A. History and Development of the Company
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Our legal name is Grupo Financiero Galicia S.A. Our commercial name is Grupo Financiero Galicia or Grupo Galicia. We are a financial services holding company that was incorporated on September 14, 1999, as a sociedad anónima (which is a stock corporation) under the laws of Argentina. As a holding company we do not have operations of our own and conduct our business through our subsidiaries.
Our goal is to consolidate our position as one of Argentina’s leading comprehensive financial services providers while continuing to strengthen our main subsidiary's, Banco Galicia, position as one of Argentina’s leading banks. We seek to broaden and complement the operations and businesses of Banco Galicia, through holdings in companies and undertakings whose objectives are related to and/or can produce synergies with financial activities. Our non-banking subsidiaries operate in financial and related activities in which Banco Galicia either cannot participate or in which it can participate only on a limited basis due to restrictive banking regulations.
We are domiciled in Buenos Aires, Argentina. Under our bylaws, our corporate duration is until June 30, 2100. Our duration may be extended by a resolution passed at the extraordinary shareholders’ meeting. Our principal executive offices are located at Teniente General Juan D. Perón 430, Twenty-Fifth floor, (C1038AAJ), Buenos Aires, Argentina. Our telephone number is (54-11) 4343-7528 and our website is www.gfgsa.com.
Our agent for service of process in the United States is CT Corporation System, presently located at 28 Liberty Street, New York, NY 10005.
On December 6, 2024, we completed the purchase from HSBC Latin America B.V. (“HSBC”) of its equity stakes
in its subsidiaries in Argentina and our acquisition of HSBC’s banking, asset management, and insurance businesses in
Argentina (the “Acquisition”) pursuant to the share purchase agreement dated April 9, 2024 (the “Share Purchase
Agreement”), by and among us, Banco de Galicia y Buenos Aires S.A., HSBC Latin America B.V. and HSBC Latin
America Holdings (UK) Limited (together with HSBC Latin America B.V., the “Sellers”). Grupo Galicia currently
provides the following services in Argentina through the following subsidiaries:
We provide bank services through Banco Galicia and during the 1st semester of fiscal year 2025, Banco GGAL S.A. (formerly, HSBC Bank Argentina S.A. and commercially known as "Galicia Más").
Through the operating subsidiaries of Tarjetas Regionales (i.e. Tarjeta Naranja S.A.U. and Naranja Digital Compania Financiera S.A.U.), we provide proprietary brand credit cards, consumer finance and digital banking services to the underbanked population of Argentina. These subsidiaries comprise a commercial umbrella known as Naranja X.
Through Galicia Asset Management and during the 1st semester of fiscal year 2025, GGAL Asset Management S.A. (formerly, HSBC Global Asset Management S.A.S.G.F.C.I. and commercially known as "Galicia Más Asset Management"), we provide mutual funds.
Through Sudamericana Holding and its subsidiaries, we provide insurance products in Argentina.
Through Galicia Securities and Inviu, we provide financial, and brokerage related products as explained herein. In order to strengthen our financial and brokerage services in the region and in the United States market, we established a subsidiary “Galicia Holdings” in Miami, United States of America.
Through Nera, a joint venture, we provide a new set of products and services that offer payment and financing options and solutions oriented to the agricultural sector.
Through Galicia Investments, Galicia Ventures and Galicia Venture Corp., Grupo Galicia started to invest in startups with venture capital funds in a variety of industries related to the activities developed by some of our subsidiaries in order to find and develop synergies and business opportunities.
We are one of Argentina’s largest financial services groups with consolidated assets of Ps.45,669,451 million as of December 31, 2025.
A.1 History
i) Grupo Financiero Galicia
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Grupo Financiero Galicia was formed on September 14, 1999 as a financial services holding company to hold all the shares of the capital stock of Banco Galicia held by members of the Escasany, Ayerza and Braun families. Its initial nominal capital amounted to 24,000 common shares, 12,516 of which were designated as class A ordinary (common) shares (the “class A shares”) and 11,484 of which were designated as class B ordinary (common) shares (the “class B shares”).
Following Grupo Financiero Galicia’s formation, the holding companies that held the shares in Banco Galicia on behalf of the Escasany, Ayerza and Braun families were merged into Grupo Financiero Galicia. Following the merger, Grupo Financiero Galicia held 46.34% of the outstanding shares of Banco Galicia. In addition, and due to the merger, Grupo Financiero Galicia’s capital increased from 24,000 to 543,000,000 common shares, 281,221,650 of which were designated as class A shares and 261,778,350 of which were designated as class B shares. Following this capital increase, all of our class A shares were held by EBA Holding S.A. ("EBA Holding" or "EBA"), an Argentine corporation that is 100% owned by our controlling shareholders, and our class B shares were held directly by our controlling shareholders in an amount equal to their ownership interests in the holding companies that were merged into Grupo Financiero Galicia.
On May 16, 2000, our shareholders held an extraordinary shareholders’ meeting during which they unanimously approved a capital increase of up to Ps.628,704,540 and the public offering and listings of our class B shares. All the new common shares issued as a result of such capital increase were designated as class B shares, with a par value of Ps.1. During this extraordinary shareholders’ meeting, all of our existing shareholders waived their preemptive rights. In addition, the shareholders determined that the exchange ratio for the exchange offer would be one class B share of Banco Galicia for 2.5 of our class B shares and one ADS of Banco Galicia for one of our ADSs. The exchange offer was completed in July 2000 and the resulting capital increase was of Ps.549,407,017. Upon the completion of the exchange offer, our only significant asset was our 93.23% interest in Banco Galicia.
On January 2, 2004, our shareholders held an extraordinary shareholders’ meeting during which they approved a capital increase of up to 149,000,000 preferred shares, each of them mandatorily convertible into one of our class B shares on the first anniversary of the date of issuance. Such shares were to be subscribed for in up to US$100 million of face value of subordinated notes to be issued by Banco Galicia to its creditors in the restructuring of the foreign debt of its head office in Argentina (the “Head Office”) and its Cayman Branch, or in cash. This capital increase was carried out in connection with the restructuring of Banco Galicia’s foreign debt. On May 13, 2004, we issued 149,000,000 preferred non-voting shares, with preference over the ordinary shares in the event of liquidation, each with a face value of Ps.1. The preferred shares were converted into class B shares on May 13, 2005. With this capital increase, our capital increased to Ps.1,241,407,017.
In August 2007, Grupo Financiero Galicia exercised its preemptive rights in Banco Galicia’s issuance of shares and subscribed for 93.6 million shares of Banco Galicia. The consideration paid for such shares consisted of: (i) US$102.2 million face value of notes due 2014 issued by Banco Galicia in May 2004, and (ii) cash. After the capital increase, Grupo Financiero Galicia increased Banco Galicia’s shares from 93.60% to 94.66%.
In September 2013, Grupo Financiero Galicia announced that it had reached an agreement to absorb Lagarcué S.A. and Theseus S.A. (entities that were shareholders of Banco Galicia at the moment of the merger). The consolidated financial statements prepared specifically for this merger were issued as of June 30, 2013 and the effective date of such merger was September 1, 2013.
This merger resulted in an increase of the ownership interest Grupo Financiero Galicia had in its principal subsidiary Banco Galicia in the amount of 25,454,193 class B shares, which also represented all of the total capital stock (4.526585%) Lagarcué S.A. and Theseus S.A. had in Banco Galicia.
Consequently, Grupo Financiero Galicia agreed to increase its capital stock by issuing 58,857,580 new class B shares representing 4.526585% of the outstanding capital stock of Grupo Financiero Galicia to be delivered to the shareholders of Lagarcué S.A. and Theseus S.A.
All documentation related to the merger by absorption of Lagarcué S.A. and Theseus S.A. by Grupo Financiero Galicia was approved at the extraordinary shareholders’ meeting of Grupo Financiero Galicia held on November 21, 2013, including the exchange ratio and the above mentioned capital increase of Ps.58,857,580 through the issuance of 58,857,580 class B shares, with a face value of Ps.1, one vote per share, entitling its owners to participate in the profits of the financial year beginning on January 1, 2013.
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On December 18, 2013, the definitive merger agreement contemplating the absorption of Lagarcué S.A. and Theseus S.A. was registered in a public deed pursuant to the terms of paragraph 4 of article 83 of the Ley General de Sociedades (Law No. 19,550, as amended, the General Corporations Law or “Corporations Law”), and effective as of September 1, 2013. Therefore, 25,454,193 class B shares of Banco Galicia, representing 4.526585 % of its capital stock previously owned by Lagarcué S.A. and Theseus and S.A. were transferred to Grupo Financiero Galicia. As a result, Grupo Financiero Galicia then owned 560,199,603 shares of Banco Galicia, representing 99.621742% of its capital stock and voting rights.
On February 27, 2014, by Resolution No. 17,300, the Board of the Comisión Nacional de Valores (the “National Securities Commission”, or the “CNV”) consented to the absorption of Lagarcué S.A. and Theseus S.A and to the above mentioned increase in capital of Grupo Financiero Galicia.
On February 25, 2014, the Board of Directors of Grupo Financiero Galicia resolved to offer to acquire all of the remaining shares of Banco Galicia owned by third parties, amounting to 2,123,962 shares, at an amount of Ps.23.22 per share, which was approved by the CNV on April 24, 2014.
In compliance with Argentine regulations, Grupo Financiero Galicia made all required communications and paid the amounts corresponding to the remaining shares of Banco Galicia held by third parties. On August 4, 2014, Grupo Financiero Galicia became the owner of 100% of the outstanding capital stock of Banco Galicia when the relevant unilateral declaration to acquire the remaining shares of Banco Galicia held by third parties was recorded as a public deed pursuant to Article 95 of the Law No. 26,831 (the “Capital Markets Law”, in Spanish “Ley de Mercado de Capitales”).
On August 15, 2017, the shareholders of Grupo Financiero Galicia approved an increase of its share capital by issuing up to a maximum of 150,000,000 of new Class B shares, book-entry, with a right to one vote and a face value of Ps.1 per share.
On September 26, 2017, the global primary follow-on offering period for Grupo Financiero Galicia’s new Class B shares ended and 109,999,996 class B shares were subscribed for a price of US$5 per share. Such shares were issued on September 29, 2017. The Company granted the underwriters the option to purchase additional class B ordinary shares at the offering price, and on October 2, 2017, the underwriters exercised such option and 16,500,004 additional class B shares at US$5 per share were issued on October 4, 2017.
As a result of the foregoing offering, a total of 126,500,000 ordinary class B shares, book-entry, with a right to one vote and a face value of Ps.1 per share were issued. The new issued and outstanding capital of Grupo Financiero Galicia was therefore Ps.1,426,764,597, represented by 281,221,650 ordinary class A shares, book-entry, entitled to five votes per share and a face value of Ps.1 per share and 1,145,542,947 ordinary class B shares, book-entry, entitled to one vote and a face value of Ps.1 per share.
On May 28, 2019, the Board of Directors of Grupo Financiero Galicia approved a capital contribution to Tarjetas Regionales for Ps.500,000,000 (which, as adjusted for inflation, is equal to Ps.23,048,260,206 as of December 31, 2025) to fund the creation of a new digital financial company, called “Naranja Digital Compañía Financiera S.A.U.” ("Naranja Digital") designed to reach and offer digital banking services to the underbanked population of Argentina. Said capital contribution was effective in two payments of Ps.250,000,000 each, the first one made in June 2019 and the second one made in December 2019. The formation of said company was approved on September 16, 2019, by Resolution 205 of the BCRA.
On July 2, 2019, the Board of Directors of Grupo Financiero Galicia accepted an offer made by Inviu, to acquire 5% of the stock of Galicia Asset Management for US$920,000. Such acquisition made Grupo Financiero Galicia the sole shareholder of Galicia Asset Management. Likewise, on the same date, the Board of Directors of Grupo Financiero Galicia approved the creation of a new company denominated IGAM, to be registered in the State of Delaware, United States of America, to provide brokerage, investing and other financial services in Argentina and in other countries. The registration of IGAM took place on July 3, 2019.
On August 15, 2019, the Board of Directors of Grupo Financiero Galicia accepted a purchase offer made by Banco Galicia to sell 10,000 shares, representing 1% of the capital stock of Inviu, for Ps.695,308.54 (which, as adjusted for inflation, is equal to Ps.29,370,826 as of December 31, 2025). With this share purchase, Inviu is 100% owned by our subsidiary Banco Galicia.
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On September 20, 2019, the Board of Directors of Grupo Financiero Galicia approved a capital contribution to IGAM for Ps.71,000,000, (which, as adjusted for inflation, is equal to Ps.2,832,433,921 as of December 31, 2025), to be applied to the purchase of the total stake in Inviu owned by Banco Galicia. Said operation was closed at a total price of Ps.69,530,854 (which, as adjusted for inflation, is equal to Ps.2,773,824,639 as of December 31, 2025).
On May 5, 2020, the Board of Directors of Grupo Financiero Galicia, with the goal of strengthening its brokerage service offerings approved a sale offer to purchase the entire capital stock of a brokerage company (an ALYC company -Agente de Liquidación y Compensación- meaning those Argentine entities with a broker-dealer license given by the Argentine Market Regulator) called 34 Grados Sur Securities S.A. Said operation was closed for a total price of US$441,230 and the company was re named Galicia Securities.
On May 28, 2020, the Board of Directors of Grupo Financiero Galicia. agreed with the minority shareholders of Tarjetas Regionales to proceed with a corporate reorganization process. Through this corporate reorganization, the minority shareholders of Tarjetas Regionales, Fedler S.A. and Dusner S.A., holders of 17% of Tarjetas Regionales’s shares spin- off its shares in Tarjetas Regionales and they were absorbed, through a merger by Grupo Financiero Galicia.
On September 14, 2020, Grupo Financiero Galicia and the companies Dusner S.A. and Fedler S.A. signed the Preliminary Spin off - Merger Agreement and on December 15, 2020 the definitive Spin off - Merger Agreement was executed. As a result of said corporate reorganization, the shareholders of Fedler S.A. and Dusner S.A received GFG’s 47,927,494 Class B common shares, book-entry, with a par value of Ps.1 per share and 1 vote per share, representing their equity interest in Tarjetas Regionales and Grupo Financiero Galicia acquired the control of the 100% equity of Tarjetas Regionales. The new issued and outstanding capital of Grupo Financiero Galicia was therefore Ps.1,474,692,091, represented by 281,221,650 ordinary class A shares, book-entry, entitled to five votes per share and a face value of Ps.1 per share and 1,193,470,441 ordinary class B shares, book-entry, entitled to one vote and a face value of Ps.1 per share.
Additionally, on June 8, 2021, the Board of Directors of Grupo Financiero Galicia S.A. agreed to make a sale offer of 10,000 Class B book-entry ordinary shares, with a Par Value 1 and Ps.1 per share, representing 0.000569% of Tarjetas Regionales to Galicia Securities for a total price of Ps.175.9 million, (which, as adjusted for inflation, is equal to Ps.3,681.4 million as of December 31, 2025). The price was set based on a book value per share of Ps.17.59 resulting from the Net Assets of Tarjeta Regionales as of April 30, 2021. The sale offer was accepted and implemented on June 15, 2021 by Galicia Securities.
On March 22, 2022, the Board of Directors of Grupo Financiero Galicia approved the creation of Agri Tech, to develop agricultural business opportunities through a digital platform that makes agro-financial management easy to use through digital payment and financing functionalities. The company was registered in Delaware, USA, on April 1, 2022 and locally is developing its commercial activities under the trademark Nera. Grupo Financiero Galicia made an initial capital contribution of Ps.200 million during September 2022 to the company (which, as adjusted for inflation, is equal to Ps.2,092.7 million as of December 31, 2025) and owns the 100% equity of the company. Likewise, during February 2023, Grupo Financiero Galicia made a new capital contribution to Agri Tech of Ps.300 million (which, as adjusted for inflation, is equal to Ps.2,367.2 million as of December 31, 2025).
During the first quarter of 2023, the Board of Directors of Grupo Galicia resolved to create two companies, Galicia Investments, incorporated in the state of Delaware, United States of America and Galicia Ventures, incorporated in Ontario, Canada, in order to channel the investment initiatives within the open innovation and corporate venturing program.
On October 11, 2023, Grupo Galicia acquired 99.43% of the share capital of Seguros Sura S.A. (currently known as Seguros Galicia S.A., formerly known as Sudamericana Seguros S.A. and Sudamericana Seguros Galicia S.A., all changes of name have been approved by the Superintendence of Insurance and the Public Registry, hereinafter "Seguros Galicia"), an insurance company that has insurance solutions and services for individuals and families, SMEs, large companies and the agricultural segment, served by a wide network of insurance advisory producers. On September 21, 2023, the National Insurance Superintendency approved the operation, and as a consequence, on October 11, 2023, it was carried out through the transfer of 4,512,697,946 ordinary shares with a nominal value of Ps.1 (expressed in Pesos) and with the right to one vote per share, representing 99.43% of the capital and votes of Sudamericana Seguros Galicia. Finally, on October 30, 2023, the General Shareholders' Meeting of Sudamericana approved an increase in share capital for Sudamericana through the capitalization of the capital adjustment account and the issuance of new shares. After said approval, the percentage of Banco Galicia's participation on Sudamericana amounts to 9.61% and the participation of Grupo Financiero Galicia amounts to 90.39%.
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On October 23, 2023, the Grupo Galicia's Board of Directors approved the creation of two companies in the United States, Galicia Holdings. in the state of Delaware, parent company of Galicia Capital US LLC, in the state of Florida.
On December 6, 2024, Grupo Financiero Galicia and Banco Galicia completed the purchase from HSBC of its equity stakes in its subsidiaries in Argentina and the acquisition of HSBC's banking, asset management, and insurance businesses in Argentina. On December 11, 2024, as part of the Acquisition, the Company issued a Private Negotiable Obligation under the terms of Law No. 23,576 to cover the price adjustments established in the Share Purchase Agreement, which are based on parameters customary in such transactions. In connection with the Acquisition, Grupo Financiero Galicia also conducted subscription rights offerings, as a result of which 1,325,032,079 Class B shares were outstanding as of February 13, 2025.
Following the acquisition of HSBC Argentina's businesses in December 2024, Grupo Galicia initiated a corporate reorganization. The objective of this reorganization was to optimize and integrate the use of available resources, consolidate a single portfolio of products and services, and offer a high-value customer experience. This transformation was part of Grupo Galicia's strategy to strengthen its financial ecosystem, expand its value proposition, and support the sustainable growth of its businesses. The reorganization was approved by the shareholders' meeting of Banco Galicia, Fondos Fima and Galicia Seguros on April 23, 2025, and approved by the BCRA on May 22, 2025, with accounting and tax effect from January 1, 2025 and legal effect on June 23, 2025.
The GGAL Corporate Reorganization included the dissolution without liquidation of GGAL Holdings S.A. (formerly HSBC Argentina Holdings S.A., "Galicia Más Holdings") and mergers by absorption, with the following results:
•Unification of the banking business: Banco Galicia absorbed Galicia Más (formerly HSBC Bank Argentina S.A.), which was dissolved without liquidation, resulting in a single banking entity.
•Unification of the mutual fund management business: Galicia Asset Management absorbed Galicia Más Asset Management S.A., which was dissolved without liquidation, thus consolidating the business into a single entity.
•Absorption of GGAL Participaciones S.A.U.: Sudamericana Holdings absorbed GGAL Participaciones S.A.U., which was dissolved without liquidation.
As of June 23, 2025, Banco Galicia and Galicia Más began operating as a unified financial entity.
On February 25, 2025, Grupo Financiero Galicia and Banco Santander S.A. entered into an agreement to implement a joint venture to enhance the growth and expansion of Nera's business.
The joint venture comprises Agri Tech Investments Argentina S.A.U. ("Nera Argentina"), Nera Paraguay S.A. and Nera Uruguay S.A. Under this agreement, the parties agreed to establish a holding company in Spain to control the joint venture entities, with Grupo Financiero Galicia and Banco Santander S.A. sharing equal governance and economic rights.
On December 23, 2025, the transaction was completed. On that date, Grupo Financiero Galicia S.A. and Banco Santander S.A. executed a shareholders' agreement pursuant to which each party holds a 50% stake in the holding company, now named Nera Agro Holdings S.L. and domiciled in Spain. Also on that date, an extraordinary general meeting of shareholders approved a capital increase, with Banco Santander S.A. subscribing for the newly issued shares. As a result, both parties share equally in the governance and results of the holding company.
In October 2025, within the framework of companies already established to channel venture capital investment initiatives and to provide the appropriate legal framework for certain investments and new initiatives, the Board of Directors of Grupo Financiero Galicia resolved to create a new entity named Galicia Venture Corp., incorporated in the state of Delaware, United States of America.
During the fourth quarter of 2025, the Board of Directors of Grupo Financiero Galicia, with the objective of continuing to strengthen its brokerage services through its subsidiary commercially known as Inviu, resolved to establish three entities in the United States of America, (i) Vestly Group Corp., which will act as a holding company; (ii) Vestly Capital, LLC, which will operate as a broker-dealer; and (iii) Vestly Advisory LLC, which will act as a registered investment advisor.
ii) Banco Galicia
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Banco Galicia is a banking corporation organized as a stock corporation under Argentine law and supervised and licensed to operate as a commercial bank by the Superintendencia de Entidades Financieras y Cambiarias (Superintendency of Financial Institutions and Exchange Bureaus or, the “Superintendency”).
Banco Galicia was founded in September 1905 by a group of businessmen in Argentina and began operations in November 1905. Banco Galicia’s business and branch network increased significantly by the late 1950s and continued expanding in the following decades, after regulatory changes allowed Banco Galicia to exercise its potential and gain a reputation for innovation, thereby achieving a leading role within the domestic banking industry.
In the late 1950s, Banco Galicia launched the equity mutual fund Fima Acciones and founded the predecessor of the asset manager Galicia Asset Management.
Between 1995 and 1999, Banco Galicia acquired equity interests in entities and formed several non-banking companies providing financial services to individuals in the Interior through the issuance of proprietary brand credit cards. See “—Tarjetas Regionales” below.
On December 27, 2017, Grupo Financiero Galicia, in its capacity as sole shareholder and holder of 100% of the capital of Banco Galicia, integrated a capital contribution of Ps.10,000,000,000 (which, as adjusted for inflation, is equal to Ps.811,035,925,946 as of December 31, 2025). The BCRA, through its Resolution No.35 dated January 11, 2018, approved the capital contribution and its consideration as computable capital.
On January 21, 2019 Banco Galicia, sold to AI Zenith (Netherlands) B.V. 3,182,444 book-entry common shares, with face value of Ps.1 each and one vote per share, representing 7.7007% of Prisma Medios de Pago S.A. (“Prisma”) capital stock. Banco Galicia continues to hold 3,057,642 shares in Prisma, which represents 7.3988% of its capital stock.
In September 2019, Banco Galicia accepted an offer to acquire 100% of the shareholding in Inviu made by IGAM. The price of the operation amounted to Ps.69,530,854 (which as adjusted for inflation, is equal to Ps.2,773,824,639 as of December 31, 2025). See “—Grupo Financiero Galicia”.
During the fiscal year 2020, Banco Galicia, together with other financial institutions, formed a company named Play Digital S.A. (“Play Digital”) with the corporate purpose of developing and marketing a payment solution linked to the bank accounts of the financial system users, which will significantly enhance their payment experience. As of December 31, 2025, Banco Galicia held 19.79% of Play Digital.
On October 1, 2021, the Bank, together with the other Prisma Class B shareholders, provided a notification that the put option had been exercised, and thus that they had initiated the procedure to sell 49% of the capital stock and votes to AL ZENITH (Netherlands) B.V. (a company related to Advent International Global Private Equity). In March 2022, the Bank executed the transfer of all of the remaining capital stock. The price of said shares amounts to US$54,358 and will be paid as follows: (i) 30% in Pesos, adjusted by a CER (UVA) rate plus a nominal annual rate of 15% and (ii) 70% in US Dollars at a nominal annual rate of 10% for a term of six years.
On August 10, 2023, Banco Galicia made an irrevocable equity contribution in the amount of Ps.86.4 million (which as adjusted for inflation, is equal to Ps.427.8 as of December 31, 2025) to Sudamericana. Subsequently, on August 11, 2023 Sudamericana entered into a Share Purchase Agreement for the acquisition of 99.43% of Sudamericana Seguros Galicia for US$19 million. On September 21, 2023, the National Insurance Superintendency approved the transaction, and as a consequence, on October 11, 2023, it was carried out through the transfer of 4,512,697,946 ordinary shares with a nominal value of Ps.1 and with the right to one vote per share, representing 99.43% of the capital and votes of Sudamericana Seguros Galicia. Finally, on October 30, 2023, the General Shareholders' Meeting of Sudamericana approved an increase in share capital for Sudamericana through the capitalization of the capital adjustment account and the issuance of new shares. After said approval, the percentage of Banco Galicia's participation in Sudamericana amounts to 9.61% and its percentage participation in Grupo Financiero Galicia amounts to 90.39%.
In 2024, Banco Galicia, together with Grupo Galicia, consummated the Acquisition. As part of the GGAL Corporate Reorganization, effective June 23, 2025, Galicia Más was merged into Banco Galicia, consolidating the banking operations acquired from HSBC into a single banking entity.
iii) Galicia Más Holdings
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Galicia Más Holdings S.A. (“Galicia Más Holdings”) was a member of Grupo Galicia. Galicia Más Holdings was founded in August 1997 when HSBC Latin America BV, a company ultimately controlled by HSBC Holdings plc, purchased a 97.36% stake in the parent company, Roberts S.A. de Inversiones (now HSBC Argentina Holdings S.A.).
Its origins date back to 1908 with the organization of Leng, Roberts & Company as a partnership that participated in the development of the Argentine economy through activities in the areas of international trade, insurance, and investment banking.
On December 6, 2024, Grupo Galicia acquired HSBC's banking asset management, and insurance businesses in Argentina, for more information, please see "History and development" - "History" - "Grupo Galicia". HSBC Bank Argentina (now “Galicia Más”) is one of the country's leading private retail banks, with 101 branches in 23 provinces and 2,843 employees, as of December 31, 2024. The Acquisition allowed Galicia Más to increase its distribution network and market share in the country, particularly in the retail banking segment.
In 2025, as part of the integration of the businesses acquired from HSBC, Grupo Galicia carried out a corporate reorganization (as described in Item 8.B, the "GGAL Corporate Reorganization"). On April 23, 2025, the shareholders of the relevant entities approved the following transactions, with accounting and tax effect from January 1, 2025 and legal effect on June 23, 2025: (i) the dissolution without liquidation of Galicia Más Holdings and the transfer of its assets and interests to Banco Galicia, Galicia Asset Management, and Sudamericana Holding; (ii) the merger of Galicia Más (bank) into Banco Galicia; and (iii) the merger of Galicia Más Asset Management into Galicia Asset Management. As a result, Galicia Más Holdings and the Galicia Más entities ceased to exist as separate legal entities.
iv) Tarjetas Regionales
In the mid-1990s, Banco Galicia made the strategic decision to target market of the “non-account holding” individuals in Argentina. This segment primarily included low and medium-low income populations residing in the interior regions of the country, as well as certain areas of Greater Buenos Aires. To implement this strategy, Banco Galicia began investing in non-bank companies (the “Regional Credit Card Companies”) in 1995. These companies provided financial services to individuals through proprietary credit card brands and extended credit to customers.
Banco Galicia's first investment in this sector occurred in 1995 with the acquisition of a minority stake in Tarjeta Naranja S.A.U. (“Naranja”). By 1997, Banco Galicia had increased its ownership to 80%. Naranja, which had been operating since 1985 in the city of Córdoba, marketed its proprietary brand credit card and experienced significant local growth.
In 1999, Banco Galicia restructured its credit card business by forming Tarjetas Regionales S.A (“Tarjetas Regionales”) as a holding company for Naranja, Comfiar S.A., Tarjetas Cuyanas S.A. (“Tarjetas Cuyanas”), and Tarjetas del Mar. Between 1999 and 2000, Tarjetas Regionales also acquired Tarjetas del Sur S.A., a credit card company operating in southern Argentina, which merged into Naranja in March 2001.
In February 2019 and December 2019, Cobranzas Regionales S.A. ("Cobranzas Regionales") received capital contributions from its shareholders, Naranja and Tarjetas Regionales, with the purpose of maximizing supporting the growth of its "NPOS" business (now called "Toque," a service that enables merchants to accept debit and credit card payments through wireless devices) and the subsequent launch of the "Naranja X" virtual wallet.
In 2019, Tarjetas Regionales created a new digital financial company called “Naranja Digital”, designed to offer digital banking services to the underbanked population of Argentina. The formation of Naranja Digital was approved by the BCRA on September 16, 2019 pursuant to Resolution No. 205. Naranja Digital subsequently obtained its license to commence operations from the BCRA.
In 2023, Naranja's Board of Directors approved a merger by absorption whereby Naranja (absorbing company) absorbed Cobranzas Regionales (absorbed company) effective October 1, 2023.
In 2024, NHI (UK) Limited was established in the United Kingdom as a wholly-owned subsidiary of Tarjetas Regionales. NHI UK Limited holds a 95% stake in NXers S.A. de C.V., a variable capital corporation incorporated in Mexico in 2024. As of February 2026, NXers S.A. de C.V. has applied for a banking license from the Mexican National Banking and Securities Commission (CNBV) to operate as a Multiple Banking Institution in Mexico, in accordance with the Mexican Law of Credit Institutions.
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v) Sudamericana Holding
In 1996, Banco Galicia entered the bank insurance business, through the establishment of a joint venture with Hartford Life International to sell life insurance and annuities, in which it had a 12.5% interest. In December 2000, Banco Galicia sold its interest in this company and purchased 12.5% of Sudamericana, a subsidiary of Hartford Life International. As a result of various acquisitions, Grupo Financiero Galicia owns 90.39% of Sudamericana (with the remaining 9.61% being held by Banco Galicia) which offers life, retirement, property and casualty insurance products in Argentina through its subsidiaries Galicia Seguros S.A.U. (“Galicia Seguros”), which provides property, casualty and life insurance, Galicia Retiro Compañía de Seguros S.A.U. ("Galicia Retiro"), which provides retirement insurance, Galicia Broker Asesores de Seguros S.A. ("Galicia Broker"), an insurance broker, Well Assistance S.A.U. ("Well Assistance") which provides assistance services and Seguros Sura S.A. ("Seguros Sura") which provides property, casualty and life insurance.
On August 10, 2023, Sudamericana acquired equity interest of Seguros Sura, which provides property, casualty and life insurance through agents, brokers, affinities and directly to local customers.
As part of the GGAL Corporate Reorganization, effective June 23, 2025, the insurance businesses acquired from HSBC were consolidated under Sudamericana Holding. As a result, Grupo Galicia owns 96.28% of Sudamericana, with the remaining 3.72% held by Banco Galicia.
vi) Galicia Asset Management
Galicia Asset Management was incorporated in 1958 and manages the Fima family mutual funds, which are distributed by Banco Galicia through its various channels, including its branch network, home banking and investment centers, among others.
The Galicia Asset Management team consists of experienced asset management professionals dedicated to managing the Fima family funds to meet the needs of individuals, companies, and institutions. Each fund’s assets are allocated across a diverse range of investments, such as bonds, negotiable obligations, trusts, shares and deposits, in alignment with the fund’s investment objective.
In August 2021, the company received approval from the Inspección General de Justicia to change its corporate name from Galicia Administradora de Fondos S.A. to Galicia Asset Management S.A.U.
As part of the GGAL Corporate Reorganization (as described in Item 8.B), effective June 23, 2025, Galicia Más Asset Management was merged into Galicia Asset Management. As a result, Galicia Asset Management incorporated the management of 13 additional mutual funds from the HF fund family. Subsequently, 9 HF funds were merged into 8 FIMA funds, strengthening the product offering and consolidating Galicia Asset Management's position as the leading mutual fund management company in Argentina.
vii) Galicia Warrants
Incorporated in 1993, Galicia Warrants has been providing a wide range of financial services to the agricultural and industrial sectors. Its administrative headquarters are located in the Autonomous City of Buenos Aires and it has an important logistics and storage center in the city of San Miguel de Tucumán that is currently rented. Its shareholders are Grupo Financiero Galicia, which holds 87.5% of the outstanding equity interests of Galicia Warrants, and Banco Galicia, which holds the remaining 12.5% outstanding equity interests.
viii) IGAM and Vestly Group Corp
Incorporated in 2019, IGAM is the holding company for Inviu S.A.U. (“Inviu”), Inviu Uruguay Agente de Valores S.A. (“Inviu Uruguay”), Inviu Capital Markets Limited, Inviu Technology Limited and Inviu Perú SAB SAC. IGAM is registered in Delaware, USA.
Inviu was established in 2019 with the mission to conduct transactions typical of authorized agents, either independently, on behalf of third parties, or through agents, agencies, or branches, in compliance with current laws and regulations governing authorized securities markets. Inviu offers a digital investment platform for independent financial advisors, enabling them to deliver investment experiences to their clients, optimize their daily operations, and improve their financial performance. For investors, Inviu delivers the investment experience they seek: comprehensive advisory services from their trusted advisors, complemented by a mobile app and web platform.
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Inviu Uruguay was established in 2019 and, on July 23, 2021, obtained authorization from the Central Bank of Uruguay to operate as a broker-dealer (agente de valores). As of that date, it became a regulated financial institution under the Financial Intermediation Law and the regulations issued by the Central Bank of Uruguay. This authorization allows Inviu Uruguay to offer brokerage services across Latin America, including access to a wide range of financial products such as equities, fixed income, and mutual funds.
To support its expansion across Latin America, Inviu established Inviu Capital Markets Limited and Inviu Technology Limited in the United Kingdom in 2022. In 2024, Inviu opened its first office in Peru, marking a new phase in its regional growth strategy.
In 2025, it obtained its license to operate as a Sociedad Agente de Bolsa (SAB) in Peru. This authorization enables Inviu to operate as a regulated broker in the Peruvian capital markets, allowing direct access to local market operations. Additionally, the same year, Vestly Group Corp was established as the parent company of Vestly Capital LLC—formed to apply for a broker-dealer license—and Vestly Advisory LLC—formed to apply for a Registered Investment Advisor (RIA) license. Vestly Capital LLC formally initiated its broker-dealer licensing application in December 2025 which is pending regulatory approval.
ix) Galicia Securities
Galicia Securities was incorporated on December 23, 2015, under the name of 34 Grados Sur Securities S.A. and was acquired by Grupo Financiero Galicia on May 5, 2020, with its name subsequently amended to Galicia Securities S.A.U.
Galicia Securities is authorized to act as a settlement and compensation agent and placement and distribution agent of mutual funds in Argentina. The stated purpose of Galicia Securities is to conduct on its own behalf, on behalf of third parties, or through agents, agencies or branches, the operations which are typically performed by settlement and compensation agents and distribution agents and those authorized by current Argentine laws.
Galicia Securities is a member of the Argentine Stock Exchange Market (“BYMA”) and the Argentine Electronic Open Market.
x) Galicia Ventures, Galicia Investments and Galicia Ventures Corp
On January 10, 2023, the Board of Directors of Grupo Financiero Galicia resolved to create two companies, (i) Galicia Investments, established in Delaware, United States of America and (ii) Galicia Ventures, established in Ontario, Canada. These two companies were created to invest in venture capital startups that offer potential synergies with Grupo Financiero Galicia's subsidiaries, partnering with both local and foreign entrepreneurs at various stages of development. The investment focus includes fintech (financial technology), agtech (technologies aimed at improving efficiency, productivity and sustainability in agriculture and livestock) and insurtech (technology-driven innovations in the insurance sector).
Additionally, on October 28, 2025, the Board of Directors of Grupo Financiero Galicia resolved to create Galicia Ventures Corp, a company incorporated in the State of Delaware, United States of America, with the same investment focus as Galicia Investments and Galicia Ventures.
