db-20251231

–

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act.

Yes ☐ No ☒

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports pursuant to

Section 13 or 15(d) of the Securities Exchange Act of 1934.

Yes ☐ No ☒

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities

Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and

(2) has been subject to such filing requirements for the past 90 days.

Yes ☒ No ☐

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted

pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the

registrant was required to submit such files).

Yes ☒ No ☐

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, or an emerging

growth company. See definition of “large accelerated filer”, “accelerated filer”, and emerging growth company in Rule 12b-2 of the

Exchange Act.

Large Accelerated Filer ☒ Accelerated filer ☐

Non-accelerated filer ☐ Emerging growth company ☐

If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by check mark if the

registrant has elected not to use the extended transition period for complying with any new or revised financial accounting standards*

provided pursuant to Section 13(a) of the Exchange Act. ☐

*The term “new or revised financial accounting standard” refers to any update issued by the Financial Accounting Standards Board to

its Accounting Standards Codification after April 5, 2012.

Indicate by check mark whether the registrant has filed a report on and attestation to its management’s assessment of the

effectiveness of its internal control over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the

registered public accounting firm that prepared or issued its audit report. ☒

If securities are registered pursuant to Section 12(b) of the Act, indicate by check mark whether the financial statements of the

registrant included in the filing reflect the correction of an error to previously issued financial statements. ☐

Indicate by check mark whether any of those error corrections are restatements that required a recovery analysis of incentive-based

compensation received by any of the registrant’s executive officers during the relevant recovery period pursuant to §240.10D-1(b). ☐

Indicate by check mark which basis of accounting the registrant has used to prepare the financial statements included in this filing:

U.S. GAAP☐ International Financial Reporting Standards☒ Other ☐

as issued by the International Accounting Standards Board

If “Other” has been checked in response to the previous question, indicate by check mark which financial statement item the registrant

has elected to follow

Item 17 ☐ Item 18 ☐

If this is an annual report, indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange

Act).

Yes ☐ No ☒

(APPLICABLE ONLY TO ISSUERS INVOLVED IN BANKRUPTCY PROCEEDINGS DURING THE PAST FIVE YEARS)

Indicate by check mark whether the registrant has filed all documents and reports required to be filed by Sections 12, 13 or 15(d) of the

Securities Exchange Act of 1934 subsequent to the distribution of securities under a plan confirmed by a court.

Yes ☐ No ☐

Securities registered or to be registered pursuant to Section 12(b) of the Act (as of February 28, 2026)


Title of each class	Trading Symbol(s)	Name of each exchange on which registered
Ordinary shares, no par value	DB	The New York Stock Exchange
DB Gold Double Long Exchange Traded Notes due February 15, 2038	DGP	NYSE Arca, Inc.
DB Gold Double Short Exchange Traded Notes due February 15, 2038	DZZ	NYSE Arca, Inc.
DB Gold Short Exchange Traded Notes due February 15, 2038	DGZ	NYSE Arca, Inc.

–


Deutsche Bank
Annual Report 2025 on Form 20-F

Table of Contents


Table of Contents			3
PART I			8
Item 1: Identity of Directors, Senior Management and Advisers			8
Item 2: Offer Statistics and Expected Timetable			8
Item 3: Key Information			8
Dividends			8
Capitalization and Indebtedness			9
Reasons for the Offer and Use of Proceeds			9
Risk Factors			10
Item 4: Information on the company			40
History and development of the company			40
Business Overview			40
The competitive environment			49
Regulation and Supervision			57
Organizational Structure			77
Property and Equipment			77
Information required by subpart 1400 of SEC Regulation S-K			77
Item 4A: Unresolved Staff Comments			78
Item 5: Operating and Financial Review and Prospects			78
Overview			78
Material accounting policies and critical accounting estimates			78
Recently adopted accounting pronouncements and new accounting pronouncements			78
Operating results			79
Results of operations			79
Financial position			79
Liquidity and capital resources			80
Post-employment benefit plans			80
Off-balance sheet arrangements			80
Tabular disclosure of contractual obligations			80
Research and development, patents and licenses			80
Item 6: Directors, Senior Management and Employees			81
Directors and Senior Management			81
Board practices of the Management Board			84
Compensation			85
Employees			85
Share Ownership			85
Item 7: Major Shareholders and Related Party Transactions			86
Major Shareholders			86
Related Party Transactions			88
Interests of Experts and Counsel			88
Item 8: Financial Information			89
Consolidated statements and other financial information			89
Significant changes			90
Item 9: The Offer and Listing			91
Offer and Listing Details and Markets			91
Plan of Distribution			91
Selling Shareholders			91
Dilution			91
Expenses of the Issue			91
Item 10: Additional Information			92
Share Capital			92
Memorandum and Articles of Association			92
Notification Requirements			96

–


Deutsche Bank
Annual Report 2025 on Form 20-F

Deutsche Bank Aktiengesellschaft, also called Deutsche Bank AG, is a stock corporation organized under the laws of the

Federal Republic of Germany. Unless otherwise specified or required by the context, in this document, references to

“Deutsche Bank”, “the bank” or “the Group” are to Deutsche Bank Aktiengesellschaft and its consolidated subsidiaries.

Due to rounding, numbers presented throughout this document may not add up precisely to the totals presented and

percentages may not precisely reflect the absolute figures.

The bank’s registered address is Taunusanlage 12, 60325 Frankfurt am Main, Germany, and its telephone number is

+49-69-910-00.

Inclusion of its Annual Report

Deutsche Bank has included as an integral part of this Annual Report on Form 20-F its Annual Report 2025, to which the

bank refers to in response to certain items included in Form 20-F. Certain portions of the Annual Report 2025 have been

omitted, as indicated therein. The included Annual Report 2025 contains the consolidated financial statements, which

the bank refers to in response to Items 8 and 18.

The Annual Report 2025 and consolidated financial statements included herein differ from those Deutsche Bank

publishes for other purposes (the “non-SEC” versions thereof) in that the financial information presented in the Annual

Report 2025 and consolidated financial statements included herein has been prepared in accordance with International

Financial Reporting Standards (IFRS) as issued by the International Accounting Standards Board (IASB). The financial

information as well as financial targets and capital objectives presented in the non-SEC Annual Report 2025 and

consolidated financial statements included therein, by contrast, have been prepared in accordance with IFRS as issued

by the IASB and endorsed by the European Union (EU), including, effective as of January 1, 2020, the application of fair

value hedge accounting for portfolio hedges of interest rate risk (fair value macro hedges) in accordance with the EU

carve out version of International Accounting Standard (IAS) 39. Deutsche Bank does not use the IASB IFRS financial

results presented in this document as a basis for measuring the bank’s progress towards its financial targets or capital

objectives. For further information, see Note 01 “Material accounting policies and critical accounting estimates – Basis of

accounting – EU carve out” to the consolidated financial statements.

Such consolidated financial statements differ from those contained in the Annual Report 2025 used for other purposes

(the “non-SEC financial statements”) in that (i) Notes 42, 43 and 44 of the non-SEC financial statements, which address

non-U.S. requirements, have been deleted, and (ii) Note 42, which addresses U.S. requirements, has been added to the

included financial statements.

The consolidated financial statements have been audited by EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft, as

described in their “Report of Independent Registered Public Accounting Firm” included in the Annual Report 2025. Such

report is included only in the version of the Annual Report 2025 included in this Annual Report on Form 20-F.

