additionally, if Banco Galicia were permitted to, and actually did, increase the interest rates and fees it charged (or if these were otherwise raised by the BCRA or other authorities), such increases could result in higher debt service obligations for Banco Galicia’s customers, leading to higher levels of delinquent loans or discouraging customers from borrowing. Interest rates and regulated fees are highly sensitive to many factors beyond Banco Galicia’s control, such as regulation of the financial sector in Argentina, domestic and international economic and political conditions, increase competition in the banking sector, among other factors. Changes in the demand for our subsidiaries services and/or increases in the levels of delinquency among their customers could have a material and adverse effect on their businesses. This, in turn, could impact Grupo Galicia’s results of operations and financial condition, and consequently, the trading price for its ADSs. Class actions against financial institutions for an indeterminate amount may adversely affect the profitability of the financial system and of Banco Galicia, specifically. Certain public and private organizations have initiated class actions against financial institutions in Argentina, including Banco Galicia. Class actions are contemplated in the Argentine National Constitution and the Consumer Protection Law, however, the procedure for carrying them out is not regulated by any specific law. The courts (national or provincial), however, have admitted class actions in spite of lacking specific regulations, providing some guidelines with respect to the procedures for the same. These courts have admitted several complaints filed against financial institutions to defend collective interests, based on arguments that object to charges applied to certain products, applicable interest rates and the advisory services rendered in the sale of government securities, among others. Final judgments entered against financial institutions under these class actions may affect the profitability of financial institutions in general and of Banco Galicia specifically in relation to class actions filed against Banco Galicia. For further information regarding class actions brought against Banco Galicia, please refer to the Item 8. “Financial Information”─A. “Consolidated Statements and Other Financial Information”—“Legal Proceedings”— “Banco Galicia”. To the extent that the profitability of Banco Galicia is impacted by the foregoing, the same could have a material and adverse effect on Grupo Galicia’s business, results of operations and financial condition and on the trading price for its ADSs. Administrative procedures filed by the tax authorities of certain provinces against financial institutions, such as Banco Galicia (the primary subsidiary of Grupo Galicia) and amendments to tax laws applicable to Grupo Galicia could generate losses for Grupo Galicia. In recent years, the Autonomous City of Buenos Aires´ tax authorities, as well as certain provincial tax authorities, have initiated administrative proceedings against financial institutions in order to collect higher gross income taxes from such financial institutions. Although Banco Galicia (the primary subsidiary of Grupo Galicia) believes it has met its tax obligations regarding current regulations and has properly recorded provisions for those risks based on the opinions and advice of its external legal advisors and pursuant to the applicable accounting standards, certain risks may render those provisions inadequate. Tax authorities may not agree with Banco Galicia’s tax treatment, possibly leading to an increase in its tax liabilities. Moreover, amendments to existing regulations may increase Grupo Galicia’s tax rate and a material increase in the tax burden could adversely affect its financial results, results of operations and the trading price for its ADSs. 15 Table of Contents Holders of Grupo Galicia's ordinary shares and the ADSs may not receive any dividends if Banco Galicia or other subsidiaries are not able to distribute dividends to Grupo Galicia. Dividend distributions by our subsidiary Banco Galicia are subject to the prior approval of the Superintendency of Financial and Foreign Exchange Institutions (Superintendencia de Entidades Financieras y Cambiarias, the “SEFyC”). The SEFyC assesses a financial institution’s capacity to distribute dividends at the time it receives the relevant approval request. The SEFyC may authorize the distribution of dividends if, during the month immediately preceding the request, the following requirements are met: (i) the financial institution is not subject to liquidation proceedings; (ii) it is not receiving financial assistance from the Central Bank; (iii) it is in compliance with its information reporting obligations to the Central Bank; (iv) it complies with minimum capital and liquidity requirements, among others; and (v) the financial institution is not subject to significant fines—exceeding twenty-five percent (25%) of the last reported computable regulatory capital (Responsabilidad Patrimonial Computable, or “RPC”)—disqualifications, suspensions, revocations or prohibitions imposed during the previous five years by the Central Bank, the Financial Intelligence Unit (UIF), the Argentine Securities Commission (CNV) and/or the Superintendency of Insurance, unless the financial institution has implemented corrective measures deemed satisfactory by the SEFyC (which measures are also communicated to the regulatory authority that originally imposed the sanction). The SEFyC also considers information received from, and/or sanctions imposed by, equivalent foreign authorities. In assessing the relevance of such sanctions, the SEFyC takes into account the type of sanction, the underlying reasons for its imposition and its amount. In addition, the SEFyC considers the degree of participation in the events that led to the sanction, the economic effects of the infringement, the extent of harm caused to third parties, the economic benefit obtained by the sanctioned party, its operating volume, its level of responsibility and the position or role of the individuals involved. Although in the past the Central Bank has authorized Banco Galicia to distribute dividends, there can be no assurance that the Central