Grupo Financiero Galicia owns 100% of the shares of Galicia Investments and 100% of the shares of Galicia Ventures Corp.
Galicia Investments owns a 1% stake in Galicia Ventures, and the remaining 99% is owned by Grupo Financiero Galicia.
As of December 31, 2025, Galicia Ventures had a presence in four Latin American countries with a total of 10 active investments. In Argentina, it has invested in Eiwa, Remitee, Fudo, Lebane, Moova, and SiloReal. In Uruguay, it has invested Strike. In Colombia, it has invested in Payana and Simetrik. In Mexico, it has invested in Crabi.
xi) Galicia Holdings
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On October 23, 2023, the Board of Directors of Grupo Financiero Galicia approved the creation of two companies in the United States of America, (i) Galicia Holdings US Inc., incorporated in the State of Delaware, and (ii) Galicia Capital US LLC, incorporated in the State of Florida .
Galicia Holdings US Inc. controls and serves as the holding company of Galicia Capital US LLC.
Galicia Capital US LLC is a Broker - Dealer member of FINRA, authorized to engage in transactions involving listed and over-the counter corporate equities securities, mutual funds, government securities, time deposits at financial institutions, and put and call options as a broker, dealer or option writer. The company may act as a non-exchange member arranging transactions in listed securities through exchange members, trade for its own account and engage in private placements of securities. Customer accounts will be introduced to carrying brokers on a fully-disclosed basis. Galicia Capital US LLC is also authorized to act as a chaperone for its foreign affiliates for both research distribution and the execution of securities transactions with U.S. institutional investors pursuant to Rule 15A-6. Additionally, it may offer structured notes issued by banks and other broker-dealers.
xii) Agri Tech
Agri Tech Investments LLC (commercially known as "Nera") was incorporated on April 1, 2022, in the United States of America, under the laws of the State of Delaware. Nera offers a digital ecosystem for payments and financing in the agricultural sector, connecting producers, suppliers and financial institutions. Through a fully digital integrated platform, it offers multiple financing alternatives for the purchase of agricultural inputs or livestock.
Agri Tech is the holding company of Agri Tech Investments Argentina S.A.U., incorporated in Argentina on August 16, 2022, and Nera Uruguay S.A. (formerly Halsiuk S.A.), a Uruguayan public limited company acquired by Agri Tech in June 2023, as part of Nera’s regional growth strategy for 2024 and 2025.
As part of this regional expansion, Nera also established a subsidiary in Asunción, Paraguay, named Nera Paraguay, which commenced operations in 2025.
On February 25, 2025, Grupo Financiero Galicia and Banco Santander S.A. entered into an agreement to implement a joint venture to enhance the growth and expansion of Nera's business.
The joint venture comprises Agri Tech Investments Argentina S.A.U. ("Nera Argentina"), Nera Paraguay S.A. and Nera Uruguay S.A. Under this agreement, the parties agreed to establish a holding company in Spain, to control the joint venture entities, with Grupo Financiero Galicia and Banco Santander S.A. sharing equal governance and economic rights.
On December 23, 2025, the transaction was completed. On that date, Grupo Financiero Galicia and Banco Santander S.A. executed a shareholders' agreement pursuant to which each party holds 50% stake in the holding company, now named Nera Agro Holdings S.L. and domiciled in Spain. Also on that date, an extraordinary general meeting of shareholders approved a capital increase, with Banco Santander S.A. subscribing for the newly issued shares. As a result, both parties share equally in the governance and results of the holding company.
A.2 Capital Investments and Divestitures
During 2025, our capital expenditures amounted to Ps.112,765 million, allocated as follows:
•Ps.117 million in fixed assets (real estate, machinery and equipment, vehicles, furniture and fixtures);
•Ps.112,649 million in licenses and other intangible assets.
During 2024, our capital expenditures amounted to Ps.284,963 million, allocated as follows:
•Ps.177,576 million in fixed assets (real estate, machinery and equipment, vehicles, furniture and fittings); and
•Ps.107,388 million in licenses and other intangible assets.
During 2023, our capital expenditures amounted to Ps.212,037 million, allocated as follows:
•Ps.102,770 million in fixed assets (real estate, machinery and equipment, vehicles, furniture and fittings); and
•Ps.109,268 million in licenses and other intangible assets.
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These capital expenditures were primarily made in Argentina.
For a description of our divestitures in 2025, 2024 and 2023, please see “—History” —“Grupo Financiero Galicia”, “Banco Galicia” and “Tarjetas Regionales”.
A.3 Investment Planning
We have budgeted capital expenditures for the fiscal year ending December 31, 2026, for the following purposes and amounts:
December 31, 2026
(in millions of Pesos)
Infrastructure of Corporate Buildings, Tower and Branches (construction, furniture, equipment and other fixed assets) 80,534
Organizational and IT System Development 173,026
Total Investment Planning 253,560
These capital expenditures will primarily be made in Argentina. Management believes that internal funds will be sufficient to finance capital expenditures for the year ending December 31, 2026.
The SEC maintains the following website that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC: http:// www.sec.gov.
B. Business Overview
B.1 Business
We are a financial services holding company and conduct our business through the following subsidiaries and joint ventures:
•Banco Galicia;
•Tarjetas Regionales, commercially known as "Naranja X";
•Galicia Asset Management, commercially known as "Fondos Fima";
•Sudamericana Holding, commercially known as "Galicia Seguros";
•IGAM and Vestly Group Corp, commercially known as "Inviu";
•Galicia Securities;
•Galicia Ventures, Galicia Investments and Galicia Ventures Corp, collectively known as "Galicia Ventures"; and
•Agri Tech, commercially known as "Nera" (joint venture).
Please refer to the aforementioned commercial names for the purposes of identifying the different entities when reviewing this Item 4. "Information on the Company" – Section B. "Business Overview".
(i) Banco Galicia
Banco Galicia is one of Argentina’s largest full-service banks and is a leading provider of financial services in Argentina. It is also our largest subsidiary. According to information provided by the BCRA, as of December 31, 2025, Banco Galicia ranked first in terms of assets, deposits, loans and in terms of net worth within private-sector banks in Argentina. Its market share of private sector deposits and of loans to the private sector was 16.21% and 14.31%, respectively, as of December 31, 2025. As of December 31, 2025, Banco Galicia had total assets of Ps.36,652,385 million, total loans and other financing of Ps.18,347,925 million, total deposits of Ps.25,566,662 million, and its shareholders’ equity amounted to Ps.6,023,617 million.
In 2025, Banco Galicia marked 120 years of uninterrupted presence in Argentina. Since its founding in 1905, it has demonstrated a sustained capacity to adapt to different macroeconomic and regulatory contexts, consistently maintaining its core values of trust, proximity, and customer focus. This anniversary represented not only an institutional
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milestone but also the starting point of a new phase of growth, aligned with Banco Galicia's commitment to continue driving economic development and financial innovation in the country.
Furthermore, in 2025, following the successful completion of the integration process of Galicia Más businesses, which began in 2024, Banco Galicia consolidated its position as Argentina's leading privately held financial services platform. This process was centered on the customer, prioritizing a seamless migration that ensured operational continuity and provided a consistent experience throughout the transition.
Banco Galicia provides a full range of financial services through one of the most extensive and diversified distribution platforms amongst private-sector financial institutions in Argentina. This distribution platform, as of December 31, 2025, was comprised of 316 full service banking branches, located throughout the country, 787 ATMs and 1,356 self-service terminals owned by Banco Galicia, phone banking and e-banking facilities. Banco Galicia also maintains an operational presence within company facilities through its On-Site Banking (BeP) model, allocating resources and personnel to provide direct, on-site service. This channel is a strategic element of proximity, designed to facilitate access to financial products and services, strengthen relationships with corporate clients, and support the daily operations of employees at these institutions. As of December 31, 2025, the total number of BeP locations was 27.
Banco Galicia’s customer base was comprised of 5,216,740 customers. Banco Galicia has a strong competitive position in retail banking, both with respect to individuals and SMEs. Specifically, based on internal studies undertaken by Banco Galicia, it is estimated that Banco Galicia is one of the primary providers of financial services to individuals, one of the largest providers of credit cards, one of the primary private-sector institutions serving SMEs, and has traditionally maintained a leading position in the agriculture and livestock sectors. Banco Galicia’s primary clients are classified into four categories or segments, Retail, Business and SMEs, Wholesale and Financing, as explained further below in the Segment Tribes subsection.
Alongside its growth and consolidation, since 2018 Banco Galicia has undergone a significant transformation aimed at increasing flexibility, efficiency, and adaptability in an environment of constant change. This process led to the consolidation in 2020 of an agile organizational model, designed to respond dynamically to business challenges without sacrificing stability or strategic focus.
Building on this foundation, beginning in 2021, Banco Galicia, focused on developing a data-driven culture, recognizing that personalization, efficiency, and informed decision-making are key to enhancing the customer experience and business profitability. This approach was further developed in 2022 with the evolution of the cultural framework, placing people, teamwork, innovation, and continuous experimentation at the center, as drivers to sustain growth and generate a positive impact on customers' daily lives.
Throughout 2025, Banco Galicia continued to consolidate its data-driven culture through various complementary approaches. First, by strengthening the operational and cultural model, focusing on skills development, behavioral guidance, and effective communication, fostering habits such as systems thinking, analytical learning, information democratization, critical thinking, and analytical innovation. This approach was supported by training programs and internal communication initiatives aimed at consolidating an increasingly data-driven organization.
Second, in 2025, Banco Galicia continued to expand the use of machine learning and artificial intelligence models applied to specific business cases, with a direct impact on operational efficiency and service personalization. These initiatives strengthened operational intelligence, with data as a central component of services, and advanced the progressive decentralization of knowledge to business teams. This process was supported by the incorporation and evolution of technological tools that enable more agile and efficient use of information, automating key business decisions and processes, and serving as a fundamental enabler of simpler and more personalized service.
Finally, in 2025, Banco Galicia advanced industry specialization as a strategic initiative to reinforce its customer focus. In an increasingly commoditized financial system, vertical integration of the business was consolidated as a means of generating differentiated value, deepening sector knowledge, and achieving a more precise understanding of each client's specific needs.
a) Segments
Through segment tribes (i.e. multidisciplinary teams that are organized around one single objective) Banco Galicia offers clients a value proposition that meets their needs and behavior. Segments are focused on Banco Galicia’s clients'
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everyday operations, ensuring an agile and simple relationship between Banco Galicia and its clients that is designed to result in sustained customer growth. In order to best tailor its everyday client support and offerings, Banco Galicia has divided its clients in four segments as described below.
a.i) Retail Segment
The Retail Segment comprises all clients who are individuals without any business activity. This segment serves 4,632,661 customers.
Banco Galicia has focused on enhancing the digital experience, leveraging advancements in the Galicia App to improve customer service processes and strengthen self-service capabilities. One of the key objectives has been to encourage use of the help section, making it increasingly easy for customers to find answers and resolve common issues independently within the app – without needing to contact a representative.
This transformation process continued throughout 2025. During this period, Banco Galicia focused on proactively meeting the needs of its customer base by developing new features and optimizing processes across its service channels. This was complemented by the adoption of advanced technologies designed to improve and enrich the everyday experience of its customers. In 2025, 89% of active customers chose to operate through digital channels, reaching 3 million monthly users on the mobile app and an 84% token adoption rate.
Furthermore, to strengthen self-service and the user experience, during 2025, Banco Galicia:
•implemented a new management system for customer service officers, reducing response times and streamlining case resolution;
•incorporated artificial intelligence tools into its e-learning platform, enhancing knowledge development within teams and improving interaction between representatives and clients;
•continued to promote the use of digital channels, such as the help section, to facilitate self-service inquiries;
•enhanced customer service through Gala, its virtual assistant, improving the accuracy of responses and offering a smoother experience for unassisted interactions; and
•continued to develop the Cuenta FIMA experience and launched interest-bearing savings accounts in US dollars, reinforcing its commitment to innovative financial solutions focused on savings management and yield generation.
Finally, in 2025, Banco Galicia achieved a strategic milestone that embodies its commitment to putting customer first: the integration of Galicia Más customers. Banco Galicia ensured a seamless transition through strategic communications and personalized support, and implemented a dedicated post-migration support program designed to safeguard customer experience and trust. This program included continuous monitoring, priority omnichannel support with a digital focus, dedicated 24/7 representatives, and advanced self-service tools, allowing customers to operate normally from day one and immediately access all of Banco Galicia's products and services.
Within the Retail Segment, customers are served under the following models:
•MOVE
•Personas (Individuals)
•Plus
•EMINENT
1.Personas (Individuals), MOVE, and Plus Clusters: These clusters represent 82.8% of clients within the Retail Segment.
For customers in these sub-segments, the value proposition includes a comprehensive package of products and services designed to support their daily lives. This package includes credit cards, loans, insurance, benefits, and exclusive promotions. Cashback is credited immediately directly to the customer's account, allowing them to save and access their money when they need it. Customers also have access to personalized support 24/7 and a comprehensive app that allows them to manage their transactions simply and independently. Specifically for the Move sub-segment, the proposition is based on four main pillars: free access, speed, simplicity, and digitalization.
Under the "Tenés Galicia" initiative, Banco Galicia offers a simple, secure and fully digital solution aimed at simplifying customer’s lives through products and services that support their day-to-day needs. Within this
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framework, the Bank continuously reviews and optimizes its communications and customer touchpoints, aiming to position itself as the first choice in various aspects of their daily lives and interactions with financial services.
In 2024, the financing vertical was strengthened to provide greater credit flexibility, enabling more customers to access credit solutions. A credit card specifically designed for MOVE clients was introduced, allowing access to installment payments, exclusive benefits, and discounts. Additionally, in 2025, Banco Galicia introduced an option that allows clients to pay for services and purchases made via QR code in installments, without the need for a physical card, providing greater flexibility in payment methods.
Another major focus was on enhancing the customer experience. The goal is to optimize self-service capabilities, ensuring that the help portal offers all the necessary information for customers to resolve issues independently—without needing in-person or digital support.
Throughout 2025, Banco Galicia continued expanding the value proposition initiated in 2024, focusing on acquisition and development of sub-segments such as retirees, clients with direct salary deposit, and students. Specifically, in the university segment, the Bank offered a welcome cashback benefit upon account opening, along with specific academic-related offers, such as discounts at dining halls, cafeterias, and bookstores, with the aim of facilitating students' daily banking needs.
2.ÉMINENT Cluster: This cluster represents 17.2% of clients within the Retail Segment.
Banco Galicia aims to meet the needs of its most demanding and distinguished clients through Eminent Black and Eminent Platinum. They are structured through three core pillars of service: exclusive attention, personalized benefits and experiences, and agile, simplified processes. With a focus on building long-term, trust-based relationships, Banco Galicia offers the Galicia ÉMINENT premium service, which provides differentiated and exclusive support through dedicated ÉMINENT executives at branches and digitally via Galicia Conecta—offering personalized assistance through WhatsApp or email, regardless of the client’s location, with 24/7 availability.
Additionally, customers in this sub-segment have access to higher cashback percentages and limits across various consumption categories compared to other customer segments. These include, among others, supermarkets, fuel, restaurants, and clothing, reinforcing a value proposition focused on savings and everyday spending.
During 2025, Galicia launched a savings account service in US dollars, offering an attractive alternative for clients seeking to earn interest on their foreign currency balances. It also finalized the reassignment of executive portfolios to improve and focus preferential attention on the clients who need it most. Simultaneously, it implemented fees adjustments on high-interest products for this segment, reducing fees on securities and lowering costs for foreign trade payment orders. In addition, it introduced the new Travel Section, designed to support clients at every stage of their trip—before, during, and after—providing them with the right products at the right time.
In terms of experiences, Galicia continued to develop outstanding events associated with different card brands. For Amex clients, the Food & Wine event was held at the Palacio Duhau, along with tennis tournaments and clinics, and marathons in conjunction with the Runners Club. For Visa clients, the golf tournament at Olivos Golf Club was a highlight, and for Mastercard clients, padel tournaments and clinics were offered. Furthermore, it expanded its reach to the interior of the country, with golf tournaments in key locations in partnership with Visa Signature. Other initiatives included guided tours at the Museum of Fine Arts, cultural events at the Jockey Club, and sponsorship of the Buenos Aires International Book Fair (FILBA) with workshops and exclusive benefits. It also supported customers during peak tourist seasons with benefits at ski resorts, spas, and other vacation destinations. Finally, in the entertainment sector, Galicia customers enjoyed exclusive presales through interest-free installments and ongoing discounts at restaurants, thus reinforcing a comprehensive and distinctive offering.
a.ii) Business and SMEs
The Business & SMEs cluster is composed of individuals with commercial activity that generate annual revenues up to Ps.125 million and small to medium-sized enterprises (SMEs) that generate annual revenues between Ps.125 million and Ps.10 billion. This is a heterogeneous segment, with differentiated operational needs depending on the type of activity and business model. Clients categorized as Businesses have a daily routine focused on collecting payments in a simple, agile and efficient manner. SMEs, on the other hand, often require support with payment products (for assets, suppliers, etc.) and guidance on foreign trade, among other needs. In 2025, 74% of the segment corresponded to Businesses and 26% to SMEs.
Banco Galicia classifies businesses and SMEs based on their business models:
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•Business to Consumer (B2C): Focused on a high number of clients and transaction volumes
•Business to Business (B2B): Companies with fewer clients but higher average transaction values, with a stronger focus on payment solutions.
With the purpose of improving the everyday lives of more people, Banco Galicia is committed to supporting and empowering businesses and SMEs by being a reliable partner in their operations. Since 2022, the Bank has offered Nave, an innovative solution designed to boost sales, streamline tasks, and foster business growth. With Nave, businesses take a one-stop approach, accept all digital payment and collection methods instantly—with competitive rates—and access insight about their customers. For those with e-commerce operations, Nave offers seamless integration with Tienda Nube or the option to create an online store from scratch via Tienda Negocio.
For SMEs that serve other businesses (B2B), Banco Galicia provides tools to strengthen their value chains. Examples include:
•“Valued Partners”: A financing solution that benefits both buyers and suppliers. Buyers receive fixed-rate financing through their suppliers, who in turn receive cash payments for their sales.
•Specialized foreign trade advisors: Dedicated professionals who help clients explore international markets and secure financial support through accessible, localized service.
In 2025, Banco Galicia relaunched “PYMEntón” as a mass-market brand positioning campaign, while continuing to offer special benefits for small and medium-sized enterprises (SMEs). In this new phase, the Galicia Office App served as the central focus of the communication strategy. The relaunch yielded positive results, driving new client acquisition and generating a favorable impact throughout the entire business development process, from initial contact to the completion of sales.
Finally, during 2025, Banco Galicia actively promoted the development of SME communities nationwide through various initiatives. Training and networking events were held under the "Encuentro PyME" brand in several locations across the country, such as Entre Ríos, Salta, and Buenos Aires, with high participation. Special emphasis was also placed on the franchise ecosystem, creating spaces for connection between companies, investors, and success stories. The "El Ascenso" initiative was the main support program, consisting of regular meetings aimed at boosting the businesses of groups of entrepreneurs from different regions, such as Neuquén, Santa Fe, and Tucumán. These efforts were strengthened by the addition of strategic partners, such as business schools and universities, which allowed for the dissemination of valuable tools and best management practices to a growing number of SMEs.
a.iii) Wholesale Segment
The Wholesale Segment, comprised of 42,983 customers as of December 31, 2025, is focused on becoming a strategic partner by orchestrating business ecosystems and contributing to the development and improvement of the day-to-day operations of more companies.
Among the pillars of the value proposition, the focus is on the service model through an omnichannel strategy, which seeks to be available 24/7 when the customer needs it. In line with this strategy and in order to provide national coverage to these clients, they have a team of specialists who provide coverage nationwide in 25 business centers strategically located by industry.
At the same time, Galicia continues to build loyalty, strengthening the relationship with customers by inviting them to more than 200 events scheduled throughout the year, as well as digital meetings on content of interest on economy, politics and digitalization, which allows reaching every point in the country, allowing Galicia to be placed in the first position of TOM (Top Of Mind) in all segments.
Banco Galicia continues to enhance the daily operations of its wholesale clients through technological solutions that optimize management workflows. These tools improve operational efficiency at competitive costs and offer a fully digital experience, available through Office Banking and the Wholesale App. In 2025, Banco Galicia revamped its digital channels for businesses, implementing an improved version of Office Banking. Key enhancements included the addition of Business Switch functionality, which enables efficient management of accounts for multiple companies from a single platform. Additionally, Banco Galicia redesigned the login process, password and user recovery features, and the account
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overview. In line with strengthening its financial value proposition, Banco Galicia added a new investment section and incorporated specific functionalities in critical areas such as checks, agreements, credit ratings, loans, and foreign trade.
During 2025, the integration of client portfolios from Galicia Más was successfully completed, adding 2,642 clients to the Wholesale segment. This process consolidated Banco Galicia's market position and expanded its client base while maintaining its standards of service, agility, and specialized attention.
With a focus on client growth, Banco Galicia expanded its service model by incorporating three new strategic verticals: Energy and Mining, Automotive, and Mass Consumption. This expansion deepened sector expertise and enriched the business ecosystem, providing clients with access to a validated network of potential customers, suppliers, and business partners to accelerate growth opportunities.
Verticalization is a long-term strategic decision. Industry specialization allows for a deep understanding of clients' businesses, enables more valuable conversations, and improves support capabilities. Experience in the agricultural sector demonstrates that a thorough understanding of a production chain allows for a more effective and sustainable impact.
As a result of this evolution, the segmentation of the Wholesale business is defined in the following verticals:
1.Energy and mining
The Energy and Mining sector comprises companies dedicated to the exploration, extraction, and processing of natural resources. These activities are characterized by long-term investment cycles and high capital intensity. In this context, Banco Galicia's strategy focuses on integrating across the entire value chain of the sector, positioning itself through strategic alliances with key players to indirectly reach their extensive network of suppliers.
Banco Galicia has 2,121 clients within the Energy and Mining sector, with a predominant focus on the Oil & Gas, mining, and renewable energy sectors. Active participation throughout the entire value chain, along with a sales team dedicated exclusively to this industry, allows the Bank to deeply understand the sector's specific needs and its main operational challenges. This knowledge enables the design of financial solutions that connect the large companies driving the sector's activity with their supplier network, strengthening the functioning of the entire ecosystem. Within this framework, during 2025, Banco Galicia developed strategic alliances with leading companies in the sector and expanded its presence in segments where it previously had no participation.
2.Automotive
The Automotive vertical encompasses the various players that make up the sector's ecosystem, including manufacturers, auto parts suppliers, dealerships, and savings plan administrators. Banco Galicia's value proposition focuses on providing financial and operational support to these companies through specific solutions for inventory management, secured financing, and leasing.
During 2025, the automotive industry experienced strong growth. In this context, Banco Galicia leveraged the sector's positive momentum to consolidate its presence throughout the entire value chain.
At the end of 2025, the Bank had 1,971 clients within this vertical. Coverage includes everything from large manufacturing plants and importers to auto parts suppliers, distributors, logistics operators, dealerships, and after-sales service centers. This cross-sector presence, along with a specialized sales team dedicated exclusively to the automotive industry, allows the Bank to deepen its relationship with manufacturers and extend this work to the rest of the ecosystem, generating high-impact alliances.
Within this framework, Banco Galicia developed strategic alliances with key players in the sector, including Toyota, Mercedes-Benz, and Iveco, consolidating a strong position in vehicle financing. By the end of 2025, its secured loan portfolio reached Ps.29,673 million. Additionally, through agreements, collection solutions, insurance, and new products—such as the implementation of QR code payments for savings plans—the Bank expanded its value proposition, extending its coverage from auto parts suppliers to dealerships and reinforcing its role within the automotive ecosystem.
3.Mass Consumption
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The Mass Consumption vertical comprises manufacturers, distributors, and large retailers dedicated to the sale of fast-moving consumer goods. This sector is characterized by a high level of transaction volume and intensive cash flow management. In this context, Banco Galicia's strategy focuses on building a vertical with a comprehensive vision, designed to orchestrate these flows efficiently and sustainably.
Even in a challenging environment, the consumer goods sector maintained a significant level of activity. Large companies in the sector continue to transform their business models, incorporating fintechs, marketplaces, and new ways of operating. In this scenario, Banco Galicia has 5,739 clients, with a presence throughout the entire value chain. This coverage includes large producers of food, beverages, appliances, and textiles, as well as suppliers, distributors, logistics operators, and points of sale.
This cross-chain presence is supported by a sales team fully specialized in this vertical. This approach allows for the development of solutions focused on managing collections and payments, financing based on actual cash flow, and the development of platforms that connect the various stakeholders in the ecosystem. The goal is to support daily operations and facilitate client growth in a high-scale and complex environment.
Within this framework, in 2025 Banco Galicia launched a Minimum Viable Product (MVP) with Coca-Cola, designed to finance approximately 10,000 businesses, with a potential customer base exceeding 40,000. By year-end, this initiative had achieved a 14% market share, consolidating the Bank's presence within the mass consumption value chain and strengthening its position in the segment.
4.Agriculture
The Agribusiness subsegment serves clients comprised of agricultural producers and companies involved in the various stages of the agribusiness chain. Banco Galicia supports the development of these clients through an ecosystem of agile digital solutions, designed to handle the sector's daily operations and adapt to the seasonality inherent in the agricultural business. As of December 31, 2024, the total number of clients in this segment was 22,513, increasing to 24,637 as of December 31, 2025.
Galicia Rural's financing offerings are continuously evolving and expanding year after year to meet the needs of producers. The Bank recognizes the high potential of the agribusiness ecosystem and, within this framework, offers a wide range of financial products for the acquisition of inputs, machinery, vehicles, and livestock. These solutions stand out for their competitive features in terms of digitalization, operational simplicity, rates, currencies, and terms. Among the most relevant products and services are daily operations with eCheq, payroll, bill payments, and collection solutions, all available at competitive rates and 100% online through Office Banking.
Through Nera joint venture (see Item 4.A-Agri Tech), the digital payments and financing ecosystem for agriculture, Banco Galicia offers alternatives to finance production campaigns through lines of credit in dollars, pesos, and grains. The platform allows producers to analyze online the offers of more than 1,400 providers and select the terms that best suit their production cycle.
In 2025, Galicia Rural's disbursements through the Nera platform amounted to Ps.138,060 million and US$766 million, and secured loans totaled Ps.17,172 million and US$81 million, reflecting a greater share of financing in foreign currency.
During 2024, the PUMA Platform finalized the development of the MVP for carbon footprint measurement. This tool allows for differentiated measurements by type of activity and geographic area, facilitating the definition of action plans based on real data. Clients who use the platform to measure their carbon footprint can access the sustainable loan program, which offers special conditions aimed at promoting responsible practices.
In line with this approach, Banco Galicia promoted several sustainable financing initiatives. These include agreements with Igaris, the Bayer and Viterra Project, and the LDC Sustainable Agriculture Project, developed in partnership with Syngenta and Nestlé, all aimed at promoting more efficient and sustainable production models.
Furthermore, in 2025 Banco Galicia launched Auto Warrant Ganadero, an innovative product that allows producers to access preferential financing options. The guarantee is established through digital tracking of livestock, both on dairy farms and in feedlots, via integration with the Silo Real platform, strengthening traceability and risk management.
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5.Public Sector
The Public Sector subsegment comprises the national, provincial, and municipal governments. It also includes state-owned enterprises, universities and public educational institutions, pension funds, professional associations, and social welfare organizations, among other relevant entities.
During 2024, the segment was impacted by the economic situation and the macroeconomic measures implemented. The decline in revenue collection and resources from revenue sharing affected investment balances in provinces and municipalities. In this context, although greater demand for credit and financing was expected, particularly for infrastructure projects, this demand was lower than initially anticipated.
In 2025, the national economy experienced a fiscal surplus and slowing inflation, albeit with volatility characteristic of a midterm election year. The Public Sector saw an improvement in revenue collection levels but continued to face pressures related to social spending and pre-existing financial obligations. This dynamic limited the availability of resources, especially in jurisdictions highly dependent on national transfers and with lower self-generated revenue.
Within this context, demand for financing remained active, with a predominant focus on infrastructure projects. Banco Galicia actively participated in key provincial and municipal debt issuances, reinforcing its role as a financial partner to the public sector.
Banco Galicia's strategy focused on identifying sustainable and scalable business opportunities, aligned with a long-term vision and strengthening of institutional ties. As a result of this approach, Banco Galicia was appointed Financial Agent for the City of Luján de Cuyo, in the province of Mendoza. This milestone represents the second jurisdiction under this operating model for the institution, consolidating its nationwide presence and strengthening its management capacity in this segment.
6.Other activities
This category comprises companies whose economic activity is not included in any of the previously defined strategic verticals.
a.iv) Financial Segment
The Financial Segment includes (i) financial institutions clients and (ii) institutional clients which are described below.
(i)Financial institutions: This subsegment includes local and international banking entities, international organizations, international investors, capital markets participants, and both financial and non-financial companies regulated by the BCRA, with credit card companies among the most relevant players.
On the international front, Banco Galicia maintains relationships with correspondent banks, international credit agencies, official credit institutions, and export credit insurance companies. Domestically, Banco Galicia’s clients include banks, financial companies, brokerage firms, and other entities involved in financial activities.
During 2025, local financial institutions faced a more challenging environment for liquidity management and high interest rate volatility. This dynamic was a direct consequence of monetary policy, which allowed interest rates to be determined endogenously. As a result, an increase in interbank lending operations was observed, primarily through short-term secured loans.
The high level of real interest rates had a significant impact on the financial system. It contributed to an increase in the loan portfolio delinquency rate and eroded the financial margins of financial institutions, in a context of a sharp increase in reserve requirements. Settlement and clearing agents (ALyCs, by their Spanish acronym) also faced an adverse environment, reporting significant losses in their equity to the CNV
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(National Securities Commission) due to the high volatility of assets during an election year.
Internationally, as a consequence of the December 2023 devaluation and the reduced economic activity resulting from the anti-inflation plan, a decrease in the demand for external funding to finance imports was observed. This need was primarily met through lines of credit provided by correspondent banks and multilateral organizations.
During 2025, a shift in perceptions toward the Argentine financial system was observed. A greater number of institutions expressed a willingness to resume or deepen relationships with local banks, reflecting support for the orthodox fiscal policy implemented by the government. However, these institutions continue to await improvements in the country's credit ratings, which would allow them to operate with lower capital requirements.
(ii)Institutional: This subsegment comprises the Bank's clients such as mutual funds, insurance companies, and other institutional investors (e.g., the ANSES) served by the Bank.
This subsegment is characterized by a limited number of clients, but they are highly significant in terms of the volume of financial and capital market operations. Given the scale and intensity of activity, clients in this subsegment prioritize not only competitive pricing, but also high-quality advisory services and speed of execution. The offering is complemented by transactional products (collection payments) and asset custody services, which are particularly relevant in the insurance segment.
In 2025, the Institutional segment showed nearly neutral performance in real terms relative to deposit growth, while maintaining a steady volume of trading operations with clients in the secondary market. Deposit growth was again primarily driven by Mutual Funds, whose assets under management grew by more than 20%, with a greater weighting of money market funds.
b) Trading & Global Markets
One of the main responsibilities of the Office of Trading & Global Markets is the administration and operation of the positions in foreign currency, financial derivatives, liquidity position and securities, public or private, for its own portfolio or intermediation, in the primary or secondary market, with counterparties or clients.
Based on the latest information available in 2025 regarding the secondary market for sovereign bonds, Banco Galicia and its subsidiaries ranked sixth in the BYMA fixed income ranking for the twelve-month period, with a 3.14% market share.
In the primary market for fixed income, according to the latest information available from A3 Mercados, Banco Galicia remains one of the leading entities in the consolidated ranking (trusts, private debt, and sub-sovereigns) with a market share of 12.6%, ranking second among banks and first among banks with private national capital. Additionally, comprehensive advisory services have allowed Banco Galicia to stand out in the placement of corporate securities, achieving a leading position with a 20% market share.
In the foreign exchange market, Banco Galicia ranked first in the A3 Mercados ranking, having traded US$ 34,726 million out of the total market volume of US$226,519 million during 2025, representing a 15.33% market share.
In the A3 Mercados guaranteed futures market, Banco Galicia ranked first in trading volume.
iii) Naranja X
Consolidated as one of the most important local fintech companies, Naranja X develops products, services and functionalities to manage personal finances. It seeks to offer the best experience and promote financial inclusion.
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Naranja X is committed to providing financial solutions that facilitate and promote a good relationship between people and their money. Naranja X aims to create opportunities for millions of people in Argentina who are excluded from the traditional financial system and access to credit. With over 40 years of history, it has evolved from Salto 96, a sports store, to become the most chosen credit card in Argentina, and since 2019, to become Naranja X, a comprehensive platform of financial products and services.
Through its app, digital channels, and more than 100 branches throughout the country, Naranja X offers an agile, efficient, and personalized experience. This allows people to make transactions, pay for services, manage their cards, and enjoy exclusive promotions and access to loans and insurance.
During 2025, associated with the credit card business, Naranja X issued 3.4 million account statements, an 8% decrease compared to 2024. Additionally, Naranja X reached 3.9 million active users and authorized 8.9 million credit cards, including Naranja X Classic, Naranja X Visa, Naranja X MasterCard, and Naranja X American Express. Naranja X optimized its logistics and security by launching Infoless with Mastercard, reducing delivery times by 90% (from 5 to 1.3 days) and achieving an 11% activation rate for virtual cards. Additionally, the company enhanced e-commerce safety by certifying Visa Click to Pay integration. During this period, customers averaged six monthly transactions, including purchases, automatic debits, cash advances, and ATM withdrawals.
In terms of savings accounts, during 2025, Naranja X registered an 24% growth, with more than 8.6 million active account users, achieved a 30% increase in levels of transactionality and the issuance of physical debit cards reached 6.2 million. Naranja X also reached a record balance of Ps.2,156 billion, achieving a year-over-year real growth of 42% and over 6.9 million loans were granted, representing a growth of more than 20% compared to 2024. Adoption of daily yield tools surged, with over 5.8 million users on remunerated accounts (13% YoY). Then 27 million “Frascos” were created, consolidating this feature as the preferred tool for capital organization, while the new "Frascos Fijos" (Fixed-Term) captured 350,000 users in just two months.
iv) Galicia Seguros
Grupo Galicia operates its insurance business in Argentina through Sudamericana Holding and its operating subsidiaries, including Galicia Seguros; Galicia Retiro, Galicia Broker, Well Assistance, Seguros Galicia, GGAL Seguros and GGAL Seguros de Retiro. All these subsidiaries operate exclusively in Argentina. For the year ended 2025, their total premiums and surcharges amounted to Ps.610,605 million.
Galicia Seguros offers property, casualty and life insurance to customers. Its property and casualty offerings mainly include home, theft, automobile and fire insurance, as well as general liability coverage and coverage for other minor risks such as theft insurance. In respect of life insurance, Galicia Seguros' offerings include group life and personal accident insurance.
Seguros Galicia offers a diversified portfolio of insurance products, including property, casualty and life insurance, addressing the needs of different customer segments through various distribution channels.
GGAL Seguros and GGAL Vida focus on life insurance products, complementing the Group’s overall offering in the personal insurance segment.
Galicia Retiro and GGAL Seguros de Retiro offer annuity products, providing long‑term savings and retirement solutions to their customers.
In addition, Galicia Broker and Well Assistance operate as insurance brokers, supporting the distribution of insurance products and services across the Group’s customer base.
v) Other Business
Fondos Fima
Since 1960, Asset Management has been dedicated to the administration of the Fima Common Investment Funds, which are distributed through the various commercial channels of Banco Galicia. It offers a wide range of investment funds designed for each investor profile, allowing all types of investors to easily access the capital market through the various Fima funds.
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For more information, please see “Sales and Marketing” – "Investments" - “Fima Funds”, below.