–


Deutsche Bank
Annual Report 2025 on Form 20-F

Cautionary Statement Regarding Forward-Looking Statements

Deutsche Bank makes certain forward-looking statements in this document with respect to its financial condition and

results of operations. In this document, forward-looking statements include, among others, statements relating to:

–The potential development and impact on the bank from the challenging global macroeconomic and geopolitical

environment, market conditions and the legal and regulatory environment to which the bank is subject. This includes

the significant escalation in global trade tensions, divergence in monetary policies, risk of market corrections, along

with elevated geopolitical risks

–Deutsche Bank's ability to meet its strategic initiatives planned for 2026-2028 could be adversely affected by these

economic, geopolitical and business conditions, along with the legal and regulatory environment

The development of aspects of Deutsche Bank’s results of operations

–The bank’s expectations of the impact of risks that affect the bank’s businesses, including the risks of losses in its

trading businesses and credit exposures

–Other statements relating to the bank’s future business development and economic performance

In addition, Deutsche Bank may from time to time make forward-looking statements in the periodic reports to the United

States Securities and Exchange Commission on Form 6-K, annual and interim reports, invitations to Annual General

Meetings and other information sent to shareholders, offering circulars and prospectuses, press releases and other

written materials. Deutsche Bank’s Management Board, Supervisory Board, officers and employees may also make oral

forward-looking statements to third parties, including financial analysts.

Forward-looking statements are statements that are not historical facts, including statements about the bank’s beliefs

and expectations. Deutsche Bank uses words such as “believe”, “anticipate”, “expect”, “intend”, “seek”, “estimate”,

“project”, “should”, “potential”, “reasonably possible”, “plan”, “aim” and similar expressions to identify forward-looking

statements.

By their very nature, forward-looking statements involve risks and uncertainties, both general and specific. Deutsche

Bank bases these statements on its current plans, estimates, projections and expectations. The reader of this document

should therefore not place too much reliance on them. The bank’s forward-looking statements speak only as of the date

the bank makes them, and Deutsche Bank undertakes no obligation to update any of them in light of new information or

future events.

Deutsche Bank cautions the reader that a number of important factors could cause its actual results to differ materially

from those the bank describes in any forward-looking statement. These factors include those listed above and, among

others, the following:

–Other changes in general economic and business conditions or market corrections

–Changes in the geopolitical environment

–Changes and volatility in currency exchange rates, interest rates and asset prices

–Changes in governmental policy and regulation, including measures taken in response to economic, business, political

and social conditions

–The potential development and impact on the bank of legal and regulatory proceedings to which the bank is or may

become subject

–Changes in the bank’s competitive environment

–The success of acquisitions, divestitures, mergers and strategic investments and alliances

–Other factors, including those the bank refers to in “Item 3: Key Information – Risk Factors” and elsewhere in this

document and others to which the bank does not refer

–


Deutsche Bank
Annual Report 2025 on Form 20-F

Use of Non-GAAP financial measures

This document and other documents Deutsche Bank has published or may publish contain Non-GAAP financial

measures. Non-GAAP financial measures are measures of the bank’s historical or future performance, financial position or

cash flows that contain adjustments that exclude or include amounts that are included or excluded, as the case may be,

from the most directly comparable measure calculated and presented in accordance with IFRS in the financial

statements. Examples of Deutsche Bank’s Non-GAAP financial measures and the most directly comparable IFRS financial

measures, are as follows:


Non-GAAP financial measure	Most Directly Comparable IFRS financial measure
Net interest income in the key banking book segments	Net interest income
Revenues on a currency-adjusted basis	Net revenues
Adjusted costs, Costs on a currency-adjusted basis, Nonoperating costs	Noninterest expenses
Net assets (adjusted)	Total assets
Tangible shareholders’ equity, Average tangible shareholders’ equity, Tangible book value, Average tangible book value	Total shareholders’ equity (book value)
Post-tax return on average tangible shareholders’ equity (based on Profit (loss) attributable to Deutsche Bank shareholders after AT1 coupon)	Post-tax return on average shareholders’ equity
Tangible book value per basic share outstanding, Book value per basic share outstanding	Book value per share outstanding

For descriptions of these Non-GAAP financial measures and the adjustments made to the most directly comparable

financial measures under IFRS, please refer to “Supplementary Information (Unaudited): Non-GAAP financial measures”,

which is included herein.

When used with respect to future periods, Non-GAAP financial measures used by Deutsche Bank are also forward-

looking statements. The bank cannot predict or quantify the levels of the most directly comparable financial measures

under IFRS that would correspond to these measures for future periods. This is because neither the magnitude of such

IFRS financial measures, nor the magnitude of the adjustments to be used to calculate the related Non-GAAP financial

measures from such IFRS financial measures, can be predicted. Such adjustments, if any, will relate to specific, currently

unknown, events and in most cases can be positive or negative, so that it is not possible to predict whether, for a future

period, the Non-GAAP financial measure will be greater than or less than the related IFRS financial measure.

Use of Internet Addresses

This document contains inactive textual addresses of Internet websites operated by the bank and third parties.

Reference to such websites is made for informational purposes only, and information found at such websites is not

incorporated by reference into this document.


		8

–


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Dividends

PART I

Item 1: Identity of Directors, Senior Management and

Advisers

Not required because this document is filed as an Annual Report.

Item 2: Offer Statistics and Expected Timetable

Not required because this document is filed as an Annual Report.

Item 3: Key Information

Dividends

The following table shows the dividend per share in Euro and in U.S. dollars for the years ended December 31, 2025,

2024, 2023, 2022 and 2021. Deutsche Bank declares dividends at its Annual General Meeting following each year. For

2025, the Management Board intends to propose to the Annual General Meeting to pay a dividend of € 1.00 per share.

Deutsche Bank’s dividends are based on the non-consolidated results of Deutsche Bank AG as prepared in accordance

with German accounting principles. Because the Group declares dividends in euro, the amount an investor actually

receives in any other currency depends on the exchange rate between Euro and that currency at the time the euros are

converted into that currency.

In general, the German withholding tax applicable to dividends is 26.375% (consisting of a 25% withholding tax and an

effective 1.375% surcharge). Under the German Investment Tax Act, dividends received by an investment fund within the

meaning of the German Investment Tax Act are subject to 15% German withholding tax equal to the treaty tax rate. For

individual German tax residents, the withholding tax paid represents for private dividends, generally, the full and final

income tax applicable to the dividends. Dividend recipients who are tax residents of countries that have entered into a

convention for avoiding double taxation may be eligible to receive a refund from the German tax authorities for a portion

of the amount withheld and in addition may be entitled to receive a tax credit for the German withholding tax not

refunded in accordance with their local tax law.

Generally, U.S. residents will be entitled to receive a refund equal to 11.375% of the dividends paid. For U.S. federal

income tax purposes, the dividends the Group pays are not eligible for the dividends received deduction generally

allowed for dividends received by U.S. corporations from other U.S. corporations.

Dividends in the table below are presented before German withholding tax.

See “Item 10: Additional Information – Taxation” for more information on the tax treatment of the bank’s dividends.


			Payout ratio2,3
Financial Year for which dividend is paid	Dividends per share1	Dividends per share	Basic earnings per share	Diluted earnings per share
2025 (proposed)	$ 1.17	€ 1.00	33%	34%
2024	$ 0.77	€ 0.68	36%	37%
2023	$ 0.49	€ 0.45	16%	16%
2022	$ 0.32	€ 0.30	13%	13%
2021	$ 0.21	€ 0.20	20%	21%

N/M – Not meaningful

1From 2025 onwards, dividends declared and paid in U.S. $ were translated from € into U.S. $ based on the exchange rates as of the payment date. This is a change in

presentation only and does not affect the amount of dividends paid. For the current year proposed divided, the translation has been performed using the exchange rate

on the last business day of the year

2Payout ratio defined as dividends per share the Group paid in respect of each financial year as a percentage of basic and diluted earnings per share for that year


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risk Factors

An investment in Deutsche Bank’s securities involves a number of risks. Potential investors should carefully consider the

following information about the risks Deutsche Bank faces, together with other information in this document, when they

make investment decisions involving Deutsche Bank’s securities. If one or more of these risks were to materialize, it could

have a material adverse effect on Deutsche Bank’s financial condition, results of operations, cash flows or prices of its

securities.

Summary of Risk Factors

Risks Relating to the Macroeconomic, Geopolitical and Market Environment. Deutsche Bank is materially affected by

global macroeconomic, geopolitical and market conditions. Significant challenges may arise from evolving global trade

tensions, political instability, asset deterioration, market volatility and a deteriorating macroeconomic environment.