Bank will continue to grant Banco Galicia authorization to distribute the dividends approved by its shareholders at the annual ordinary shareholders’ meeting, or that such authorization will be granted for the full amount of distributable dividends. The distribution of profits by financial institutions was suspended from January 1, 2023 through March 31, 2023. As from April 1, 2023 and through December 31, 2023, financial institutions that had obtained authorization from the Central Bank of the Argentine Republic (“BCRA”)—in accordance with the provisions of Section 6 of the Consolidated Text on Profit Distribution—were permitted to distribute profits in six (6) equal, monthly and consecutive installments, for up to forty percent (40%) of the amount that would have been distributable under the applicable regulations. Likewise, through Communication “A” 7984 dated March 21, 2024, the BCRA provided that, through December 31, 2024, financial institutions that had obtained authorization from the BCRA—in accordance with the provisions of Section 6—would be permitted to distribute profits in six (6) equal, monthly and consecutive installments, for up to sixty percent (60%) of the amount that would have been distributable under the applicable regulations. Such profit distributions were required to be consistent with the information reported under the “Business Plan and Projections and Capital Self-Assessment Report” Informative Regime. Additionally, through Communication “A” 7997 dated April 30, 2024, the BCRA provided that financial institutions that resolved or had resolved to distribute profits within the framework of Communication “A” 7984 would be permitted to do so in three (3) equal, monthly and consecutive installments, for up to the amount permitted thereunder. Said communication also introduced a special regime applicable to non-resident shareholders through the primary subscription of Bonds for the Reconstruction of a Free Argentina (BOPREAL), subject to certain restrictions and conditions. Also, through Communication “A” 8214 dated March 13, 2025, the BCRA provided that, through December 31, 2025, financial institutions that have obtained prior authorization from the BCRA—in accordance with the provisions of Section 6 of the Consolidated Text on Profit Distribution—will be permitted to distribute profits in ten (10) equal, monthly and consecutive installments, commencing on June 30, 2025 and not earlier than the penultimate business day of the following months, for up to sixty percent (60%) of the amount that would have been distributable under said consolidated text. Such profit distributions must be consistent with the objectives of monetary stability and with the information reported under the “Business Plan and Projections” Informative Regime and the Capital Self-Assessment Report. Finally, through Communication “A” 8410 dated March 19, 2026, the BCRA established that, through December 31, 2026, financial institutions that have obtained prior authorization from the BCRA—in accordance with the provisions of Section 6 of the Consolidated Text on Profit Distribution—will be permitted to distribute profits in three (3) equal, 16 Table of Contents monthly and non-cumulative installments, payable as from the third business day of May and of each subsequent month in which the payment is made, for up to sixty percent (60%) of the net income for fiscal year 2025, after deducting the amounts corresponding to mandatory legal and statutory reserves. Such distributions must be consistent with the information reported under the “Business Plan and Projections” Informative Regime and the Capital Self-Assessment Report, and the calculation of the distributable amount and applicable thresholds must be carried out in homogeneous currency as of the date of the relevant shareholders’ meeting. If, in the future, restrictions on the distribution of dividends by financial institutions were to be intensified or increased, this could limit Grupo Galicia’s ability to receive dividends from Banco Galicia and, as a result, could adversely affect Grupo Galicia’s results and, ultimately, the market price of the ADSs. Governmental measures and regulatory framework affecting financial entities could have a material adverse effect on the operations of financial entities. Grupo Galicia has no control over governmental regulations or laws governing all aspects of its operations and those of its subsidiaries, including: minimum capital requirements; minimum cash reserve requirements; requirements on fixed-rate asset investments; limits on lending capacity and other credit restrictions, including mandatory allocations; limits and other restrictions on fees; reduced time for financial institutions to deposit the amount of credit card sales into appropriate merchant accounts; limits on the amount of interest a bank may charge or pay, or on the period for capitalizing interest; accounting and statistical requirements; restrictions on dividends; limits or restrictions on foreign exchange; limits on market share; reporting or control regimes as agents or regulated entities; and changes in the deposit insurance regime. It is not possible to offer any guarantee that new stricter regulations will not be implemented in the future that may generate uncertainty and adversely affect future financial activities. Such changes in the regulatory framework and further changes in the future could limit the ability of financial institutions, including us, to make long-term decisions, such as asset allocation decisions, which could cause uncertainty with respect to our future financial condition and results of operations. We cannot assure that laws and regulations currently governing the economy, or the financial sector will not continue to change in the future or that any changes will not adversely affect our business, financial condition and results of operations. Risk Factors Relating to Us As a foreign private issuer, Grupo Galicia applies disclosure policies and requirements that differ from those governing U.S. domestic registrants. As a foreign private issuer, Grupo Galicia is subject to different disclosure policies and other requirements than a domestic U.S. registrant. For example, as a foreign private issuer in the U.S., Grupo Galicia is not subject to the same