Inviu
Inviu is a financial services company using technology to create a distinctive investment experience in Latin America. Its platform enables independent advisors to offer the best products and services, facilitating the management and growth of their business.
For more information, please see “Sales and Marketing” – “Investments” - “Inviu”, below.
Galicia Securities
As one of the main settlement and compensation agents (ALyC, for its acronym in Spanish: Agente de Liquidación y Compensación), Galicia Securities offers unbanked financial products and services to its customers through an integrated value proposition.
For more information, please see “Sales and Marketing” – "Investments" - “Galicia Securities", below.
Galicia Ventures
Galicia Ventures aims to bring innovation closer to Grupo Financiero Galicia by fostering relationships with startups while simultaneously supporting their growth.
Nera
Nera is a digital payments and financing ecosystem for the agricultural sector, connecting producers, suppliers and financial institutions. On a single site, and 100% digitally, it offers multiple alternatives to finance the purchase of supplies or livestock.
For more information, please see “Sales and Marketing” – “Nera”, below.
B.2 Competition
Due to our financial holding structure, competition is experienced at the level of our operating subsidiaries. We face strong competition in most of the areas in which our subsidiaries are active. For a breakdown of our total revenues, for each of the past three fiscal years, for the activities discussed below (i.e., banking, credit cards and insurance), see Item 5. “Operating and Financial Review and Prospects”-A. “Operating Results”.
i) Banking
Banco Galicia
Banco Galicia faces significant competition in all of its principal areas of operation from various entities, including foreign banks operating in Argentina (mainly large retail banks which are subsidiaries or branches of banks with global operations), Argentine national and provincial government-owned banks, private-sector domestic banks, cooperative banks, non-bank financial institutions as well as digital banks and virtual wallets.
Regarding private sector customers, Banco Galicia's main competitors are large foreign banks and certain domestically owned private sector banks. Banco Galicia also faces competition from government-owned banks. Despite this competitive landscape, Banco Galicia has maintained a growing trend in its share of the deposit market in recent years.
Banco Galicia’s estimated market share of private-sector deposits in the Argentine financial system was 16.21% as of December, 2025, as compared to 13.79% as of December, 2024 and 9.83% as of December, 2023.
With respect to loans extended to the private sector, Banco Galicia’s Argentine market share was 14.31% as of December 2025, compared to 12.82% in December 2024 and 10.93% in December 2023, according to information published by the BCRA.
According to the BCRA, as of December 31, 2025, Banco Galicia was the largest private-sector bank in Argentina as measured by its assets, loans and deposits.
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Banco Galicia believes it has a strong competitive position in retail banking, both with respect to individuals and SMEs. Specifically, Banco Galicia considers itself one of the primary providers of financial services to individuals, the primary private-sector institution serving SMEs, and has traditionally maintained a leading position in the agriculture and livestock sector.
Argentine Banking System
As of December 2025, the Argentine financial system consisted of 73 financial institutions, of which 60 were banks and 13 were non-bank financial institutions (i.e., finance companies). Among the 60 banks, 14 were Argentine national and provincial government-owned or related banks. Of the 46 private-sector banks, 34 were domestically owned and 12 were foreign-owned banks (i.e., local branches or subsidiaries of foreign banks).
Consolidation has been a dominant theme in the Argentine banking sector since the 1990s, with the total number of financial institutions declining from 214 in 1991 to 73 as of December 2025.
Top Banks in Argentina
As of December 31, 2025, the top 10 banks in Argentina, in terms of total deposits, were:
1.Nación
2.Banco Galicia
3.Santander
4.BBVA
5.Provincia
6.Macro
7.Industrial
8.Ciudad
9.Credicoop
10.Banco Patagonia.
Banco Nación, Banco Provincia and Banco Ciudad are government-owned banks. Banco Galicia, Banco Macro and Banco Credicoop are locally owned while the rest are foreign-owned. These top 10 banks hold 80% of total deposits in the Argentine financial system while the other entities hold the remaining 20%.
Loan Distribution
In relation to loans, the same 10 banks appear in the top positions, with the exception of Credicoop, which is replaced by Supervielle. These banks hold 80% of total loans in the Argentine financial system.
Government-owned Banks
As of December 31, 2025, the largest Argentine national and provincial government-owned or related banks, in terms of total deposits, were Banco Nación and Banco de la Provincia de Buenos Aires. Under the provisions of the Financial Institutions’ Law, public-sector banks have comparable rights and obligations to private banks, except that public-sector banks are:
•usually chosen as depositories for public-sector revenues
•promote regional development
•certain public-sector banks have preferential tax treatment.
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The bylaws of some public-sector banks provide that the governments that own them (both national and provincial governments) must guarantee their commitments.
Foreign Banks
Foreign banks continue to have a significant presence in Argentina, despite the number of these financial institutions decreasing from 39 at the end of 2001 to 12 as of December, 2025. Their share of total deposits has decreased since the 2001-2002 financial crisis while the share of domestic private-sector banks has increased.
Sector Focus
The Argentine banking sector focuses on transactional business, with limited availability of medium and long-term lending. As of December 31, 2025, private sector deposits and credit in local currency represented 12.2% and 10.3% of Gross Domestic Product (GDP), respectively, which is below the levels typically observed in other countries in the region.
ii) Naranja X
Naranja X operates as a comprehensive digital financial ecosystem, competing primarily within the fintech space against an evolving landscape of digital wallets and non-financial credit providers (proveedores no financieros de crédito, or PNFCs). Traditional commercial banks represent a secondary competitive tier, typically targeting different customer segments. In this environment, Naranja X distinguishes its platform through four decades of institutional experience and proprietary data in the consumer credit market.
To compete effectively at both national and regional levels, Naranja targets low- to middle-income clients by offering personalized services in each region and focusing its commercial efforts on these segments. While other Argentine credit card issuers and consumer loan providers primarily generate revenue from interest on outstanding personal loans and credit card balances, Naranja benefits from additional income sources, including merchant fees and commissions. This diversified revenue model allows Naranja to offer competitive pricing and financing terms.
The company's extensive distribution network, has enabled Naranja to establish a strong local presence in every province of Argentina. Naranja believes that its diversified and stable funding sources, extensive branch network, robust information technology infrastructure, relationships with merchants, and strong brand recognition provide a competitive advantage. These factors help consolidate and expand its market share while making it challenging for new players to compete effectively on a national scale.
iii) Insurance
Sudamericana’s subsidiaries face significant competition in the Argentine insurance industry. As of December 31, 2025, the industry was comprised of approximately 184 insurance companies. Among these companies are subsidiaries of foreign insurance companies and some of the world’s largest insurance companies with global operations.
During this period, the insurance industry experienced an acceleration. Production amounted to Ps.23,084,890 million, which was 11% higher than the level recorded in the previous year. Of total insurance production in that period:
•89% related to property insurance;
•9.6% related to life and personal insurance; and
•1.4% related to retirement insurance.
Within the property insurance segment, automobile insurance continued to be the most significant category, representing 41.4%, followed by workers’ compensation insurance at 23.7%. Within the life insurance segment, group life insurance was the most significant category, representing 47%, followed by individual life insurance at 32%.
As of December 31, 2025, based on internal studies, it is estimated that Sudamericana ranked:
•sixth in personal accident insurance;
•second in home insurance;
•fourth in theft insurance;
•twelfth in motor insurance; and
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•fifth in life insurance.
B.3. Sales and Marketing
i) Service Channels
Grupo Galicia’s subsidiaries interact with their customers through a variety of marketing channels, tailored to meet specific customer needs.
The strategy of the customer service model of Grupo Financiero Galicia is aimed at allowing its customers to access Grupo Financiero Galicia’s companies services (e.g. Banco Galicia, Naranja X and Galicia Seguros, among others) through all the service channels provided. This approach enables customers to operate both assisted and self-managed channels, with a strong focus on digital channels as well.
Banco Galicia's Customer Service Principles and Guidelines
Banco Galicia has the following customer service principles and guidelines:
•Anticipate: It works proactively to anticipate customer needs. It strengthens the use of data to transform the "voice of the customer" into actionable insights for the organization. By integrating these learnings with the Product and IT teams, it addresses problems at their root cause and deploys timely communications. The focus is on delivering the right information at the right time, reducing friction, and ensuring that key functionalities are available across all channels.
•Attend and resolve 24x7: It boasts a customer service ecosystem leveraging digital channels to support its clients' daily needs. It promotes efficient self-service without neglecting personalized support, and guarantees assistance from an officer anytime, anywhere. Its priority is first-contact resolution: to achieve this, it minimizes wait times, avoids delays, and equips its platforms with the immediate response capabilities that customers demand.
•Technology-driven transformation: It drives the transformation of the care ecosystem with a focus on technology. In 2025, it enhanced knowledge management with the deployment of Guru, which uses artificial intelligence to expedite information retrieval. This evolution is complemented by the migration to Genesys, which enables a more integrated omnichannel experience and positions technology as a "copilot" for its officers. Furthermore, it scaled initiatives from help sites to the first generative AI agents to provide faster, more accurate, and more consistent responses.
Assisted Channels
Assisted contact channels provide personalized support to customers, with assistance available at different times of day and through multiple channels. To respond quickly and consistently, officers use integrated tools—both in-person and digital—that allow them to guide customers, resolve inquiries, and assist with more complex transactions.
Assisted support is based on omnichannel management that integrates telephone, WhatsApp, chat, email, and social media. This model facilitates a consistent experience, regardless of the channel the customer chooses to use.
During 2025, Banco Galicia completed its migration to Genesys and consolidated a single tool to centralize customer contact channels. The platform enables integrated management of calls, messaging, and digital inquiries, and continues to incorporate features aimed at improving operational efficiency.
The support teams are organized under a "blend" model, in which officers resolve both telephone and digital inquiries. This allows for allocating capacity according to demand and maintaining appropriate service levels and response times.
In 2025, the Customer Service area played a central role in the "hypercare" service model defined for the first three months following the migration of Galicia Más customers to Banco Galicia. To support the process, a team of over 200 people was formed and trained in advance, prepared to handle inquiries even before onboarding. The focus was on prioritizing contacts from migrated customers and transforming the transition into a supportive and welcoming experience.
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Furthermore, in 2025, Vista 360 was consolidated as a key internal tool for Naranja X's assisted channels. The platform integrates customer financial information (balances, debts, investments, and behavior) into a single interface, with direct access to the tools needed for resolution. This facilitates more efficient service and reduces friction between the digital experience and human support.
Branches
Branches are part of Grupo Galicia´s service channel, providing support for customer servicing, transactional activities and operational requirements across the Group’s client base.
The chart below sets forth Grupo Financiero Galicia’s branches as of December 31, 2025.
As of December 31, 2025
Branches (number)
Banco Galicia 316
Naranja X 104
Galicia Seguros 12
On-site Services (BeP)
Banco Galicia maintains an operational presence within company facilities by allocating resources and/or personnel to provide direct, on-site service.
These on-site banking services (BeP) constitute a convenient channel that facilitates access to financial products and services, strengthens relationships with corporate clients, and supports the daily operations of employees at the companies where they are located. As of the end of 2025, the model had reached a total of 27 BeP locations.
Telephone and digital attention
The Banco Galicia telephone and digital call center is available to serve its customers continuously from Monday to Sunday 24 hours a day (24x7). Call center officers assist clients who are referred to Fonobanco IVR (the automated call center focused on addressing customer inquires) and manage various contact channels, including chat through online banking, WhatsApp and email.
During 2025, and in a context of increasing delinquency and greater financing needs, several initiatives were implemented to better support its clients. On the one hand, a pilot program was launched to proactively assist clients in loan delinquency via telephone, offering them financing alternatives to settle their debts. The possibility of extending this approach to other service channels was explored.
In addition, a WhatsApp channel with a dedicated line for businesses was added in 2025. After the initial interaction with the chatbot, specialized teams handle inquiries requiring human intervention, focusing on faster resolutions tailored to the needs of the business segment.
In 2025, Banco Galicia handled an average of 227,966 assisted telephone contacts per month. Additionally, Galicia's digital channels handled an average of 160,960 assisted contacts per month.
Conecta
Conecta is a personalized digital service model for Banco Galicia's ÉMINENT and SME clients. Through an assigned Conecta Advisor, clients can make inquiries and manage their accounts without leaving home, using everyday digital channels. These advisors manage a portfolio of clients with a focus on personalization and relationship development, and operate in a hybrid model, combining in-person service with in-person support at Conecta Nodes, depending on the specific needs of each region.
Social Media Networks
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Social media works as a communication channel and a link with audiences. In this space, Grupo Galicia informs, educates, and engages with its community, but it does not manage operational support or case resolution, which are handled through the designated support channels.
Banco Galicia uses social media platforms to achieve the following objectives:
•Inform (40%): Promote self-management by sharing content about new launches, regulations, holidays, and more.
•Educate (30%): Reinforce basic concepts and introduce new product launches, including topics such as computer security, financial education, and investments.
•Connect (30%): Engage with the audience by sharing content on benefits, special dates, sustainability, and trends.
Banco Galicia employs a differentiated strategy for each platform, adapting content to meet the specific needs of its community:
•Facebook: It plays a primarily informative and educational role. Supportive content that facilitates self-service is prioritized, allowing users to resolve issues quickly and easily.
•Instagram: It combines entertainment with information. The main objective is to connect with the audience through active conversation, fostering a dynamic and participatory community.
•X: It functions as a contextual information channel. It stands out as a friendly and proactive space where news is communicated in real time and intensive awareness campaigns on cybersecurity and fraud prevention are conducted.
•YouTube: Its role is educational, with an empathetic and accessible tone. The platform is used to provide in-depth self-service tutorials, transforming complex processes into simple and engaging visual formats.
•TikTok: Focused on education and native information. The bank adopts the codes and trends of the internet to generate relatable content that resonates with new audiences and strengthens brand engagement.
Banco Galicia uses its social media channels as a communication platform to promote content that adds value and reinforces the safe and responsible use of its services. Within this framework, its digital presence is organized around three pillars:
1.Financial education: Through practical advice and management tools, the organization aims to empower people to "do more with their money." The focus is on promoting responsible personal finance management, encouraging strategic saving, and providing clarity on the best investment options based on each client's individual goals.
2.Cybersecurity: Prevention is a priority. Banco Galicia conducts ongoing awareness campaigns and shares recommendations for safe banking practices and how to recognize warning signs of potential scams. The goal is to help protect users' data and assets
3.Sustainability: The communication strategy incorporates content that promotes a conscious and sustainable lifestyle. It disseminates institutional initiatives related to environmental protection and provides practical recommendations for users to adopt responsible habits, aligning economic growth with a positive environmental impact.
In 2025, the "Galicia couple" was reintroduced and linked to the Tooth Fairy to communicate, in an integrated way, the year's main benefits: app improvements, instant cashback on leading promotions, financing options, and the dollar-denominated savings account, among other initiatives. Simultaneously, the slogan "Tenés Galicia" was maintained as a core element of brand consistency. The combination of these elements—with a style that, when appropriate, uses humor and the relatable nature of its characters—strengthens the bank's positioning as an ally in people's everyday financial management and contributes to the institutional purpose of improving the daily lives of more people.
For its part, Naranja X is consolidating its presence on social media as a bridge between people and their finances, transforming everyday concerns into practical content and solutions. Its strategy aims to democratize access to financial services and reduce connectivity gaps, so that every user can manage their digital finances simply and efficiently. It also serves as a platform for ongoing training in areas such as cybersecurity and environmental stewardship, reinforcing its commitment to a secure and sustainable digital ecosystem.
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Through its specialized blog, "Let's Talk About Money," and the creation of dynamic content in reel format with influencers, Naranja X translates complex concepts into an educational and accessible language. The initiative aims to empower people to regain control of their daily finances and plan personal projects through financial education that is accessible to everyone.
Indirect Channels
Banco Galicia has the following indirect channels to enhance its reach and service delivery. These channels include:
•Telemarketing: This channel is dedicated to acquiring new customers and businesses, as well as selling loans through call centers. Banco Galicia focuses on providing the best experience by bringing its solutions to the entire country and ensuring the quality of its services through client feedback and reinforcing good market practices.
•Points of sale: a channel for acquiring new customers through physical stands located primarily in shopping malls and supermarkets. These stands invite potential customers to experience Galicia and facilitate the beginning of their relationship with the bank.
•Assisted Links: This commercial channel is exclusively dedicated to acquiring companies and SMEs that leave their data on the Galicia Portal. The team provides tailored advice focused on the benefits of operating with Banco Galicia.
•Third-party channels: This channel allows for the origination of personal loans through partnerships with businesses, major retailers, and digital platforms, integrating the credit offering into its partners' ecosystems. This model operates in both physical and digital environments. At the point of sale, salespeople can simulate and offer loans through an integrated platform, and the transaction is then confirmed via the Galicia App with biometric validation and acceptance of terms and conditions. On third-party online channels, the experience is entirely digital: the customer simulates and applies for the loan through the partner's platform and finalizes the approval process in the Galicia App, ensuring security and traceability throughout the entire process.
•Correspondents: This channel allows access to banking products and services through authorized retailers, without needing to visit a branch. It helps reduce congestion at ATMs and teller windows, and expands the number of available service points. Through these correspondent banking locations, customers can withdraw cash, receive ANSES (Argentina's social security administration) payments, make cash deposits, pay credit card bills, and settle outstanding debts.
Self-managed channels
Self-service contact channels offer an efficient and personalized support experience, allowing customers to resolve their banking needs quickly and autonomously through digital and telephone channels. This solutions combine availability 24x7, security and personalization, and they integrate to the omnichannel ecosystem to reduce frictions and boost the customer experience.
Interactive Voice Response
Banco Galicia's IVR system reached 545,501 contacts in 2024. It also added new self-service capabilities to support customers, providing immediate solutions for critical needs; for example, the ability to block their accounts if they notice any suspicious activity and unblock them when there is no longer any risk. During 2025, the IVR channel registered a total traffic of 578,000 contacts.
App Galicia
Galicia App is the mobile online banking app for Banco Galicia. It allows clients to manage their day-to-day banking needs in one place, enabling them to send and request money transfers, make payments with a QR code, withdraw cash without a card, pay for services, request loans, make investments, purchase insurance coverage and control their expenses.
Throughout 2025, the focus was on consolidating a more complete, stable, and self-managed application, with an emphasis on ease of use, 24/7 availability, and continuous improvement of the customer experience.
Within this framework, key initiatives were carried out in the following areas:
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•Cards: A new carousel-style overview was implemented, improving visualization and navigation. In addition, after-sales functionalities were incorporated directly into the app—such as card pause, limit inquiries, and access to sensitive data—eliminating redirects. These improvements were complemented by advancements in technical stability and response times, strengthening the reliability of the service.
•Payments and transfers: International money transfers were added from the application, expanding the scope of available operations. Furthermore, interoperable QR code payments and bi-currency QR codes (pesos and dollars) were enabled, along with the integration of MODO and contactless payments, reinforcing the digital payment options.
In 2025, the new Galicia Office App (Business App) was launched, expanding the mobile capabilities of the business channel. It incorporated biometric login, a business switcher, improved welcome screens, new information cards, and push notifications with images. It also added modules for MEP Dollar (Argentine Electronic Payment Market), Fixed-Term Deposits, and Credit Cards, and enabled fully digital activation of the Office Token directly from the app, reinforcing self-service and security.
During 2025, the Galicia App for individuals registered a monthly average of 120,622,465 logins, reflecting the high level of use and adoption of digital channels by customers. Meanwhile, the Galicia App for businesses reached a monthly average of 2,317,630 logins, solidifying its position as a key channel for the digital operations of business clients.
Throughout 2025, the Galicia App maintained high user satisfaction levels, with a rating of 4.70 on iOS and 4.67 on Android. This performance was also reflected in a greater adoption of digital channels, with an increase of 16% in the use of digital channels by individuals (App and Online Banking) compared to 2024, consolidating the App as a central channel in the customer experience.
Online Banking
Online Banking is the web-based tool that allows customers to manage their accounts from home. In the digital ecosystem, it plays a complementary role to the App, providing operational continuity, enhanced visibility, and control tools from a desktop. Online Banking integrates with help channels, digital support, and assistance, forming part of the bank's omnichannel approach.
In 2025, Online Banking solidified its position as an alternative for transactions requiring greater visibility or control, especially from a desktop, complementing the mobile experience.
During 2025, an average of 8.1 million monthly logins were recorded in Online Banking, reflecting the high level of use of digital channels.
Office Banking
Office Banking (the "Office Banking platform") is a web-based online platform that Banco Galicia offers to clients in its Wholesale Segment. Banco Galicia has promoted self-management, and the Office Banking platform allows companies to carry out a credit assessment of themselves with just one click. The platform offers the Bank's clients the ability to manage their businesses from any location, both through its website and mobile versions. Banco Galicia continues to make technological improvements to offer more robust solutions to companies and add new functionalities to the Galicia Office App.
Building on this foundation, a new version of Office Banking was launched in 2025, featuring a comprehensive overhaul focused on optimizing the user experience and operational management for businesses. The update included the company switcher, a redesigned login interface, improvements to user and password recovery workflows, and a clearer, more intuitive overview. User and permissions management was also strengthened, multiple transaction authorization and rejection were added, and a new investment section was introduced. These improvements were complemented by new functionalities in checks, agreements, ratings, loans, and foreign trade, solidifying Office Banking as a comprehensive web channel for business operations.
In 2025, Office Banking registered an average of 7.0 million monthly logins, considering both the new Office Banking and the previous version, which remained in use until September 30.
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Naranja X App
The Naranja X App is establishing itself as a key self-service channel, enabling individuals and businesses to operate simply, independently, and securely. Through this channel, users access comprehensive management of financial products and services, reducing the need for in-person assistance and strengthening an experience focused on accessibility, efficiency, and inclusion.
Throughout 2025, self-service functionalities for individuals and businesses were expanded and improved. The app incorporated enhancements in account management, payments, investments, loans, insurance, and collection methods, strengthening fully digital operation and reducing the need for interaction with assisted or in-person channels. Furthermore, the integration of solutions for businesses was deepened through Cuenta Negocio (Business Account), a digital account that allows for centralized collections, sales accreditation, promotion management, and the definition of commercial terms directly from the app.
Progress was made in integrating Nave as a payment processor and collection solutions provider for small businesses and entrepreneurs operating through the Naranja X app. Within this framework, a development kit was implemented that integrates directly with the app, allowing users to continue collecting payments through the app in the same way they have done previously, but now operating as businesses acquired by Nave. As a result, sales are processed through Nave and funds are credited directly to merchants' Naranja X accounts, strengthening self-management and simplifying digital operations.
Also in 2025, the Naranja X App incorporated features focused on social impact, aimed at expanding donation opportunities through a self-managed digital environment. The creation of the "Donate" section was a highlight, enabling one-time contributions through the app, complementing the existing monthly donation option via credit card. Additionally, features were added for merchants, allowing them to channel donations through sales settlements and make in-kind contributions to social and environmental projects in various provinces across the country.
Galicia Retail Help Section
The main objective of the retail help section is to serve as the primary consultation channel for Banco Galicia's customers when they have questions about the operation of its products. This section is available across all digital channels, including Online Banking, the Galicia App, Galicia.ar, and is also accessible via Google.
In 2025, the help sites were adapted and customized for customers who migrated from Galicia Más. The aim of this measure was to ensure that their transition and integration into the Galicia ecosystem was as smooth, simple, and clear as possible.
Help Section Office Banking Galicia
The main objective of the wholesale help section is to serve as a self-managed response channel for client's needs for updated information on the use of Office Banking platform's products and operations.
In 2024, the assistant was made available for use by all customers. Its main objective is to support customers during their navigation in Office Banking platform and in the App, allowing them to immediately answer their questions and resolve issues on the same platform where they are conducting their transactions. For example, customers can address complaints about incorrectly charged fees with online accreditation. This assistant also has the capability to refer clients via chat to an officer who is available 24/7 to support them in more complex situations and resolve their issues.
The technological rollout in 2025 was a key factor in the success of critical processes. The virtual assistant and advanced support tools were crucial in achieving agile digital integration for companies from Galicia Más, facilitating their adaptation to new functionalities.
Gala
Gala is the WhatsApp chat channel for Galicia customers, available 24/7. It allows customers to handle common tasks independently, such as PIN reset; checking balances, limits, and available funds; viewing recent transactions; receiving the latest statements/excerpts in PDF format; checking and verifying your CBU (bank account number) and alias; checking closing and expiration dates; replacing cards; checking the status of COMEX transfers; tracking deliveries; retrieving cards and transferring funds between branches; and checking FIMA fund balances, among other features.
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In 2025, Gala continued to evolve as a customer service channel via WhatsApp, expanding its resolution workflows and adding new capabilities. Additionally, the first AI-powered virtual assistant MVPs were developed and will soon be launched as the first version available to our customers.
Furthermore, in 2025, as part of the "hypercare" customer service model for new Galicia Más customers, Gala provided special support during the early onboarding process. Customers could create their usernames and passwords from the outset, and Gala acted as a support channel for any issues.
In 2025, approximately more than 553,000 of conversations were generated with Gala on average each month.
NIXI
NIXI is Naranja X´s virtual assistant. During 2023, Naranja X implemented an in-app chat feature, which allows for 24x7 attention from the bot and 7x16 live attention from a collaborator. This innovation provides a secure environment where clients can receive assistance within the app, making it easier to advise, guide, and offer solutions, thereby enhancing the customer experience on this channel.
Naranja X's NIXI self-service bot was enhanced in 2025 with the "Not Understood" initiative, a feature that acts as a solution orchestrator. In this workflow, the user describes their problem, and the system generates a personalized menu of alternatives using artificial intelligence. During 2025, the use of the NIXI self-service bot grew by 64%, reflecting greater adoption of the digital channel by customers.
In 2025, an average of 1.4 million conversations were generated monthly with NIXI.
Laia
Galicia Seguros has enhanced its bot "Laia" by adding more sales and after-sales procedures, such as requesting a policy, understanding the scopes of coverages, lodging complaints for losses, and accessing additional services. These improvements have not only enhanced self-management capabilities but also initiated loyalty campaigns.
In 2025, Laia solidified its position as an operational virtual assistant powered by generative AI, providing faster and more natural responses to general inquiries and insurance-related topics. Its scope expanded to include functions such as sales, policy underwriting, customer service, claims, and fraud prevention. Its development was carried out in collaboration with technology partners and with continuous interaction monitoring to optimize service and better understand customer needs.
Automatic Channels
The chart below sets forth Grupo Financiero Galicia’s electronic terminals as of December 31, 2025:
As of December 31, 2025
Banco Galicia 2,143
ATMs 787
Self-Service Terminals 1,356
Naranja X 60
ATMs 60
Banco Galicia has a network of self-service terminals designed to offer a differentiated banking experience to its users. Using self-service terminals, Banco Galicia's clients can make deposits, integrated collection payments, and money withdrawals with a different limit than for the limit for non-clients, and without having to use the Debit Card, only using Galicia Token.
In addition, Banco Galicia has a wide network of ATMs distributed throughout the country in the Banelco Network. These ATMs are available for both Banco Galicia customers and those who are not. They allow cash withdrawals, transfers, key management and other banking operations to be carried out quickly and safely.
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During 2025, Banco Galicia incorporated new solutions to strengthen automated banking and continue advancing towards a simpler, more agile, and self-service experience, in line with its phygital approach. These initiatives expanded self-service capabilities and reduced the need for teller service.
•Cash withdrawal from FIMA Premium at Self-Service kiosks: the possibility of withdrawing cash directly from FIMA Premium has been enabled, without the need to make a prior withdrawal of the fund to the bank account, facilitating immediate access to the invested money.
•Increased daily withdrawal limits: The withdrawal limit at self-service ATMs has been increased, allowing withdrawals of up to $4,000,000 and up to US$ 2,000 per day. For withdrawals exceeding $999,000 and for transactions in US dollars, the operation must be performed with a debit card.
•Active Collaborator in the Self-Service Network: The Active Collaborator feature has been launched in 200 branches with SR-model Self-Service kiosks. This feature allows users to report incidents using a QR code displayed on the screensaver. Through this channel, customers can report cash shortages, malfunctions at self-service kiosks or ATMs, and infrastructure problems in the lobbies. Reports are automatically sent to the appropriate team, expediting responses even outside of business hours and promoting an asset role for customers in the continuous improvement of service areas.
(ii) Products and Services
With a strategic vision to become a financial platform, Grupo Galicia provides products and services tailored for each customer, individual or company, that are designed to satisfy their unique needs. Through products and services tribes, Grupo Galicia creates and manages these products and services, including financing, E-checks, insurance, credit cards, investments, foreign trade operations, among others.
a) Financing
Since 2020, the application and registration processes have been fully digital, with the goal of allowing all of our customers to proceed without any difficulties or obstacles. This digital transformation ensures a seamless and efficient experience for all users.
Banco Galicia offers loans that are differentiated according to the segment to which the customer belongs (wholesale or retail) and the purpose for which the financing is required. This approach delivers customized solutions that facilitate access to financing in a simple and accessible manner, tailored to each client's profile.
Banco Galicia offers the following financing products for its customers:
Segment Type Description
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Individuals Personal loans The traditional loan for retail customers with an amount of up to Ps.26.4 million and a term of up to 72 months. The accreditation is immediate through online banking or the Galicia app.
Salary advance It is a quick financing solution for the day-to-day life of our customers, where the Bank lends the client up to 50% of his salary. The maturity for this type of loans is between 2 to 45 days.
Préstamos Express (Express loans) Through Online Banking, Banco Galicia offers loans with a total repayment schedule that goes from 2 to 45 days. Préstamos Express is a product exclusively designed for clients who have not purchased the payroll services of Banco Galicia and which helps them better manage their finances.
AfterPay The AfterPay product allows customers to select installment plans for purchases already made with their debit card. The functionality is available to the entire customer portfolio and can be accessed from the App, in the “Accounts” or “Loans” sections.
Plata al toque Clients can access small, short-term financing quickly, securely, and easily for their everyday needs. They can request the money and have it instantly deposited into their account. Repayment can be made in 1, 3, or 6 installments, with payments beginning after 30 days.
Installments without card Possibility for clients to pay with installments without the neccesity of having a debit card.
Loan for Earnings It's a loan for certain public entities that they offer to their employees. The unique feature is that each installment is deducted from their paycheck, and the employer pays it directly to the bank.
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Companies Préstamo Inmediato (Immediate loans) Loan with immediate credit without collateral. The client can choose whether to pay in monthly, quarterly or semi-annual installments as well as the term, which can be short-term (up to 12 installments) or long-term (up to 24 installments).
Discount of electronic credit invoice and e-checks The Bank implemented the discount of electronic credit invoice and confirming checks; in both cases, the customer is allowed to discount the instrument and the debt is allocated to the payer’s margin.
Pledge and mortgage loans The bank lends customers up to 70% of the purchase price of a capital asset.
SGR loans (Sociedad de Garantía Recíproca, “SGR”) It is a loan guaranteed with a guarantee from a reciprocal guarantee association.
Mortgage loans There are 300 active loans
Prenda Galicia in Office Banking Secured loans that are offered directly from Office Banking without the need to go through an agreement.
Current account agreement It is a credit line granted on a checking account. The customer can overdraw their checking account against the agreement and thus cover their short-term financing needs at a lower cost, which will be agreed upon beforehand.
Socios de valor (Value Partners) The purpose of this product is to enable Banco Galicia's customers to offer financing at a rate subsidized by them to their own customers. Thus, a value chain is generated, since it means benefits for all its participants. It is a simple, agile, innovative and 100% digital product.
Préstamos a tu ritmo It is a bullet loan with partial cancellations based on the client's billing.
Leasing It is a type of loan through which companies are granted financing of up to 100% for the purchase of a vehicle for 36 or 48 months. When it ends, the client has the option to acquire the vehicle for a very competitive market value.
Coupon advance Businesses can advance payment coupons for Visa, Mastercard, Cabal, and American Express cards, whether the payment was made in one or several installments.
Banco Galicia introduced secured loans for individuals in 2025. To this end, it developed a new platform and a fully digital process. The initiative targeted dealerships that previously operated with HSBC. In this way, the bank migrated operations to a digital environment, expanded its financing offerings, and strengthened the experience for customers and affiliated businesses.
In 2025, Banco Galicia granted 3,293,603 loans representing a total volume of Ps.13,109,727 million. In total, 3,894,000 customers had outstanding financing through Banco Galicia as of December 31, 2025.
Regarding mortgage loans, a product relaunched in 2024, a comprehensive transformation was undertaken in 2025. Banco Galicia redesigned the loan origination process, creating a fully digital experience. Digitalization encompasses the entire process, from the customer's perspective to the management of notaries and appraisers, key players in these transactions. This advancement reduced operational friction and substantially shortened response times. As a result, based on internal studies, Banco Galicia consolidated its position as a leading private bank in mortgage loan origination. In doing so, it reaffirmed its commitment to efficiency, simplicity, and continuous improvement of the customer experience.
During 2025, the following improvements were implemented in the mortgage loan origination process:
•The Notary Portal was implemented, allowing the assigned professional to continuously update the status of the procedures required for signing the mortgage. This tool provides traceability and greater visibility of the process. The client receives automated notifications as each stage is completed and can identify any remaining steps. Furthermore, from the same platform, the notary can manage the booking of a room for signing at a Banco Galicia branch online and independently.
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•Progress was made in implementing an automated appraisal model that weighs different variables to estimate the value of properties presented by clients. This innovation accelerated the loan process, improved response times for clients, and reduced the costs associated with traditional appraisals.
•Payslip reading using artificial intelligence (AI) was implemented. Once the documentation is uploaded, the system automatically identifies the key variables for credit analysis, without manual review. This allows for immediate access to monthly income, streamlines the evaluation process, and reduces operational errors. As a result, analyst processing time was reduced by 50%.
Naranja X offers personal loans with minimal requirements in a fully digital process via its app, as well as through its branches all over the country. Loans are credited instantly, without requiring the customer to upload any documentation. Furthermore, they are integrated as a payment method within the app.
During 2025, Naranja X granted 6,941,408 loans, totaling Ps.1,815,763 million, to 2,040,545 customers. The company also managed interest rates and repayment terms to sustain the business across the year's various economic conditions. Within this framework, it consolidated a proactive lending policy. This policy adjusts credit offerings according to each client's risk profile. As a result, it helped reduce exposure to fraud and preserve portfolio quality.
Finally, Grupo Financiero Galicia promotes a triple impact business model, enhancing its role in sustainable development. This begins with the design and implementation of products that consider the social and environmental aspects of the projects financed. The focus areas include financial inclusion, climate change, diversity, social investment, and impact investment. The following chart highlights certain products offered by this area and their impact in 2025.
PRODUCT DESCRIPTION IMPACT
Financing line for SMEs with preferential rate In 2025, Galicia launched a sustainable loan program for SMEs with preferential interest rates and repayment terms of up to 24 months. The program focuses on financing initiatives that generate economic value while also protecting the environment or generating a positive impact on the community. Ps.1,273,348 million in outstanding loans qualified for programs designed to promote small businesses and community development at Banco Galicia and Ps.1,815,763 million at Naranja X.
Good practices program in the agricultural value chain Agreements with leading players in the sector. Bayer Green Credit, Corteva, UPL. Ps.38,819 million placed.
Fondes - Trust Fund for the Development of the Social Economy Public-private fund of the Government of the City of Buenos Aires that finances cooperatives, productive units and inclusive projects. In 2025, Galicia once again received the GCBA's social impact seal for our contribution to FONDES. In 2025, Ps.12.6 million was invested.
Loans for people without credit history With loans from the App, Naranja X finances people who usually cannot access a loan, either because they do not have a credit history, verifiable income, or they are rejected by other entities.This new product provides a for an increasing number of individuals to access credit. Ps.1,188 million placed.
In relation to Sustainable Financing, Banco Galicia launched the Sustainable Financing Line for SMEs with a preferential rate, expanding access to credit for projects that incorporate environmental and social criteria.