These risks could negatively affect the business environment, leading to weaker economic activity and a broader

correction in the financial markets. Materialization of these risks could negatively affect Deutsche Bank’s results of

operations and financial condition as well as the bank’s ability to achieve its strategic plans and financial targets.

Risks Relating to Deutsche Bank’s Strategy and Business. If Deutsche Bank is unable to meet its 2028 financial targets

due to a significant deterioration in the global macroeconomic environment, an adverse change in market confidence in

the banking sector and/or client behavior, the bank may incur unexpected losses or experience lower than planned

profitability. This could result in an erosion of the bank’s capital or liquidity base, which could adversely affect its ability

to access the debt capital markets or to sell assets during periods of market or firm specific liquidity constraints. This may

significantly impact Deutsche Bank’s business model, results of operations, and ability to make desired cash distributions

and share buybacks.

Risks Relating to Regulation and Supervision. Prudential reforms and increased regulatory scrutiny affecting the financial

sector continue to have a significant impact on Deutsche Bank, which may adversely affect its business and, in cases of

non-compliance, could lead to regulatory sanctions against the bank, including prohibitions against making dividend

payments, share buybacks or payments on Deutsche Bank's regulatory capital instruments, or increasing regulatory

capital and liquidity requirements. Regulatory changes may impact how key subsidiaries are funded which could affect

how businesses operate and negatively impact results. Regulatory actions may also require Deutsche Bank to change its

business model or result in some business activities becoming unviable. Regulatory and legislative changes could require

Deutsche Bank to maintain increased capital and debt that can be bailed in in a resolution scenario to abide by tightened

liquidity requirements. Any perceptions in the market that the bank may be unable to meet its capital or liquidity

requirements could intensify the effect of these factors on the bank’s business and results.

Risks Relating to Deutsche Bank’s Internal Control Environment. The bank continually enhances the effectiveness of its

internal control environment and improves its infrastructure to align with updated regulatory requirements and to close

gaps identified by the bank and/or by regulators and monitors. If progress is slower than anticipated or the bank fails to

deliver durable improvements, Deutsche Bank’s reputation, regulatory position and financial results could be adversely

affected.

Risks Relating to Technology, Data and Innovation. Digitalization and the speed of innovation in areas such as artificial

intelligence (AI) may offer market entry opportunities for new competitors. AI has the potential to amplify existing risk

factors across various domains. The emergence of agentic AI solutions has the potential to enable autonomous decision

making within processes, increasing the probability of undetected mistakes. For example, autonomous AI agents could

distort or override defined objectives and optimize in ways that undermine regulatory, ethical, or operational safeguards,

such as prioritizing speed or performance metrics over compliance obligations, fairness standards, or critical quality

controls. If Deutsche Bank does not address these emerging risks, it may face compliance issues, operational

inefficiencies and potential losses, along with reputational risks that could weaken the market’s confidence in Deutsche

Bank’s ability to apply AI responsibly.

Risks Relating to Litigation, Regulatory Enforcement Matters, Investigations and Tax Examinations. The bank operates in

a highly regulated and litigious environment, potentially exposing the bank to liabilities and other costs, the amounts of

which may be substantial and difficult to estimate, as well as to legal and regulatory sanctions and reputational risks.

Should any legal proceedings or investigations result in a finding that the bank failed to comply with an applicable law,

result in guilty pleas or convictions, Deutsche Bank could be exposed to material damages, fines, limitations on business,

remedial undertakings, criminal prosecution or other material adverse effects on the bank's financial condition as well as

risk to the bank’s reputation and potential loss of business as a result of extensive media attention.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Climate Change and Other Risks Relating to Environmental, Social and Governance (ESG)-Related Matters. The impacts

of rising global temperatures and the associated policy, technology and behavioral changes required to limit global

warming and nature degradation have led to emerging sources of financial and non-financial risks. These include the

physical risk impacts from extreme weather events and the risk that financial institutions face from increased scrutiny

from governments, regulators, shareholders, and other bodies. The emergence of significantly diverging (and sometimes

conflicting) ESG regulatory and/or disclosure standards across jurisdictions could lead to higher costs, including

compliance costs, and increased risks of failing to meet the respective regulatory requirements in each jurisdiction.

Other Risks - Deutsche Bank is also subject to other risks, including the following:

–Deutsche Bank’s risk management policies, procedures and methods may leave the bank exposed to unidentified or

unanticipated risks, which could lead to material losses

–As Deutsche Bank is dependent on legacy infrastructure providers with challenged business models, the bank

therefore has become more reliant on cloud-based and data intensive platforms which increases concentration risk

–Deutsche Bank utilizes a variety of third parties in support of its business and operations. Services provided by third

parties pose risks to the bank comparable to if Deutsche Bank performed the services internally. If such a third party

does not conduct business in accordance with applicable standards or the bank’s expectations, Deutsche Bank could

be exposed to material losses, regulatory action, litigation or reputational damage

–Operational risks, which may arise from errors in the performance of the bank’s processes, the conduct of its

employees, shortfalls in access management, instability, malfunction or outage of IT systems and infrastructure, or

loss of business continuity, or comparable issues with respect to the bank's vendors, may disrupt Deutsche Bank’s

businesses and lead to material losses

–Deutsche Bank’s large clearing and settlement business poses risks if it fails to operate properly for even short periods

–Impairments of goodwill and other intangible assets and reductions in deferred tax assets in the future may have

material adverse effects on Deutsche Bank’s profitability, equity and financial condition

–In addition to Deutsche Bank’s traditional banking businesses of deposit-taking and lending, the bank may also

engage in nontraditional credit businesses in which credit is extended via transactions that materially increase the

bank’s exposure to credit risk

–A substantial proportion of the bank’s assets and liabilities comprise financial instruments carried at fair value, with

changes in fair value recognized in the income statement, which could result in future losses and impact profitability.

–Deutsche Bank is exposed to pension risks which can materially impact the measurement of its pension obligations

and could materially impact the bank’s earnings

–The evolution of digital assets increases operational, liquidity and financial risks and could impact Deutsche Bank's

results of operations

–Deutsche Bank is subject to laws and other requirements relating to financial and trade sanctions and embargoes and

if breached, could result in the bank being subject to material regulatory enforcement actions and penalties

–Transactions with persons targeted by U.S. economic sanctions or counterparties in countries designated by the U.S.

State Department as state sponsors of terrorism may lead potential customers and investors to avoid doing business

or investing in Deutsche Bank’s securities, harm the bank’s reputation or result in regulatory or enforcement action,

which could have a material and adverse effect on the bank’s business


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risks Relating to the Macroeconomic, Geopolitical and Market Environment

Deutsche Bank is materially affected by global macroeconomic and market conditions. Significant challenges may arise

from evolving global trade tensions, political instability, asset deterioration, market volatility and a deteriorating

macroeconomic environment. These risks could negatively affect the business environment, leading to weaker economic

activity and a broader correction in the financial markets. Materialization of these risks could negatively affect Deutsche

Bank’s results of operations and financial condition as well as the bank’s ability to achieve its strategic plans and financial

targets. Deutsche Bank takes step to manage these risks through its risk management and hedging activities but remains

exposed to these macroeconomic and market risks.

The macroeconomic and market environment in 2025 was defined by persistent uncertainty, policy divergence, and

heightened volatility factors that collectively shaped the risk landscape for the bank and its stakeholders. This included a

significant escalation in global trade tensions, particularly in the first half of the year following the U.S. administration's

announcement of sweeping “reciprocal” tariffs and with even more punitive measures targeted at China, along with

ongoing uncertainty around Russia’s war in Ukraine and global divergence on central banks' monetary policies which

have led to significant currency movements. In Europe, uncertainty around political stability and fiscal positions for

certain larger economies led to sovereign credit rating downgrades and pressure on bond yields which could have a

negative impact on the economy and ultimately impact the creditworthiness of European clients. Although the U.S.

economy expects growth in 2026, inflation is expected to remain elevated in the near term and slower labor force growth

could devalue or create volatility in the U.S. dollar exchange rate, which could negatively impact the bank’s revenues and

results of operations.