requirements and disclosure policies as a domestic U.S. registrant under the Exchange Act, including the requirements to prepare and issue financial statements, report on significant events and the standards applicable to domestic U.S. registrants under Section 14 of the Exchange Act or the insider reporting and short-swing profit rules applicable to domestic U.S. registrants. In addition, although Argentine laws provide for certain requirements that are similar to those prevailing in the U.S. in relation to publicly listed companies (including, for example, those related to price manipulation), in general, applicable Argentine laws are different to those in the U.S. and in certain aspects may provide different or fewer protections or remedies as compared to U.S. laws. Further, Grupo Galicia relies on exemptions from certain Nasdaq rules that are applicable to domestic companies. Accordingly, the corporate information available about Grupo Galicia is not the same as, and may be more limited than, the information available to shareholders of a U.S. company. The price of Grupo Galicia’s ordinary shares may fluctuate significantly, and your investment may decline in value. The price of Grupo Galicia´s ordinary shares may fluctuate significantly in response to several factors, many of which are beyond our control, including those described in this annual report under “Risk Factors Relating to Argentina” and “Risk Factors Relating to the Argentine Financial System”. 17 Table of Contents The stock markets in general, and the shares of emerging markets in particular, have experienced price and volume fluctuations that have often been unrelated or disproportionate to the operating performance of the companies involved. Grupo Galicia cannot assure that any trading price or valuation will be sustained. These factors may materially and adversely affect the market price of our ordinary shares, which may limit or prevent investors from readily selling Grupo Galicia’s ordinary shares and may otherwise affect liquidity, regardless of Grupo Galicia’s operating performance. Market fluctuations, as well as general political and economic conditions in the markets in which we operate, such as recessions or currency exchange rate fluctuations, may also adversely affect the market price of Grupo Galicia’s ordinary shares and the ADSs. Adverse conditions in the credit, capital and foreign exchange markets may have a material adverse effect on Grupo Galicia’s financial position and results of operations and adversely impact it by limiting its ability to access funding sources. Grupo Galicia may sustain losses relating to its investments in fixed- or variable-income securities on the exchange market and its monetary position due to, among other reasons, changes in market prices, defaults and fluctuations in interest rates and in exchange rates. A deterioration in the capital markets may cause Grupo Galicia to record net losses due to a decrease in the value of its investment portfolios, in addition to losses caused by the volatility in financial market prices, even if the economy overall is not affected. Any of these losses could have an adverse effect on Grupo Galicia’s results of operations, business and financial condition and, in turn, on the trading price for the ADSs. A percentage of Grupo Galicia’s liquidity is derived from local banks and the local capital markets. As of December 31, 2025, Grupo Galicia’s liquidity ratio was 43.1%, as measured by liquid assets as a percentage of total deposits (liquid assets that include cash, bank loans, holdings of securities issued by the BCRA (“LELIQ” and “LEDIV”), net interbank loans, short-term placements with correspondent banks and repurchase agreement transactions in the local market). Any disruptions in the local capital markets or in the local financial market, as have been experienced by Argentina in the past, may result in a reduction in availability and/or increased cost of financing for liquidity obtained from these sources. These conditions may impact Grupo Galicia’s ability to replace, in a cost effective and/or timely manner, maturing liabilities and/or access funding to execute its growth strategy. Any such event may adversely affect Grupo Galicia’s financial position and/or results of operations and thus the trading price for Grupo Galicia's ADSs. Operational risks may impact Grupo Galicia’s businesses and negatively affect its results of operations. As with other financial institutions, operational risks could arise in any of Grupo Galicia’s businesses. These risks may include losses resulting from inadequate or failed internal and external processes, systems or human error, fraud, the effects of natural or man-made catastrophic events (such as natural disasters or pandemics) or from other external events. Exposure to such events could disrupt Grupo Galicia’s systems and operations significantly, which may result in financial losses and reputational damage. Pandemics and other material public health problems could result in social, economic or labor instability in the world and domestically and disrupt the operations of our business. These events could have a material adverse impact on the Bank's business, financial condition and results of operations. The main risk factors identified in the last risk assessment undertaken by our Risk Management Division were system failures, adverse legal decisions and economic losses generated by fraud. Although we have implemented numerous controls to avoid the occurrence of inefficient or fraudulent operations, errors can occur and compound even before being detected and corrected. In addition, some of our transactions are not fully automatic, which may increase the risk of human error or manipulation, and it may be difficult to detect losses quickly. The occurrence of any one or more of the above events could have a material adverse impact on our business, financial condition, and results of operations and, in turn, on the trading price for the ADSs. Banco Galicia's (the main subsidiary of Grupo Galicia) and Naranja X´s results of operations may be adversely affected due to an increase in the default rate. The Bank and Naranja X´s operational efficiency substantially depends on the adequacy of the measures implemented for the management, monitoring, and mitigation