In 2025, Banco Galicia also promoted the growth of sustainable finance through investment solutions aimed at mobilizing capital for impact projects. Key products and services included:
•FIMA Sustentable ESG: a fund that invests in assets with environmental, social, and governance (ESG) characteristics. In 2025, the fund registered returns exceeding those of comparable short-term liquidity funds (T+1, meaning next-day settlement) in terms of risk and horizon, with outperformance ranging between 3 to 14 percentage points. During 2025, US$6,905 million was placed in FIMA Sustentable ESG.
•Social, Green, and Sustainable (SVS) Negotiable Obligations: structuring and placement of debt instruments issued by organizations to finance projects with environmental or social impact, under verifiable sustainability criteria. In 2025, US$156 million was invested in these instruments.
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b) Current and savings accounts
Through Banco Galicia and Naranja X, Grupo Galicia offers savings accounts in pesos and dollars for different customer segments. These accounts allow users to manage balances, make transfers, and make payments through digital channels, with simple and secure operations. Banco Galicia complements this offering with checking accounts in pesos and dollars.
During 2025, individuals and businesses continued to choose these solutions to manage their daily financial transactions. These accounts are consolidating their position as the primary access point to the Grupo Galicia ecosystem and its range of associated products and services.
At December 31, 2025, Banco Galicia registered 11,985 thousand deposit accounts, while Naranja X reached 8,695 thousand accounts, totaling 20,680 thousand accounts within the Grupo Galicia ecosystem.
c) E-Checks
The electronic check (eCheq) is a payment instrument issued, accepted, and managed entirely digitally, complying with all regulatory requirements established by the Argentine Check Law. The eCheq has the same legal characteristics as a traditional check, with the advantage of operating in an electronic environment. In practice, it functions similarly to a deferred and endorsable transfer, making it a key tool for corporate financial management.
During 2025, Banco Galicia implemented significant operational improvements focused on providing greater flexibility and optimizing time management for businesses:
•Greater flexibility in eCheq issuance: Banco Galicia eliminated the requirement for strict numerical correlation in issuance. With this improvement, businesses can freely choose the numbering of their eCheqs, facilitating reconciliation, administrative organization, and internal control.
•Earlier cutoff time for internal deposits (Galicia–Galicia): Banco Galicia modified the internal clearing time, moving the cutoff from 10:00 PM to 5:00 PM. This measure allowed businesses to manage their deposits earlier, improving daily treasury planning.
•Optimized bulk file processing: Banco Galicia expanded its file processing capacity for issuance, endorsement, and assignment operations, allowing the management of up to 250 eCheqs per file (previously the limit was 25). Likewise, for deposit and custody transactions, the ability to manage up to 25 eCheqs per file was enabled, replacing the previous system of individual uploads.
Additionally, during 2025, Banco Galicia enabled the management of eCheqs in US dollars from any account in that currency. This functionality allows for the issuance, endorsement, deposit, and transaction of eCheqs directly in dollars, expanding financing and management options for companies operating in foreign currency.
During 2025, a total of 10,449,957 electronic checks were issued.
The Bank's focus on digital transformation has resulted in an exponential increase in the use of electronic checks. In 2025, the issuance of electronic checks increased by 31% as compared to 2024.
d) Insurance
Galicia Seguros offers a wide range of products that provide numerous different insurance coverages, fully addressing the diverse needs of customers based on their occupation, age, or income level.
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In December 2025, Galicia Seguros had 2,698,613 active policies which were divided in the following types of insurance:
Type of insurance Amount of policies
Life 714,691
Home 261,938
Accidents 432,444
Robbery 182,486
Cars 251,292
Others 855,762
Total 2,698,613
Insurance can be acquired in different ways:
•Through an insurance producer: Clients can purchase coverage with the assistance of an insurance producer. Subsequently, policies can be managed from the digital insurance branch (Answer Galicia), where information is centralized and self-service tools are available for simple and independent management.
•Through Banco Galicia: Banco Galicia customers can purchase and manage insurance policies directly from Online Banking, integrating financial and insurance management in a single digital environment. The offering is structured with a segmented approach, adapting coverage and services to the needs, habits, and profiles of each customer. For Move customers, simple, fully digital products are offered, such as cell phone insurance, handbag protection, pet insurance, and technology insurance. For ÉMINENT customers, more comprehensive and customizable coverage is available, including Home, Auto, and Life insurance. For SME and Wholesale customers, businesses are supported with solutions such as Comprehensive SME Insurance, Technical Insurance, Surety Bonds, Auto Fleet Insurance, and All Risks Operational Insurance.
•Through Naranja X: Naranja X enables customers to purchase insurance and assistance services digitally, with an integrated experience within the app and in partnership with leading companies in the market. From the app, customers can view, operate, and manage policies easily and centrally. As of December 31, 2025, more than 1 million customers had coverage, with over 1.4 million active policies. The offering includes coverage for home, cell phone, handbag, car, and motorcycle, as well as protection for purchases made with payment methods within the Naranja X ecosystem, in addition to options related to entrepreneurship and trades, and life and health insurance products.
•Through Answer Seguros: Answer Seguros is a Grupo Galicia's fully digital insurance company. Its offering focuses on a simple, transparent, and self-managed experience. Through its digital branch, customers can purchase and manage policies without intermediaries, with streamlined processes accessible from any device.
In 2025, Banco Galicia added life insurance with a savings component for ÉMINENT clients. This product combines life insurance coverage with a long-term savings tool by allocating a portion of the premium to protection and another portion to capital accumulation. Additionally, Personal Protection was added for Move clients, integrating personal accident coverage with health assistance, including telemedicine and reimbursements for pharmacy, dental, and other services.
During 2025, Naranja X implemented initiatives aimed at expanding access, strengthening the digital experience, and enhancing after-sales service:
•Integration of payments using Naranja X account balance, enabling access to insurance for customers without credit cards through an integration with Galicia Seguros;
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•Comprehensive optimization of the after-sales experience, with reduced service times and improved customer satisfaction, with policies now are available within minutes of purchase;
•Launch of a health product, developed in conjunction with Galicia Seguros, which expanded the offering to 12 products within the app and incorporated telemedicine and reimbursements (pharmacy, orthopedics, tests, and consultations); and
•Self-service improvements in the app, including status inquiries, payment notifications, a consolidated view of active policies, and access to the vehicle registration document for auto insurance.
e) Credit Cards
The companies of Grupo Financiero Galicia respond to the needs of their customers with an outstanding offer of services and benefits of credit and debit cards.
Banco Galicia Credit and Debit Cards
Banco Galicia meets the needs of its clients with an exceptional range of services and benefits provided through its Galicia Credit and Debit Cards. Banco Galicia offers Visa, Mastercard and American Express cards, catering to clients across various segments. Some of the products offered include International, Gold, Platinum, Black/Signature cards, each featuring different consumer financing options and exclusive promotions for all their clients.
Banco Galicia's credit card offering is complemented by exclusive promotions and financing plans (installment payments), allowing customers to access goods and services and optimize their budget management. Card management is integrated into Banco Galicia's digital channels, enabling users to view spending, configure controls, and track transactions.
In 2025, Banco Galicia incorporated new features to facilitate the customer experience with credit and debit cards with a focus on self-management and digital channels with new operations functionalities. The following features are relevant:
•Updated Cards Overview in the Retail App: In February 2025, a new card view was implemented in the retail app (Android and iOS). The redesign modernized the interface and optimized navigation with a carousel format. Displaying relevant information and adding after-sales buttons facilitated self-service. In turn, improvements to the internal system, with a more organized and flexible architecture and better development practices, helped ensure a stable service.
•24/7 International Money Transfers: In March 2025, the app enabled international money transfer functionality, available 24/7. It allows international transfers to eligible countries, processed at the CCL (Contado con Liquidación) exchange rate. Transactions are subject to an annual limit equivalent to 12 times Argentina's minimum wage (SMVM, by its Spanish acronym). This addition expanded transactional capabilities and strengthened Banco Galicia's digital offering.
•Streamlined Transfers with Biometric Security: The ability to transfer funds to frequent contacts in just a few steps and manage transaction history using filters was added. For enhanced security, biometric authentication via facial recognition was implemented. This measure strengthened real-time transaction protection and reduced operational risks.
Additionally, during 2025, business clients were a central part of the modernization process, with improvements focused on account and product management. In particular, new functionalities related to corporate and commercial cards were incorporated.
•Corporate Cards: Banco Galicia modernized the management of corporate cards and consolidated the information in a single central system. This unification allowed for the presentation of homogeneous and consistent data across business channels, such as Office Banking and the Wholesale App. As a result, response times were reduced, and operational efficiency in inquiries and transactions was improved.
•Commercial Cards: Control and self-management capabilities for Business and Corporate cards were strengthened. Users can pay statements through Office Banking and settle balances in pesos or US dollars. Immediate management of automatic debits was also enabled. Furthermore, the ability to modify daily purchase limits for business debit cards was added through Office Banking and the Wholesale App.
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These improvements were implemented in a context of high operational demands, associated with the integration of Galicia Más (the former HSBC Argentina operations). The migration of more than 1.5 million cards was carried out with a focus on minimizing impact on customers and ensuring service continuity. There were no interruptions to payments or automatic debits. The process included informative communications and a secure transfer of information, including transaction histories and credit limits.
The integration also represented an opportunity to improve and unify the value proposition. Banco Galicia reviewed its card portfolio and aligned benefits and credit limits, aiming to offer a superior proposition compared to the previous offering. The process was consolidated through proactive post-integration monitoring, focused on ensuring the correct functioning of the new cards and the swift resolution of any issues that may arise.
In 2025, Banco Galicia issued 622,683 credit cards, bringing its total credit cards in circulation to 6,100,603.
Naranja X Credit and Debit Cards
Naranja X is the leading card issuer in the country, offering a wide variety of benefits and facilities.
In 2025, Naranja X reached to 3,418,769 active clients of credit and debit cards. On average, Naranja X added 57,700 new customers each month, 100% of whom signed up through the Naranja X App. These new customers receive a virtual card immediately, and 24% of them use it instantly.
During 2025, Naranja X issued 684,977 credit cards, reaching a total of 8,904,658 credit cards, representing 3,967,739 active customers: 3,419,407 primary cardholders and 548,332 additional cardholders. Naranja X offers a comprehensive credit card solution, leading the market with 76% of transactions and a volume of Ps.10,170 billion. Year-over-year transaction volume grew by 11%, while the total amount transacted increased by 55% in constant currency.
Regarding debit cards, Naranja X reached a total of 6,128,834 cards in 2025, of which 2,699,670 are physical and 3,429,164 are virtual. Of these, 2,318,332 are active. Users aged 13 and older can access a virtual debit card immediately and can request a physical card, which is delivered to their home within 48 hours.
In addition, Naranja X implemented the following benefits as new functionalities:
•QR Code Payments from the App: Credit and debit cards were added as payment methods in the QR checkout, allowing users to pay by scanning QR codes directly from the app, without needing to use a physical card.
•Tokenization of “Card on File” Transactions: Tokenization of recurring payments saved by merchants was implemented. This measure replaces sensitive data with a unique token and reduces the risk of fraud in the event of vulnerabilities in merchant systems.
•Dual-currency Debit Card Functionality: The use of debit cards was enabled for purchases at merchants in Argentina that display prices in both pesos and US dollars, with direct debit from dollar accounts, without the need for prior conversion.
•One card, multiple accounts: The ability to use a single physical or virtual card to make purchases from different accounts (Personal, Business, or Dollars) was added, allowing users to select the source of funds from the app before completing the purchase.
•Contactless payments with Google Pay (NFC): The Google Pay wallet was integrated, enabling proximity payments from users' mobile phones at any compatible POS terminal, without needing to present the physical card.
•Debit card delivery tracking: A feature was developed that allows users to view a timeline of the card shipment, from issuance and preparation to delivery at their address.
•Visa Click to Pay Certification: Naranja X obtained Visa Click to Pay certification, enabling the enrollment of Visa credit and debit cards and improving the simplicity and security of e-commerce payments.
f) Virtual Wallets
For Grupo Galicia, virtual wallets are a central channel for engagement and transactions within its digital financial services strategy. These solutions centralize payment methods and enable transfers and payments from mobile devices by linking accounts and/or cards, with real-time security validations. Within this framework, Grupo Galicia offers wallet
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experiences through its main digital platforms, including the Galicia App and the Naranja X App, with the aim of facilitating everyday payments and expanding access to financial services.
Galicia App is Banco Galicia's virtual wallet. With it, clients can access virtual wallet services and MODO functionalities such as:
•Send money to their phone contacts with MODO (a digital payment solution), without the need to enter CBU or Alias account codes.
•Request money from their phone contacts to be sent through links.
•Pay with a QR code, with the possibility of associating available payment methods and, in cases of interoperability, processing the transaction from accounts.
•Make contactless payments (Apple Pay and Android), through their mobile device (by bringing it closer to the store terminal) or through their smartwatch.
MODO is a digital payment solution, launched jointly by over thirty public and private banks in the country. This tool allows users with bank accounts to make transfers and payments in stores easily and from their cell phones. This virtual wallet allows the user to have an all-in-one app to check balances and transfer and receive money from other users from their bank accounts in other banks.
Throughout 2024, customers who made payments via QR codes at different points of sales (e.g. supermarkets, gas stations, restaurants, shopping malls, etc.), were eligible for various cash-back promotions, with the cash-back funds immediately credited back to the customer after payments were made. For such purposes, customers were able to see the available promotions in their mobile through the Galicia App or MODO App at the time of payment.
During 2025, Banco Galicia incorporated key features that strengthen the value proposition of QR Payments and improve the payment experience:
•QR Interoperability: Banco Galicia enabled the ability to make debit card payments using any QR code available on the market. This feature significantly expanded service coverage and facilitated the use of this payment method at various merchants, regardless of the provider.
•Dual-Currency QR: Banco Galicia added the option to make payments in US dollars using a debit card directly from the Galicia App. This feature allowed for simple and secure dollar-to-dollar transactions, expanding payment options in foreign currency.
•Transportation Payments with QR: Banco Galicia enabled payment for subway and bus fares using the QR code generated from the app. This solution facilitated access to public transportation without the need for cash or physical cards, integrating everyday payments into the digital experience.
•QR Cross-Border: Banco Galicia enabled customers to make payments at businesses in Brazil using QR codes from the PIX system, directly from the Galicia App and charged to their dollar accounts. This functionality represented a significant step forward in the internationalization of digital payments.
g) Investments
Grupo Galicia develops its investment business through its companies, which operate in an integrated manner. The offering encompasses savings and investment solutions tailored to different client profiles, time horizons, and risk levels, combining traditional banking products, capital market instruments, and digital investment platforms. The Group's strategy is based on diversifying its offerings, digitizing processes, and ensuring efficient access to financial markets.
Banco Galicia
Banco Galicia offers various investment possibilities for different customer profiles and within any segment. Options include simpler investments such as interest-bearing accounts, fixed terms, mutual funds, securities, custody of securities and purchase and sale of foreign currency; or more complex ones such as primary issues, custody, structured solutions, tailored solutions for hedging rates and currencies.
Fixed Term
The Fixed Term is a very low-risk investment alternative that allows Banco Galicia´s clients to obtain returns on their savings in exchange for keeping such savings in their bank accounts, untouched, for a period of time. The types of Fixed Term offered by the Bank are the Traditional Fixed Term and the UVA Fixed Term.
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A Traditional Fixed Term is one in which an amount of money is delivered to the financial institution, either in Pesos or dollars, for a predetermined time and, consequently, monetary compensation is received in the form of interest. Such compensation is set at the time the Fixed Term is constituted.
The Purchasing Value Units (UVA) Fixed Term is a Fixed Term in Pesos with the objective to protect capital from inflation. The deposited amount is converted into UVAs taking the UVA price at the time of its constitution. The amount of capital to be received on the maturity date will be the equivalent in Pesos to the amount of UVAs deposited, calculated according to the value of the UVA on that date.
During 2025, the Bank implemented a significant upgrade to its interest rate system, incorporating tiered pricing based on business parameters. This improvement allowed for a more personalized offering, providing specific benefits, for example, to payroll clients or based on the investment amount, aligning the proposal with the business strategy and each client's profile.
Additionally, fixed-term deposits were enabled through the Wholesale App, with the aim of simplifying operations for business clients through a streamlined, fully self-service digital experience.
Investment funds
Mutual funds offer investors easy access to diversified portfolios managed by professionals. Through this instrument, unit holders contribute funds that are pooled into a common pool of assets for investment in various financial assets, according to each fund's objective.
Banco Galicia, through its Fima Funds division, offers a wide range of funds. Among them is Fima Premium, a fund with immediate liquidity and a return similar to that of a fixed-term deposit. Starting in July 2024, direct fund transfers from Fima Premium were enabled for all clients. Subsequently, in October 2024, the option to pay for services and purchases using QR codes with the fund's invested balance was added, allowing for continuous investment.
During 2025, Fima's use as a payment method was further strengthened with the addition of new features. Among them, the possibility of paying the credit card statement from Online Banking using the funds from the Fima account stands out, as well as the enabling of cash withdrawals from self-service terminals (TASi), directly using the invested balances.
For more information, see Item 4 - B3. Sales and Marketing - ii) Products and services - g. Investments - "Fondos Fima".
Securities
Banco Galicia offers its clients the possibility of trading securities in the Argentine capital market through its digital channels, including Online Banking, Office Banking and the apps for retail and wholesale clients, providing access to a wide range of instruments (Bonds, Negotiable Obligations, Shares, CEDEARs including ETFs). Additionally, Banco Galicia provides its clients with the ability to participate in the most noteworthy primary security issuances in the market.
During 2025, progress was made in digitizing operations through the implementation of online settlement of MEP dollar transactions and the purchase and sale of securities. Additionally, auctions were launched through the app for individuals, and MEP dollar trading was incorporated into the app for businesses, expanding access to these instruments.
Custody of securities
The custody of securities consists in the provision of settlement and custody services for securities traded in local and international markets by Banco Galicia's customers. Banco Galicia acts as sub-custodian in said markets. Banco Galicia also offers global custody services for corporate and institutional clients, providing such clients with differentiated attention.
Throughout 2025, the digital investment experience continued to be strengthened by incorporating new features into the Retail App. These included opening an investment account directly from the app, digitally validating the investor profile, managing multiple security transfers, and self-service custody of fixed-term certificates for global custody clients.
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•Investor Account - Direct Access from the App: Entry barriers were eliminated by integrating the Investor Account opening process directly into the Galicia App. This promotes client autonomy, simplifying access to the world of investments with an immediate and consistent digital experience across all channels.
•Investor Profile - Personalized Guide: The Investor Profile functionality was added to the Galicia App. Clients can easily identify and validate their risk profile from the app, ensuring that investment recommendations are consistent and aligned with their objectives, with a unified experience across all platforms.
•Securities Transfer - Streamlined and Transparent Management: For investors trading securities, the ability to send and receive multiple securities has been added. This allows for more agile and efficient portfolio management. In addition, a personalized HTML notification has been added for each transaction, improving traceability and clear communication with the client.
•Fixed-Term Certificate - Self-Managed Custody: Global custody clients can now deposit their fixed-term deposits in custody independently. This improvement gives clients greater autonomy and greatly simplifies the management of their investments without requiring in-person or assisted transactions.
Purchase and sale of foreign currency
Banco Galicia offers its clients the ability to buy and sell foreign currency through its digital channels, including Online Banking, the Galicia App, and Office Banking, depending on the client segment. This service is integrated into the Bank's investment offerings, facilitating quick and secure access to the foreign exchange market.
During 2025, dollar buying and selling operations registered sustained growth, driven by the lifting of exchange restrictions in April, which resulted in a significant increase in transaction volume. In this context, the Bank extended the service's availability hours, offering 24/7 service, from 4:00 AM to 2:00 AM the following day.
Banco Galicia also allows MEP dollar trading through Online Banking on business days, during market hours. This instrument enables clients to obtain dollars or pesos by buying and selling the same bond that trades in both currencies. The operation has no amount limits and the resulting funds can be withdrawn in accordance with current regulations, which expands the alternatives available to clients within their investment management strategy.
Private Banking
Private banking provides a differentiated and professional financial service to high net worth individuals, through the management of their investments and financial advice from highly trained officers. Private banking offers its clients a diverse portfolio of domestic financial investments, such as FIMA deposits and mutual funds, public and private securities, shares and trusts in which Banco Galicia acts as placement agent.
Clients benefit from the support of a team of investment professionals who advise on wealth planning in accordance with each client's financial objectives, risk profile, and investment horizon. This advice is complemented by the support of a Strategy Team, responsible for market analysis and the design of investment proposals aligned with different economic scenarios.
The service is based on a combination of personalized attention and digital tools that allow for self-managed or assisted trading. Within this framework, the ÉMINENT Black segment offers clients access to an integrated experience with solutions tailored to their specific needs.
Banco Galicia, together with Galicia Securities and Galicia Capital, forms a coordinated structure that allows for comprehensive management of the wealth management needs of Private Banking clients, both locally and internationally.
Trading Desk Service
The Trading Desk Service is geared towards wholesale clients and aims to meet their investment and financial management needs through a specialized offering of banking and capital markets products. The service is provided jointly by Banco Galicia, Galicia Securities, and Fondos Fima.
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The offering includes a wide range of instruments, notably mutual funds, the purchase and sale of public and private bonds in primary and secondary markets, derivatives, foreign exchange transactions, demand and time deposits, very short-term financing, and asset custody services.
The Trading Desk Service is characterized by a personalized approach, combining expert assistance with access to solutions tailored to each client's operational and financial needs. This model allows for support in investment decisions, as well as liquidity requirements, hedging, and management of excess cash, within a dynamic market environment.
Naranja X
Naranja X offers a savings and investment solution integrated into its app, comprised of a high-yield savings account, the "Frascos" feature and its "Frascos Fijos" extension, and the ability to buy and sell official-rate dollars. These products are designed to provide simple, digital alternatives for managing balances and accessing short- and medium-term investment instruments.
A key feature of its offering is the high-yield savings account, which automatically earns interest on the deposited balance. Funds are always available, allowing users to combine liquidity with returns without requiring complex investment strategies.
Since 2024, Naranja X has offered "Frascos", a savings alternative that brings the habit of setting aside funds for a specific goal into the digital environment. The tool allows users to allocate money for periods of 7, 14, or 28 days and enables the release of funds when needed. It also allows users to create multiple "Frascos", identify them according to goals, and organize them by priority and term.
In 2025, the offering expanded with the launch of "Frascos Fijos", an evolution of the product that incorporates fixed-term deposits as an investment instrument. Since October 2025, customers have been able to invest for periods between 30 and 180 days, with competitive market rates.
As of December 2025, the Naranja X Fixed Jars investment solution reached 3.16 million unique users, solidifying its position as a mass savings tool within the ecosystem. Within this group, 339,000 users choose "Frascos Fijos", a more focused alternative, associated with profiles that prioritize predictability and investment discipline.
During 2025, Naranja X enabled the purchase and sale of official US dollars within the application, expanding access to this transaction in a context of high demand. This functionality is available Monday through Friday, from 8:00 AM to 10:00 PM.
In this way, Naranja X consolidates a digital savings and investment proposal aimed at simplifying money management and expanding access to financial tools within its ecosystem.
Galicia Securities
Galicia Securities offers brokerage services to individuals, companies and financial institutions. It is a member of the main markets in Argentina (BYMA, A3 Mercados and MAV).
Galicia Securities provides a variety of services and products through its settlement and clearing agent (ALyC):
•Fixed income products: Bond operations in Pesos and Dollars; Public and corporate securities; Fixed Rate, Buenos Aires Deposits of Large Amount Rate (BADLAR), adjustable by Coeficiente de Estabilización de Referencia (CER), US$ Linked, etc.
•Stocks: Access to the local share market of Argentine companies listed on BYMA with a wide diversity of assets from different industries: Agriculture, Communication, Construction, Energy, Gas, among others.
•CEDEARs: Investments in Pesos in the local market but in foreign companies.
•Secured Loans: Short-term investment/financing (1 - 120 days) with greater liquidity terms 1-7 days and fixed rates, allowing the clients to anticipate investment profitability or funding cost; Trading in pesos and US$; Guarantee securities administered by BYMA.
•Mutual funds: Placement and distribution agent for common investment funds in diversified portfolios managed by professionals, with a minimal initial investment and quick availability.
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•Stock Promissory Note: Optimal tool for financing working capital and investment projects. It is a dynamic instrument, with minimal transaction costs and low complexity in terms of structuring.
•Structured solutions: Tailored solutions for the needs of each client. Temporary liquidity and coverage of fees and currencies. Investment options in Dollars and Pesos with an attractive variety of interest rates on different investment instruments (Bonds, Sureties, FIMA Funds, among others). Also provides regulatory and market context update, for different operating alternatives.
•Primary issuances: Participation in bidding for the National Treasury and corporate bonds and monitoring of the order and market context in each offer.
The Assets Under Custody as of December 31, 2025, amounted to Ps.5,232 billion.
Fima Funds
Galicia Asset Management has a wide range of investment funds designed for each investor profile, which allows all types of investors to easily access the capital markets through the various Fima funds. The market share of common investment funds was 14.80% as of December 31, 2025, increasing 190 basis points (“bp”) as compared to December 31, 2024.
During 2025, Galicia Asset Management launched a U.S. dollar–denominated money market fund, Fima Premium Dollars. In addition, as part of the GGAL Corporate Reorganization (see item 4.A), 13 funds from the former HSBC Argentina operations were incorporated into the platform. Of these, nine funds were merged in November into eight existing Fima funds, while four fixed-income funds (the "HF" funds listed below) were added to the fund offering. The following is a list of the Fima funds offered:
1.Fima Premium: A fund that provides immediate liquidity with returns comparable to a fixed-term deposit. It invests primarily in interest-bearing demand deposit accounts and fixed-term deposit certificates.
2.Fima Premium Dollars: A fund that provides immediate liquidity while generating returns on U.S. dollar balances. It invests primarily in interest-bearing demand deposit accounts and fixed-term deposit certificates denominated in U.S. dollars.
3.Fima Ahorro Pesos: Its investment portfolio includes short- to medium-term peso-denominated bonds with low volatility and high liquidity. The portfolio consists of peso Treasury bills, corporate bonds issued by leading companies, provincial notes, fixed-term deposits, repos, and interest-bearing accounts, among others. Suitable for conservative investors with an investment horizon of approximately 30 to 60 days.
4.Fima Ahorro Plus: Its investment portfolio includes short- to medium-term peso-denominated bonds with low volatility and high liquidity. It is an alternative for investors seeking a balance between risk and return. The portfolio includes peso Treasury bills, corporate bonds issued by first-line companies, provincial notes, fixed-term deposits, repos, and interest-bearing accounts, among others. Designed for conservative to moderately conservative investors with a recommended investment horizon of 90 to 120 days.
5.Fima Renta Pesos: A fixed-income fund that seeks to maximize returns from a portfolio of medium-term peso-denominated assets at fixed and variable rates (CER, Badlar). Its portfolio includes sovereign bonds, peso Treasury bills, corporate bonds, and financial trusts, among others. Although its current benchmark is CER (the Argentine inflation adjustment index), this may change depending on market conditions. Recommended for moderate investments with horizons ranging from 180 days to 1.5 years.
6.Fima Renta Plus: A fixed-income fund that primarily invests in medium- to long-term peso-denominated bonds. Its portfolio includes public and private fixed-income securities in pesos, mainly sovereign bonds, corporate bonds, and provincial bonds and notes, among others. Although its current benchmark is CER, it may be subject to change depending on market conditions. Suitable for moderate to higher-risk investments with horizons longer than two years.
7.Fima Capital Plus: Its objective is to maximize returns from a portfolio composed of dollar-linked bonds and synthetic assets that replicate the performance of the exchange rate, with liquidity within 48 hours. This strategy has been in place since late November 2019, when the fund redefined its investment objective. Suitable for moderately conservative investors with a medium-term investment horizon of six months to one year.
8.Fima Mix I: A peso-denominated fund composed of local assets designed to track the performance of the official exchange rate, combined with a smaller allocation to foreign equity instruments traded locally through CEDEARs (Argentine depositary receipts representing foreign securities). Local fixed-income assets provide stability, while
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the equity component adds volatility in pursuit of higher returns. Suitable for moderate to higher-risk investments with an approximate one-year investment horizon.
9.Fima Mix II: A peso-denominated fund composed primarily of local assets designed to track the exchange rate, complemented by equity assets and/or crypto-related instruments (equity-linked cryptos). The equity component may be invested in ETFs, equities, and/or derivatives traded on regulated markets that are correlated with fluctuations in digital assets such as Bitcoin and Ethereum, offering opportunities for exposure to crypto-linked assets. Suitable for high-risk investors with an investment horizon longer than three years. This fund involves heightened volatility risk. See item 3.D (Risk Factors).
10.Fima Acciones: The fund’s objective is long-term capital appreciation through investments in Argentine companies included in the S&P Merval index. Its investment policy seeks to track real economic growth through the selection of equities with strong performance indicators. Suitable for high-risk investments with long-term horizons exceeding three years.
11.Fima PB Acciones: A fund composed of equities included in the S&P Merval index, which reflects the performance of domestic and international companies listed on the local market. Suitable for investors seeking to track the benchmark index through a professionally managed portfolio. Designed for high-risk investments with long-term horizons exceeding three years.
12.Fima Sustentable ESG: A peso-denominated fund composed of local assets that aim to generate medium- to long-term returns through a portfolio of ESG assets issued by entities that incorporate environmental, social, and governance criteria. The portfolio may include corporate bonds issued by companies with strong ESG practices, green and sustainable securities, SME financial trusts, and other complementary instruments. Suitable for investors with a moderate risk profile.
13.Fima Fixed Income Dollars: A U.S. dollar–denominated fixed-income fund for moderate-risk investors, seeking medium-term capital appreciation through a portfolio of corporate debt and sovereign bonds. Suitable for investors with a moderate risk profile and an investment horizon longer than two years.
14.Fima Mix Dollars: A U.S. dollar–denominated equity fund for high-risk investors, seeking long-term capital appreciation through a balanced portfolio of sovereign bonds, local corporate bonds, and international equities. Suitable for high-risk investments with horizons exceeding three years.
15.Fima Latin America Equities: A U.S. dollar–denominated equity fund. Its portfolio is primarily composed of Latin American equities. The fund is managed using the S&P Latin America 40 Index as its benchmark, which includes equities from major economic sectors in Brazil, Chile, Mexico, Colombia, and Peru, among others. Suitable for high-risk investments with long-term horizons exceeding three years.
16.Fima International Fixed Income: This alternative seeks to generate returns from a medium-term portfolio of U.S. dollar–denominated bonds, primarily from Latin American markets, with up to 25% invested in U.S. Treasury bonds. The portfolio design excludes local bonds, which helps reduce fund volatility. Suitable for moderate-risk investors with a recommended medium-term investment horizon of approximately 1.5 years.
17.Fima Abierto Pymes: The fund’s objective is to generate returns from a portfolio composed of fixed-income and/or equity instruments issued by SMEs and/or small-cap companies, with a long-term investment horizon. This fund qualifies as a “Productive Investment” under Argentine insurance regulations (SSN Communication 39647, subsection L). It can be adapted to institutional investor profiles.
18.HF Balanced: A total return fund that seeks to maximize returns by investing primarily in both public and private fixed-income instruments.
19.HF Total Return: A fund that seeks to maximize returns by investing primarily in both public and private fixed-income instruments.
20.HF Infrastructure: A fund whose objective is to invest in instruments dedicated to financing productive and infrastructure projects, both public and private. It seeks to achieve optimal results by identifying investment opportunities in specific assets.
21.HF Infrastructure II: The fund’s objective is to invest in instruments dedicated to financing real economy and infrastructure projects, both public and private, seeking to achieve optimal results by identifying investment opportunities in specific assets.
In 2025, Galicia Asset Management maintained its leadership in the industry of mutual funds in Argentina, managing a total of Ps.11,842,577 million as of December 31, 2025. This reflects an increase of 58% compared to 2024.
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In 2025, Galicia Asset Management continued to expand its offering and strengthen its product and channel capabilities. Key initiatives included:
•Launch of the Money Market fund in US dollars: Fima Premium Dollars.
•Incorporation of new functionalities in the Fima account to improve operations and enhance the customer experience.
These initiatives expanded the available investment alternatives and reinforced Galicia Asset Management's value proposition, focusing on a diversified, scalable offering aligned with the needs of different types of clients.
Inviu
It is through Inviu that Grupo Financiero Galicia has developed a digital investment platform that allows both investors and independent financial advisors to manage their portfolios in an efficient, simple, and user-friendly way. This platform was launched in October 2020.
Inviu is a B2B2C company specializing in brokerage and financial services, driven by the belief that technology is key to delivering an outstanding investment experience across Latin America. Its proprietary platform enables independent financial advisors and investors to access a broad range of investment products and services, combining scalability, efficiency, and ease of use.
Inviu provides the tools and services necessary for independent financial advisors to serve more investors and grow their businesses. Through a web-based platform and advisory services, advisors can efficiently scale their operations. Inviu also expands the investment options available to clients through direct agreements with leading global players, as well as a curated selection of funds from both local and international markets, ensuring access to high-quality investment opportunities.
For investors, Inviu delivers the investment experience they seek: comprehensive advisory services from their trusted advisors, complemented by a mobile app and web platform that provide full visibility into both local and international portfolios.
In 2025, Inviu continued to consolidate its growth and advance its regional expansion.
•Sustained Financial Growth: Inviu surpassed US$3,883 million in assets under management (AUM). This result reflects sustained growth for the fourth consecutive year, reaffirming the company's position in the market.
•Regional Expansion to Peru: As a milestone in its expansion, Inviu received approval from the Lima Stock Exchange (BVL) to operate as a brokerage firm (SAB) in Peru. This license allows Inviu to enter the Andean market and advance its regional growth strategy.
The 2025 fiscal year reinforced Inviu's positioning as a regional player, leveraging organic growth, international expansion, and the development of technological capabilities.
h) Foreign Trade
The Galicia Comex (Foreign Trade) department offers product and service options tailored to export and import operations, keeping customers continuously informed of the developments in this area. Banco Galicia continues to support its clients in their international businesses through a personalized electronic platform and differentiated funding lines.
Galicia Seguros provides surety policies for various needs, including temporary importation or exportation, differences in law, value or lack of documentation, land transit and replacement of precautionary measures. It also offers surety insurance coverage required to guarantee liabilities before the ARCA (Federal Tax Authority, for its acronym in Spanish). Through its Comex Tribe (i.e. Foreign Trade department), Banco Galicia ensures quality in end-to-end foreign trade operations and compliance with current regulations.
The products and services offered by Banco Galicia in foreign trade are:
•Transfers abroad
•Foreign payment orders
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•Export and import tracking
•Export and import letters of credit
•Export pre-financing and post-financing
•Import financing
•Guarantees and stand-by letters of credit
Additionally, digital foreign trade (COMEX) management is available through Banco Galicia's channels, with specific functionalities depending on the client's profile:
Office Banking:
•Request for international transfers.
•Request for settlement of payment orders.
•View of transactions and fees.
•Tracking of exports and imports.
•Opening of import and export letters of credit.
•Financing of exports and imports.
•Collection of export and import payments.
Online Banking:
•International transfers.
•Receiving funds from abroad.
App Galicia:
•Receiving funds from abroad.
During 2025, Banco Galicia continued to enhance its foreign trade capabilities with key improvements aimed at streamlining and simplifying operations, and providing greater traceability and transparency in Office Banking and Online Banking:
•Multi-user request signing: more than one signatory can authorize international transfers and payment order settlements in Office Banking and Online Banking, strengthening internal controls.
•Transfer drafts – Upgrade: drafts now retain all data and attachments, can be resumed at any time by any company user, and are automatically sorted by date.
•Expanded transaction details: more information, including attached documents and sworn statements, has been added to “Transactions and Authorizations” to ensure a clearer and more transparent signing process.