Germany stagnated and there was weak growth across Europe during 2025 as market activity and sentiment was

impacted by the escalating trade conflict with the U.S. and increased competition with China, especially in the

automotive sector. In 2026, external headwinds are expected to remain, inflationary pressures from fiscal easing and a

tightening labor market may lead to inflation risks and pressure on the ECB to raise interest rates. These risks could have

a negative impact on the European economy and adversely affect Deutsche Bank’s loan growth and ability to achieve its

strategic goals.

Large-cap technology stocks have fueled concerns about a potential AI-driven bubble. Gold reached record highs as

investors sought safe havens amid persistent uncertainty, while long-term bond yields fluctuated in response to shifting

fiscal and political dynamics. Volatility or sharp declines or market corrections in asset prices and bond yields could

adversely impact the banks profitability and result in financial losses.

Commercial real estate (CRE) remains a key risk for potential increases in provisions for credit losses, with refinancing

challenges and price stabilization still uncertain, particularly in the U.S. While market indicators point to stabilizing CRE

prices, significant impairment risk remains depending on property types and regions (e.g., U.S. office space on the West

Coast) and could result in Deutsche Bank experiencing loan loss provisions higher than expected.

Private credit and activities from non-bank financial institutions (NBFI), continued to face pressure from higher interest

rates, refinancing risks, and subdued investor sentiment. Failures of a select number of sub-prime lenders in the U.S.

increased investor focus on risks associated with private credit and raised wider concerns around underwriting standards

and fraud risk. Although Deutsche Bank is not exposed to significant risks related to NBFIs, the bank could face potential

indirect credit risks through interconnected portfolios and counterparties.

Overall, either in isolation or in combination with other risk factors such as the potential escalation of geopolitical risks

(see below), the aforementioned risks could lead to a deterioration in Deutsche Bank’s portfolio quality and higher than

expected credit losses as well as increased capital and liquidity demands as clients draw down on funding lines. Higher

volatility in financial markets could lead to increased margin calls, higher market risk RWA and elevated valuation

reserves. Negative impacts on investor appetite may also impact the bank’s ability to distribute and de-risk capital market

commitments, which could potentially result in losses as well as making pricing and hedging more challenging and

costly. Higher volatility in capital markets amidst the challenging macro environment could also lead to increased

inherent risks in several operational risks including transaction processing, internal and external fraud. It also increases

the risk of idiosyncratic counterparty events both directly and indirectly, for example shortfalls under securities financing

transactions.

If multiple downside risks such as renewed trade tensions, fiscal instability, or disorderly market corrections were to

materialize simultaneously, these risks could have a material adverse impact on Deutsche Bank’s financial results and

ability to meet its 2028 financial targets and capital objectives.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

A number of geopolitical and political risks and events could negatively affect Deutsche Bank’s business environment,

including weaker economic activity, financial market corrections, or compliance risks which could reduce the bank’s

ability to achieve its 2028 financial targets.

Geopolitical developments continue to present a complex and evolving risk landscape that may affect Deutsche Bank’s

operating environment, market performance, and the achievement of its 2028 financial targets.

In the Middle East, the U.S. led military intervention in Iran and retaliation by Iran against targets in the Middle East, may

lead to a protracted period of uncertainty in the region. A key risk is the potential for prolonged higher oil and gas prices

if supplies through the Strait of Hormuz are restricted for an extended period. Deutsche Bank has limited direct

exposures to the Middle East, however broader geopolitical destabilization could negatively impact the bank’s clients

and have an adverse effect on Deutsche Bank's financial results (including increases in allowance for credit losses) and

operations.

Recent events in Venezuela, resulting in the U.S. apprehension of President Nicolás Maduro, marks a significant

geopolitical escalation which could elevate regional uncertainty, sanctions, market volatility, and cross‑border political

risk. Additionally, emerging territorial claims, such as those by the U.S. administration regarding Greenland, have

introduced uncertainty into the transatlantic partnership, with potential implications for European security cooperation

frameworks. If there is further targeted action on other regions, there could be market-wide implications, including

sovereign stress and/or market dislocation. These risks could have a material adverse effect on Deutsche Bank's results

of operations.

Relations between U.S. and China remain a central risk factor for the bank. Notwithstanding recent bilateral agreements

between the U.S. and China aimed at reducing trade barriers and retaliatory measures, rising U.S. and China tensions,

ongoing cross-border investment restrictions and dispute over potential tariffs, sanctions, export controls, trade of rare

earth minerals and critical technologies, Hong Kong and human rights, raise the specter of further economic polarization

and the emergence of distinct U.S. and China-led trading blocs. The risk of retaliatory measures and broader

fragmentation of global trade may increase, with potential adverse impacts on the bank’s cross-border activities and

client base.

The European Union took action to protect domestic industries, proposing sharp cuts to steel import quotas and raising

out-of-quota tariffs to 50%. These measures heightened the risk of retaliatory trade actions and further exacerbated

global trade tensions, which could have an adverse impact on the bank's loan portfolio. Sanctions regimes became more

complex and far-reaching, with sanctions intensifying in the later part of 2025. For example, the EU adopted its 19th

sanctions package against Russia, introducing a phased ban on Russian liquid natural gas imports, tighter controls on

banks and crypto exchanges, and expanded secondary sanctions targeting third-country entities, which increases the

bank’s operational and compliance risk.

Russia’s war in Ukraine continued, with Russian attacks intensifying and Western support for Ukraine showing signs of

fatigue and fragmentation. Hopes for a ceasefire remained elusive, and the risk of prolonged instability undermined

global investor confidence and increased market volatility. In Russia, fast-tracked legislation enabled the sale of foreign

state-owned assets, raising concerns about potential expropriation of foreign companies and increasing the risk of

adverse regulatory or government actions, which could adversely affect Deutsche Bank’s operations in Russia and result

in financial losses.

Hybrid and cyber warfare and operational risks emerged as significant themes. Undersea cables became targets for

attack by state and non-state actors, threatening real-time services such as trading, payments, and service delivery. The

bank’s vendors faced potential connectivity issues during regional outages, raising reputational, regulatory, and financial

risks.

Overall, the geopolitical landscape in 2025 was characterized by persistent uncertainty, evolving risks, and the potential

for rapid escalation. The interplay of trade policy, sanctions, regional conflicts, and operational threats could create a

challenging environment for the bank's operations and available resources and potentially impact its business model.

Deutsche Bank expects this uncertainty to persist in 2026, which could negatively impact the bank’s results of operations

or ability to achieve its 2028 financial targets.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risks Relating to Deutsche Bank’s Strategy and Business

If Deutsche Bank is unable to meet its 2028 financial targets or incurs future losses or low profitability, Deutsche Bank’s

financial condition, results of operations and share price may be materially and adversely affected, and the bank may be

unable to make contemplated distributions or share buybacks.

In November 2025, Deutsche Bank announced the next phase of its strategy, Scaling the Global Hausbank. The bank

announced its financial targets and objectives for the period until 2028 and management’s focus in the next phase on

accelerating value creation by scaling the Global Hausbank. While Deutsche Bank continuously plans and adapts to

changing situations, there is a risk that a significant deterioration in the global macroeconomic environment, an adverse

change in market confidence in the banking sector and/or client behavior, as well as higher competition, inflation or

unforeseen costs could result in the bank not achieving its financial targets and objectives by the end of 2028. In

addition, Deutsche Bank may incur unexpected losses including impairments and provisions, experience lower than

planned profitability or an erosion of the bank’s capital or liquidity base or broader financial condition, leading to a

material adverse effect on Deutsche Bank’s results of operations and share price. This also includes the risk that

Deutsche Bank will not be able to make desired cash distributions and share buybacks, which are subject to regulatory

approval, shareholder authorization and meeting German corporate law requirements. In these situations, the Group

would need to take actions to ensure it meets its minimum capital or liquidity objectives. These actions or measures may

result in adverse effects on Deutsche Bank’s business, results of operations, strategic plans or meeting its financial

targets and capital objectives.