of delinquency. Our ability to maintain a competitive 18 Table of Contents position and solid institutional solvency is linked, in part, to the success of our credit policies and to our capacity to offer products and services that meet customer needs throughout their financial life cycle. If we fail to properly manage changes in the macroeconomic environment or market fluctuations that directly affect our borrowers’ repayment capacity, the Bank and Naranja X could face significant adverse effects. These negative impacts include, among others: •(i) Increases in loan‑loss provisions: Greater exposure to credit risk would require increasing the reserves for expected credit losses, directly affecting our equity. •(ii) Higher operating costs: The need to reallocate internal resources or hire additional staff to intensify collection and asset recovery efforts. •(iii) Erosion of the financial margin: A reduction in total net income and business profitability. Therefore, the successful execution of our risk policies and the continuous improvement of our delinquency management procedures are critical to our performance. Any failure in implementing these strategies or adapting our methods to market conditions could have a materially adverse effect on our business, operating results, and financial condition. Banco Galicia (the main subsidiary of Grupo Galicia) uses models to make business decisions, in case these models fail, could have an adverse effect on its profitability, consequently, on Grupo Galicia and the value of the ADSs. Financial entities, such as Banco Galicia (the main subsidiary of Grupo Galicia), have increased the use of database decision-making models. There is a growing need for financial institutions to have robust models that can accurately measure and control risk, and proactively detect and prevent situations that could adversely affect the corresponding financial institution's profits. Banco Galicia is exposed to potential losses caused by a variety of non-systematic risks resulting from errors in the implementation of database decision-making models, errors in the assumptions used to run such models, which result in misleading, confusing, or incorrect results, or errors due to the improper use of said models. All of these risks could create deviations and a material adverse effect on Banco Galicia’s profitability and, consequently, on Grupo Galicia’s and the value of the ADSs. EBA Holding S.A., a major shareholder of Grupo Galicia is able to exert significant influence over us and our corporate decisions and as a result, shareholders may be limited in their ability to influence significant decisions. Grupo Galicia's capital structure is comprised of class A shares, each of which grants its holder five votes, and class B shares, each of which grants its holder one vote. As of December 31, 2025, a total of 1,606,253,729 of Grupo Galicia's shares were outstanding, of which 281,221,650 were class A shares and 1,325,032,079 were class B shares, and EBA Holding S.A. ("EBA") held 100% of the class A shares, which represented 17.51% of the total shares in circulation. Taking into account that class A shares have the right to a total of five votes per share, EBA has 51.48% of the total votes. Accordingly, EBA holds the necessary number of votes required to take all decisions at Grupo Galicia's shareholders' meeting, although it does not perform any management activities related to Grupo Galicia. Given the particular shareholder composition of Grupo Galicia (and the dominance of multiple voting shares), failure to achieve a voluntary agreement among Grupo Galicia’s shareholders could have an impact on Grupo Galicia’s normal decision-making process. It is possible that EBA may cause us to take corporate actions that other shareholders may not agree with. This could affect the making of major decisions, including, among others, the election of directors, effecting or preventing a merger, the sale or acquisition of assets, the issuance of additional equity securities, the carrying out of related party transactions and distribution of dividends, if any. An increase in cybersecurity breaches or fraudulent and other illegal activity involving Grupo Galicia or its subsidiaries could lead to reputational damage to Grupo Galicia’s (or its subsidiaries’) brands and could reduce the use and acceptance of its and its subsidiaries’ products, therefore adversely affecting its business and results of operations. The business of many of Grupo Galicia’s subsidiaries depends on the efficient and uninterrupted operation of its data processing systems, its platforms for the exchange of information and its digital networks. Many of Grupo Galicia’s subsidiaries have access to a large amount of confidential information about its respective clients. Therefore, cybersecurity breaches represent a potential risk for Grupo Galicia. 19 Table of Contents Cybersecurity breaches can result in, for example, identity fraud, phishing, ransomware, information leaks, APT (Advanced Persistent Threat), DDoS Attacks (Distributed Denial of Service) or the theft of sensitive and confidential information, and may affect negatively the security of information that is stored and transmitted through the information systems and network infrastructure of Grupo Galicia and negatively affect the reputation of Grupo Galicia’s brands, thereby causing existing and potential clients to refrain from conducting business with Grupo Galicia’s subsidiaries. In spite of all existing security measures, Grupo Galicia cannot provide any assurance that the systems are not vulnerable to cybersecurity breaches or that the mentioned measures will be successful in protecting against any such breach. In addition, any of the aforementioned events could lead to an increase in compliance costs for Grupo Galicia’s subsidiaries. If any of the above described events were to occur, it could lead to monetary losses and reputational damage to Grupo Galicia’s brands, which could reduce the use and acceptance of its products, greater regulation, and increased compliance costs, therefore adversely affect its business and results of operation and the trading price for its ADSs. Grupo Galicia’s subsidiaries estimate and establish reserves for potential credit risk or future credit losses, which may be