•Contact address book with multiple accounts: allows you to associate several accounts with the same contact, avoiding duplicates and facilitating management in Office Banking and Online Banking.
•Transactions and commissions in one place: Information on transactions related to foreign trade has been centralized, with interactive filters that improve the search and control experience.
•New notification in the Galicia App: Real-time alerts when funds are received from abroad, providing immediacy and tracking from within the application.
•Complete digitization of the document workflow: Progress towards a fully digital process that optimizes time, traceability, and efficiency in document operations.
•Ability to cancel unapproved transfers and payment orders: Users can now cancel requests that have not yet been authorized, providing greater control and flexibility in transaction management. This action can be performed directly from the "Operations and Authorizations" section.
•New and improved version for repeating transfers: A revamped version of the Repeat Transfers option allows users to reuse data from a completed transaction to quickly and easily generate a new transfer, without having to re-enter all the information.
•Receive money from abroad in the iOS App: The functionality to receive money from abroad directly from the iOS mobile application was enabled, improving the experience and availability of the service on Apple devices.
As of December 31, 2025, Banco Galicia achieved strong performance in its foreign trade operations. The total volume traded during the year reached US$65,545 million, while operations specifically related to trade business totaled US$36,199 million.
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Within the digital ecosystem, the Banco Galicia COMEX Platform also showed significant activity, registering a traded volume of US$45,424 million. In terms of market share, Banco Galicia achieved a 17.8% share of total foreign trade transactions and a 21.5% share in the trade operations segment.
This performance was reflected in the BCRA ranking as of December 31, 2025, where Banco Galicia ranked first in trade operation volume, as well as first in both total traded volume and number of trade operations, consolidating its leadership in the foreign trade market.
i) Capital Market & Investment Banking
Banco Galicia's Capital Markets division comprises a full range of investment banking and structuring services that facilitate companies' access to financing and investment solutions through instruments traded in local and international markets. The offering combines advisory services, origination, and placement, focusing on supporting corporations, SMEs, and agricultural stakeholders in defining structures tailored to their liquidity, maturity, currency, and risk hedging needs.
Banco Galicia offers services related to the capital markets and investment products across two categories:
Investment products:
•Origination and structuring of syndicated and/or long-term debt.
•Financing with multinational credit entities
•Project Finance
Capital markets:
•Issuance of Negotiable Obligations
•Sub-sovereign Debt Letters and Titles
•Financial Trusts
•Takeover BID Agent
In 2025, Banco Galicia maintained its leading position in the CBONDS ranking of primary debt placement agents. During the year, the Bank led placements in the capital markets, acting as Placement Agent in 169 issuances, including Negotiable Obligations, Treasury Bills, and Financial Trusts. This volume of transactions positioned Banco Galicia as one of the most relevant players in the Argentine financial system.
The year was also marked by a strong push for sustainable finance. Banco Galicia participated in the issuance and placement of various Negotiable Obligations with a sustainable impact, including the Class 5 bonds of 360 Energy Solar S.A., intended to finance renewable energy projects and contribute to the development of a cleaner energy matrix. As of December 2025, the issued amount of this bond totaled US$15 million.
Throughout 2025, the market showed remarkable dynamism, with dollar-denominated issuances leading the way. This performance was primarily driven by macroeconomic and political factors that created a favorable environment for capital markets. Banco Galicia played a significant role in hard dollar issuances, totaling US$14.2 billion, including both new money transactions and corporate debt swaps. Among the most notable issuances were the US$1.1 billion international bond issued by YPF S.A. and the US$725 million debt securities issued by the Province of Córdoba, in both cases with Banco Galicia acting as the local placement agent.
In the local market, the bank acted as underwriter for 85 dollar-denominated bond issuances. Among the most significant were YPF's US$250 million (2-year) bonds, Banco de Galicia y Buenos Aires S.A.'s US$144 million (1-year) bonds, and Pluspetrol S.A.'s US$123 million (5-year) bonds. In all three transactions, Banco Galicia also served as bookrunner, playing a key role in their successful execution.
The peso-denominated issuances totaled Ps.1,589 billion. Notable among these were the Province of Córdoba with an ARS 110 billion issuance, Tarjeta Naranja S.A.U. with an Ps.85 billion issuance, and Arcor S.A.I.C. with an Ps.80 billion issuance.
In the area of Investment Banking, Banco Galicia structured 28 transactions, which included not only bilateral and syndicated loans and debt restructurings carried out jointly with other top-tier financial institutions, but also the issuance of guarantees for large corporate clients. During 2025, Banco Galicia structured 9 syndicated loans and 4 bilateral loans, with its own participation of US$270 billion and Ps.90 billion respectively. These were primarily in the energy and oil and gas
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sectors. Notable transactions included syndicated loans to Tecpetrol S.A., Vista Energy Argentina S.A.U., and Metrogas S.A.
In addition, Banco Galicia acted as guarantor on intercompany loan agreements and issued performance bonds for construction contracts, primarily in the oil and gas sector. These six transactions were included in the bank's sustainable portfolio.
Finally, committed lines of credit were secured with strategic clients to ensure liquidity in an uncertain environment, totaling Ps.112 billion across nine transactions, mainly focused on the automotive sector.
j) Benefits
Grupo Galicia offers rewards and promotional programs to support everyday spending and strengthen customer relationships. The offering combines discounts, rebates, and financing in strategic categories, with an increasingly integrated experience across digital channels and differentiated offerings for each segment, maximizing relevance, ease of use, and nationwide reach.
With the purpose of providing a straightforward and unique experience to its customers, Banco Galicia aims to strengthen its value proposition through partnerships with businesses and brands nationwide, saving promotions, and installment plans. The offering includes personalized and instant benefits designed to meet diverse consumer needs and enhance the experience on digital channels.
These offers may be specific to selected brands or complement existing partnerships (exclusive to the Bank or industry-wide). In turn, ÉMINENT and MOVE account holders have access to preferential terms, and customers who have their salary deposited with Galicia receive additional benefits.
Banco Galicia is committed to improving the daily lives of more people and providing its clients with a differentiating value experience in the market. Consequently, Banco Galicia offers an extensive range of promotions and benefits tailored to the profile of each person and company, allowing them to grow and improve their well-being.
There are savings and installment benefits for various businesses across the country, as well as differentiation for ÉMINENT and MOVE customers.
In 2025, Banco Galicia deepened its benefits strategy, with a strong focus on integration with Galicia Más and expanding benefits in key categories. Throughout the year, significant offerings were highlighted in Supermarkets, Fuel, Entertainment, and Mobility—categories highly valued by users.
As part of the integration with Galicia Más, Banco Galicia worked on unifying its value proposition to offer customers better alternatives. In 2025, it incorporated new benefits and discounts, as well as options for using points. At the same time, it added savings and installment financing options, prioritizing the pillars of the Galicia Benefits experience: personalization, immediacy, and geolocation. As a result, the number of unique users who utilized benefits grew by 13% compared to the previous year.
In 2025, more than 14,000 cashback and/or installment financing benefits were offered, available in e-commerce stores and/or physical locations throughout the country. The online store expanded its digital offerings, adding over 150 sellers to create a diverse and accessible catalog of products including electronics, technology, appliances, home goods, decor, food, and more.
Throughout 2025, the benefits program was promoted through communication and positioning efforts in public spaces (subways and buses) and stadiums, raffles for sporting events (soccer, Formula 1), and experiences at events and lifestyle venues. Benefits in the Mobility, Fuel, and Supermarket categories are the most popular choices among customers. Thanks to the differentiated offering and communication efforts in the Mobility sector (benefits on subways and buses), NFC payments increased by 726% in 2025.
In this way, MODO and Nave play an important role as allies to strengthen agreements and expand the scope of the proposal nationwide.
Among the features implemented in 2025 on the Benefits Platform, the following stand out:
•Events Section: accompanies the customer before, during, and after the show with personalized promotions, countdowns, exclusive content, post-event videos, and raffles.
•Cumulative Refunds: allows easy viewing of received cashbacks and available limits.
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•Travel Section in the App: centralizes everything the customer needs for travel: enabling cards for international use, useful information, purchasing travel assistance, investment options, and destination promotions.
•Benefit Notification on QR Payment: allows users to see if there is an active benefit before confirming the purchase, optimizing the use of promotions.
On the other hand, Naranja X offers a range of promotions and benefits designed to enhance the use of its payment ecosystem and support its customers' everyday spending. The initiative combines discounts and cashback with financing options in relevant categories, leveraging segmentation and self-service capabilities to improve the user experience, expand reach, and strengthen relationships with merchants and users.
In 2025, Naranja X implemented key initiatives that strengthened its promotions and benefits offering:
•More cashback promotions: The number of participating merchants and categories was expanded, increasing the reach and relevance of the offer.
•Multi-payment benefits: Promotions were introduced that allow purchases with the Naranja X Card and the cashback to be received directly in the account, enabling cross-payment experiences, simplifying the customer experience, and boosting the most profitable products.
•Subscription Plan benefits: The option to offer exclusive or incremental cashback to customers subscribed to a plan was added. The strategy included differentiated offers in supermarkets, travel, mobile top-ups, and bill payments. As part of this initiative, the Flash Promo was launched, surprising subscribers with relevant offers and generating verifiable incremental value.
•Promotional umbrellas: Massive cashback promotions were implemented, with regional reach and a presence in major supermarket chains. These multi-mode payment options and differentiated benefits for subscribers allowed Naranja X to streamline its offerings and position itself more clearly and consistently in key sectors.
•Penetration in the Greater Buenos Aires Metropolitan Area (AMBA): The regional growth strategy was supported by a strong presence in leading food brands (via QR code payments) and entertainment venues, consolidating its reach to new audiences.
•User activation campaigns: Segmented promotions were developed specifically for inactive customers or those at risk of churn, incentivizing reactivation through targeted rebates.
•Transportation promotions: In November, cashback rebates were launched for QR code payments on subways. Additionally, throughout the year, NFC use for transportation was rewarded with rebates on account statements thanks to initiatives with various brands, and several promotions were implemented with Uber.
•Promotions as enablers of the NX ecosystem: Naranja X supported the launch of the Mexico project, managing the logic of promotions, and acted as a facilitator of Mango Challenges, the gamified experience within the app.
These improvements were supported by key advancements in internal operations:
•Strengthening cashback management tools: This allowed for scaling the number of refunds and further personalization of promotions.
•New shared contribution models with merchants: These optimized profitability and contributed to the sustainability of the business.
•Improvements to the user experience of finding and understanding promotions in the App: The main Naranja X showcases were optimized to facilitate the identification and use of benefits.
In the second half of 2025, Naranja X enabled the Promotions section within the "Tu Comercio" ("Your Business") section, allowing merchants to manage their available promotions themselves. This allowed them to accept a promotion up to the day before it started, without depending on manual processes and with a much more agile operation. In addition, the acceptance process was simplified: it went from 8 clicks to just 2. This allowed more local businesses to join the promotions. The way information is displayed before accepting a promotion was also improved, with a clearer and more complete details sheet that helped businesses better understand the benefit. Finally, access to this section was opened to all businesses, regardless of size. This allows them to view their current, scheduled, or past promotions at any time without having to call the call center. This made the information more transparent and easier to access, and improved self-service overall.
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k) Merchants
Grupo Galicia develops payment and management solutions for businesses that combine technology, financial services, and support. Through Nave—Grupo Galicia's offering for businesses, operated through Banco Galicia—and the Naranja X service, the Group promotes the digitalization of payments, improves the payment experience, and provides tools to boost sales, optimize business administration, and manage end-to-end operations.
NAVE
Nave, Banco Galicia's dedicated platform for businesses, offers an independent online banking experience without the need to log out. This platform allows businesses to manage their collections, offer installment plans without a card, customize user permissions, and view and monitor all their sales in a single place (including QR, Processors, Mercado Pago, and Naranja X). Additionally, businesses can manage chargebacks and unrecognized charges, among other functionalities.
Nave aims to understand its clients' business to simplify their daily operations and boost their sales, allowing each business to focus on what is most valuable: its clients.
Throughout 2025, Nave Point solidified its position as the preferred payment method, accounting for 70% of total transaction volume. This positioning was supported by the addition of new, agile, and flexible integrations, exclusive promotions, and more competitive financing plans for SMEs, expanding the value proposition and enabling businesses to access more comprehensive solutions tailored to their needs.
As of the end of December 2025, the Nave network reached 61,498 active merchants, with a cumulative payment volume of Ps.2,599 billion, equivalent to 91.19 million transactions during the year and an average monthly real growth rate of 6.60%. At the same time, Nave had 39,761 active terminals, registering an average of 245 transactions per minute, reflecting the operational scale and growing adoption of the platform.
NARANJA X
Naranja X develops payment and acceptance solutions for businesses, startups, and service providers. Its offering aims to expand acceptance of the Naranja X card while providing in-person and digital alternatives (such as terminals, mobile payments, QR codes, and payment links) that adapt to different sales methods, with fast processing and self-service tools.
The solution focuses on enabling businesses to accept Naranja X card payments and manage their operations simply, with features that support their business growth.
Naranja X offers different collection solutions that adapt to the needs of its individual clients with commercial activity:
•Toque: Toque is the Naranja X reader, which connects via Bluetooth to the merchant's mobile phone and allows them to accept payments from any card through the contactless system, chip or magnetic stripe. When merchants collect payments with Toque, the funds from their sales are deposited in the business's Naranja X account and can be used as needed.
•Payment link and QR: A QR can be read from mobile devices and allows contactless payment. The customer scans with their mobile phone camera and pays from any bank App. This payment method is faster, safer and contactless.
•TAP: TAP is an innovative solution from Naranja X designed to simplify collections. Instead of dealing with different devices, this tool allows the merchant to use a cell phone with NFC technology to collect sales with Visa and Mastercard cards. It is a universal solution for in-person collections, which adapts to all types of businesses.
•QR PIX: A QR code is generated for transactions with tourists from Brazil. The merchant enters the amount to be charged and shows it to the customer, who scans and pays. The buyer must have a PIX account.
Naranja X merchants are businesses, ventures, or service providers that register on the network to collect payments through the various available payment solutions. As of December 31, 2025:
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•133,180 merchants enabled to operate with Naranja X payment solutions.
•108,693 merchants accept the Naranja X credit card as a payment method.
Throughout 2025, the focus was on further expanding card acceptance, adding more active merchants, payment methods, and new features. Among the model's main advancements are:
•Onboarding new merchants thanks to streamlined onboarding processes and a fast payment processing system. Merchants can receive their sales payments within 24 or 48 hours, improving their cash flow and facilitating the adoption of payment solutions.
•Developments to simplify daily operations, including the Payment Calendar, a tool that allows merchants to clearly view payment dates, due dates, and upcoming income.
•Strategic promotions to strengthen relationships with merchants, focusing on installment financing to boost sales.
•Evolution of Naranja X's digital solutions to simplify merchant management and offer a streamlined and modern operating experience. Support for businesses to boost their sales through marketing initiatives and app improvements.
•Integration with physical payment terminals and digital tools like Toque and QR codes, streamlining the experience between businesses and the Naranja X card.
In 2025, Naranja X launched Naranja X Businesses (Your Business), a comprehensive solution designed to support entrepreneurs and businesses in managing their sales and payments, offering a simple, digital, and centralized experience. The initiative relies on a web platform and the Naranja X app, from which businesses can accept payments via various methods, track their sales, and manage their business all in one place.
The proposal allows businesses to choose and combine different payment solutions, such as payment terminals, QR codes, mobile TAP payments, PIX payments for tourists, and the option to offer installment plans with Plan Z, adapting to the needs and characteristics of each business. It also provides management tools, including access to sales, commission, and settlement information, the configuration of financing plans, and the administration of work teams with different permission levels.
In this way, Naranja X Businesses consolidates a proposal designed to enable businesses to sell more and better manage their collections, integrating payment solutions and operational tools within the Naranja X digital ecosystem.
In 2025, Naranja X merchants used a variety of payment solutions tailored to different sales methods. QR codes were the most widely used, with 102,332 active merchants. This was followed by Toque transactions, reaching 100,483 merchants, while TAP—the solution that allows payments via NFC-enabled mobile phones—registered 39,646 merchants. Payment links were used by 2,459 merchants, and PIX, the tool designed for Brazilian tourists, accounted for 1,540 merchants.
In this way, Naranja X allows each merchant to choose the payment option that best suits their sales style. In 2025, 43,497 merchants used digital payment solutions, including digital wallets and QR codes, even without a direct link to the card. This group of merchants is currently migrating to Nave. Within this framework, progress was made in integrating Nave as a payment processor and collection solutions provider for small businesses and entrepreneurs operating through the Naranja X App. To facilitate this transition, an integrated development kit was implemented directly into the application, allowing users to continue collecting payments through the app as they have done previously, but now operating as merchants acquired by Nave. As a result, sales are now processed through Nave, and funds are credited directly to the merchants' Naranja X accounts, strengthening self-management and simplifying digital operations.
l) Electronic credit invoice
Banco Galicia offers a mechanism designed to enhance the financing conditions for micro, small and medium-sized companies. This mechanism enables these companies to boost their productivity by facilitating the early collection of credits and accounts receivable associated with the sale of goods or services on a forward-term basis.
The issuance of invoices is carried out through the ARCA (Customs Collection and Control Agency), ensuring compliance with regulatory requirements. Companies can manage their digital documents and collections account through Banco Galicia’s Office Banking platform. Within the Office Banking platform, Banco Galicia provides a special section
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that allows SMEs to efficiently manage digital documents and collection accounts. This section enables automatic payments or collection upon due date and allows SMEs to offer discounts and advance funds.
By leveraging this mechanism, companies can streamline their financial operations, improve cash flow, and ultimately enhance their overall productivity.
m) Integrated Collections
Through the Integrated Collection Galicia ("ICG") function, clients can utilize various communication channels with Banco Galicia to send and receive information about their collections, thereby delegating collection operations to Banco Galicia. This service offers multiple payment channels and forms, allowing businesses to adapt the product to their specific needs.
Companies inform the bank of their customer base of payers and/or outstanding invoices. The bank then provides payers with various means of payment to settle their debts, ensuring flexibility and convenience. Finally, Banco Galicia supplies the servicing company with detailed information on the payments received, facilitating easy reconciliation.
During 2025, key improvements were implemented to simplify and streamline the customer experience, reducing complexity in daily operations. As part of this effort, data format conversion tools were added, and the migration of customers operating under the Galicia Más integrated collections service (SIR, by its Spanish acronym) was completed. These customers began operating directly with Banco Galicia in a seamless and uninterrupted manner, ensuring operational continuity throughout the transition.
The automatic eCheq acceptance service was also optimized, incorporating features that allow customers to configure transaction amount limits and endorsement limits. These improvements strengthen operational control, increase security, and provide greater efficiency in daily operations.
n) Nera
Nera, operated through Grupo Galicia's joint venture with Banco Santander S.A. (see Item 4.A—Agri Tech), offers a digital payments and financing ecosystem that provides agricultural producers with valuable information and measurement alternatives. This allows them to access multiple financial and payment options, as well as customized products to finance their agricultural campaigns, purchase inputs or buy livestock.
Nera accelerates agricultural development by connecting producers, suppliers, and financial institutions on a fully digital platform that consolidates credit options, compares terms, and allows users to simulate costs and payments to choose the solution best suited to their production cycle.
In 2025, the platform expanded its offerings and capabilities. It incorporated bank loans to finance inputs, livestock, and machinery, adding Banco Santander S.A. as a new originator and investor. Existing lines of credit were also strengthened: the Signature Loan, available in pesos and dollars for immediate access, and the Future Grain Loan, backed by forward contracts—open or fixed price—that allows payment with future production in installments aligned with the harvest.
As an innovation, Nera launched the Available Grain Loan, financing guaranteed by grain already harvested and stored in silo bags. This product, developed in partnership with Banco Galicia and SiloReal (a digital agricultural asset verification platform), allows producers to obtain liquidity without selling their production and choose the optimal time to market it. SiloReal provides Remote and Recurring Verification (RRV) to securely digitize and validate agricultural assets.
To improve decision-making, the platform has incorporated new tools: an agreement search engine, a line comparison tool, and a financial simulator, which display payment alternatives and scenarios in real time. On the supplier side, it has added segmentation of commercial terms and a credit evaluator that expands opportunities with clients and prospects.
B.4 Selected Statistical Information
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You should read this information in conjunction with the other information provided in this annual report, including our audited consolidated financial statements and Item 5. “Operating and Financial Review and Prospects”. We prepared this information from our financial records in conformity with IFRS.
i) Average Balance Sheet and Income from Interest-Earning Assets and Expenses from Interest-Bearing Liabilities
The average balances of interest-earning assets and interest-bearing liabilities, including the related interest that is receivable and payable, are calculated on a monthly basis for Banco Galicia and Naranja X on a consolidated basis. The average balances of interest-earning assets and interest-bearing liabilities are calculated on a quarterly basis for Grupo Financiero Galicia and its other non-banking subsidiaries.
The following table shows our consolidated average balances, accrued interest and average yield for interest-earning assets and interest-bearing liabilities for the fiscal year ended December 31, 2025, December 31, 2024 and December 31, 2023.
For the Fiscal Year EndedDecember 31, 2025 For the Fiscal Year EndedDecember 31, 2024 For the Fiscal Year EndedDecember 31, 2023
Average Balance Accrued Interest Average Yield / Rate Average Balance Accrued Interest Average Yield / Rate Average Balance Accrued Interest Average Yield / Rate
(in millions of Pesos, except otherwise noted)
Interest-Earning Assets
Debt Securities at fair value through profit or loss
Government Securities 1,237,878 534,185 43.15 1,088,160 1,141,289 104.88 5,024,370 117,505 2.34
Others Debt Securities 209,802 185,641 88.48 30,665 6,991 22.80 97,069 159,404 164.22
Total Debt Securities at fair value through profit or loss 1,447,680 719,826 49.72 1,118,825 1,148,280 102.63 5,121,439 276,909 5.41
Repurchase Transactions 188,030 118,948 63.26 1,617,196 1,187,114 73.41 1,538,350 1,373,968 89.31
Loans and Other Financing
Loans 21,186,170 7,255,101 34.24 9,337,615 3,539,988 37.91 9,447,582 4,700,727 49.76
Financial Leases 45,513 20,869 45.85 16,949 11,321 66.80 27,618 18,572 67.24
Other Loans and Other Financing 280,093 42,528 15.18 12,276 3,860 31.44 18,122 2,360 13.03
Total Loans and Other Financing 21,511,776 7,318,499 34.02 9,366,840 3,555,168 37.95 9,493,322 4,721,659 49.74
Other Interest-Earning Assets 6,852,308 2,103,489 30.70 4,277,821 3,666,051 85.70 1,671,818 6,482,021 387.72
Total Interest-Earning Assets 29,999,794 10,260,762 34.20 16,380,682 9,556,613 58.34 17,824,929 12,854,557 72.12
Interest-Bearing Liabilities
Deposits
Savings Accounts 7,781,477 495,996 6.37 6,058,606 1,019,837 16.83 5,416,435 1,823,389 33.66
Time Deposits 9,068,676 2,726,047 30.06 3,788,431 2,051,106 54.14 6,748,167 5,708,876 84.60
Total Interest-Bearing Deposits 16,850,153 3,222,043 19.12 9,847,037 3,070,943 31.19 12,164,602 7,532,265 61.92
Financing Received from the Argentine Central Bank and Other Financial Institutions 711,373 212,815 29.92 508,953 15,382 3.02 100,486 17,119 17.04
Debt Securities and Subordinated Debt Securities 1,952,075 220,563 11.30 630,521 77,390 12.27 781,065 42,136 5.39
Other Interest-Bearing Liabilities 3,240,813 222,075 6.85 458,215 219,297 47.86 318,518 202,499 63.58
Total Interest-Bearing Liabilities 22,754,414 3,877,496 17.04 11,444,726 3,383,012 29.56 13,364,671 7,794,019 58.32
Spread and Net Yield
Interest Rate Spread 17.16 28.78 13.80
Cost of Funds Supporting Interest-Earning Assets 12.93 20.65 43.73
Net Yield on Interest-Earning Assets 21.28 37.69 28.39
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(*)Rates include the CER/UVA adjustment.
ii) Changes in Net Interest Income-Volume and Rate Analysis
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The following table allocates, changes in our consolidated interest income and interest expenses between changes in the average volume of interest-earning assets and interest-bearing liabilities and changes in their respective average yield/rate for (i) the fiscal year ended December 31, 2025 compared with the fiscal year ended December 31, 2024 and (ii) the fiscal year ended December 31, 2024, compared with the fiscal year ended December 31, 2023. Differences related to both rate and volume are allocated proportionally to the rate variance and the volume variance, respectively.
Fiscal Year Ended December 31, 2025 /Fiscal Year Ended December 31, 2024Increase (Decrease) due to changes in Fiscal Year Ended December 31, 2024 /Fiscal Year Ended December 31, 2023Increase (Decrease) due to changes in
Volume Rate Net Change Volume Rate Net Change
(in millions of Pesos)
Interest Earning Assets
Debt Securities at fair value through profit or loss
Government Securities 185,226 (792,330) (607,104) (18,625) 1,042,409 1,023,784
Others 119,637 59,014 178,651 (67,473) (84,940) (152,413)
Total Debt Securities at fair value through profit or loss 304,863 (733,316) (428,453) (86,098) 957,469 871,371
Repurchase Transactions (923,702) (144,464) (1,068,166) 75,488 (262,341) (186,854)
Loans and Other Financing
Loans 4,021,636 (306,523) 3,715,113 (54,108) (1,106,632) (1,160,740)
Financial Leases 11,730 (2,182) 9,548 (7,128) (123) (7,250)
Other Loans and Other Financing 39,607 (939) 38,668 (443) 1,942 1,499
Total Loans and Other Financing 4,072,973 (309,644) 3,763,329 (61,679) (1,104,813) (1,166,491)
Other Interest-Earning Assets 23,523,501 (25,086,063) (1,562,562) (5,628,878) 2,812,908 (2,815,970)
Total Interest-Earning Assets 26,977,635 (26,273,487) 704,148 (5,701,167) 2,403,223 (3,297,944)
Interest Bearing Liabilities
Deposits
Savings Account 441,758 (965,599) (523,841) 249,778 (1,053,330) (803,552)
Time Deposits 991,281 (316,339) 674,941 (2,008,826) (1,648,945) (3,657,771)
Total Interest-Bearing Deposits 1,433,039 (1,281,938) 151,100 (1,759,048) (2,702,275) (4,461,323)
Financing Received from the Argentine Central Bank and Other Financial Institutions 8,446 188,987 197,433 (2,178) 441 (1,737)
Debt Securities and Subordinated Debt Securities 148,807 (5,634) 143,173 (6,277) 41,531 35,254
Other Interest-Bearing Liabilities 3,234 (456) 2,778 38,496 (21,699) 16,798
Total Interest bearing liabilities 1,593,526 (1,099,041) 494,484 (1,729,007) (2,682,002) (4,411,008)
The increase of Ps.704,148 million in interest income for the fiscal year ended December 31, 2025, as compared to the previous year, is primarily attributable to a Ps.26,977,635 million increase in volume of interest-earning assets, slightly offset by lower interest rates for Ps.26,273,487 million.
The increase was due to higher net change from loans, with higher volume for Ps.4,021,636 million, offset by lower rates for Ps.306,523 million.
Additionally, there was a decrease of Ps.(1,068,166) million in repurchase transactions, due to a decrease in the volume and interest rate equal to Ps.923,702 million and Ps.144,464 million respectively.
In terms of interest expenses, the Ps.494,484 million increase for the fiscal year ended December 31, 2025, as compared to the fiscal year ended December 31, 2024, is primarily a result of a increase in the volume on time deposits of Ps.991,281 million.
iii) Debt and Equity Securities
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The following table shows our holdings of debt and equity securities at the balance sheet dates stated below. Our holdings of Government securities represent mainly holdings of Banco Galicia.
As of December 31,
2025 2024
(in millions of Pesos)
Debt Securities at FV through profit or loss 1,359,681 1,811,745
Argentine Government Securities 1,339,044 1,776,302
Government Bonds 872,997 1,210,199
Provincial Bonds 70,815 63,959
City of Buenos Aires Bonds 6,125 5,380
Treasury Bills 389,107 496,764
Argentine Central Bank´s Bill 7,541 3,413
Notes 7,541 3,413
Corporate Securities 220,700 169,450
Debt Securities 219,529 169,066
Debt Securities of Financial Trust 1,171 384
From Abroad Government Securities 20,637 35,443
Treasury Bills 20,637 35,443
Other Debt Securities 5,868,624 5,894,313
Measured at FV through OCI 3,235,247 3,026,159
Argentine Government Securities 3,235,247 3,019,063
Government Bonds 2,325,349 1,197,010
Treasury Bills 909,898 1,822,053
Provincial Government Bonds — —
City of Buenos Aires Bonds — —
Argentine Central Bank´s Bill — —
LELIQ (liquidity Bills) — —
Corporate Securities — 7,096
Debt Securities — 7,096
Measured at Amortized Cost 2,633,377 2,868,154
Argentine Government Securities 2,623,405 2,854,169
Government Bonds 1,397,728 2,700,074
Treasury Bills 1,236,629 173,018
Allowance (10,952) (18,923)
Argentine Central Bank´s Bills — —
Internal Bills — —
Corporate Securities 9,972 13,985
Debt Securities 9,961 13,913
Debt Securities of Financial Trusts — —
Others 11 72
International Government Securities 19,321 —
Treasury Bills 19,321 —
Investments in Equity Instruments 108,203 48,411
Domestic 108,203 48,411
International 12,568 6,954
Total Debt and Equity Securities 7,355,829 7,754,469
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As of December 31, 2025, the increase in our holdings of debt and equity securities was mainly a result of an decrease in the volume of government bonds and Treasury Bills recorded at fair value and fair value through profit or loss. As of December 31, 2024, our government bonds and our Argentine Treasury Bills amounted to Ps.1,210,199 million and Ps.496,764 million respectively, compared to Ps.872,997 million and Ps.389,107 million as of December 31, 2025.
The amount of Government securities recorded at fair value as of December 31, 2025 in an amount of Ps.1,339,044 million corresponded to securities issued by the Government (for Ps.872,997 million), the National Treasury Bills (for Ps.389,107 million), provincial governments (for Ps.70,815 million) and the City of Buenos Aires (for Ps.6,125 million).
As of December 31, 2025, our holding of government securities denominated in Dollars was composed of Government bonds recorded at their fair value (for Ps.400,856 million), U.S. Treasury Bonds recorded at their fair value (Ps.20,220 million) and Government bonds recorded at their amortized cost (for Ps.388,106 million).
As of December 31, 2024, the decrease in our holdings of debt and equity securities was mainly a result of an decrease in the volume of Argentine Treasury Bills recorded at fair value and fair value through OCI. As of December 31, 2024, our Argentine Treasury Bills amounted to Ps.1,822,053 million.
The amount of Government securities recorded at fair value as of December 31, 2024 in an amount of Ps.1,776,302 million corresponded to securities issued by the Government (for Ps.1,210,199 million), the National Treasury Bills (for Ps.496,764 million), provincial governments (for Ps.63,959 million) and the City of Buenos Aires (for Ps.5,380 million).
As of December 31, 2024, our holding of government securities denominated in Dollars was composed of Government bonds recorded at their fair value (for Ps.376,067 million), U.S. Treasury Bonds recorded at their fair value (Ps.25,896 million) and Government bonds recorded at their amortized cost (for Ps.380,961 million).
Remaining Maturity and Weighted-Average Yield
The following table analyzes the remaining maturity and weighted-average yield of our holdings of debt securities recorded at amortized cost as of December 31, 2025. Our debt securities portfolio yields do not contain any tax equivalency adjustments.
Fiscal Year Ended December 31, 2025
Maturing within 1 year Maturing after 1 year but within 5 years Maturing after 5 years but within 10 years Maturing after 10 years
Total Book Value Book Value Yield(1) Book Value Yield Book Value Yield(1) Book Value Yield(1)
in millions of Pesos, except percentages)
Other Debt Securities
Measured at Amortized Cost - Domestic
Argentine Government Securities 1,397,731 897,153 5.7 % 500,578 10.3 % — — % — — %
Argentine Central Bank´s Bill and Bonds 1,236,630 1,236,630 29.4 % — — — — % — — %
Corporate Securities 9,983 8,463 23.2 % 1,520 17.2 % — — % — — %
Debt Securities 9,972 8,452 23.2 % 1,520 17.2 % — — % — — %
Debt Securities of Financial Trust — — — % — — — — % — — %
Others 11 11 — % — — — — % — — %
Measured at Amortized Cost - Foreign 19 19 — % — — — — % — — %
Total Other Debt Securities Measured at Amortized Cost 2,644,363 2,142,265 502,098 — —
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(1)Effective yield based on December 31, 2025 quoted market values.
iv) Loan and Other Financing Portfolio
Our total loans and other financing reflect Banco Galicia’s and Tarjetas Regionales’ loan and other financing portfolios including past due principal amounts. Personal loans and credit-card loans are typically loans to individuals granted by Banco Galicia or Naranja. Most of the Naranja’s loans are included under “credit card loans”. Also, certain amounts related to advances, promissory notes, mortgage loans and pledge loans are extended to individuals. However, advances and promissory notes mostly represent loans to companies for accounting purposes. The following table analyzes our consolidated loan and other financing activities portfolio.
As of December 31,
2025 2024
(in millions of Pesos)
Principal and Interest
Non- Financial Public Sector 15,500 10,715
Argentine Central Bank — —
Financial Institutions 622,506 216,201
Non-Financial Private Sector and Residents Abroad (1)
Loans 24,303,385 19,081,325
Advances 991,035 824,033
Overdrafts 6,995,473 5,167,009
Mortgage Loans 1,077,040 417,857
Pledge Loans 651,398 523,093
Personal Loans 2,951,577 2,319,866
Credit Card Loans 8,682,943 8,109,849
Other Loans 2,076,610 1,169,155
Accrued Interest, Adjustment and Quotation Differences Receivable 937,197 596,179
Documented Interest (59,888) (45,716)
Financial Leases 49,936 41,911
Other Financing 485,072 455,555
Non-financial Private Sector and Residents Abroad 24,838,393 19,578,792
Total Gross Loans and Other Financing 25,476,399 19,805,708
Less: Allowances (2,202,958) (878,351)
Total 23,273,441 18,927,357
(1)Categories of loans include:
•Advances: short-term obligations drawn on by customers through overdrafts.
•Overdrafts: endorsed promissory notes, notes and other promises to pay signed by one borrower or group of borrowers and factored loans.
•Mortgage Loans: loans granted to purchase or improve real estate and collateralized by such real estate and commercial loans secured by a real estate mortgage.
•Pledge Loans: loans secured by collateral (such as cars or machinery) other than real estate, where such collateral is an integral part of the loan documents.
•Personal Loans: loans to individuals.
•Credit-Card Loans: loans granted through credit cards to credit card holders.
•Other Loans: loans not included in other categories.
•Documented Interest: discount on notes and bills.
As of December 31, 2025, Grupo Financiero Galicia’s loan and other financing portfolio before allowances for loan and other financing losses amounted to Ps.23,273,441 million, a 23% increase as compared to the year ended December 31, 2024.
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Maturity Composition of the Loan Portfolio
The following table sets forth an analysis by type of loan and time remaining to maturity of our loan portfolio as of December 31, 2025.