Deutsche Bank has the objective to maintain a strong capital position with CET1 ratio operating range of 13.5-14.0%,

with no less than 200 basis points distance to the Maximum Distributable Amount (MDA) threshold. The Group’s capital

ratio development reflects among other things: the performance of the bank’s operating businesses; the delivery of

associated benefits from change initiatives including for example front-to-back optimization and AI adoption programs;

cost related to potential litigation and regulatory enforcement actions; growth in the balance sheet usage of business

divisions; changes in the bank’s tax and pensions accounts; impacts on other comprehensive income; and changes in

regulation and regulatory technical standards (including assumptions made in CRR 3 rules in relation to the output floor).

Deutsche Bank enters into contracts and letters of intent in the ordinary course of business. When these are preliminary

in nature or conditional, the bank is exposed to the risk that they do not result in execution of the final agreement or

consummation of the proposed arrangement, putting associated benefits with such agreements at risk.

The financial results of the bank could be adversely impacted if anticipated benefits from mergers and acquisitions, joint

ventures, strategic partnerships, planned cost savings and other investments do not materialize. Potential business

disposals could also result in additional costs to be incurred by the bank. At the same time, any integration process would

require significant time and resources, and the bank may not be able to manage the process successfully.

All of the above could have a material impact on the bank’s CET 1 ratio as well as its financial targets. It is therefore

possible that the bank could fail to meet certain capital objectives e.g., the CET 1 ratio within an operating range of

13.5% to 14.0% with 200 basis points distance to the MDA as a floor; and a 60% total payout ratio from 2026 and

distribution of excess capital when CET 1 ratio is sustainably above 14%.

In addition to other risks described in the Risk Factors, the following could adversely impact the bank’s strategic goals

and ability to achieve its financial targets and capital objectives for 2028:

–The base case scenario for Deutsche Bank’s financial and capital plan includes revenue growth estimates which are

dependent on a number of factors including: macroeconomic developments, market fee pools and market share of

the overall fee pool. If there is stagnation or downturn in any of these areas this could significantly impact the bank’s

ability to generate revenue growth. This base case scenario also includes assumptions regarding the bank’s ability to

manage costs in future periods

–In addition, the bank’s base case scenario is based on current market implied forward interest rate curves, inflation

levels and expected foreign exchange rates. If any of these develop or fluctuate differently than the bank's

expectations, this could have an adverse impact on Deutsche Bank’s revenues and costs

–Reputational risk or negative market perceptions of Deutsche Bank could impact client levels, deposits or asset

outflows


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Adverse market volatility, asset price deteriorations, and cautious investor sentiment may materially and adversely affect

Deutsche Bank’s revenues and operating profits, particularly in investment banking, brokerage and other commission and

fee-based businesses.

Deutsche Bank has significant exposure to the financial markets and is more at risk from adverse developments in the

financial markets than institutions predominantly engaged in traditional banking activities. Sustained market declines

have in the past caused and can in the future cause the bank’s revenues to decline, increase hedging costs and result in

material losses.

Specifically, revenues in the Investment Bank, in the form of origination and advisory fees, directly relate to the number,

size, and asset values of the underlying transactions in which the bank participates and are susceptible to adverse effects

from sustained market downturns or loss of market share. In addition, periods of market decline and uncertainty tend to

dampen client appetite for market and credit risk, a critical driver of transaction volumes and Investment Banking &

Capital Markets (IBCM) revenues, especially transactions with higher margins. In the past, decreased client appetite for

risk has led to lower levels of activity and lower levels of profitability in IBCM. If there is a reduction in market activity or

IBCM is unable to attain its expected market share, Deutsche Bank's revenues and profitability could be adversely

affected.

Market downturns have in the past and may in the future lead to declines in the volume of transactions that the bank

executes for its clients and could result in a decline in noninterest income. Because fees that the bank charges for

managing clients’ portfolios are in many cases based on the value or performance of those portfolios, a market downturn

that reduces the value of clients’ portfolios, or increases withdrawals, reduces the revenues received from Asset

Management and Private Bank businesses. Even in the absence of a market downturn, below market or negative

performance by Asset Management’s investment funds may result in increased withdrawals and reduced inflows, which

would impact Deutsche Bank’s revenues. While clients would be responsible for losses incurred in taking positions on

their accounts, the bank may be exposed to additional credit risk and need to cover the losses if the bank does not hold

adequate collateral or cannot realize the expected value of the collateral. Deutsche Bank’s businesses may also suffer if

clients lose money and lose confidence in Deutsche Bank’s products and services.

In addition, the revenues and profits Deutsche Bank earns from trading and investment positions and transactions in

connection with them can be directly and negatively impacted by market prices. When Deutsche Bank owns assets,

market price declines can expose the bank to losses. Many of the Investment Bank’s more sophisticated transactions are

influenced by price movements and differences among prices. If prices move in a way not anticipated, the bank may

experience losses. In addition, Deutsche Bank has committed capital and takes market risk to facilitate certain capital

markets transactions; doing so can result in losses as well as income volatility. Such losses may especially occur on assets

the bank holds which do not trade in very liquid markets. Assets that are not traded on stock exchanges or other public

trading markets, such as derivatives contracts between banks without publicly quoted prices, may have values that the

bank calculates using models. Monitoring the deterioration of prices of assets like these is difficult and could lead to

losses the bank does not anticipate. Deutsche Bank can also be adversely affected if general perceptions of risk cause

uncertain investors to remain on the sidelines of the market, curtailing clients’ activity and in turn reducing the levels of

activity in those businesses’ dependent on transaction flow.

Deutsche Bank’s liquidity, business activities and profitability may be adversely affected by an inability to access the

debt capital markets or to sell assets during periods of market-wide or firm-specific liquidity constraints.

Deutsche Bank has a continuous demand for liquidity to fund its business activities and the bank’s liquidity may be

impaired if the bank is unable to access secured and/or unsecured debt markets, access funds from subsidiaries, allocate

liquidity optimally across businesses, sell assets, or experiences unforeseen outflows of cash or deposits. These situations

may arise due to disruptions in the financial markets, including limited liquidity, defaults by counterparties, non-

performance or other adverse developments that affect financial institutions. Such adverse developments may include

the reluctance of counterparties or the market to finance Deutsche Bank’s operations due to perceptions about potential

outflows (including deposit outflows) resulting from litigation, regulatory or similar matters. These items may be actual or

perceived weaknesses in the bank’s businesses, business model or strategy, as well as in Deutsche Bank’s resilience to

counter negative economic and market conditions. If such situations occur, internal estimates of the bank’s available

liquidity over the duration of a stressed scenario could be negatively impacted.

In addition, these perceptions could affect Deutsche Bank in multiple ways like negative market perceptions which can

raise Deutsche Bank's cost of accessing capital markets and negatively affect the bank's funding curve and increase

funding spreads. Such situations may hinder the bank's ability to refinance assets, support business activities or maintain

capital levels. As a result, the bank may be forced to sell assets at unfavorable prices or reduce business activities,

including lending.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Liquidity risk could also arise from lower value and marketability of Deutsche Bank’s High Quality Liquid Assets (HQLA),

impacting the amount of proceeds available for covering cash outflows during a stress event. Additional haircuts may be

incurred on top of already impaired asset values. Moreover, securities might lose their eligibility as collateral necessary

for accessing central bank facilities, as well as their value in the repo/wholesale funding market.