inadequate or insufficient, and which may, in turn, materially and adversely affect its financial position and results of operations. Grupo Galicia’s subsidiaries estimate and establish reserves for potential credit risk and losses related to changes in the levels of income of debtors/borrowers, increased rates of inflation, increased levels of non-performing loans or an increase in interest rates. This process requires a complex, and subjective analysis, including economic projections and assumptions regarding the ability of debtors to repay their loans. Therefore, if in the future Grupo Galicia’s subsidiaries are unable to effectively control the level of quality of their loan portfolios, if loan loss reserves are inadequate to cover future losses, or if they are required to increase their loan loss reserves due to an increase in the amount of their non-performing loans, the financial position and the results of operations of Grupo Galicia’s subsidiaries may be materially and adversely affected and, in turn, the trading prices for the ADSs. If Grupo Galicia’s subsidiaries should fail to meet regulatory standards or expectations or detect money laundering and other illegal or inappropriate activities in a comprehensive or timely manner, Grupo Galicia´s subsidiaries may incur fines, penalties, reputational harm and other negative consequences which may, in turn, negatively impact dividends received by Grupo Galicia. Grupo Galicia’s subsidiaries must be in compliance with all applicable laws and regulations with respect to anti-money laundering, funding of terrorist activities, corruption, bribery, sanctions and other regulatory matters. These laws and regulations require, among other things, that Grupo Galicia’s subsidiaries adopt and implement control policies and procedures which involve “know your customer” principles that comply with the applicable regulations and reporting suspicious or unusual transactions to the applicable regulatory authorities. As such, Grupo Galicia’s subsidiaries maintain systems and procedures designed to ensure that they comply with applicable laws and regulations. However, Grupo Galicia’s subsidiaries are subject to heightened compliance and regulatory oversight and expectations, particularly due to the evolving and increasing regulatory landscape that they operate in. Further, Grupo Galicia’s subsidiaries could become subject to future regulatory requirements beyond those currently proposed, adopted or contemplated. The cumulative effect of all of the legislation and regulations on their business, operations and profitability remains uncertain. This uncertainty necessitates that Grupo Galicia’s subsidiaries make certain assumptions with respect to the scope and requirements of the proposed rules in their business planning. If these assumptions prove incorrect, Grupo Galicia’s subsidiaries could be subject to increased regulatory and compliance risks and costs as well as potential reputational harm. In addition, a single event or issue may give rise to numerous and overlapping investigations and proceedings in different jurisdictions. Also, the laws and regulations in jurisdictions in which Grupo Galicia’s subsidiaries operate may be different or even conflict with each other as to the products and services offered by Grupo Galicia’s subsidiaries or other business activities Grupo Galicia’s subsidiaries may engage in, which can lead to compliance difficulties or issues. Furthermore, many legal and regulatory regimes require Grupo Galicia’s subsidiaries to report transactions and other information to regulators and other governmental authorities’ self regulatory organizations, exchanges, clearing houses and customers. Grupo Galicia´s subsidiaries may be subject to fines, penalties, restrictions on our business, or other negative consequences if they do not timely, completely, or accurately provide regulatory reports, customer notices or disclosures, or make tax-related with holdings or payments, on behalf of themselves or their customers. While Grupo Galicia’s subsidiaries have adopted policies and procedures intended to detect and prevent the use of their networks for money laundering activities and by terrorists, terrorist organizations and other types of organizations, 20 Table of Contents those policies and procedures may fail to fully eliminate the risk that Grupo Galicia’s subsidiaries have been or are currently being used by other parties, without their knowledge, to engage in activities related to money laundering or other illegal activities. Moreover, some legal/regulatory frameworks provide for the imposition of fines or penalties for noncompliance even though the noncompliance was inadvertent or unintentional and even though there was in place at the time, systems and procedures designed to ensure compliance. For example, Grupo Galicia’s subsidiaries are subject to regulations issued by the Office of Foreign Assets Control (“OFAC”) that prohibit financial institutions from participating in the transfer of property belonging to the governments of certain foreign countries and designated nationals of those countries. OFAC may impose penalties or restrictions on certain activities for inadvertent or unintentional violations even if reasonable processes are in place to prevent the violations. Any violation of the applicable laws or regulatory requirements, even if inadvertent or unintentional, or any failure to meet regulatory standards or expectations, including any failure to satisfy the conditions of any consent orders, could result in fees, penalties, restrictions on Grupo Galicia’s subsidiaries ability to engage in certain business activities, reputational harm, loss of customers or other negative consequences all of which could have a material and adverse effect on Grupo Galicia’s, which could have a material adverse effect on the business, financial condition and results of operations of Grupo Galicia. In addition, their businesses and reputation could be adversely affected if customers use any of them for money laundering activities or other illegal activities. A disruption or failure in Grupo Galicia’s information technology system could adversely affect its operations and financial position. The success of Grupo Galicia’s subsidiaries is dependent upon the efficient and uninterrupted