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As of December 31, 2025
In 1 year or less After 1 year through 5 years After 5 years through 15 years After 15 years Total atDecember 31,2025
Variable Rates
Financial institutions 22,027 — — — 22,027
Non-Financial Private Sector and Residents Abroad 1,333,554 167,658 19 — 1,501,231
Loans 1,333,554 167,658 19 — 1,501,231
Advances 38 — — — 38
Overdrafts 1,186,946 79,531 — — 1,266,477
Mortgage Loans 145,265 86,320 19 — 231,604
Pledge Loans 1,304 1,806 — — 3,110
Personal Loans 1 1 — — 2
Total Variable Rate 1,355,581 167,658 19 — 1,523,258
Fixed Rates
Non- Financial Public Sector 15,500 — — — 15,500
Financial Institutions 572,684 12,592 — — 585,276
Non-Financial Private Sector and Residents Abroad 17,771,892 2,817,267 24,624 — 20,613,783
Loans 17,771,892 2,817,267 24,624 — 20,613,783
Advances 988,058 31 — — 988,089
Overdrafts 4,785,675 943,321 — — 5,728,996
Mortgage Loans 15,809 31,158 1,194 — 48,161
Pledge Loans 284,931 212,762 42 — 497,735
Personal Loans 1,419,579 1,148,282 23,388 — 2,591,249
Credit Card Loans 8,452,189 230,754 — — 8,682,943
Placements in Banks Abroad 1,237,179 — — — 1,237,179
Pre-financing and financing of exports 588,472 250,959 — — 839,431
Total Fixed Rate 18,360,076 2,829,859 24,624 — 21,214,559
Adjustable Rate
Financial Institutions 9,378 5,825 — — 15,203
Non-Financial Private Sector and Residents Abroad 316,636 387,715 296,989 309,722 1,311,062
Loans 316,636 387,715 296,989 309,722 1,311,062
Advances 2,908 — — — 2,908
Mortgage Loans 53,688 137,210 296,654 309,722 797,274
Pledge loans 49,057 101,440 57 — 150,554
Personal Loans 210,983 149,065 278 — 360,326
Total Adjustable Rate 326,014 393,540 296,989 309,722 1,326,265
Total Loan 20,041,671 3,391,057 321,632 309,722 24,064,082
Accrued Interest, Adjustment and Quotation Differences Receivable 937,197 — — — 937,197
Documented Interest (59,888) — — — (59,888)
Allowance (2,101,055) — — — (2,101,055)
TOTAL 18,817,925 3,391,057 321,632 309,722 22,840,336
____________________
(*)Interest and the UVA/CER adjustment were assigned to the first month.
v) Credit Review Process
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Credit risk is the potential for financial loss resulting from the failure of a borrower to honor its financial contractual obligations. Our credit risk arises mainly from Banco Galicia’s and Naranja’s lending activities, and from the fact that, in the normal course of business, these subsidiaries are parties to certain transactions with off-balance sheet treatment and associated risk, mainly commitments to extend credit and guarantees granted. See also Item 5. “Operating and Financial Review and Prospects ”—A. “Operating Results”—“Off-Balance Sheet Arrangements”.
Our credit approval and credit risk analysis is a centralized process based on balancing a variety of factors. In undertaking credit approval and credit risk analyses, the Bank’s risk management, credit and origination divisions, both with respect to retail and wholesale businesses, efficiently work together on management of asset quality, proactive management of problem loans, aggressive charge-offs for uncollectible loans, and adequate loan loss provisioning. These processes also include the update of financial models to measure portfolio risk at operational and customer levels, facilitating the detection of defaulting, or potentially defaulting, loans and losses associated therewith, which allows for the proactive management of the same in order to prevent portfolio deterioration, enabling appropriate protection of our assets.
Banco Galicia
The Risk Division is responsible for the overall risk management of the Bank in accordance with international best practices and handles solvency, financial, operational, credit, technological, reputational and strategic risks. The Risk Division is independent from the business areas of the Bank and its subsidiaries and reports directly to the Bank’s General Division. The Risk Division works with the functional support of the Compliance and Money Laundering Prevention Division, a division that also reports to the Board of Directors, and whose purpose is to prevent the execution of financial operations with funds derived from illegal activities, and the use of the Bank as a vehicle for laundering money and funding terrorist activities. In addition, the Risk Division monitors compliance with the laws, regulations and internal policies in order to prevent financial and/or criminal penalties and to minimize any reputational impact. It is an independent role that coordinates and assists in identifying, providing advice on, monitoring, reporting and warning management regarding compliance risks.
Moreover, in order to have timely information and a flexible structure in place to efficiently respond and adjust to macro and microeconomic variables, the Risk Division is responsible for credit extension and recovery functions for companies and individuals.
The mission of the Risk Division is comprised of the following activities:
• actively and comprehensively managing and monitoring the risks taken by Banco Galicia and its subsidiaries, ensuring compliance with internal policies and regulations in force;
• keeping the Board of Directors informed of the risks faced by the Bank, proposing how to deal with such risks;
• helping to strengthen a risk management culture;
• establishing the risks the Bank is willing to take and designing policies and procedures to monitor, control and mitigate the same;
• escalating deviations from internal policies to the Bank’s General Division; and
• managing the evaluation process of available financing capabilities and required capital resources to maintain an appropriate risk profile.
The Risk Division’s responsibilities include:
• ensuring action and contingency plans are in place to address any deviations from acceptable thresholds for risks posing a threat to business continuity;
• recommending the most suitable methodologies for the Bank to measure identified risks;
• guaranteeing that the launching of any new product includes a previous assessment of potential risks involved;
• providing technical support and assisting the Management Division regarding risk management;
• developing and proposing the strategies for credit and credit-granting policies; and
• managing and monitoring the credit origination processes, follow-up and control thereof, and the recovery of past-due loans.
Banco Galicia complies with all regulatory requirements set forth by Law No.25,246, as amended and Resolution No.30/2017, as amended, issued by the Financial Information Unit (the “UIF”) and BCRA’s Communication “A” 6399, as supplemented and/or amended.
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The Bank has policies, procedures and control structures in place related to the features of the various products offered, which help monitor transactions in order to identify unusual or suspicious transactions and report them to the UIF. The Compliance and Money Laundering Prevention Division is responsible for managing this risk, through the implementation of control and prevention procedures as well as the communication thereof to the rest of the organization through the drafting of the corresponding handbooks and the training of all employees.
Banco Galicia has appointed a Managing Director responsible for the management of this risk, and has created a Committee in charge of planning, coordinating and enforcing the compliance with the policies set by the Board of Directors. The basic principle on which the regulations regarding prevention and control of money laundering are based is in line with the “know your customer” policy in force worldwide. Such risks are regularly reviewed through internal and external audits.
The following subdivisions depend on support from the Risk Division: Wholesale Credit, Retail Credit and Credit Recovery. They are responsible for developing and proposing strategies for credit and credit-granting policies, as well as managing and monitoring credit origination processes, follow-up and control thereof, and the recovery of past-due loans. The goal of these divisions is to ensure the quality of the loan portfolio, minimize costs while maximizing efficiency, and recovery optimization, thus minimizing loan losses and optimizing efficiency in the credit extension process.
The Retail Credit Division is responsible for ensuring that credit strategies and policies are adequate to maintain the quality of the retail portfolio. This Division designs and manages complex credit decision-taking models and tools, directs the alignment efforts to implement retail business strategies, and works together with the business team to suggest business opportunities.
The Wholesale Credit Division is responsible for the corporate rating process, thus assuring the quality of the wholesale portfolio. This Division directs alignment efforts to implement business strategies based on the customer service model, working together with the business team to suggest business opportunities. This Division deals specifically with complex businesses such as banks, public companies, capital markets transactions and investment projects.
Before approving a loan, Banco Galicia performs an assessment of the potential borrower and his/her financial condition. Approvals of loans exceeding certain amounts are analyzed based on the credit line and the customer.
Banco Galicia performs its risk assessment based on the following factors:
Qualitative Analysis Assessment of the corporate borrower’s creditworthiness performed by the officer in charge of the account based on personal knowledge.
Economic and Financial Risk Quantitative analysis of the borrower’s balance sheet amounts.
Economic Risk of the Sector Measurement of the general risk of the financial sector where the borrower operates (based on statistical information, internal and external).
Environmental Risk Environmental impact analysis (required for all investment projects of significant amounts).
Loans are generally approved pursuant to pre-set authorization levels, except loans exceeding certain amounts, which are approved by the Credit Committee.
The Recovery Management Division is responsible for administering and managing both the Bank’s performing and under-performing credit portfolio, seeking to minimize the deterioration thereof and establishing recovery of such credit portfolios. Management models and specific strategies are applied to each type of portfolio, segments and tranches in arrears, from early defaults to out-of-court and judicial proceedings.
Naranja X
Credit Risk
Credit risk for Naranja X arises from certain liquid assets, deposits with banks and financial institutions, as well as credit exposures to clients, including outstanding receivables and committed transactions.
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Regarding the management of credit risk for cash, cash equivalents, and deposits with banks and financial institutions, Naranja X evaluates its credit risk or exposure pursuant to an investment and credit evaluation policy. In accordance with this policy, Naranja X (i) has certain internal credit risk rating requirements that any company in which it invests must meet, (ii) requires that the amount invested in any entity maintain a specific ratio relative to the equity of both the counterparty financial institution and Tarjeta Naranja S.A.U., and (iii) establishes upper limits on the percentage of the total investment portfolio that may be invested in any single entity.
Naranja X actively monitors the creditworthiness of its clients to minimize its overall exposure to their credit risk. Naranja X uses the following tools to evaluate and manage the creditworthiness of its clients:
•statistical models and analytical tools that determine the amount of credit that Naranja X is comfortable extending to a client based on the client’s specific financial situation and risk profile;
•guidelines for providing credit cards and loans based on the client’s creditworthiness, including verification of the identity, assessment of financial capacity, and credit history reports obtained from Credit Bureaus);
•case-by-case evaluation of appropriate credit limits for each applicant;
•credit atomization;
•geographical diversity; and
•ongoing monitoring of each client’s credit position and payment history.
Naranja - Procedure for Credit Card Application
Each applicant's credit risk is evaluated taking into consideration certain requirements established in the credit policies, the level of monthly income and the information obtained from companies specialized in credit information. Naranja's credit policy consists of various guidelines defined by the Risk Committee. These guidelines are based on set parameters and automated to determine the approval or rejection of the credit application and to inform the documentation to be submitted for those applications that are referred for review by a credit analyst.
It also verifies the non-existence of negative credit history, the applicant's credit score and payment history in Naranja, if applicable, among others. If the customer meets these requirements, the credit card is approved on the spot and can be delivered at the address provided by the applicant or can be picked up at any of the company's branches.
Naranja - Determination of Credit Limits
Credit limits are determined through a comprehensive assessment of each client's credit situation. Credit limit offers are determined through the application of various sub-policies that generate an income estimate and credit scores. The decision engine then assigns floors, caps, and multipliers based on the applicable risk segment.
Naranja - Segmentation by risk level and province
Risk categories are represented by letters (A, B, C, D, E), where segment "A" represents the lowest risk level and segment "E" is considered the highest risk level.
A high-risk level does not preclude an applicant from obtaining a credit card. However, if an applicant fails to meet the conditions for a defined risk segment within the policy, the application is rejected.
Naranja - Assignment of credit limits
Each client is assigned a single credit limit per account, which is shared among all associated cards, whether primary or additional. These limits are automatically determined according to the described segmentation and classified into three categories:
•Monthly Balance Limit (LSM): This represents the maximum allowable amount for monthly due installments, calculated based on the client's net income.
•Long-Term Purchase Limit (LCPL): This represents the maximum permitted amount for purchases made in installment plans of six or more months using credit cards.
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•Total Credit Limit (LTC): This represents the total maximum amount a client can accumulate as outstanding debt for any concept.
Naranja - Distribution of limits and nominal caps
The percentages assigned to the limits and their nominal values vary based on the client's risk segment and their classification into one of the following categories:
Banked Population
Risk Segment POLITICS TOP FLOOR IN
LSM LCPL LTC LSM LPCL LTC ZETA (1) LSM LCPL LTC
A 1 1 1 2,000,000 2,000,000 2,000,000 2,000,000 690,000 690,000 690,000
B 0.8 0.8 0.8 1,000,000 1,000,000 1,000,000 1,000,000 600,000 600,000 600,000
E 0.5 0.5 0.5 300,000 300,000 300,000 300,000 250,000 250,000 250,000
D 0.5 0.5 0.5 400,000 400,000 400,000 400,000 278,000 278,000 278,000
C 0.5 0.5 0.5 600,000 600,000 600,000 600,000 540,000 540,000 540,000
(1) Zeta Limit: limit associated with an exclusive product of the Naranja X credit card, which allows you to opt for different payment options in installments.
Unbanked Population
Risk Segment POLITICS TOP FLOOR IN
LSM LCPL LTC LSM LPCL LTC ZETA (1) LSM LCPL LTC
A 1 1 1 800,000 800,000 800,000 800,000 610,000 610,000 610,000
B 0.8 0.8 0.8 600,000 600,000 600,000 600,000 530,000 530,000 530,000
C 0.5 0.5 0.5 500,000 500,000 500,000 500,000 477,000 477,000 477,000
D 0.5 0.5 0.5 400,000 400,000 400,000 400,000 278,000 278,000 278,000
E 0.5 0.5 0.5 250,000 250,000 250,000 250,000 200,000 200,000 200,000
Naranja reviews credit limits periodically and a credit limit may be automatically increased for eligible cardholders meeting certain requirements, including their payment history and a decrease in their probability of default. In addition, Naranja evaluates cardholders’ applications for increases in the monthly limit and may, at its sole discretion, raise such limits based on the individual customer’s payment history and total income level. The risk of default varies for each client. Naranja evaluates the risk of uncollectibility and maintains allowances, calculated according to the criteria described in the financial statements, which are considered sufficient to cover probable losses from bad debts.
Credit cards are extended to thousands of clients active across a wide range of economic sectors. As such, Naranja considers the risk of credit concentration in any specific sector to be low. Naranja develops and executes pilots with the aim of continuously refining the credit policy and enhancing the customer experience.
Naranja Digital - Loan granting procedure
The client can apply for a loan through the Naranja X application. The requirements to be able to access the loan are the following:
•Not to be in default in risk products in the financial system.
•Not to have a payment plan.
•According to the latest information available from the BCRA, the applicant must not have a credit rating of "2" or higher with any financial institution.
The determination of the offer is made on the basis of the customer's estimated income, internal and external indebtedness and the customer's risk level.
Naranja Digital - Calculation of pre-approved amounts
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The calculation of the amount to be granted depends on several variables that influence its determination:
•Income: the estimated income for each client, considered net of financial system commitments.
•RCI: installment/income ratio calculated as a percentage
•Term: Maximum term a client can access.
•Cap: Maximum amount of income each client can access, by risk level.
•Rate: Annual Nominal Rate (TNA) determined for the loan. In the calculation, it serves as an installment update factor.
•Risk: Segmentation variable that determines the parameters to be used: RCI, Term, Income Cap, Interest Rate. The score model used depends on each policy according to the population covered by it.
•Maximum Amount: The maximum credit cap that can be offered to the client according to their segment, determined by the Risk Policy.
Once the income and the corresponding RCI for each client have been established, the value of the installment is calculated, which arises from making INCOME x RCI. With this value, the present value of the installments determined by the assigned term is calculated.
Where:
•V0 = value of the pre-approved loan (unknown in our formula)
•C = Theoretical loan installment
•n = Loan term (months)
•i = (Loan TNA + IVA)/12
The final amount will be the minimum between the previously calculated value, the Cap based on income, and the Maximum Amount per segment:
Pre-approved Amount = MIN (V0; Cap; Maximum Amount).
Particularly for renewing clients, the calculation of the granted amount depends on additional variables that impacts its determination:
•Previous installment: Amount of the installment paid by the client in the previous operation.
•Risk level: Current Risk Level of the client
•Term: The maximum term a client can access
•Rate: Nominal Annual Rate (TNA) determined for the loan. In the calculation, it serves as an installment update factor.
The formal system used to calculate loan installments is the french system, also known as the "constant amortization system" or "fixed principal repayment method," (the "French system"). Once the product to be offered and the term are defined, the loan amount to be offered is determined based on the 'Maximum Installment' the client can afford, which is expressed as a percentage of the installment paid by the client in their previous operation. By combining this 'Maximum Installment' with the 'Maximum Term' indicated in the previous table and the 'Interest Rate' in the French system, the final loan amount is obtained. Additionally, a 'Maximum Loanable Amount' is established, which depends on the client's Risk Level.
Pre-approved amounts do not generate an obligation for Naranja Digital to grant the loan. All applicants with pre-approved amounts will be reassessed at the time of application.
Personal loans are granted through the App. Installments are calculated using the French system and are fixed and denominated in Pesos. The final installment of a Personal Loan is composed of a principal component, an interest component, taxes, expenses, and commissions.
vi) Financial Instruments Classification and Loss Provisions
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General
The “Expected Credit Loss” (“ECL”) model applies to financial assets which are valued at both amortized cost and fair value through other comprehensive income (“OCI”). The standard establishes three categories to classify financial instruments, primarily taking into account the credit risk evolution over time. Stage 1 includes financial assets with normal or no significant risk associated; Stage 2 includes financial assets for which a significant increase in credit risk has been identified but they are not yet deemed to be credit-impaired, and Stage 3 comprises financial assets which are impaired and/or subject to serious risk of impairment. To calculate the provisions for credit impairment risk, IFRS 9 differentiates among these three stages by applying the following concepts:
•12- Month Expected Credit Losses: Possible events of default within the 12 months following the date of the presentation of financial statements. Assets included in Stage 1 have their ECL measured at 12-month ECL.
•Lifetime Expected Credit Losses: ECL during the active period of the financial asset, which results of calculating the probability of impairment of an asset throughout its duration, up until its maturity. Instruments in Stage 2 or 3 have their ECL measured based on lifetime ECL.
The measurement of ECL in accordance with IFRS 9 should consider forward looking information. To estimate ECL, Grupo Galicia has applied the following definitions and parameters, in accordance with IFRS 9.
Financial Instruments Classification
Grupo Galicia classifies its financial instruments into the following groups: (i) retail loans, (ii) retail-like loans, (iii) wholesale loans and (iv) Naranja X.
Each subsidiary of Grupo Galicia classifies financial instruments subject to impairment under IFRS 9 in stages, as follows:
•Stage 1: With respect to retail portfolios, Stage 1 includes every financial instrument up to 30 days past due. With respect to wholesale portfolios, Stage 1 includes every client whose BCRA situation indicates a normal status (rating A1) (i.e. low risk of bankruptcy).
•Stage 2: This stage includes financial assets for which a significant increase in credit risk has been identified. This stage considers two groups:
◦For retail and retail like Portfolios between 31 and 90 days past due. For wholesale it considers credit ratings for which the risk of default has increased significantly (rating B).
◦Probability of Default or Score with impairment risk.
•Stage 3: For all portfolios, Stage 3 includes every client whose BCRA situation indicates a serious risk of bankruptcy (ratings C, D, E). With respect to retail portfolios, Stage 3 also includes financial instruments that are 90 or more days past due. Furthermore, this stage also includes refinanced transactions originated more than 90 days past due or with another transaction in force within the last 24 months.
See the BCRA Classification, on —“Argentine Banking Regulation”—“Loan Classification System”.
Definition of Default
A financial instrument is considered to be in default whenever payment is more than 90 days past due, or if Grupo Galicia believes that the amount due will not be repaid in full. The credit analysis for wholesale loans is not the same as for retail loans, Grupo Galicia’s definition of default for wholesale portfolios is based on a credit analysis of the individual borrower. The definition of default is applied consistently to produce models for the Probability of Default, Exposure at Default and Loss Given Default in Grupo Galicia’s expected loss calculations:
•Probability of Default (“PD”): This is the likelihood of a borrower defaulting on its financial obligation, either over the next 12 months or during the remaining term of the obligation.
•Exposure at Default: This is based on the amounts Grupo Galicia expects to be owed at the time of default, either over the next 12 months or over the remaining term. For example, for a revolving commitment, Grupo Galicia includes the current draw down balance plus any further amount that it is expected to be drawn up to the current contractual limit by the potential time of default.
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•Loss Given Default: This represents Grupo Galicia’s expectation of effective loss from the total exposure at default. Its value changes according to the counterparty, seniority of the claim and availability of collateral or other credit support. Loss Given Default is expressed as a percentage loss per Peso of exposure at the time of default and is calculated on a 12-month or lifetime basis, where 12-month LGD is the percentage loss expected to be incurred if default occurs within the next 12 months and lifetime LGD is the percentage loss expected to be incurred if default occurs during the remaining life of the financial instrument.
A financial instrument is no longer considered to be in default when it does not meet any of the above-mentioned default criteria.
Methodology for Expected Credit Loss Estimation
ECL impairment allowances recognized in the financial statements reflect the effect of a variety of possible economic outcomes (as described below) and calculated on a probability-weighted basis. ECL measurement involves the application of judgment and estimates. It is necessary to formulate multiple forward-looking economic forecasts and incorporate them into the ECL estimates. Grupo Galicia uses a standard framework to form economic scenarios to reflect assumptions about future economic conditions, supplemented with the use of management judgment, which may result in using alternative or additional economic scenarios and/or management adjustments.
IFRS 9 establishes the following standards regarding ECL:
•An unbiased weighted probability index, determined by the evaluation of different outcomes.
•Time value of money.
•Reasonable and sustainable information available at no additional cost or effort that provides evidence to support forecasts, as well as present conditions and past events.
Grupo Galicia developed a forward-looking methodology to evaluate the impact of different future macroeconomic scenarios on the credit risk of the financial assets. Grupo Galicia prepared three outcomes with varying probabilities in accordance with IFRS: (i) a base scenario with a 70% probability of occurrence, (ii) a pessimistic scenario with a 15% probability of occurrence and (iii) an optimistic scenario with a 15% probability of occurrence
In order to take the time value of money into account, Grupo Galicia assumes expected losses will take place proportionally over time. The ECL is determined by calculating the Probability of Default, Exposure at Default and the Loss Given Default for each future month for each collective segment. These three components are multiplied and adjusted, as applicable, to take into account any forward-looking information, thus calculating ECL for each month on a forward-looking basis, which is then discounted back to the reporting date and summed. The discount rate used in the ECL calculation is the original effective interest rate (or its estimation).
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vii) Credit Risk Exposure of Financial Instruments
The following table sets forth the credit risk exposure of financial instruments for which an ECL allowance is recognized.
Retail Portfolio
December 31, 2025
ECL Staging
Stage 1 Stage 2 Stage 3
12-month ECL Lifetime ECL Lifetime ECL Total
Days past due
0 5,846,642 537,931 214,308 6,598,881
1-30 164,178 106,856 48,982 320,016
31-60 — 185,011 44,067 229,078
61-90 — 135,413 88,186 223,599
Default — — 957,330 957,330
Gross Carrying amount 6,010,820 965,211 1,352,873 8,328,904
Loss allowance (128,235) (198,748) (957,424) (1,284,407)
Net Carrying amount 5,882,585 766,463 395,449 7,044,497
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 11.49 %
Allowance for Financial Instruments as a Percentage of Default 134.17 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 15.42 %
Retail Like Portfolio
December 31, 2025
ECL Staging
Stage 1 Stage 2 Stage 3
12-month ECL Lifetime ECL Lifetime ECL Total
Days past due
0 4,444,379 147,309 36,560 4,628,248
1-30 78,729 44,435 16,030 139,194
31-60 — 48,121 8,464 56,585
61-90 — 19,524 11,242 30,766
Default — — 126,037 126,037
Gross Carrying amount 4,523,108 259,389 198,333 4,980,830
Loss allowance (16,512) (18,572) (101,712) (136,796)
Net Carrying amount 4,506,596 240,817 96,621 4,844,034
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 2.53 %
Allowance for Financial Instruments as a Percentage of Default 108.54 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 2.75 %
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Wholesale Portfolio
December 31, 2025
ECL Staging
Stage 1 Stage 2 Stage 3
12-month ECL Lifetime ECL Lifetime ECL Total
Days past due
A 10,883,795 276,725 — 11,160,520
B1 — 29,239 — 29,239
Default — — 41,502 41,502
Gross Carrying amount 10,883,795 305,964 41,502 11,231,261
Loss allowance (28,228) (1,916) (19,052) (49,196)
Net Carrying amount 10,855,567 304,048 22,450 11,182,065
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 0.37 %
Allowance for Financial Instruments as a Percentage of Default 118.54 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 0.44 %
Naranja X
December 31, 2025
ECL Staging
Stage 1 Stage 2 Stage 3
12-month ECL Lifetime ECL Lifetime ECL Total
Days past due
0 4,200,065 200,705 411 4,401,181
1-30 264,954 44,056 110 309,120
31-60 — 225,552 130 225,682
61-90 — 182,136 1,658 183,794
Default — — 652,983 652,983
Gross Carrying amount 4,465,019 652,449 655,292 5,772,760
Loss allowance (164,061) (196,685) (415,439) (776,185)
Net Carrying amount 4,300,958 455,764 239,853 4,996,575
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 11.31 %
Allowance for Financial Instruments as a Percentage of Default 118.87 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 13.45 %
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Retail Portfolio
December 31, 2024
ECL Staging
Stage 1 Stage 2 Stage 3
12-month Lifetime Lifetime Total
Days past due
0 6,125,759 286,569 52,506 6,464,834
1-30 186,415 56,303 15,025 257,743
31-60 — 81,868 13,404 95,272
61-90 — 38,607 25,342 63,949
Default — — 179,088 179,088
Gross Carrying amount 6,312,174 463,347 285,365 7,060,886
Loss allowance (233,830) (53,113) (196,816) (483,759)
Net Carrying amount 6,078,344 410,234 88,549 6,577,127
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 2.54 %
Allowance for Financial Instruments as a Percentage of Default 270.12 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 6.85 %
Retail Like Portfolio
December 31, 2024
ECL Staging
Stage 1 Stage 2 Stage 3
12-month Lifetime Lifetime Total
Days past due
0 3,004,547 56,887 10,657 3,072,091
1-30 33,088 8,211 3,501 44,800
31-60 — 4,003 657 4,660
61-90 — 2,673 1,495 4,168
Default — — 23,876 23,876
Gross Carrying amount 3,037,635 71,774 40,186 3,149,595
Loss allowance (21,055) (5,830) (21,698) (48,583)
Net Carrying amount 3,016,580 65,944 18,488 3,101,012
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 0.76 %
Allowance for Financial Instruments as a Percentage of Default 203.48 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 1.54 %
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Wholesale Portfolio
December 31, 2024
ECL Staging
Stage 1 Stage 2 Stage 3
12-month Lifetime Lifetime Total
Days past due
A 9,938,529 2,617 — 9,941,146
B1 1,181,585 2,336 249 1,184,170
Default — — 36,878 36,878
Gross Carrying amount 11,120,114 4,953 37,127 11,162,194
Loss allowance (48,121) (480) (15,163) (63,764)
Net Carrying amount 11,071,993 4,473 21,964 11,098,430
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 0.33 %
Allowance for Financial Instruments as a Percentage of Default 172.90 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 0.57 %
Naranja X
December 31, 2024
ECL Staging
Stage 1 Stage 2 Stage 3
12-month Lifetime Lifetime Total
Days past due
0 3,979,064 243,756 99 4,222,919
1-30 216,330 48,440 28 264,798
31-60 — 138,958 63 139,021
61-90 — 95,732 1,871 97,603
Default — — 170,106 170,106
Gross Carrying amount 4,195,394 526,886 172,167 4,894,447
Loss allowance (143,225) (85,937) (107,848) (337,010)
Net Carrying amount 4,052,169 440,949 64,319 4,557,437
Credit Quality
Default as a Percentage of Total Financial Instruments Portfolio 3.48 %
Allowance for Financial Instruments as a Percentage of Default 198.12 %
Allowance for Financial Instruments as a Percentage of Financial Instruments Portfolio 6.89 %
Under BCRA rules, we are required to cease the accrual of interest or to establish provisions equal to 100% of the interest earned on all loans pertaining to the non-accrual loan portfolio, meaning, all loans to borrowers in Stage 3.
The table below shows the interest income that would have been recorded on non-accrual loans on which the accrual of interest was discontinued and the recoveries of interest on loans classified as non-accrual on which the accrual of interest had been discontinued:
December 31,
2025 2024 2023
(in millions of Pesos)
Interest Income that Would Have Been Recorded on Non-Accrual Loans on which the Accrual of Interest was Discontinued 159,483 48,232 28,604
Recoveries of Interest on Loans Classified as Non-Accrual on which the Accrual of Interest had been Discontinued (1) 2,961 1,975 1,487
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____________________
(1)Recorded under “Other operating income”.
viii) Loss Experience
The following tables present the changes in the loss allowance between December 31, 2024, and December 31, 2025, and the changes in the loss allowance between December 31, 2023, and December 31, 2024.
Stage 1 Stage 2 Stage 3
12-month Lifetime Lifetime Total
Loss Allowance as of December 31, 2024 446,230 145,361 341,525 933,116
Inflation effect (120,316) (72,284) (240,106) (432,706)
Financial instruments arising from business combinations (*) — — — —
Movements with P&L Impact — — — —
Transfer from Stage 1 to Stage 2 (24,187) 24,187 — —
Transfer from Stage 1 to Stage 3 (33,845) — 33,845 —
Transfer from Stage 2 to Stage 1 15,691 (15,691) — —
Transfer from Stage 2 to Stage 3 — (17,804) 17,804 —
Transfer from Stage 3 to Stage 2 — 11,553 (11,553) —
Transfer from Stage 3 to Stage 1 1,841 — (1,841) —
New Financial Assets Originated or Purchased 252,684 316,304 945,490 1,514,478
Changes in PDs/LGDs/EADs 127,303 92,248 271,445 490,996
Foreign exchange and other movements (15,156) 49,246 791,768 825,858
Other movements with no P&L impact — — — —
Financial assets collected during the year (253,044) (168,243) (654,747) (1,076,034)
Loss allowance as of December 31, 2025 337,035 415,920 1,493,629 2,246,584
Stage 1 Stage 2 Stage 3
12-month Lifetime Lifetime Total
Loss Allowance as of December 31, 2023 144,523 74,319 177,341 396,183
Inflation effect (125,910) (57,061) (121,842) (304,813)
Financial instruments arising from business combinations 7,450 — 6,494 13,944
Movements with P&L Impact — — — —
Transfer from Stage 1 to Stage 2 (3,049) 3,049 — —
Transfer from Stage 1 to Stage 3 (2,820) — 2,820 —
Transfer from Stage 2 to Stage 1 15,648 (15,648) — —
Transfer from Stage 2 to Stage 3 — (3,428) 3,428 —
Transfer from Stage 3 to Stage 2 — 7,842 (7,842) —
Transfer from Stage 3 to Stage 1 1,036 — (1,036) —
New Financial Assets Originated or Purchased 349,044 140,351 286,476 775,871
Changes in PDs/LGDs/EADs 190,452 18,669 60,346 269,467
Foreign exchange and other movements (15,036) 2,503 214,281 201,748
Write-offs (1,648) — (123,633) (125,281)
Other movements with no P&L impact — — — —
Financial assets collected during the year (113,460) (25,236) (155,307) (294,003)
Loss allowance as of December 31, 2024 446,230 145,360 341,526 933,116
ix) Deposits
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The following table sets out the composition of our deposits as of December 31, 2025 and December 31, 2024.
As of December 31,
2025 2024
(in millions of Pesos)
Deposits in Pesos
Checking Accounts 2,549,986 2,632,390
Savings Accounts 5,242,183 5,784,142
Time Deposits 7,378,579 5,406,661
Time Deposits UVA 42,232 116,749
Other Deposits (1) 81,238 93,373
Plus: Accrued Interest, Quotation Differences Adjustment 182,480 308,411
Total Deposits in Pesos 15,476,698 14,341,726
Deposits in foreign currency
Savings Accounts 9,994,430 9,425,730
Time Deposits 2,174,638 718,621
Other Deposits (1) 18,269 25,744
Plus: Accrued Interest, Quotation Differences Adjustment 4,905 1,410
Total Deposits in foreign currency 12,192,242 10,171,505
Total Deposits 27,668,940 24,513,231
(1)Includes other deposits originated by Decree No.616/05, reprogrammed deposits under judicial proceedings and other demand deposits.
As of December 31, 2025, our consolidated deposits increased 13% as compared to December 31 2024, mainly as a result of a Ps.568,700 million increase in foreign currency saving accounts and Ps.1,971,918 million increase in peso denominated time deposits.. These increases were mainly due to deposits received by Banco Galicia.
The following table shows the amount of uninsured deposits as of December 31, 2025 and December 31, 2024.
As of December 31,
2025 2024
(in millions of Pesos)
Uninsured Deposits 17,734,543 12,400,760
For more information, see Item 5. “Operating and Financial Review and Prospects” – A.“Operating Results”- “Funding”.
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The following table provides a breakdown of our consolidated deposits by contractual term and currency of denomination as of December 31, 2025.
December 31, 2025
Within 3 Months After 3Months butWithin 6Months After 6 Months but Within 12 Months 1 year After 1 but Within 5 years Total
(in millions of Pesos, except percentages)
Deposits in Pesos
Savings Accounts 5,497,032 — — 5,497,032 5,497,032
Checking Accounts 2,315,012 — — 2,315,012 2,315,012
Time Deposits 6,882,844 477,903 17,497 7,378,244 335 7,378,579
Total deposits in Pesos 14,694,888 477,903 17,497 15,190,288 335 15,190,623
Deposits in Pesos + UVA adjustment
Savings Accounts 73,957 73,957 73,957
Time Deposits 39,691 3,573 729 43,993 43,993
Total deposits in Pesos + UVA adjustment 113,648 3,573 729 117,950 — 117,950
Deposits in foreign currency
Savings Accounts 9,995,846 9,995,846 9,995,846
Checking Accounts 16,853 16,853 16,853
Time Deposits 2,098,554 30,906 45,178 2,174,638 2,174,638
Total deposits in foreign currency 12,111,253 30,906 45,178 12,187,337 — 12,187,337
Total deposits 26,919,789 512,382 63,404 27,495,575 335 27,495,910
Savings Accounts 15,566,835 — — 15,566,835 — 15,566,835
Checking Accounts 2,331,865 — — 2,331,865 — 2,331,865
Time Deposits 9,021,089 512,382 63,404 9,596,875 335 9,597,210
____________________
(1)Only principal. Includes the UVA adjustment.
The chart above shows that the highest concentration of maturities for time deposits was in the period of up to 89 days, representing 94.0% of total time deposits. As of December 31, 2025, the average term for the raising of non-adjusted Peso-denominated time deposits was 38 days, for UVA-adjusted deposits the average term was 110 days and for those in foreign currency the term was about 38 days. Foreign currency-denominated deposits, equal to Ps.12,187,337 million, represented 44.3% of total deposits.
x) Regulatory Capital
Grupo Financiero Galicia
Grupo Financiero Galicia and its subsidiaries are regulated by the Corporations Law. Section 186 of the Corporations Law establishes the minimum capital amount of a corporation at Ps.100,000.
Grupo Financiero Galicia’s capital adequacy is not regulated by the BCRA, however Grupo Financiero Galicia is required to comply with the minimum capital requirement established by the Corporations Law. On October 8, 2012, through Decree No.1331/12, such amount was established as Ps.100,000. As of February 29, 2024, by Decree 209/2024, a new amount of Ps.30,000,000 (thirty million) was established.
Banco Galicia
With respect to regulatory capital, Banco Galicia must comply with the regulations set forth by the BCRA. These regulations are based on the Basel Committee methodology, which provides the minimum capital requirements for financial institutions to cover the different risks inherent to its business activity and assets, such as credit risk (generated both by exposure to the private sector and to the public sector); operational risk (generated by the losses resulting from the
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non-adjustment or failures of internal processes); and market risk (generated by positions in securities and in foreign currency).
Computable capital is divided as follows:
•Computable regulatory capital is divided into Basic Shareholders’ Equity (Tier I Capital) and Supplementary Shareholders’ Equity (Tier II Capital). Deductible items generally fall within Basic Shareholders’ Equity.
•Intangible assets and deferred tax asset credit balances should be deducted from the calculation of computable capital.
•Results for a given period are part of Basic Shareholders’ Equity (Income: 100% of audited results, 50% of unaudited results; Losses: 100%).