Additional liquidity risks, due to negative developments in the wider financial sector, may also occur from withdrawal of

deposits not insured by deposit guarantee schemes or result in deposits moving into other investment products. In times

of economic uncertainty or market stress, digital banking allows depositors to swiftly move funds digitally to other

market participants, leading to a faster and larger scale of deposit outflows. This risk may be exacerbated by the rollout

of the European Instant Payments Regulation which could lead to accelerated outflows outside of normal business hours

in addition to increased needs for intraday liquidity. In addition, higher interest rates could foster price competition

among banks for retail deposits increasing Deutsche Bank’s funding costs, as well as putting further pressure on the

volume of Deutsche Bank’s retail deposits, which are one of the main funding sources for the bank.

Uncertain macroeconomic developments could negatively affect Deutsche Bank’s ability to transact foreign exchange

(FX) trades due to volatility in the FX markets or if counterparties are concerned about the bank’s ability to fulfil agreed

transaction terms and therefore seek to limit their exposure. In addition, if Central Bank emergency FX swap facilities

were removed, this may lead to the widening of spreads in the FX markets, increased foreign currency funding costs and

a reduction in USD liquidity in the market. Additionally, increased FX mismatches on the bank’s balance sheet may lead

to increased collateral outflows if the Euro (Deutsche Bank’s reporting currency) materially depreciates against other

major currencies and may lead to difficulties in supporting liquidity needs in different currencies.

As part of emerging risks, digital payments and blockchain are assessed as areas which could impact the depth and

volatility of market liquidity and funding and may temporarily impact cost of funding and thereby adversely affect

profitability.

Any future credit rating downgrade to below investment grade could adversely affect funding costs and the willingness

of counterparties to do business with Deutsche Bank and could impact aspects of the bank’s business model.

Rating agencies regularly review the bank’s credit ratings, and such reviews could be negatively affected by a number of

factors that can change over time, including the credit rating agency’s assessment of the financial condition of the bank

or if the bank’s actual results materially differ from its strategic targets.

A reduction in Deutsche Bank’s credit rating below investment grade could affect the bank’s access to money markets,

reduce its deposit base or trigger additional collateral or other requirements, which could adversely affect the cost of

funding and limit the range of counterparties willing to enter into transactions with the bank. This could in turn adversely

impact Deutsche Bank’s competitive position, financial results and threaten its prospects in the short to medium-term.

Deutsche Bank may have difficulties selling businesses or assets at favorable prices and may experience material losses

from the sale of such assets irrespective of market conditions.

Deutsche Bank may seek to sell or otherwise reduce its exposure to assets as part of its strategy or to meet or exceed

capital and leverage requirements, as well as to help the bank meet its return on tangible equity target. Where the bank

sells businesses, it may remain exposed to certain losses or risks under the terms of the relevant sale agreement and the

process of separating and selling such businesses may also give rise to operating risks or further losses. Unfavorable

business or market conditions may make it difficult for the bank to sell businesses or assets at favorable prices, or may

preclude a sale of a business or assets altogether.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Deutsche Bank may have difficulty in identifying, integrating, and executing business combinations or other types of

investments which could impact the bank’s financial performance. In addition, if Deutsche Bank is unable to pursue

strategic transactions when needed, this could also materially harm the bank’s results of operations and share price.

Deutsche Bank considers business combinations and other types of investments from time to time. If investors viewed a

significant business combination to be too costly, dilutive to existing shareholders or unlikely to improve the bank's

competitive position, Deutsche Bank's share price could significantly decline. Also, the need to revalue certain classes of

assets at fair value in a business combination may make transactions infeasible or result in an impairment of any goodwill

created. In addition, business combination or other types of investments may not perform as well as expected or the

bank may fail to integrate the combined entity’s operations successfully. Failure to complete announced business

combinations or failure to achieve the expected benefits of any such combination or investment could materially and

adversely affect profitability. Unsuccessful acquisitions could also lead to departures of key employees or additional

costs if financial incentives to retain employees is required.

If Deutsche Bank avoids or is unable to enter into business combinations or if announced or expected transactions fail to

materialize, market participants may perceive the bank negatively. The bank may also be unable to expand its businesses,

especially into new business areas, as quickly or successfully as competitors if the bank does so through organic growth

alone. These perceptions and limitations could cost Deutsche Bank business and harm its reputation, which could have

material adverse effects on the bank's financial condition, results of operations and liquidity.

Intense competition, in Deutsche Bank’s home market of Germany as well as in international markets, could materially or

adversely impact revenues and profitability.

Deutsche Bank operates in highly competitive markets in all business divisions. If the bank is unable to respond to the

competitive environment with attractive product and service offerings that are profitable, the bank may lose market

share or incur losses. In addition, downturns in the economies of these markets could add to the competitive pressure, for

example, through increased price pressure and lower business volumes. Also, Deutsche Bank’s competitiveness may be

impaired if it is not able to deploy capital and fund investments to grow revenues. The bank continuously monitors and

responds to competitive developments to protect its market position and realize growth opportunities. Competitors in

that context include large, international banks, smaller domestic banks, new international banks entering the German

market, as well as emerging and non-banking competitors (e.g., digital first or fintechs). If significant competitors were to

merge or be acquired, this could have an adverse impact on Deutsche Bank’s business model and opportunities to grow

non-organically in the future.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risks Relating to Regulation and Supervision

Prudential reforms and heightened regulatory scrutiny affecting the financial sector continue to have a significant

impact on Deutsche Bank, which may adversely affect its business and, in cases of non-compliance, could lead to

regulatory sanctions against the bank, including prohibitions against the bank making dividend payments, share

repurchases or payments on its regulatory capital instruments, or increasing regulatory capital and liquidity

requirements.

Governments and regulatory authorities continue to work to enhance the resilience of the financial services industry

against future crises through changes to the regulatory framework, in particular through the final implementation of the

regulatory reform agenda outlined by the Basel Committee on Banking Supervision (the "Basel Committee") and, more

recently, the envisaged transition towards sustainable economies.

As a core element of the reform of the regulatory framework, the Basel Committee developed and continues to refine a

comprehensive set of rules regarding minimum capital adequacy and liquidity standards as well as other rules (Basel III)

which apply to Deutsche Bank (as described further in “Item 4: Regulation and Supervision” of this report under

Highlights). In July 2024, the EU prudential rules (Capital Requirements Regulation and Directive – CRR 3 and CRD 6)

took effect following their publication in the EU Official Journal in June 2024. The reform implements the Basel

Committee’s Final Basel III reforms. These reforms change how EU banks will calculate their risk weighted assets. The

majority of the reforms began to apply as of January 2025, with the exception of the rules on market risk (implementing

the fundamental review of the trading book – FRTB), which has been delayed by the European Commission, via a

Delegated Act, until January 2027. The output floor, which limits the internal-model RWA to ultimately 72.5% of the

standardized approach RWA, will apply fully in January 2030. Final Basel III will increase the bank’s RWA and associated

capital requirements. The Basel III reforms are also being implemented, with different timelines, in all major global

jurisdictions. At the start of 2024, the European Banking Authority (EBA) consulted on amendments to its regulatory

technical standard (RTS) on prudent valuation. This standard sets out the requirements that institutions operating in the

EU should apply to the valuation of their fair-valued assets and liabilities for prudential purposes. The EBA is working

through the comments received, and depending on their final view, this may lead to an increase in Deutsche Bank’s CET

1 requirements and adversely affect its CET 1 ratio. The EBA also published its final draft RTS on off-balance sheet items

in August 2025, establishing a criteria for assigning off-balance sheet items reflecting differing levels of conversion risk.

An earlier proposal during the consultation stage to cover the treatment of credit card chargeback risks in RTS has been

dropped.

The implementation of new regulatory requirements or the introduction of additional, individual or increased capital

requirements or similar discretionary decisions by banking supervisory authorities could have a negative effect on the

capital ratio as well as reduce business opportunities and require measures to reduce risk assets or increase regulatory

capital.