operation of their communications and computer hardware systems, including those systems related to the operation of their ATM networks and digital channels. Grupo Galicia’s communications, systems or transactions could be harmed or disrupted by power failures, data breaches, cyber-attacks, acts of terrorism, physical theft, reputational damage and similar events or disruptions. Any of the foregoing events may cause disruptions in Grupo Galicia’s systems, delays in the provision of and/or the loss of critical data and could prevent it from operating at optimal levels. In addition, the contingency plans in place may not be sufficient to cover all those events and, therefore, this may mean that the applicable insurance coverage is limited or inadequate, preventing Grupo Galicia (or its subsidiaries) from receiving full compensation for the losses sustained as a result of such a global disruption. If any of these events occur, it could damage the reputation, entail serious costs and affect Grupo Galicia’s transactions, as well as its results of operations, business and financial position and, in turn, the trading price for the ADSs. The Argentine Peso qualifies as a currency of a hyperinflationary economy, and Grupo Galicia is required to apply inflationary adjustments to its financial statements, which adjustments could adversely affect its financial statements, results of operations and financial condition. Pursuant to IAS 29 (Financial Reporting in Hyperinflationary Economies), the financial statements of entities whose functional currency is that of a hyperinflationary economy must be restated using a suitable general price index to control for the effects of changes. Further, such regulation requires that the financial statements of an entity whose functional currency is one of a hyperinflationary economy be measured in terms of the current unit of measurement at the closing date of the reporting period. In June 2018, the International Practices Task Force of the Centre for Quality, which monitors “highly inflationary countries”, categorized Argentina as a country with a projected three year cumulative inflation rate greater than 100%. Additionally, some of the other qualitative factors of IAS 29 were present. Argentine companies applying IFRS are required to apply IAS 29 to their financial statements for periods ending on and after July 1, 2018. In addition, the CNV, through Resolution No. 777/18 established the method to restate financial statements in constant currency to be applied by issuers subject to oversight of the CNV, in accordance with IAS 29. Law No. 27,468 delegated to the BCRA, in the case of financial entities, the entry into force of new regulations. Likewise, for purposes of the determination of the indexation for tax purposes, Law No.27,468, enacted on December 4, 2018, substituted the Wholesale Price Index for CPI and modified the standards triggering tax indexation procedures. From January 1, 2021 onwards, the tax indexation procedure will be triggered under similar standards as those set forth by IAS 29. Because of the fluctuating levels of inflation, Grupo Galicia cannot predict the full impact of the application of such tax indexation procedures and the related adjustments on its financial statements or the effects of such tax indexation procedures on its business, results of operations and financial condition (or on the trading price for its ADSs). Small spreads in interest rates between loans and deposits, could harm our financial position and results of operations. 21 Table of Contents We carry out our operations in a country that is subject to frequent regulatory changes, high inflation and frequent currency devaluations. As a result, interest rates fluctuate frequently with direct impacts on the main source of income for the business of our subsidiaries. These fluctuations may generate losses based on the type of financing granted, the value of the interest rate for the financing and the other terms of the loans extended. For example, in such a volatile country, the granting of long term loans with fixed rates can result in severe monetary losses if the interest rate earned on the loans extended does not exceed the interest that we (or our subsidiaries) pay on deposits we or they hold. In addition to this, the increasing competition we face from digital banks has forced us to offer lower interest rates than we otherwise would in order to remain competitive in the market. If we are not able to maintain profitable spreads between interest that we earn on the loans that we and our subsidiaries grant and the interest that we pay on the deposits that we and our subsidiaries hold, our results of operations and financial condition may be materially adversely impacted and, in turn, the trading price for our ADSs. Grupo Galicia’s main subsidiary (Banco Galicia) faces significant and increasing competition in the rapidly evolving financial services industry. Banco Galicia operates in a highly competitive environment in which it must evolve and adapt to changes in financial regulation, technological advances, increased public scrutiny and changes in economic conditions. Grupo Galicia expects that competition in Argentina and global financial services industry will continue to be intense. Competitors include: •other banks and financial institutions •trading, advisory and investment management firms •finance companies •technology companies, and •other non-bank firms that are engaged in providing similar as well as new products and services. No assurance can be provided that the significant competition in the financial services industry will not materially and adversely affect its future results of operations. For example, aggressive or less disciplined lending practices by non-bank competitors could lead to a loss of market share for traditional banks, and in an economic downturn could result in instability in the financial services industry in Argentina and adversely impact other market participants. New competitors in the financial services industry continue to emerge. For example, technological advances and the growth of e-commerce have made it possible for non-depository institutions to offer products and services that traditionally were banking products. These advances have also allowed financial institutions and