•Supplementary Shareholders’ Equity includes 100% of the portfolio allowance in normal situation (up to the limit of 1.25%) and for subordinated notes, with respect to which, as from each of the last five years of each issuance term, the computable amount shall be reduced by 20% of the face value issued.
The following percentages apply in determining minimum capital requirements:
•Exposures in Pesos to the National Non-financial Public Sector: 0%.
•Property, Plant and Equipment and Miscellaneous Assets: 8%.
•Family Mortgage Loans: 20% over 8%, if the loan‑to‑value ratio does not exceed 55% of the appraised value of the property.
•Retail Portfolio – non‑transactional regulatory exposures: 75% over 8%.
•Retail Portfolio – non‑ regulatory exposures: 100% over 8%.
The following table sets forth Banco Galicia´s capital required pursuant to the BCRA regulations in force for each period indicated below.
December 31,
2025 2024
(in millions of Pesos, except percentages)
Minimum capital required (A)
Allocated to Credit Risk 1,635,141 878,871
Allocated to Market Risk 35,935 38,581
Allocated to Operational Risk 231,436 364,615
Total minimum capital required (A) 1,902,512 1,282,067
Computable Capital (B)
Tier I 5,811,263 2,852,154
Tier II 29,188 51,625
Total computable capital (B) 5,840,451 2,903,779
Excess over Required Capital (B)-(A) 3,937,939 1,621,712
Risk assets 23,186,086 15,703,410
Ratios (%)
Equity / Total assets 16.43 20.25
Excess / Minimum capital required 207.0 126.5
Total Capital Ratio(1) 25.19 18.49
Tier I Capital Ratio 25.06 18.16
____________________
(1)Total computable capital / risk weighted assets credit, market and operational risks.
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As of December 31, 2025, the Bank’s computable capital amounted to Ps.5,840,451 million, which was PS.3,937,939 million (207%) higher than the Ps.1,902,512 million minimum capital requirement. As of December 31, 2024, this excess amounted to Ps.1,621,712 million which was 126% higher than the minimum capital requirement.
As of December 31, 2025, the minimum capital requirement increased by Ps.620,445 million as compared to December 31, 2024, mainly due to the increase in regulatory requirements on risk weighted assets. Computable capital increased by Ps.2,936,672 million as of December 31, 2025 as compared to December 31, 2024, primarily originated by an increase in accounting shareholders’ equity as a result of the inflation adjustment and by the incorporation into shareholders’ equity of Galicia Más. Banco Galicia's total capital ratio was 25.19%, increasing 626 bps as of December 31, 2024 as compared to 18.49% as of December 31, 2024.
Naranja X
Tarjetas Regionales and Tarjeta Naranja are not qualified as financial institutions under the FIL and, thus, their capital adequacy is not regulated by the BCRA and they only have to comply with the minimum capital requirement established by the Corporations Law, which as of the date of this annual report amounts to Ps.30,000,000.
Conversely, Naranja Digital is a financial institution class “B” and, based on that condition, is regulated by the BCRA and has to comply with the minimum capital requirement established by the BCRA by means of Communication "A" 8367. Such regime, based on the Basel Committee methodology, establishes the minimum capital that a financial entity must maintain to cover the different risks inherent to its activity that are incorporated in its assets, mainly: credit risk, operational risk generated by the losses resulting from the lack of adequacy or failures in the internal processes and the market risk, generated by the positions in securities and in foreign currency. As of the date of this annual report, the minimum capital requirement established by the BCRA applicable to Naranja Digital is Ps.194,773 million.
Minimum Capital Requirements of Insurance Companies
The insurance companies controlled by Sudamericana must meet the minimum capital requirements set by General Resolution No.24/2025 of the National Insurance Superintendency. This resolution requires insurance companies to maintain a minimum capital level equivalent to the highest of the amounts calculated as follows:
(a)By line of insurance: a fixed amount of 375,000 UVA, equivalent to Ps.640.4 million as of December 31, 2025.
(b)By premiums and additional fees: to use this method, Sudamericana must calculate the sum of the premiums issued and additional fees earned in the last 12 months. Based on the total, Sudamericana must calculate 16% of such amount. Finally, it must adjust the total by the ratio of net paid claims to gross paid claims for the last 36 months. This ratio must not be lower than minimum capital requirements required for a particular line of insurance as set forth above in (a).
(c)By claims: to use this method, Sudamericana must calculate the sum of gross claims paid during the 36 months prior to the end of the period under analysis. To that amount, it must add the difference between the balance of unpaid claims as of the end of the period under analysis and the balance of unpaid claims as of the 36th month period prior to the end of the period under analysis. The resulting figure must be divided by three. Then Sudamericana must calculate 23% of the resulting figure. The resulting figure must then be adjusted by the ratio of net paid claims to gross paid claims for the last 36 months. This ratio must be at least 50%.
(d)For life insurance companies that offer policies with an investment component, the figures obtained in b) and c) must be increased by an amount equal to 4% of the technical reserves adjusted by the ratio of net technical reserves to gross technical reserves (at least 85%), plus 0.3% of at-risk capital adjusted by the ratio of retained at-risk capital to total at-risk capital (at least 50%).
The minimum required capital must then be compared to computable capital, defined as shareholders’ equity less non-computable assets. Non-computable assets consist mainly of deferred charges, pending capital contributions, proposed distributions and excess investments in authorized instruments.
As of December 2025, the computable capital of the companies controlled by Sudamericana amounted to Ps.336,179 million, exceeding the minimum requirement of Ps.102,019 million by Ps.234,160 million.
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Sudamericana also owns Galicia Broker and Well Assistance, companies engaged in insurance brokerage across different lines of insurance. These companies are regulated under the General Corporations Law, which provides for a minimum capital requirement of Ps.30 million, as of the date of this annual report.
B.5 Government Regulation
i) General
All companies operating in Argentina must be registered with the applicable Public Registry of Commerce. In addition, any company with publicly issued equity or debt securities is subject to the rules of the CNV. Further, financial entities, such as Banco Galicia, are subject to BCRA regulations. As public issuers of securities in Argentina, Grupo Financiero Galicia and Banco Galicia must comply with the disclosure, reporting, governance and other rules applicable to such companies in the markets in which they are listed and those of regulators in the countries in which they are listed, including the Law No. 26,831 (the “Capital Markets Law”, in Spanish “Ley de Mercado de Capitales”, as amended by Law No. 27,440, among others), Law No.20,643, the Decrees No.659/1974 and No.2220/1980 (as amended by Decree No. 572/1996, among others), and CNV’s Rules (General Resolution No. 622/2013, as amended and/or supplemented, the “CNV Rules”).
In their capacity as public issuers of securities, Grupo Financiero Galicia and Banco Galicia are subject to the aforementioned rules. Since Grupo Financiero Galicia has publicly listed American Depository Shares (or “ADSs”) in the United States, it is also subject to the reporting requirements of the United States Securities and Exchange Act of 1934 (the “Exchange Act”) for foreign private issuers and to the provisions applicable to foreign private issuers under the Sarbanes Oxley Act. See Item 9. “The Offer and Listing”.
Banco Galicia’s operating subsidiaries are also subject to the following laws: Law No.27,442 (the Competition Defense Law or, in Spanish “Ley de Defensa de la Competencia”), Decree No. 274/2019 that repeals the Fair Business Practice Law No. 22,802 and the Consumer Protection Law No. 24,240, as amended (or, in Spanish “Ley de Protección del Consumidor”).
As a financial service holding company, we do not have a specific institution that regulates our activities. Our banking and insurance subsidiaries are regulated by different regulatory entities. The BCRA is the main regulatory and supervising entity for Banco Galicia.
The banking industry is highly regulated in Argentina. Banking activities in Argentina are regulated by Law No.21,526, as amended (the “FIL”), which places the supervision and control of the Argentine banking system in the hands of the BCRA. The BCRA regulates all aspects of financial activity. See “Argentine Banking Regulation” below.
Banco Galicia and our insurance subsidiaries are subject to Law No.25,246 which was passed on April 13, 2000 (as amended, among others, by Laws No.26,087, 26,119, 26,683, 26,734, 26,831, 26,860, 27,446 and 27.739 collectively, the "Anti-Money Laundering Law"), which provides for an anti-money laundering framework in Argentina, including Laws No. 26,268 and 27,304, which amend Law No.25,246 to include activities associated with terrorism and Law No. 27,401, which provides for the criminal liability of corporate entities upon their direct or indirect execution of prohibited activities. Furthermore, the Anti-Money Laundering Law created the Financial Information Unit (Unidad de Información Financiera), which established an administrative criminal system, compliance monitoring and the ability to impose sanctions.
Sudamericana’s insurance subsidiaries are regulated by the National Insurance Superintendency and Laws No.17,418, as amended and modified by Law No.20,091. Galicia Broker is regulated by the National Insurance Superintendency, through Law No.22,400, as amended.
Naranja and the credit card activities of Banco Galicia are regulated by the Credit Card Law No. 25,065, as amended. Both the BCRA and the Secretary of Industry and Commerce (Secretaría de Industria y Comercio) have issued regulations to, among other things, enforce public disclosure of companies’ pricing (fees, interest rates, and advertising) in order to ensure consumer awareness of such pricing. See “Credit Cards Regulation”.
On January 6, 2002, the Argentine Congress enacted Law No.25,561 (as amended and supplemented, the “Public Emergency Law” or in Spanish “Ley de Emergencia Pública”), which, together with various decrees and BCRA rules, provided for the principal measures intended to manage the 2001-2002 financial crisis, including the introduction of the so
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called "Asymmetric Pesification" (Pesificacion Asimetrica) measure, and the elimination of the requirement that the BCRA’s reserves in gold, foreign currency and foreign currency denominated debt be at all times equal to 100% of the monetary base, among others. The Public Emergency Law, which has been extended year after year and remained in force until December 31, 2017, granted the Government the power to fix the exchange rate of the Peso against foreign currencies and to issue regulations relating to the foreign exchange market. The Argentine Government did not extend the term of the Public Emergency Law following December 31, 2017. However, on December 14, 2016, the Argentine Congress enacted Law No. 27,345, which extended the state of emergency on social matters until December 31, 2019.
Following the expiration of the Public Emergency Law on December 31, 2017, Argentina remained subject to various other emergency regimes and related regulatory measures. Most recently, pursuant to Decree of Necessity and Urgency No. 70/2023, the Argentine Executive Branch declared a public emergency in economic, financial, fiscal, administrative, pension, public service charges, health and social matters through December 31, 2025, while Decree No. 942/2025 extended the national health emergency originally declared thereunder through December 31, 2026.
ii) Foreign Exchange Market
In January 2002, through the Public Emergency Law, Argentina declared a public emergency situation in respect of its social, economic, administrative, financial, and foreign exchange matters and authorized the Argentine Executive Branch to establish a system to determine the foreign exchange rate between the Argentine Peso and foreign currencies and to issue foreign exchange-related rules and regulations.
Within this context, on February 8, 2002, through Decree No. 260/2002, as amended by Decree No. 27/2018, the Argentine Executive Branch established (i) a single and free-floating foreign exchange market (a “MULC”, or “Mercado Único y Libre de Cambios”) through which all foreign exchange transactions in a foreign currency must be conducted, and (ii) that foreign exchange transactions in a foreign currency must be conducted at the foreign exchange rate to be freely agreed upon among the contracting parties, subject to the requirements and regulations imposed by the BCRA.
On June 9, 2005, through Decree No.616/2005, the Argentine Executive Branch mandated that inflows of funds into the MULC arising from foreign debt incurred by residents (subject to certain exceptions) and all inflows of funds of non-residents channeled through the MULC for certain concepts were required to be credited into a local account and maintained for a “Minimum Stay Period”, requiring a mandatory deposit equal to 30% of the amount of the transaction for a period of 365 calendar days. Such requirements were eliminated by the former administration.
In February 2017, the former Ministry of Economy and Public Finance issued Resolution No. 1/2017, which reduced the “Minimum Stay Period” described above to zero days. As of July 1, 2017, with the issuance of Communication “A” 6244, the foreign exchange rules and regulations described above were reversed. In the same sense, the Government issued Decree 27/2018 by which it modified the denomination of the official foreign exchange market, from “MULC”, or “Mercado Único y Libre de Cambios” to “MLC” or “Mercado Libre de Cambios”.
On September 1, 2019, the Government issued Decree No. 609/19 (as later amended by Decree No. 91/19 on December 28, 2019), setting forth certain controls and restrictions on the acquisition, sale, and transfer of foreign currency, applicable to both individual persons and legal entities in Argentina. This decree also enabled the BCRA to establish, through regulations, the necessary measures to avoid “practices and operations aimed at avoiding, through public titles or other instruments” the restrictions set forth by the decree. In furtherance of such decree, since its date of implementation the BCRA has adopted a series of measures that regulate the MLC, which are all included in the Amended and Restated Text on Foreign Exchange (the “FX Regulatory Framework”). Within the Amended and Restated Text on Foreign Exchange the “MC” or “Mercado Libre de Cambios” is now referred to as “Mercado de Cambios” or “MC” (hereinafter, indistinctly the “MC”, the "MLC", the "FX Market", or the “Mercado de Cambios”).
Inflow of Funds:
Export of goods, provision of services, and sales of non-financial, non-locally produced assets: Funds entering into Argentina from (i) the export of Argentine goods, (ii) the provisions of services to a non-resident by a resident and (iii) payments received in foreign currency from the sale to a non-resident of non-financial, non-locally produced assets are required to be entered through the FX Market, converted into Pesos, and deposited into a local bank account, all within specifically prescribed periods.
Payments received from outstanding loans, payment of amounts earned from term deposits or payments received from the sale of any type of asset that is granted, set up or acquired after May 28, 2020: Furthermore, by
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means of Communication “A” 7030 (as amended), the BCRA set forth that, in order to grant their clients access to the FX Market, financial entities must first request from such clients an affidavit stating, among others, that such client will agree to transfer into Argentina and convert into local currency through the FX Market within five business days, any funds received abroad arising from payments received from outstanding loans, payments of amounts earned from term deposits held outside of Argentina or payments received from the sale of any type of asset (e.g. shares, securities, goods, etc.) outside of Argentina in case such loans, deposits or assets were granted, set up or acquired after May 28, 2020.
Offshore financial indebtedness: Regarding offshore financial debts, the Argentine borrower receiving the foreign funds must convert such funds into Argentine Pesos in order to be able to access the FX Market in the future for the payment of principal and interest when due.
Outflow of Funds:
The FX Regulatory Framework establishes certain limitations and regulations on the ability to access to the FX Market using the official foreign exchange rate for the import of goods, payment for offshore services, payment of dividends and earnings, repayment of loans, etc. The necessary requirements will depend on each particular transaction. BCRA's prior authorization will be required when the necessary applicable requirements are not met. The ability to access the FX Market for cross-border payments will depend on the terms and conditions established by the BCRA at the time of the execution of each specific transaction. Currently, both general requirements, as well as specific ones that depend on the nature of the transaction, need to be complied with.
As a general rule, in order to grant their clients access to the FX Market to perform cross-border payments, financial institutions must request their clients to provide an affidavit stating compliance with the provisions and requirements of the FX Regulatory Framework. In this context, clients that are not human persons must submit the following affidavits pursuant to the terms of Section 3.16 of the Amended and Restated Text on Foreign Exchange (the “Affidavits”):
(a) Affidavit of Foreign Assets: By means of this affidavit, the corresponding client must state that, on the day it is requesting access to the FX Market (i.e. on the day a given payment is to be executed), all of its foreign currency holdings in Argentina are deposited in accounts held in local financial institutions, and it does not hold any “available liquid foreign assets” (including Argentine certificates of deposit representing foreign shares, known as “CEDEARs”) in an amount in excess of US$100,000. In the event that the client holds available liquid foreign assets in an amount in excess of the threshold referred to above, it will have to file an additional affidavit before the bank (through which the corresponding payment is being executed) stating that such amount in excess is subject to any of the exceptions set forth under Section 3.16.2.1. of the Amended and Restated Text on Foreign Exchange (e.g. that the exceeding funds correspond to collections from exports of goods and/or services or advances, pre-financing or post-financing of exports of goods granted by non-residents, and that the 5 (five) business day term to convert those funds into Argentine Pesos has not elapsed).
(b) Affidavit of Mandatory Repatriation: By means of this affidavit, the corresponding client must undertake to convert any funds received abroad from the collection of any of the following sources into Argentine Pesos through the FX Market within 5 business days from the date on which any such funds become available: (a) loans; (b) term deposits; or (c) sales of any type of assets (e.g. shares, securities, goods, etc.): provided, that the same were granted, constituted, or acquired after May 28, 2020.
(c) Affidavit on Securities Transaction: By means of this affidavit, the corresponding client must state that, on the day on which it is requesting to access to the FX Market, and during the previous ninety (90) calendar days (the ninety (90) calendar-day term applies only to transactions conducted after September 19, 2024; for transactions carried out before this date, the applicable terms are as follows: 90 calendar days for transactions involving securities governed by local legislation, and one hundred and eighty (180) calendar days for transactions involving securities governed by foreign legislation) it has not performed any of the following (the "Securities Transactions"): (a) sold securities that were settled in a foreign currency; (b) arranged swaps of securities issued by residents for foreign assets, (c) transferred securities to depository institutions abroad; (d) acquired domestic securities issued by non-residents with payment in Pesos; (e) acquired CEDEARS; (f) acquired securities representing private debt issued in a foreign jurisdiction; and (g) delivered local funds or other local assets (except funds in foreign currency deposited in local financial institutions) to any individual or legal entity, whether resident or non-resident, related or not, in order to receive, as prior or subsequent consideration, directly or indirectly, by itself or through a related, controlled or controlling entity, foreign assets, crypto-assets or securities deposited abroad. Furthermore, the client must also undertake not to carry out these operations during the ninety (90) calendar days immediately thereafter.
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In addition to the above, pursuant to Section 3.16.3.3 of the Amended and Restated Text on Foreign Exchange, as part of the Affidavits, the client must include a list of persons who exercise "direct control" over it and entities that are part of the same economic group, in accordance with Sections 1.2.1.1 and 1.2.2.1 of the “Large Exposures to Credit Risk” standards of the BCRA rules, and state that, on such day and during the ninety (90) calendar days prior to such day, it has not delivered funds in local currency or other liquid local assets to said controlling entities (except for funds in foreign currency deposited in Argentine financial institutions), except for those funds directly related to usual and customary transactions between Argentine residents for the acquisition of goods and/or services (the "Local Deliveries"). This requirement shall be deemed satisfied if: (a) the client submits an affidavit stating that it has not delivered local assets to any third party (except for funds directly related to usual and customary transactions between Argentine residents for the acquisition of goods and services); (b) all the direct controlling entities and entities forming part of the same economic group submit an affidavit stating that (i) they have not performed Securities Transactions, or (ii) an affidavit stating that they have not executed Local Deliveries, within the relevant timeframes; or (c) the direct controlling entities (and entities forming part of the same economic group) who have received Local Deliveries of the client within the relevant timeframe, submit an affidavit stating that they have not performed Securities Transactions and Local Deliveries, within the relevant timeframes.
Import of Goods. The FX Regulatory Framework establishes the possibility for Argentine residents to access the FX Market in order to pay amounts that they owe for the import of goods with customs entry registration on or after December 13, 2023, upon compliance with certain requirements. In summary: (i) all imports of goods for consumption (not temporary or other imports) must have an approved “Import Statistical System” (Sistema Estadístico de Importaciones - SEDI) declaration, whereby they provide information regarding import operations; (ii) financial institutions must register and validate each payment in a separate system managed by the BCRA called “Imports Payments Registration” (Registro de Pagos de Importaciones - REPI), which will review compliance by the local payer of the FX Regulatory Framework; (iii) the applicable payment obligation must be reported to the BCRA through the “Foreign assets and liability informative regime” (Relevamiento de Activos y Pasivos Externos) set forth pursuant to Communication “A” 6401; (iv) the payment must be made after maturity of the commercial payment term (i.e., the invoice maturity date); and (v) compliance with all other general applicable requirements and with the affidavits set forth in the BCRA’s regulations.
If the above-mentioned conditions are complied with, Argentine financial entities may grant Argentine residents with access to the FX Market for the outflow of funds (i.e., the purchase of foreign currency), in order to make deferred payments for the import of goods according to the schedule established by the BCRA at the time of payment. Such terms must be counted as of the date of customs entry registration. Payments for imports of goods without customs entry registration or before the applicable terms are permitted if the operation falls within a number of exceptional cases stipulated in the regulations.
Offshore Services. Financial entities may grant their clients access to the FX Market for the payment of offshore services provided or accrued as of December 13, 2023, to the extent that certain requirements are met. In summary, such requirements consist of the following: (i) the transaction must be reported, if applicable, in the last presentation of the “Foreign assets and liability informative regime" established under Communication “A” 6401; (ii) the payment must be made after maturity of the commercial term; and (iii) all other applicable general requirements and affidavits described above must be complied with.
If the above-mentioned conditions are complied with, Argentine financial entities may grant Argentine residents with access to the FX Market in order to make the payments of such services according to a time schedule. The terms applicable for the payment of services abroad will depend on the concept code assigned to the service provided. Such terms must be calculated from the date of service provision or accrual. Any payments made before the above-mentioned terms are permitted if the operation falls within a number of exceptional cases stipulated in the regulations.
Commercial Debt Stock prior to December 13, 2023. The access to the FX Market for the payment of imports of goods with customs entry registration or services rendered by non-residents prior to December 13, 2023 is subject to the prior approval of the BCRA, with very few exceptions. In practical terms, the BCRA does not grant concrete possibilities to transfer funds from Argentina for these purposes. The main alternative to make such payments is with the funds obtained from both capital and interest accumulated through the subscription of public bonds referred to as "Bonos para la Reconstrucción de una Argentina Libre" (BOPREAL).
Dividends and Earnings. No authorization from the BCRA is required to carry out foreign exchange transactions to pay dividends and earnings to “non-residents” arising from financial statements, provided that the following requirements are met: (i) the dividends and earnings arise from closed and audited financial statements, (ii) the payment is made in accordance with the relevant corporate documents, (iii) the total amount of transfers for this reason made as of
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January 17, 2020 and onward, does not exceed 30% of the value of new contributions of foreign direct investment in Argentine companies, entered and settled through the MLC as of the mentioned date, (iv) access to the FX Market for the payment of dividends cannot occur sooner than 30 calendar days following the settlement of the last contribution (v) the payer submits sufficient documentation that evidences the final capitalization of the contributions, and (vi) the payment obligation is reported to the BCRA through the “Foreign assets and liability informative regime”. There are other alternatives for the payment of dividends and earnings with are established under the FX Regulatory Framework.
In addition, legal entities are allowed to access the FX Market for the payment of dividends and earnings to non-resident shareholders corresponding to profits derived from realized gains reflected in regular, annual, audited financial statements for financial years beginning on or after January 1, 2025, provided that the payment is made in accordance with the relevant corporate documents (e.g., the shareholders resolution approving the distribution) and the payment obligation was reported to the BCRA through the “Foreign assets and liability informative regime”, among others.
Offshore Financial Indebtedness. Regarding offshore financial indebtedness, financial entities may only grant access to the FX Market when, in summary: (i) the funds disbursed as of September 1, 2019 entered Argentina through the FX Market, were converted into Argentine Pesos, and deposited into local bank accounts; (ii) the transaction is reported to the BCRA through the “Foreign assets and liability informative regime” established under Communication “A” 6401, (iii) the payment is not made to an affiliated offshore company (subject to certain exceptions); (iv) the payment is performed at maturity (i.e. no more than 3 days in advance of the scheduled due date, subject to certain exceptions); and (v) all other applicable general requirements and affidavits are complied with.
Regarding offshore financial indebtedness where the offshore creditor is a related or affiliated entity, prior approval from the BCRA is required to pay any capital and interest on such offshore financial indebtedness. This requirement (i.e. BCRA’s prior approval) is not applicable (and the financing can be repaid on the maturity date, assuming no further relevant regulatory changes) provided the other applicable requirements are met, in the following cases (among others): (i) the indebtedness has an average life of no less than six (6) months, and the funds have been entered into Argentina and settled through the FX Market as from April 21, 2025; (ii) the indebtedness has an average life of no less than two (2) years, and the funds have been entered into Argentina and settled through the FX Market as between October 2, 2020 and April 20, 2025; (iii) access is related to compensatory interests and payment is made simultaneously with the settlement for an amount no less than the amount paid from: (a) new financial indebtedness with an average maturity of no less than two years and providing for at least one year's grace period for the payment of principal; or (b) new direct investment contributions from non-residents.
Collateral trusts. Collateral trusts established by Argentine resident entities with the purpose of guaranteeing principal and interest payments for their obligations have access to the FX Market in order to make such payments, as long as it is verified that the debtor would have also had access to make such payments on its own behalf because of its compliance with the applicable regulations, and that the payment abroad by the collateral trust is the only available option set forth in the transaction documents. Collateral trusts are able to access to the FX Market to either transfer or purchase foreign currency to comply with guarantee deposits of this type of indebtedness, as long as certain requirements are met. However, this possibility is provided up to the equivalent payable amount in the relevant contract or the “value to be paid at the next maturity date of services”.
Investment Instruments. The BCRA‘s prior authorization is required to access the FX Market for the making of foreign investments, including the purchase of foreign currency for portfolio investments (“atesoramiento”) and the purchase of securities, (i) by legal entities, and non-Argentine residents (with certain exceptions -such as multilateral agencies, embassies, etc.-), for any amount; (ii) by individual residents, when the monthly sum of US$200 is exceeded, subject to compliance with certain requirements and affidavit filings; and (iii) for non- resident individual persons (for example, tourists), when the monthly sum of US$100 is exceeded, subject to compliance with certain requirements.
Foreign Currency–Settled Securities Transactions (Individuals). Individuals who have accessed the FX Market for purchase of foreign currency or cross-border payments are generally restricted, from the time of such access and for the following 90 consecutive calendar days, from entering into purchases of securities with settlement in foreign currency, whether directly, indirectly, or on behalf of or for the account of third parties. This restriction does not apply to: (i) purchases made in connection with primary subscriptions of debt securities issued by Argentine residents, provided that such securities are held in the purchaser’s portfolio for a minimum period of 15 business days (except in cases where such holding period does not apply under the applicable regulations); or (ii) purchases resulting from the reinvestment of collections in foreign currency corresponding to principal and/or interest payments on securities issued by the National
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Treasury or by the BCRA, provided that such reinvestment is carried out within 15 business days following the date of collection. This restriction is not applicable to legal entities.
Notwithstanding the above-described rules, the FX Regulatory Framework sets forth additional provisions that are applicable on a case-by-case basis. This is only a brief summary of applicable regulations.
iii) BCRA Reporting Regime
The BCRA’s reporting regime was established under Communication “A” 6401 and sets forth reporting requirements with respect to debt securities and external liabilities for the financial and private non-financial sector and direct investments of companies in such sector under the “Foreign assets and liability informative regime”.
The completion and validation of the information corresponding to the foregoing must be done electronically through the ARCA website. Such information, must be reported as follows: (i) at the end of any calendar quarter, by all individuals and legal entities who have outstanding offshore financial indebtedness (or if cancelled during that period, when filing the Foreign assets and liability informative regime); and (ii) in an annual presentation, by those individuals or legal entities for whom the balance of external assets and liabilities at the end of each year reaches or exceeds the equivalent of US$50 million.
iv) Foreign Exchange Criminal Regime
Exchange operations can only be carried out through the entities authorized for such purposes by the BCRA. As such, any exchange operation that does not comply with the provisions of the applicable regulations will be subject to Law No. 19,359, as regulated by Decree 480/95, and BCRA regulations (“Foreign Exchange Criminal Regime”), pursuant to which the following constitute offenses: (i) any foreign exchange transaction not performed before an authorized institution; (ii) the completion of foreign exchange transactions without the applicable authorization; (iii) any misrepresentation related to foreign exchange transactions; (iv) the failure to make accurate representations or to complete the necessary procedures in cases where the actual transactions are different than those declared; (v) any foreign exchange transaction executed without fulfilling the conditions established by applicable regulations, regarding quantity, foreign currency exchange rate, dates, etc.; and (vi) any other omission or act performed in violation of the Foreign Exchange Criminal Regime.
Violations to the Foreign Exchange Criminal Regime may be subject to fines of up to ten times the amount of the operation in breach and imprisonment in certain instances.
B.6 Argentine Banking Regulation
The following is a summary of certain matters relating to the Argentine banking system, including provisions of Argentine law and regulations applicable to financial entities in Argentina. This summary is not intended to constitute a complete analysis of all laws and regulations applicable to financial entities in Argentina.
i) General
Since 1977, banking activities in Argentina have been regulated by the Argentine Financial Institutions Law No. 21,526 (the “FIL”), which places the supervision and control of the Argentine banking system in the hands of the autonomous BCRA, the principal monetary and financial authority in Argentina that operates independently from the Argentine government. The BCRA enforces the FIL and grants authorization to banks to operate in Argentina. The FIL confers numerous powers to the BCRA, including the ability to grant and revoke bank licenses, authorize the establishment of branches of Argentine banks outside of Argentina, approve bank mergers, capital increases and certain transfers of stock, set minimum capital, liquidity and solvency requirements and lending limits, grant certain credit facilities to financial entities in cases of temporary liquidity problems and to promulgate other regulations and to enforce the FIL. The BCRA has vested the Superintendency with most of the BCRA’s supervisory powers. Such entity is responsible for enforcing Argentina’s banking laws, establishing accounting and financial reporting requirements for the banking sector, monitoring and regulating the lending practices of financial entities and establishing rules for participation of financial entities in the FX Market and the issuance of bonds and other securities, among other functions. In this section, unless otherwise stated, references to the BCRA should be understood to be references to the BCRA acting through the Superintendency. FIL grants the BCRA broad access to the accounting systems, books, correspondence, and other documents belonging to
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banking institutions. The BCRA regulates the supply of credit and monitors the liquidity, and generally supervises the operation, of the Argentine banking system.
Current regulations equally regulate Argentine and foreign-owned banks.
ii) Supervision
As the regulator of the Argentine financial system, the BCRA requires financial entities to submit information on a daily, monthly, quarterly, semiannual, and annual basis. These reports, which include balance sheets and income statements, information relating to reserve funds, use of deposits, portfolio quality (including details on debtors and any established loan loss provisions) and other pertinent information, allow the BCRA to monitor financial entities financial condition and business practices.
The BCRA periodically carries out formal inspections of all banking institutions in order to monitor compliance by banks with legal and regulatory requirements and confirm the accuracy of the information provided to the BCRA. If BCRA rules are breached, it may impose various sanctions depending on the magnitude of the infringement. These sanctions range from warning calls up to the imposition of fines, or even the revocation of the financial institution’s operating license. Moreover, non-compliance with certain rules may result in the obligatory presentation to the BCRA of specific adequacy or regularization plans. The BCRA must approve these plans in order for the financial institution to remain operational.
Financial institutions operating in Argentina have been subject to the supervision of the BCRA on a consolidated basis since 1994. Information regarding “Limitations on Types of Business”, “Capital Adequacy Requirements”, “Lending Limits”, and “Loan Classification System and Loan Loss Provisions” related to a bank’s loan portfolio is calculated on a consolidated basis. However, regulations relating to a bank’s deposits are not based on consolidated information, but on such bank’s deposits in Argentina (for example, liquidity requirements and contributions to the deposit insurance system).
Examination by the BCRA
The BCRA began to rate financial institutions based on the “CAMEL” quality rating system in 1994. Each letter of the CAMEL system corresponds to an area of the operations of each bank being rated, with: “C” standing for capital, “A” for assets, “M” for management, “E” for earnings, and “L” for liquidity. Each factor is evaluated and rated on a scale from one to five, with one being the highest rating an entity can receive. The BCRA modified the supervision system in September of 2000. The objectives and basic methodology of the new system, referred to as “CAMELBIG,” do not differ substantially from the CAMEL system. The components were redefined in order to evaluate business risks separately from management risks. The components used to rate the business risks are capital, assets, market, earnings, liquidity, and business. The components to rate management risks are internal control and the quality of management. By combining the individual factors under evaluation, a combined index can be populated that represents the final rating for the financial institution.
In the case of Banco Galicia, the last audit finished in August 2025.
Regulatory Capital (Minimum Capital Requirements)
Financial entities are subject to the capital adequacy rules of the BCRA, consequently Banco Galicia, as a commercial bank, must maintain a minimum capital amount measured as of each month’s closing. BCRA regulations establish that financial institutions legal capital should be equal to the greater value resulting from the comparison between the applicable basic requirement (corresponding to the type of entity) and the sum of those determined by credit and market risk, as well as operational risk.
The minimum basic capital requirement for a commercial bank, such as Banco Galicia, is a capital reserve of at least Ps.5,000 million. The minimum capital requirements related to credit risk, which are calculated according to a formula established by the BCRA, are designed to establish the minimum capital necessary to offset the risk that the counterparty does not comply with its obligation in a transaction related to the assets that are being reviewed. The minimum capital requirements related to market risks are designed to offset the eventual losses generated by a change of market rates or of credit quality, which would affect the assets and liabilities of the bank. Such market risk includes (among other risks) liquidity risk and interest rate risk. Operational risk includes the possibility of incurring a failure or deficiency
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in losses as a result of external events or as a result of a failure or deficiency in internal processes, human error, or internal systems.
In order to verify compliance with the minimum capital requirements, the BCRA considers the computable regulatory capital (“RPC”) of a particular entity (i.e., capital that the entities actually have). Pursuant to the BCRA’s regulations, a bank’s RPC is the sum of the minimum core capital (Tier I capital) and supplementary capital (Tier II capital), minus certain deductible concepts. The BCRA considered Basel III requirements in order to regulate the RPC (and listed the assets included in each Tier as well as the deductible concepts in accordance with such rules).
According to the BCRA’s regulations, any financial entity operating with an RPC under the minimum capital requirements must: (i) pay-in the corresponding amount within the following two months from the month in which it fails to comply with the requirement, or (ii) submit to the Superintendency a regularization and reorganization plan within the following 30 calendar days counted as from the last day of the month in which it fails to comply with the requirement. The Superintendency may appoint a supervisor and impose restrictions on distribution of dividends, among other actions, when non-compliance with the RPC requirements occurs or any warning from the Superintendency is received.
In addition, any financial entity operating under the daily integration of the minimum capital requirement related to market risk (when such failure is caused by the requirements established to guard against interest rate risk, foreign exchange risk or equity price risk), must pay-in the corresponding amount necessary to comply with the requirements and/or reduce its asset position until the applicable requirement is complied with, within a term of ten business days counted from the first failure to comply with the requirements. In case the non-compliance situation remains after such term has elapsed, the entity must submit to the Superintendency a regularization and reorganization plan within the following five days.
iii) Legal Reserve
The BCRA and FIL rules requires that every year banks allocate to a legal reserve a percentage of their net profits established by the BCRA, which currently amounts to 20% of their yearly income. Such reserve may only be used during periods in which such financial institution has incurred losses and has exhausted all other reserves. Distribution of dividends will not be allowed if the legal reserve is not met.
iv) Profit Distribution
Profit distribution of financial institutions (the concept pursuant to which a payment of dividends is included) must be authorized by the Superintendency. Financial institutions may distribute profits without exceeding the limits set forth in the “Distribution of Profits” rules established by the BCRA. The amount to be distributed must not compromise the entity’s liquidity and solvency. The Superintendency is entitled to intervene to verify the correct application of the procedures and regulations with respect to dividends approved and to be distributed by financial institutions. Nevertheless, as explained above, dividends to be paid in a foreign currency to international investors, may be subject to foreign exchange restrictions.
The BCRA sets rules for the conditions under which financial institutions can make distributions of profits. BCRA regulations require that 20% of a company’s profits, subject to certain adjustments, be allocated to legal reserves. This requirement applies regardless of the company’s ratio of legal reserves to capital stock.