Furthermore, Deutsche Bank’s prudential regulators, including the European Central Bank (ECB) under the EU’s Single

Supervisory Mechanism (SSM), conduct stress tests and regular reviews of asset quality and risk management processes

in accordance with the supervisory review and evaluation process (SREP). Prudential regulators have discretion to impose

capital surcharges on financial institutions for risks which they deem to not be sufficiently covered by the general capital

rules (Pillar 1) or impose other measures, such as restrictions on or changes to the business. In this context, the ECB has

imposed, individual capital requirements on Deutsche Bank resulting from the SREP (referred to as “Pillar 2

requirements”) which it must meet with at least 75% of Tier 1 capital and at least 56.25% of CET 1 capital. Pillar 2

requirements must be fulfilled in addition to the statutory minimum capital and buffer requirements and any non-

compliance may have immediate legal consequences such as restrictions on dividend payments. In addition, regulatory

supervisors could amend interpretations on previously issued guidance and require financial institutions to apply the new

interpretations on a retrospective basis, which could negatively impact the bank.

Following the 2025 SREP, Deutsche Bank has been informed by the ECB of its decision regarding prudential capital

requirements to be maintained from January 1, 2026 onwards, that Deutsche Bank’s Pillar 2 requirement will be 2.85% of

RWA, of which at least 1.60% must be covered by CET 1 capital and 2.14% by Tier 1 capital. Further, the decision

includes conclusions the ECB draws from regulatory stress tests conducted by the EBA or the ECB, including the results

of the 2025 EBA stress test published on August 1, 2025, indicating that European banks remain resilient even under a

severe hypothetical downturn. Similarly, the 2026 SREP will take into account the outcome of the 2026 ECB thematic

geopolitical risk reverse stress test. The ECB evaluates each bank’s performance from a qualitative angle to inform the

decision on the level of Pillar 2 Requirement and a quantitative outcome which is one aspect when assessing the level of

Pillar 2 Guidance. The ECB has already used these powers in its SREP decisions in the past and it may continue to do so

to address findings from onsite inspections. In extreme cases, the ECB can even suspend certain activities or permission

to operate within their jurisdictions and impose monetary fines or capital surcharges for failures to comply with rules

applicable to the guidelines.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Regulatory authorities have substantial discretion in how to regulate banks, and this discretion and the powers available

to them have been steadily increasing over the years. Also, new regulation may be imposed on an ad-hoc basis by

governments and regulators in response to ongoing or future crises (such as global pandemics or climate change), which

may especially affect financial institutions such as Deutsche Bank that are deemed to be systemically important.

The ECB conducted its first-ever cyber resilience stress test in 2024 which, according to the ECB, revealed certain areas

where banks in the European Union needed to make improvements, including business continuity frameworks, incident

response planning, back-up security and management of third-party providers. Deficiencies in operational resilience

frameworks as regards IT security and cyber risks have thus become part of the ECB’s 2025-2027 supervisory priorities.

If Deutsche Bank fails to comply with regulatory requirements, in particular with statutory minimum capital requirements

or Pillar 2 requirements, or if there are shortcomings in Deutsche Bank’s governance and risk management processes,

competent regulators may prohibit the bank from making dividend payments to shareholders or distributions to holders

of other regulatory capital instruments or require the bank to take action which may impact its strategy, profitability,

capital and liquidity profile. This could occur, for example, if the bank fails to make sufficient profits due to declining

revenues, or as a result of substantial outflows due to litigation, regulatory and similar matters. Failure to comply with the

quantitative and qualitative regulatory requirements could result in other forms of regulatory enforcement action being

brought against Deutsche Bank, which may result in sanctions including fines. Such enforcement action could have a

material adverse effect on Deutsche Bank’s current and future business, financial condition and results of operations,

including Deutsche Bank’s ability to pay out dividends to shareholders or distributions on other regulatory capital

instruments.

Both the regulatory and legislative environment will continue to be dynamic and may impact Deutsche Bank’s revenue

and costs (e.g., the cost to ensure ongoing and future compliance). Additionally, the prospect of regulatory conditions

easing in certain non-European regions could present a competitive disadvantage to the bank.

Please refer to “Item 4: Regulation and Supervision” of this report for further details on current regulation and supervision

requirements applicable to Deutsche Bank.

Deutsche Bank is required to maintain capital and bail-inable debt (debt that can be bailed-in in resolution) and abide by

liquidity requirements. These requirements may significantly affect the bank’s business model, financial condition and

results of operations, as well as the competitive environment generally. Any perceptions in the market that the bank may

be unable to meet its capital or liquidity requirements with an adequate buffer, or that the bank should maintain capital

or liquidity in excess of these requirements, or any other failure to meet these requirements, could intensify the effect of

these factors on the business model and results of the bank.

As described above and as described further in “Item 4: Regulation and Supervision” of this report under “Capital

Adequacy Requirements” and “Liquidity Requirements”, Deutsche Bank is, among other things, subject to increased

capital and tightened liquidity requirements under applicable law, including additional capital buffer requirements. If

Deutsche Bank fails to meet regulatory capital or liquidity requirements, the bank may become subject to enforcement

actions. In addition, any requirement to maintain or increase liquidity could lead the bank to reduce activities that pursue

revenue and profit growth.

In addition to such regulatory capital and liquidity requirements, Deutsche Bank is also required to maintain a sufficient

amount of instruments which are eligible to absorb losses in resolution with the aim of ensuring that failing banks can be

resolved without recourse to taxpayers’ money. These rules are referred to as “TLAC” (Total Loss Absorbing Capacity) and

“MREL” (minimum requirement for own funds and eligible liabilities) requirements, as more fully described in “Item 4:

Regulation and Supervision” of this report under “MREL Requirements”. The need to comply with these requirements

may affect Deutsche Bank’s business, financial condition and results of operations and in particular may increase its

financing costs.

Deutsche Bank may not have or may not be able to issue sufficient capital or other loss-absorbing liabilities to meet

these or other regulatory requirements. This could occur due to regulatory changes and other factors, such as the bank’s

inability to issue new securities which are recognized as regulatory capital or loss-absorbing liabilities under the

applicable standards, due to an increase of risk-weighted assets based on more stringent rules for the measurement of

risks or as a result of a future decline in the value of the Euro as compared to other currencies.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

If Deutsche Bank is unable to maintain sufficient capital to meet its aforementioned regulatory requirements, the bank

may become subject to enforcement actions and/or restrictions on the pay-out of dividends, share buybacks, payments

on other regulatory capital instruments, and discretionary compensation payments. In addition, any requirement to

increase risk-based capital ratios or the leverage ratio could lead the bank to adopt a strategy focusing on capital

preservation and creation over revenue generation and profit growth, including the reduction of higher margin risk-

weighted assets. If Deutsche Bank is unable to increase its capital ratios to the regulatory minimum in such a case by

raising new capital through the capital markets, through the reduction of risk-weighted assets or through other means,

the bank may be required to activate its Group recovery plan. If these actions or other private or supervisory actions do

not restore capital ratios to the required levels, and the bank is deemed to be failing or likely to fail, competent

authorities may apply resolution powers under the Single Resolution Mechanism (SRM) and applicable rules and

regulations, which could lead to a significant dilution of shareholders’ or even the total loss of the bank’s shareholders’ or

creditors’ investment.

Deutsche Bank is required to meet capital requirements to comply with rules on liquidity and risk management

separately for its local operations in different jurisdictions, in particular in the United States.

Federal Reserve Board rules set forth how the U.S. operations of certain foreign banking organizations (FBOs), such as

Deutsche Bank, are required to be structured, as well as the enhanced prudential standards that apply to its U.S.

operations. Under these rules, Deutsche Bank designated two separately capitalized top-tier U.S. intermediate holding

companies: DB USA Corporation and DWS USA Corporation (each, an "IHC") that hold substantially all of the FBO’s

ownership interests in its U.S. subsidiaries. For additional details on these requirements see Item 4: Regulation and

Supervision – Regulation and Supervision in the United States in this report. Each IHC is subject, on a consolidated basis,

to the risk-based and leverage capital requirements under the U.S. Basel III capital framework, capital planning and stress

testing requirements, U.S. liquidity buffer requirements and other enhanced prudential standards comparable to those

applicable to large U.S. banking organizations. The IHCs are also subject to supplementary leverage ratio requirements,

as well as requirements on the maintenance of TLAC and long-term debt. The IHCs and Deutsche Bank’s principal U.S.

bank subsidiary, Deutsche Bank Trust Company Americas, are also subject to liquidity coverage ratio and net stable

funding ratio requirements.