other companies to provide electronic and internet-based financial solutions, including electronic securities and cryptocurrency trading, lending and other extensions of credit to consumers, payments processing and online automated algorithmic-based investment advice. Furthermore, both financial institutions and their non-banking competitors face the risk that payments processing and other products and services, including deposits and other traditional banking products, could be significantly disrupted by the use of new technologies, such as cryptocurrencies and other applications using secure distributed ledgers, that may not require intermediation. New technologies have required and could require Banco Galicia to spend more to modify or adapt its products to attract and retain clients and customers or to match products and services offered by its competitors, including technology companies. In addition, new technologies may be used by customers, or breached or infiltrated by third parties, in unexpected ways, which can increase Banco Galicia’s costs for complying with laws, rules and regulations that apply to the offering of products and services through those technologies and reduce the income that Banco Galicia earns from providing products and services through those technologies. Ongoing or increased competition may put pressure on the pricing for Banco Galicia’s products and services or may cause Banco Galicia to lose market share, particularly with respect to traditional banking products. This competition may be based on quality and variety of products and services offered, transaction execution, innovation, reputation and price. The failure of Banco Galicia’s business to meet the expectations of clients and customers, whether due to general market conditions, underperformance, a decision not to offer a particular product or service, changes in client and customer expectations or other factors, could affect Banco Galicia’s ability to attract or retain clients and customers. Any such impact could, in turn, reduce Banco Galicia’s revenues. Increased competition also may require Banco Galicia to make additional capital investments in its businesses, or to extend more of its capital on behalf of its clients to remain 22 Table of Contents competitive. A reduction in Banco Galicia's profits would reduce the dividends it can pay to Grupo Galicia which, in turn, would negatively impact the payment of dividends in respect of, and trading price for, Grupo Galicia's ADSs. Grupo Galicia could experience operational issues due to failures in services provided by external vendors. Given the nature of and the size of our business, many of our IT systems and operations depend on services provided by external vendors. Grupo Galicia maintains strict oversight of the services it contracts and how they are managed by the vendors. However, Grupo Galicia is unable to fully control the operation of these services. Consequently, failures in the contracted services could result in operational losses or system issues, with a corresponding impact on financial results and corporate reputation. Payments on class B shares or ADSs may be subject to FATCA withholding. Pursuant to certain provisions of the U.S. Internal Revenue Code of 1986, as amended, commonly known as FATCA, a “foreign financial institution” may be required to withhold on certain payments it makes (“foreign passthru payments”) to persons that fail to meet certain certification, reporting, or related requirements. We are a foreign financial institution for these purposes. Several jurisdictions have entered into, or have agreed in substance to, intergovernmental agreements with the United States to implement FATCA (“IGAs”), which modify the way in which FATCA applies in their jurisdictions. Certain aspects of the application of the FATCA provisions to instruments such as the class B shares and the ADSs, including whether withholding would ever be required pursuant to FATCA with respect to payments on such instruments, are uncertain and may be subject to change. Even if withholding would be required pursuant to FATCA with respect to payments on the class B shares or the ADSs, proposed regulations have been issued that provide that such withholding would not apply prior to the date that is two years after the date on which final regulations defining “foreign passthru payments” are published in the U.S. Federal Register. In the preamble to the proposed regulations, the U.S. Treasury Department indicated that taxpayers may rely on these proposed regulations until the issuance of final regulations. Holders should consult their tax advisors regarding how these rules may apply to their investment in the class B shares and the ADSs. Grupo Galicia’s main subsidiary (Banco Galicia) operates in a highly regulated environment and their operations are subject to regulations adopted, and measures taken by several regulatory agencies. Financial institutions are subject to significant regulation relating to functions that historically have been determined by the BCRA and other regulatory authorities. The BCRA may penalize Banco Galicia in case of any breach of applicable regulations, including any involuntary breaches. Similarly, the CNV, which authorizes its securities offerings and regulates the public markets in Argentina has the authority to impose sanctions on Banco Galicia and its Board of Directors for breaches of corporate governance. The Financial Information Unit (Unidad de Información Financiera or “UIF”) regulates matters relating to anti-money laundering and has the ability to monitor compliance with any such regulations by financial institutions and, eventually, impose sanctions. From time to time, Banco Galicia might be subject to investigation by the UIF regarding Banco Galicia’s compliance with such regulations. Any such regulatory agencies could initiate proceedings against Banco Galicia, its shareholders or directors and, accordingly, impose sanctions, including suspension or revocation of Banco Galicia ’s banking license, on Banco Galicia or any of its future subsidiaries, if any. See “Business—Legal Proceedings.” In addition to regulations specific to its industry, Banco Galicia is subject to a wide range of federal, provincial and municipal regulations and supervision generally