In addition to the foregoing, BCRA regulations regarding profit distributions provide that profits can be distributed so long as a company’s results of operations are positive after deducting required legal reserves, the difference between the carrying amount and the fair market value of public sector assets and/or debt instruments issued by the BCRA not valued at fair market price, and the amounts capitalized for legal proceedings related to deposits and any unrecorded adjustments required by external auditors or the BCRA. Furthermore, companies must also comply with capital adequacy rules, which set forth minimum capital requirements and required regulatory capital.
All Argentine financial institutions are also required to maintain capital in an additional capital reserve equal to 2.5% of risk-weighted assets and 3.5% for financial institutions classified as systemically important, which must be comprised of only Tier I Common Capital, net of deductible items. Profit distributions of financial institutions will not be authorized if failing to meet with the required computable regulatory capital set forth above. In certain cases, that margin may be modified by the BCRA, as established in the “Distribution of Profits” rules.
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Profits, if any, resulting from the first-time application of IFRS may not be distributed. Any such profits will be allocated to a special reserve recorded under equity, which may only be released for capitalization purposes, or to otherwise offset potential losses.
In addition, 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.
While BCRA authorization is still required for dividend distribution, approved distributions no longer need to be made in installments but must comply with the conditions set forth in the “Distribution of Profits” rules established by the BCRA, as duly referenced in the preceding paragraphs.
v) Legal Reserve Requirements for Liquidity Purposes
The deposit amount minus the minimum cash requirement determines the “lending capacity” of a particular deposit.
The BCRA can modify the applicable minimum cash requirement from time to time based on monetary policy considerations.
The then-applicable minimum cash requirement is determined on the basis of the average daily balances of the obligations: (i) recorded at the end of each day, during the period prior to their integration for Argentine Pesos; and (ii) at the end of each day during each calendar month, for foreign currency and securities.
The averages will be obtained by dividing the sum of the daily balances by the total amount of days of each month. For days in which no movement is recorded, the balance will be that of the immediately preceding day. Compliance with minimum cash requirements must be made in the same debt currency and/or instrument that corresponds to the requirement (with certain exceptions), and might be completed through, among others, (i) checking accounts, denominated in Pesos, opened by financial entities in the BCRA; (ii) “Minimum Cash Accounts”, denominated in Dollars or other foreign currencies, opened by financial entities in the BCRA; (iii) special guarantee accounts in favor of clearing houses and for coverage of credit cards, vouchers and ATM operations and for transfer settlement of immediate funds; (iv) non-bank financial entities checking accounts opened in commercial banks for the requirement of minimum cash integration; (v) special accounts opened in the BCRA linked for the provision of social security benefits administered by National Social Security Administration (“Administración Nacional de la Seguridad Social” or ANSES) and (vi) “sub-accounts 60” which are accounts that contain a minimum amount of cash received from investments in public securities and debt instruments issued by the BCRA, at market value.
According to the “Minimum Cash” rule of the BCRA (as modified and complemented), the percentages of minimum cash requirements for financial institutions that belong to Group "A", are as follows:
•Demand deposits:
◦Peso-denominated checking accounts and savings accounts: 45%.
◦Savings accounts denominated in foreign currency: 25%.
•Fixed term deposits:
◦Peso-denominated: (i) up to 29 days, 28.5%; (ii) 30 to 59 days, 17.5%; (iii) 60 to 89 days, 7.5%; (iv) 90 days or more, 3.5%.
◦Foreign currency-denominated: (i) up to 29 days, 23%; (ii) 30 to 59 days, 17%; (iii) 60 to 89 days, 11%; (iv) 90 to 179 days, 5%; (v) 180 to 365 days, 2% and (vi) more than 365 days, 0%.
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•Fixed term deposits adjusted by UVA/UVI (by remaining maturity):
◦(i) up to 29 days, 10.5%; (ii) from 30 to 59 days, 8.5%; (iii) from 60 to 89 days, 6.5%; (iv) 90 days or more, 3.5%.
As of December 31, 2025, Banco Galicia was in compliance with its legal reserve requirements and continued to be in compliance as of the date of this annual report.
vi) Limitations on Types of Business
In accordance with the provisions of the FIL, commercial banks are authorized to carry out all activities and operations which are not strictly prohibited by law or by the BCRA regulations. Permitted activities include the capacity to grant and receive loans; receive deposits from the general public in local and foreign currency; secure its customers’ debts; acquire, place and trade with shares and debt securities in the Argentine over-the-counter market (subject to prior approval of the CNV, if applicable); carry out operations in foreign currencies; act as trustee in financial trusts; and issue credit cards.
Pursuant to the BCRA’s regulations, financial institutions are not allowed to hold more than a 12.5% interest (or more than a specific percentage of the financial institution’s adjusted shareholders’ equity) in the outstanding capital of a company which does not provide services complementary to those offered by financial institutions, as established in the “Complementary services of financial activities” rules. The BCRA determines which services are complementary to those provided by financial institutions. To this date, among others, it has been determined that such services mainly include those offered in connection with stock brokerage, the issuance of credit, debit or similar cards, financial intermediation in leasing and factoring transactions. Since May 5, 2022, financial institutions may not carry out or facilitate transactions with digital assets –including crypto assets and those whose yields are determined based on the variations that they register– which are not authorized by a national regulatory authority or by the BCRA.
Non-banking financial institutions are not allowed to provide certain services and activities, such as opening checking accounts, among other activities.
vii) Capitalization of Debt Instruments
Communication “A” 6304 (as amended) of the BCRA provides that all regulations related to capital increases must be cash contributions. However, the regulation establishes that subject to the prior authorization of the Superintendency, the following instruments are allowed as capital contributions: (i) securities issued by the Argentine government, (ii) debt instruments issued by the BCRA, and (iii) a financial institution’s deposits and other liabilities resulting from its financial brokerage activities, including subordinated obligations. With respect to instruments (i) and (ii), the contributions must be recorded at their market value. It is understood that an instrument has a market value when it is regularly listed on regulated local or foreign stock markets and traded on such markets in such amounts that the liquidation of such instruments does not significantly affect the listing price of such instruments. With respect to clause (iii) above, contributions must be recorded at their market value, as defined in the previous sentence or, in the case of financial institutions that publicly offer their stock, at the price determined by the applicable regulatory authority. If the aforementioned conditions are not met, the instruments in question will not be contributable as capital.
Deposits and other liabilities resulting from a given financial institution’s financial brokerage activities, including subordinated obligations that are not permitted to be traded in local or foreign regulated secondary markets, will be allowed to be contributed as capital at their accounting value, pursuant to BCRA rules.
viii) Lending Limits
According to the “large exposures to credit risk” and “minimum capital for financial institutions” rules, the total amount of all credit risk exposure values of a financial entity to a single counterparty or, where appropriate, a group of related counterparties, may not exceed at any time the limits established for level capital one (Tier 1) by the BCRA.
In accordance with the BCRA’s regulations, the exposure limit to a counterpart or connected counterpart group of the non-financial private sector will be 15% of the Bank’s level one capital. However, this limit may be increased by 10% for exposures that are secured with preferred guarantees.
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The total amount of financial assistance a bank is authorized to provide to a borrower and its affiliates is also limited based on the borrower’s shareholders’ equity. The total amount of financial assistance granted to a borrower and its affiliates shall not be higher than, in the aggregate, 100% of such borrower’s shareholders’ equity, although such limit may be increased an additional 200% of the borrower’s shareholders’ equity if the sum does not exceed 2.5% of the bank’s adjusted shareholders’ equity.
Global exposure to the public sector (national, provincial and municipal public sector) shall not be higher than 75% of an institution’s adjusted shareholders’ equity. Additionally, Section 12 of Communication “A” 3911, as amended, establishes that the average monthly financial assistance to non-financial public sector, in the aggregate, shall not be higher than 35% of the bank’s total assets as of the end of the previous month.
The BCRA also regulates the level of “total financial exposure” a bank has to related parties. A party may be a “related party” by: a) control, when an individual or a legal person directly or indirectly exercises control over the bank or is controlled directly or indirectly by the bank; or b) personal relationship, regarding individuals (including their families and any other entity which they control) who serve as directors, trustees, general managers, or managers with credit attributions.
Financial institutions may not grant, directly or indirectly, new financial assistance to related counterparties in the following cases: (i) if the counterparties have at least one classification other than "in normal status," according to the most recent information available in the “Central de Deudores del Sistema Financiero”; and (ii) if the institution has outstanding debt due to financial assistance from the BCRA.
The BCRA limits the level of total financial exposure that a bank can have outstanding to related parties, depending on the rating granted to each bank by the Superintendency. Banks rated 4 or 5 are prohibited from extending financial assistance to related parties. For banks ranked between 1 and 3, the financial assistance offered to related parties based on a relationship of control and without a guarantee, may not exceed 5% of the bank’s level one capital. The bank may increase this limit to 10% if the financial assistance is secured.
Financial assistance to related parties based on a “personal relationship” has a 5% limit of Level 1 capital of the entity providing the financing (the limit is unique for all cases and includes operations with and without guarantees).
However, a bank may grant additional financial assistance to such related parties up to the following limits:
a)Individual maximum limits for customers over which a bank has control:
•Domestic financial entities:
ü Financial institutions rated 1, 2 or 3, and its controller or the borrower:
•If the receiving affiliate is a financial institution rated 1, subject to consolidation with the lender, the amount of total financial exposure can reach 100% of a bank’s TIER 1, and 50% for additional financial assistance
•If the receiving affiliate is a financial institution rated 2, subject to consolidation with the lender, the amount of total financial exposure can reach 20% and an additional 105% can be included
•If the receiving affiliate is a financial institution rated 3, the amount of total financial exposure can reach 10%, and additional financial assistance can reach 40%
ü Financial institutions that do not meet the above conditions with the lender or the borrower: 10%
•If the receiving affiliate is a financial institution that does not fulfill any of the above-mentioned categories, the amount of total financial exposure can reach 10%.
•Domestic companies with complementary services:
ü Domestic companies with complementary services associated with brokerage activities, financial brokerage in leasing and factoring operations, and temporary acquisition of shares in companies to facilitate their development in order to sell such shares afterwards
•Controlling company rated 1: General assistance 100%
•Controlling company rated 2: General assistance 10% / Additional assistance 90%
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ü Domestic companies with complementary services related to the issuance of credit cards, debit cards or other cards:
•Controlling company rated 1: General assistance 100% / Additional assistance 50%
•Controlling company rated 2: General assistance 20% / Additional assistance 105%
•Controlling company rated 3: General assistance 10% / Additional assistance 40%
ü Domestic companies with complementary services, not subject to consolidation with the lender or the borrower: 10%
•Foreign financial entities:
ü Investment grade 10%
ü No Investment grade: Unsecured 5%; with and without warrants 10%
•Other counterparties related by control
ü Unsecured 5%; with and without warrants 10%
b)Individual maximum limits for customers over which there is a personal relationship
•Lender is ranked from 1 to 3: 5% of its TIER 1
In addition, the aggregate amount of a bank’s total financial exposure to its related parties, except for the ones subject to individual maximum limits higher than 10% (complementary services companies), may not exceed 20% of such bank’s TIER 1.
Notwithstanding the limitations described above, the sum of computable exposure is also limited in order to prevent risk concentration. To that end, the total exposure independently of whether customers qualify as such bank’s related parties or not, in the case in which such exposure exceeds 10% of such bank’s TIER 1, may not exceed three times the bank’s TIER 1, excluding total financial exposure to domestic financial institutions, or five times the bank’s TIER 1, including such exposure.
For a second-grade financial institution (i.e., a financial institution that provides financial products to other banks and not to retail customers), the latter limit is ten times such financial institution’s TIER 1.
Banco Galicia has historically complied with such rules.
ix) Loan Classification System
General
Banco Galicia applies the expected loss methodology in accordance with IFRS standards. It no longer uses the previous regulatory approach based on minimum provisions according to loan classification. This former methodology was used only to determine an item that affects the RPC.
Loan classification criteria differ based on portfolio type—consumer or commercial—but are applied
independently of the loan’s currency.
•Consumer portfolio classification is based on the client’s compliance with obligations to the banks, with other financial institutions and credit card issuers, and the client’s legal status.
•For the purposes of the BCRA regulations, consumer loans include mortgage loans, pledge loans, credit card loans, and other installment-based loans granted to individuals. All other loans are treated as commercial loans.
Banco Galicia, in accordance with an option provided in BCRA regulations, prospectively applies the consumer portfolio classification criteria to commercial loans up to Ps.2,742,160,000. This classification is based on payment performance and borrower condition.
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The main classification criterion for loans in the commercial portfolio is the borrower’s ability to pay, primarily in terms of projected future cash flows. If a borrower has both commercial and consumer loans, all loans are considered jointly for classification purposes. Loans backed by preferred guarantees are considered at 50% of their face value.
When applying the BCRA’s commercial loan classification criteria, banks must evaluate several factors, including:
•The borrower’s current and projected financial condition,
•Exposure to currency risk,
•Managerial and operational background,
•Ability to provide accurate and timely financial information,
•Sector-wide risk and the borrower’s position within that sector.
BCRA regulations also require an independent team to conduct periodic reviews of the commercial loan portfolio. At Banco Galicia, these reviews are conducted by the Credit Division, which is independent from the business units that originate credit.
•The Retail Credit Risk Management Department is responsible for implementing guidelines defined by the Board of Directors. It participates in product development or modifications, aligns practices with local regulations, and approves credit lines for the retail portfolio. It also develops, monitors, and validates statistical models for strategic management credit risk management.
•The Wholesale Credit Risk Management Department performs similar functions for the wholesale portfolio, also aligned with the Board of Directors direction and local regulatory standards.
For borrowers with debt balances exceeding Ps.2,742,160,000, a portfolio review must be conducted. The frequency of such reviews depends on the bank's exposure.
•Quarterly reviews for exposures equal to or exceeding 5% of the bank's total interest-bearing portfolio.
•Semiannual reviews for exposures between Ps.2,742,160,000 and less than 5% of the total portfolio, and less than 1% individually.
In all cases:
•At least 50% of Banco Galicia’s commercial portfolio must be reviewed once every six months; and
•The remaining borrowers must be reviewed during the fiscal year, ensuring a full review of the commercial portfolio annually.
Additionally, discrepancies in credit classifications across banks are regulated. A bank may differ by no more than one classification level from the lowest rating assigned by at least two other banks whose combined exposure accounts for 40% or more of the total credit to the borrower. If Banco Galicia’s or Galicia Mas´s classification differs by more than one level, the bank must immediately adjust its classification to match—or be within one level of—the lowest classification assigned.
Loan Classification
The following tables contain the five loan classification categories corresponding to the different risk levels set forth by the BCRA. Banco Galicia’s total exposure to a private sector customer must be classified according to the riskier classification corresponding to any part of such exposure.
Commercial Portfolio
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Loan Classification Description
A. Normal Situation The debtor is widely able to meet its financial obligations, demonstrating significant cash flows, a liquid financial situation, an adequate financial structure, a timely payment record, competent management, available information in a timely, accurate manner and satisfactory internal controls.The debtor belongs to a sector of economic activity that records an acceptable future trend with good prospects and the debtor is competitive within such economic activity.
B. With Special Follow-up Cash flow analysis reflects that the debt may be repaid even though it is possible that the customer’s future payment ability may deteriorate without a proper follow-up.This category is divided into two subcategories:B1. Under Observation;B2. Under Negotiation or Refinancing Agreements.
C. With Problems Cash flow analysis evidences problems to repay the debt, and therefore, if these problems are not solved, there may be some losses. It also includes customers that maintain payment agreements resulting from judicial or extrajudicial agreements approved by the relevant insolvency court.
D. High Risk of Insolvency Cash flow analysis evidences that repayment of the full debt is highly unlikely. It also includes customers who have been sued by the creditor financial institution for the payment of amounts due or that have requested the preventive tender or concluded, and extrajudicial preventive agreement not yet approved by the relevant insolvency court.
E. Uncollectible The amounts in this category are deemed total losses. Even though these assets may be recovered under certain future circumstances, inability to make payments is evident at the date of the analysis. It includes loans to insolvent or bankrupt borrowers.Additionally, this category includes loans to borrowers indicated by the BCRA to be in non-accrual status with financial institutions that have been liquidated or are being liquidated, or whose authorization to operate has been revoked. It also includes customers with arrears of more than one year.
Consumer Portfolio
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Loan Classification Description
A. Normal Situation Loans with timely repayment or arrears not exceeding 31 days, both of principal and interest.A customer classified in “Normal” situation that has been refinanced more than twice in the last twelve months in this category, must be re-classified to “Low-Risk”.
B. Low Risk Occasional late payments, with a payment in arrears of more than 32 days and up to 90 days. A customer classified as “Low Risk” having been refinanced may be recategorized to “Normal”, as long as they amortize one principal installment (whether monthly or bimonthly) or repays 5% of principal.
C. Medium Risk Some inability to make payments, with arrears of more than 91 days and up to 180 days. A customer classified as “Medium Risk” having been refinanced may be recategorized to “Low Risk” within this category, as long as they amortize two principal installments (whether monthly or bimonthly) or repays 5% of principal.
D. High Risk Judicial proceedings demanding payment have been initiated or arrears of more than 180 days and up to one year. A customer classified as “High Risk” having been refinanced may be recategorized to “Medium Risk” within this category, as long as they amortize three principal installments (whether monthly or bimonthly) or repays 10% of principal.
E. Uncollectible Loans to insolvent or bankrupt borrowers, or subject to judicial proceedings, with little or no possibility of collection, or with arrears in excess of one year. A customer classified as “Uncollectible” having been refinanced in this category, may be recategorized to “High Risk”, as long as they amortize three principal installments (whether monthly or bimonthly) or repays 15% of the principal.Additionally, this category includes loans to borrowers indicated by the BCRA to be in non-accrual status with financial institutions that have been liquidated or are being liquidated, or whose authorization to operate has been revoked.
x) Limitation on Fees and Other Substantial Elements
The BCRA has issued regulations that limit the fees financial entities and credit card issuers (as well as other similar entities) may charge for their services. These regulations require that any such fees be technically and economically justified. Additionally, the regulations mandate the prior disclosure of applicable interest rates to credit card holders.
In addition, such regulations provide that in order to modify fees and other conditions established in agreements executed by and between financial entities and consumers, the following requirements must be met (i) reasons for fee increases must be established in the agreements and must be duly justified; (ii) modifications cannot change the core or fundamental provisions of the agreement; (iii) the consumer must be duly informed of any such changes; and (iv) for the imposition of new fees, the consumer’s consent must be obtained.
xi) Foreign Currency General Position
Pursuant to the FX Regulatory Framework, financial entities may determine their own Foreign Currency General Position, with certain limitations.
xii) Deposit Insurance System
In 1995, Law No.24,485 and Decree No.540/95, as amended, created a mandatory deposit insurance system for bank deposits and delegated to the BCRA the organization and start-up of the deposit insurance system. The deposit insurance system was implemented through the creation of a fund named Fondo de Garantía de los Depósitos (“FGD”), which is administered by Seguros de Depósitos S.A. (“Sedesa”). The shareholders of Sedesa are the Argentine government, through the BCRA, which holds at least one share, and a trust constituted by the financial institutions which participate in the fund. The BCRA establishes the extent of participation by each institution in proportion to the resources contributed by each such institution to the FGD. Banks must contribute to the FGD on a monthly basis in an amount that is currently equal to 0.015% of the monthly average of daily balances of such institution’s deposits (both Peso- and foreign currency-denominated).
In addition, when the contributions to the FGD reach the greater of Ps.2 billion or 5.0% of total deposits, the BCRA may suspend or reduce the monthly contributions and reinstate the same when contributions fall below such required level.
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The deposit insurance system covers all Peso and foreign currency deposits held in demand deposit accounts, savings accounts, and time deposits for an amount up to Ps.25,000,000 per person, account, and deposit. Certain deposits are not covered by the guarantee of the deposit insurance system, such as deposits received at rates higher than the reference rate in accordance with the limits established by the BCRA, deposits acquired by endorsement, and those made by persons related to the financial institution (as defined by BCRA regulations).
The guarantee provided by the deposit insurance system must be made effective within 30 days from the revocation of the license of a financial institution, subject to the outcome of the exercise by depositors of their priority rights described under “—Priority Rights of Depositors” below. The BCRA may modify, at any time, and with general scope, the amount of the mandatory deposit guarantee insurance.
Decree No.1292/96 enhanced Sedesa’s functions by allowing it to provide equity capital or make loans to Argentine financial institutions experiencing difficulties and to institutions that buy such financial institutions or their deposits. As a result of such decree, Sedesa has the flexibility to intervene in the restructuring of a financial institution experiencing difficulties prior to bankruptcy.
Debt securities issued by banks are not covered by the deposit insurance system.
xiii) Priority Rights of Depositors
According to section 49(e) of the FIL, in the event of a judicial liquidation or the bankruptcy of a financial entity, the holders of deposits in Pesos and foreign currency benefit from a general priority right to obtain repayment of their deposits up to the amount set forth below, with priority over all other creditors, with the exception of the following: (i) deposits secured by a mortgage or pledge, (ii) rediscounts and overdrafts provided to financial entities by the BCRA, according to section 17 subsections (b), (c) and (f) of the BCRA Charter, (iii) credits provided by the Banking Liquidity Fund, which was created by Decree No.32, dated December 26, 2001, secured by a mortgage and pledge and (iv) certain labor credits, including accrued interest until the date of their total repayment.
The holders of the following deposits are entitled to the general preferential right established by the FIL (following this order of preference):
•deposits of individuals or entities up to Ps.50,000, or the equivalent thereof in foreign currency, with only one person per deposit being able to use this preference. For the determination of this preference, all deposits of the same person registered by the entity are computed;
•deposits in excess of Ps.50,000, or the equivalent thereof in foreign currency, referred to above;
•liabilities originated on commercial credit lines provided to the financial entity, which are directly related to international trade.
According to the FIL, the preferences set forth in previous paragraphs (i) and (ii) above are not applicable to deposits held by persons who are affiliates of the financial entity, either directly or indirectly as determined by the BCRA.
In addition, pursuant to Section 53 of the FIL, the BCRA has an absolute priority over all other creditors of the entity, except as provided by the FIL.
xiv) Deposit and Loans in Housing Units
In order to facilitate access to mortgage loans, through Communication “A” 5945, dated as of April 8, 2016, and complementary regulations, the BCRA established a new type of loan denominated in Acquisition Value Units (Unidades de Valor Adquisitivo or “UVAs”). The value of such units will be updated using the Reference Stabilization Coefficient.
xv) Financing Loans for Economic Development
The BCRA enacted several communications, by means of which it implemented several policies to promote economic development and productivity in Argentina. Among others, the required minimum cash to be held by financial institutions (as above-explained) is reduced in certain cases, among others, the following:
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(i) by taking into account the share of financing to small and medium companies in Pesos as a percentage of total financing to the non-financial private sector - in the same amount - in the same period, according to certain percentages established by the BCRA.
(ii) The requirement is reduced based on cash withdrawals made through the entity's ATMs, giving greater consideration to withdrawals made at ATMs located in locations with less economic activity.
(iii) in an amount equivalent to 40% of the sum of outstanding financing granted until December 31, 2024 in local currency to small and medium companies (PyME), provided such financing is granted according to the provisions set forth in Sections 4.1 and 5.1.1 of the "Financing Line for the Productive Investment of MSME's" BCRA's rules.
The required minimum cash to be held by financial institutions might also be reduced in other specific cases established by the BCRA (such as in the case of certain financings in pesos granted as of April 1, 2021 until December 31, 2024, to individuals and MSMEs that have not been reported by financial institutions in the BCRA's "Central of debtors of the financial system" (CENDEU) as of different dates).
xvi) Financial Institutions with Economic Difficulties
The FIL establishes that financial institutions, including commercial banks such as Banco Galicia, which do not meet certain minimum cash reserve requirements, have not complied with certain required technical standards, including minimum capital requirements, or whose solvency or liquidity is deemed to be impaired by the BCRA, must submit a restructuring plan to the BCRA. Such restructuring plan must be presented to the BCRA on the date specified by the BCRA, which should not be later than 30 calendar days from the date on which the request is made by the BCRA. In order to facilitate the implementation of a restructuring plan, the BCRA is authorized to provide a temporary exemption from compliance with technical regulations and/or the payment of charges and fines that arise from such non-compliance.
The BCRA may also, in relation to a restructuring plan presented by a financial institution, require such financial institution to provide guarantees or limit the distribution of profits, and appoint a supervisor, to oversee such financial institutions’ management, with the power to veto decisions taken by the financial institution’s corporate authorities.
In addition, the BCRA’s charter authorizes the Superintendency, subject only to the prior approval of the president of the BCRA, to suspend for up to 30 days, in whole or in part, the operations of a financial institution if its liquidity or solvency have been adversely affected. Notice of this decision must be given to the board of directors of the BCRA. If at the end of such suspension period the Superintendency considers renewal necessary, such renewal can only be authorized by the board of directors of the BCRA for an additional period not to exceed 90 days. During the suspension period: (i) there is an automatic stay of claims, enforcement actions and precautionary measures; (ii) any commitment increasing the financial institution’s liabilities is void; and (iii) acceleration of indebtedness and interest accrual is suspended.
If, in the judgment of the BCRA, a financial institution is in a situation which, under the FIL, would authorize the BCRA to revoke the financial institution’s license to operate as such, the BCRA may, prior to considering such revocation, order a variety of measures, including (i) taking steps to reduce, increase or sell the financial institution’s capital; (ii) revoking the approval granted to the shareholders of the financial institution to own an interest therein, giving a term for the transfer of such shares; (iii) excluding and transferring assets and liabilities; (iv) constituting trusts with part or all the financial institution’s assets; (v) granting of temporary exemptions to comply with technical regulations and/or pay charges and fines arising from such defective compliance; or (vi) appointing a bankruptcy trustee and removing statutory authorities.
Furthermore, any actions authorized, commissioned or decided by the BCRA under Section 35 of the FIL involving the transfer of assets and liabilities, or complementing such transfers, or that are necessary to execute the restructuring of a financial institution, as well as those related to the reduction, increase or sale of equity, are not subject to any court authorization and cannot be deemed inefficient in respect of the creditors of the financial institution which was the owner of the excluded assets, even though its insolvency preceded any such actions.
xvii) Dissolution and Liquidation of Financial Institutions
The BCRA must be notified of any decision to dissolve a financial institution pursuant to the FIL. The BCRA, in turn, must then notify a court of competent jurisdiction, which will determine who will liquidate the entity: the corporate authorities (extrajudicial liquidation) or an appointed independent liquidator (judicial liquidation). This determination is based on whether or not sufficient assurances exist regarding the ability of such corporate authorities to carry out the liquidation properly.
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Pursuant to the FIL, the BCRA no longer acts as liquidator of financial institutions. However, when a restructuring plan has failed or is not considered viable, local, and regulatory violations exist, or substantial changes have occurred in the financial institution’s condition since the original authorization was granted, the BCRA may decide to revoke the license of the financial institution to operate as such. In this case, the law allows judicial or extrajudicial liquidation as in the case of voluntary liquidation described in the preceding paragraph.
The bankruptcy of a financial institution cannot be adjudicated until the license is revoked by the BCRA. No creditor, with the exception of the BCRA, may request the bankruptcy of the former financial institution before 60 calendar days have elapsed since the revocation of its license.
B.7 Credit Cards Regulation
The Credit Cards Law establishes the general framework for credit card activities, applicable to both financial institutions offering credit cards and non-financial credit card issuers (empresas no financieras emisores de tarjetas de crédito). Among other regulations. This law was amended by Decree No. 70/2023, dated December 21, 2023, pursuant to which:
a.The credit card system was defined as a set of individual contracts, removing the adjectives “complex and systematized.”
b.The definition of "issuer" was modified, establishing that any entity can be an issuer as long as it is provided for in its corporate purpose.
c.The identification instrument (i.e. credit card) can be physical or virtual.
d.The prohibition of setting fees or differentiated charges between businesses of the same category or concerning similar products or services was removed.
e.The cap on fees charged to businesses for credit and debit card transactions was also removed, as well as the crediting period for the latter.
f.Issuers shall disclose to the public the financing rate applied to the credit card system.
g.The limit that existed for punitive interest was removed, stating that they cannot be capitalized interests.
h.The issuer must prepare and send monthly statements, preferably electronically. The obligation to have a copy of the statement available at the issuing branch of the card was removed.
i.The need to obtain prior approval of the contract from the regulatory authority was removed.
j.Various provisions of the Credit Card Law No 25,065 were eliminated, such as those related to user identification on the credit card; the content and wording of the contract; the perfection of the contractual relationship; the request for card issuance; nullities related to imposing a fixed amount for late payment of the statement and additions not authorized by the regulatory authority; the BCRA’s power to impose sanctions on issuers who do not report rates or violate the level of rates to be applied; the issuer’s obligation to provide businesses with identification materials, the regime on losses and thefts, and card cancellations; the obligation to provide electronic terminals for businesses; the prohibition of reporting to databases and personal backgrounds when obligations have not been canceled, and the obligation on issuers to monthly report their offers to the Federal Secretariat of Commerce, and the consequent power of the BCRA to impose sanctions in case of non-compliance with this obligation.
The BCRA has issued regulations to enforce public disclosure of companies’ pricing (fees and interest rates) to ensure consumer awareness of such pricing. All applicable regulations are included in the rules of “Interest Rate” of the BCRA.
B.8 Concealment and Laundering of Assets of a Criminal Origin
Law No.25,246 (as amended in July 2011 by Law No.26,683) incorporates money laundering as a crime under the Argentine Criminal Code. Additionally, with the goal of preventing money laundering, the UIF was created under the jurisdiction of the Argentine Ministry of Justice, Security and Human Rights. As a result of such modification, money laundering is now classified as a separate offense.
In addition to the above, Law No.26,683 sanctions “self-laundering”, which sanctions money laundering tied to a crime the individual in question committed his or herself. It also includes certain tax offenses described in Article 303 of the Argentine Penal Code as punishable laundering behavior. The new standard falls under Article 303 of the Argentine Penal Code in the chapter titled “Crimes against economic and financial order”.
The minimum and maximum of the criminal scale will be doubled when (i) the foregoing acts were crimes that are particularly serious, meaning those crimes with a punishment that is greater than three years of imprisonment; (ii) the perpetrator committed the crime for profit; and (iii) the perpetrator regularly performs concealment activities.
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The criminal scale can only be increased once, even when more than one of the above-mentioned acts occurs. In such case, the court may take into consideration the multiple acts when determining the original punishment.
The “Committee for the Control and Prevention of Money Laundering and the Financing of Terrorist Activities” was formed in 2005 and is responsible for establishing and maintaining the general guidelines related to the Bank’s strategy to control and prevent money laundering and the financing of terrorism. For more information, see “Item 6. Directors, Senior Management and Employees—Functions of the Board of Directors of Banco Galicia”.
Banco Galicia has also appointed two directors to fulfill the roles of Compliance Officer and Substitute Compliance Officer. In addition, a specialized management unit was created in this area that is responsible for the execution of the policies approved by the committee and for the monitoring of the control systems and procedures to ensure that they are adequate.
Law No.26,734 enacted on December 22, 2011, incorporated terrorism financing and the financing of terrorism as an aggravating circumstance to all criminal conduct in the Argentine Criminal Code. With the enactment of this law, new sections were introduced to the National Criminal Code that sanction any individual who directly or indirectly collects or provides goods or money with the intention of being used, or knowing that they will be used, in whole or in part (i) to finance a crime with the purpose established in Section 41.5; (ii) for an organization who commits or attempts to commit crimes with the purpose established in Section 41.5; and (iii) for a person who commits or attempts to commit or participates in any way in committing crimes with the purpose established in Section 41.5.
The legislation also punishes terrorism as an aggravating factor in other punishable crimes when any such offense was committed in order to terrorize the population.
Banco Galicia has implemented measures to combat the use of the international financial system by criminal organizations. The Bank has policies, procedures and control structures in place to monitor operations based on client profiles and risk assessments based on the information and documentation related to the economic, patrimonial and financial situation of each client to detect clients that could be considered unusual, and eventual reporting to the UIF as appropriate. The Asset Laundering Prevention Management program is charged with the implementation of such control and prevention procedures, as well as communication of such procedures and measures within the Bank, drafting of compliance manuals and employee training. Such management program is also periodically reviewed by senior management.
Banco Galicia has appointed a Director as Compliance Officer, in accordance with Resolution 14/2023 of the UIF, who is responsible for ensuring the observance and implementation of procedures and obligations in the matter. The Compliance Officer contributes to the prevention and mitigation of the risks of criminal transactions and is involved in the establishment of internal policies and measures to monitor and prevent the same.
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C. Organizational Structure
The following table illustrates our organizational structure as of December 31, 2025. Percentages indicate the ownership interests held by each entity.
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D. Property, Plants and Equipment
The following are our main property assets, as of December 31, 2025:
Property Address Square meters (approx) Main uses
Grupo Financiero Galicia
Rented Tte. Gral. Juan D. Perón 430, 25th floor, Buenos Aires, Argentina 568 Administrative activities
Banco Galicia
Owned Tte. Gral. Juan D. Perón 407, Buenos Aires, Argentina 18,223 Administrative activities
Tte. Gral. Juan D. Perón 430, Buenos Aires, Argentina 35,300 Administrative activities
Corrientes 6287, Buenos Aires, Argentina 12,068 Administrative activities
Florida 229, Buenos Aires, Argentina 10,602 Administrative activities
Bouchard 551, Buenos Aires, Argentina 8,802 Administrative activities
Naranja X
Owned Sucre 152, 154 and 541, Córdoba, Argentina 6,300 Administrative activities
La Tablada 451, Humberto Primo 450 y 454, Córdoba, Argentina 14,228 Administrative activities
Jujuy 542, Córdoba, Argentina 507 Administrative activities
Ruta Nacional 36, km. 8, Córdoba, Argentina 7,715 Storage
Río Grande, Tierra del Fuego, Argentina 309 Administrative and commercial activities
San Jerónimo 2348 and 2350, Santa Fe, Argentina 1,475 Administrative and commercial activities
Rented Av. Corrientes 6287, 7th and 8th floor, CABA, Argentina 2,369 Administrative activities
Tte. Gral. Juan D. Perón 430, 19th floor, Buenos Aires, Argentina 94 Administrative activities
Galicia Asset Management
Rented Tte. Gral. Juan D. Perón 430, 22nd floor, Buenos Aires, Argentina 208 Administrative activities
Galicia Warrants
Owned Tte. Gral. Juan D. Perón 456, 6th floor, Buenos Aires, Argentina 118 Administrative activities
Galicia Seguros
Rented Tte. Gral Juan D Perón 430, 7th floor, Buenos Aires, Argentina 804 Administrative activities
Rented Tte. Gral Juan D Perón 430, 5, 6 and 8th floor, Buenos Aires, Argentina 2,414 Administrative activities
Owned San Martin 910, CABA, Buenos Aires 176 Storage
Owned San Ireneo 141, CABA, Buenos Aires 392 Storage
Galicia Securities
Rented Tte. Gral. Juan D. Perón 430, 23rd floor, Buenos Aires, Argentina 115 Administrative activities
Inviu
Rented Corrientes 6295, Torre Leiva, 7th floor, Buenos Aires, Argentina 926 Administrative activities
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Property Address Square meters (approx) Main uses
Rented Local F Building M1, Ruta 8, Km 17500, Montevideo, Uruguay 152 Administrative activities
Nera
Rented Corrientes 6295, Torre Leiva, 1st floor, Buenos Aires, Argentina 647 Administrative activities
As of December 31, 2025, our distribution network consisted of:
•Banco Galicia: 316 branches, located throughout Argentina’s 23 provinces, 182 of which were owned and 134 of which were leased by Banco Galicia.
•Naranja X: 104 branches, located in all the country, 0 of which was owned and 0 of which were leased by Naranja X.
•Sudamericana: 12 branches, located throughout Argentina's 8 provinces, 2 of which were owned and 10 of which were rented.