applicable to businesses operating in Argentina, including laws and regulations pertaining to labor, social security, public health, consumer protection, the environment, competition and price controls. The absence of a stable regulatory framework or the imposition of measures that may affect the profitability of financial institutions and limit the capacity to hedge against currency fluctuations could result in significant limits to financial institutions’ decisions, such as Banco Galicia, regarding asset allocation. In turn, this could cause uncertainty and negatively affect Banco Galicia’s future financial activities and results of operations. In addition, existing or future legislation and regulation could require material expenditures or otherwise have a material adverse effect on the consolidated operations of Banco Galicia. A reduction in Banco Galicia's profits would reduce the dividends it can pay to Grupo Galicia which, in turn, would negatively impact the payment of dividends in respect of, and trading price for, Grupo Galicia's ADSs. 23 Table of Contents Although Grupo Galicia has completed the acquisition of HSBC’s businesses in Argentina (“Acquisition”) and has already incurred the related integration and restructuring cost, the anticipated cost savings, synergies and other benefits of the Acquisition may not be fully realized, or may take longer to materialize than currently expected. We may not be able to realize some or all of the currently anticipated benefits of the Acquisition, especially if the integration process takes longer or is more costly than originally expected. In addition, although we have already incurred the related integration and restructuring costs, we anticipate that the overall integration of HSBC’s businesses in Argentina will be a time-consuming and expensive process that, without proper planning and effective and timely implementation, may result in significant expenses and significantly disrupt our business. The anticipated cost savings, synergies and other benefits of the Acquisition are based on projections and other assumptions that are inherently uncertain, notwithstanding the successful completion of the integration process. As a result, the expected benefits may not be realized in the amounts or within the timeframes currently anticipated, or at all. A reduction in Banco Galicia's profits would reduce the dividends it can pay to Grupo Galicia which, in turn, would negatively impact the payment of dividends in respect of, and trading price for, Grupo Galicia's ADSs. It may be difficult to effect service of process against Grupo Galicia’s executive officers and directors, and foreign judgments may be difficult to enforce or may be unenforceable. Service of process upon individuals or entities which are not resident in the United States may be difficult to obtain in the United States. Grupo Galicia and its subsidiaries are companies incorporated under the laws of Argentina. Most of their shareholders, directors, members of the Supervisory Syndics’ Committee, officers, and some specialists named herein are domiciled in Argentina and the most significant part of their assets is located in Argentina. Although Grupo Galicia has an agent to receive service of process in any action against it in the United States with respect to its ADSs, none of its executive officers or directors has consented to service of process in the United States or to the jurisdiction of any United States court. As a result, it may be difficult to effect service of process against Grupo Galicia’s executive officers and directors. Additionally, under Argentine law, the enforcement of foreign judgments will only be allowed if the requirements in sections 517 to 519 of the National Code of Civil and Commercial Procedures or the applicable local code of procedures are met, and provided that the foreign judgment does not infringe on concepts of public policy in Argentine law, as determined by the competent courts of Argentina. As such, an Argentine court may find that the enforcement in Argentina of a foreign judgment (including a U.S. court) that requires payment be made by an Argentine individual to holders of its foreign currency-denominated securities outside of Argentina is contrary to the public policy if, for instance, there are legal restrictions in place prohibiting Argentine debtors from transferring foreign currency abroad to pay off debts. Holders of the ADSs may also be subject to any future changes in Argentine law which could make it more difficult to enforce foreign judgments in the future, or render them unenforceable. Corporate governance standards and disclosure policies that govern companies listing their shares pursuant to the public offering system in Argentina may differ from those regulating highly developed capital markets, such as the U.S. As a foreign private issuer, Grupo Galicia applies disclosure policies and requirements that differ from those governing U.S. domestic registrants. As a foreign private issuer, Grupo Galicia is subject to different disclosure policies and other requirements than a domestic U.S. registrant. For example, as a foreign private issuer in the U.S., Grupo Galicia is not subject to the same requirements and disclosure policies as a domestic U.S. registrant under the Exchange Act, including the requirements to prepare and issue financial statements, report on significant events and the standards applicable to domestic U.S. registrants under Section 14 of the Exchange Act or the insider reporting and short-swing profit rules applicable to domestic U.S. registrants. In addition, although Argentine laws provide for certain requirements that are similar to those prevailing in the U.S. in relation to publicly listed companies (including, for example, those related to price manipulation), in general, applicable Argentine laws are different to those in the U.S. and in certain aspects may provide different or fewer protections or remedies as compared to U.S. laws. Further, Grupo Galicia relies on exemptions from certain Nasdaq rules that are applicable to domestic companies. See "Item 6.C — Board Practices." Accordingly, the corporate information available about Grupo Galicia is not the same as, and may be more limited than, the information available to shareholders of a U.S. company.