Deutsche Bank AG is required under the Dodd-Frank Act to prepare and submit a resolution plan (the “U.S. Resolution

Plan”) to the Federal Reserve Board and the Federal Deposit Insurance Corporation (the "Agencies") on a timeline

prescribed by the Agencies, alternating between filing a full plan and a targeted plan. The U.S. Resolution Plan must

demonstrate that Deutsche Bank AG has the ability to execute a strategy for the orderly resolution of its designated U.S.

material entities and operations. Deutsche Bank’s U.S. Resolution Plan describes the single point of entry strategy for

Deutsche Bank’s U.S. material entities and operations and prescribes that DB USA Corporation would provide liquidity

and capital support to its U.S. material entity subsidiaries and ensure their partial sale or solvent wind-down outside of

applicable resolution proceedings.

Deutsche Bank submitted its most recent full U.S. Resolution Plan submission by the October 1, 2025 due date and its

next U.S. Resolution Plan is a targeted plan due by July 1, 2028. If the Agencies were to jointly deem Deutsche Bank’s

U.S. Resolution Plan not credible and Deutsche Bank failed to remediate any designated deficiencies in the required

timeframe, the Agencies could impose restrictions on Deutsche Bank's U.S. operations, including its U.S. IHCs or U.S.

regulated subsidiaries, or require the restructuring or reorganization of businesses, legal entities, operational systems

and/or intra-company transactions which could negatively impact the bank’s operations and/or strategy. Additionally,

the Agencies could also subject Deutsche Bank to more stringent capital, leverage or liquidity requirements, or require

Deutsche Bank to divest certain assets or operations.

The IHCs are each subject, on an annual basis, to the Federal Reserve Board’s supervisory stress testing and capital plan

requirements. The IHCs are also each subject to the Federal Reserve Board’s Comprehensive Capital Analysis and Review

("CCAR"), which is an annual supervisory exercise that assesses the capital positions and planning practices of large bank

holding companies and IHCs. The CCAR process combines the CCAR quantitative assessment and the buffer

requirements in the Federal Reserve Board’s capital rules to create an institution-specific stress capital buffer (SCB)

requirement, which is floored at 2.5%. The SCBs for DB USA Corporation and DWS USA Corporation, based on the 2025

supervisory stress test results, are 11.5% and 5.3%, respectively. These SCBs became effective October 1, 2025 and will

remain in effect until 2027, when new requirements can be calculated based on models that take public feedback into

consideration. Increases in the SCB may require the bank to increase capital or restructure businesses in ways that may

negatively impact the bank’s operations and strategy.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

U.S. rules and interpretations, including those described above, could cause the bank to reduce assets held in the United

States, or to inject capital and/or liquidity into or otherwise change the structure of the bank’s U.S. operations, and could

also restrict the ability of the U.S. subsidiaries to pay dividends or the amount of such dividends. To the extent that the

bank is required to reduce operations in the United States or deploy capital or liquidity in the United States that could be

deployed more profitably elsewhere, these requirements could have an adverse effect on the bank’s business, financial

condition and results of operations.

It is unclear whether the U.S. capital and other requirements described above, as well as similar developments in other

jurisdictions, could lead to a fragmentation of supervision of global banks that could adversely affect the bank’s reliance

on regulatory waivers allowing the bank to meet capital adequacy requirements, large exposure limits and certain

organizational requirements on a consolidated basis only rather than on both a consolidated and non-consolidated basis.

Should the bank no longer be entitled to rely on these waivers, the bank would have to adapt and take the steps

necessary in order to meet regulatory capital requirements and other requirements on a consolidated as well as a non-

consolidated basis, which could result also in significantly higher costs and potential adverse effects on the bank’s

profitability and dividend paying ability.

Deutsche Bank may make business decisions related to regulatory capital, liquidity ratios and funds available for

distributions on its shares or regulatory capital instruments that may not be aligned with the interests of the holders of

such instruments. In accordance with applicable law and the terms of the relevant instruments, Deutsche Bank could

decide to make lower or no payments on its shares or regulatory capital instruments.

Deutsche Bank’s regulatory capital and liquidity ratios are affected by a number of factors, including decisions the bank

makes relating to its business and operations as well as the management of its capital position, risk-weighted assets and

balance sheet. These decisions could be impacted by external factors, such as regulations regarding the risk weightings

of the bank’s assets, commercial and market risks or the costs of its legal or regulatory proceedings. While Deutsche Bank

takes into account a broad range of considerations in its decisions, including the interests of the bank as a regulated

institution and those of its shareholders and creditors (particularly in times of weak earnings and increasing capital

requirements), regulatory requirements to build capital and liquidity may impact the bank’s decisions. Accordingly, in

making decisions in respect of capital and liquidity management, the bank is not required to adhere to the interests of

the holders of instruments issued that qualify for inclusion in regulatory capital, such as Deutsche Bank’s shares or

Additional Tier 1 capital instruments. The bank may decide to refrain from taking certain actions, including increasing

capital at a time when it is feasible to do so, even if failure to take such actions would result in a non-payment or a write-

down or other recovery- or resolution-related measure in respect of any of Deutsche Bank’s regulatory capital

instruments. Deutsche Bank’s decisions could cause the holders of such regulatory capital instruments to lose all or part

of the value of these instruments and the holders will not have any claim against Deutsche Bank relating to such

decisions.

In addition, the annual profit and distributable reserves which form an important part of the funds available to pay

dividends on shares and make payments on other regulatory capital instruments, as determined for each instrument

based on its terms or operation of law, are calculated on an unconsolidated basis generally in accordance with German

accounting rules set forth in the Commercial Code (Handelsgesetzbuch). Any adverse change in Deutsche Bank’s

financial position or profitability, or Deutsche Bank AG’s distributable reserves, each as calculated on an unconsolidated

basis, may have a material adverse effect on the bank’s ability to make dividend or other payments on these instruments.

In addition, profit or distributable reserves may be impacted in the future by litigation settlements in excess of existing

provisions and impairments that reduce the carrying value of subsidiaries on Deutsche Bank AG’s unconsolidated

balance sheet as a part of its annual review. Future impairments or other events that reduce profit or distributable

reserves on an unconsolidated basis could result in the bank making partial or no payments in the future.

Also, German law places limits on the extent to which annual profits and otherwise-distributable reserves, as calculated

on an unconsolidated basis, may be distributed to shareholders or the holders of other regulatory capital instruments,

such as Additional Tier 1 capital instruments. Subject to applicable law, Deutsche Bank has the broad discretion under

the applicable accounting principles to influence amounts relevant for calculating funds available for distribution. Such

decisions may impact the ability to make dividend or other payments under the terms of the bank’s regulatory capital

instruments.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

If resolvability or resolution measures were imposed on Deutsche Bank in accordance with European and German

legislation, Deutsche Bank’s business operations could be significantly affected. Any such measures could lead to losses

for shareholders and creditors of the bank.

Germany participates in the Single Resolution Mechanism (SRM), which centralizes at a European level the key

competences and resources for managing the failure of any bank in member states of the European Union participating

in the banking union. The SRM Regulation and the German Recovery and Resolution Act (Sanierungs- und

Abwicklungsgesetz), which implemented the EU Bank Recovery and Resolution Directive in Germany, require the

preparation of recovery and resolution plans for banks and grant broad powers to public authorities to intervene in a

bank which is failing or likely to fail. Resolution measures that could be imposed upon a bank in resolution may include

the transfer of shares, assets or liabilities of the bank to another legal entity, the reduction, including to zero, of the

nominal value of shares, the dilution of shareholders or the cancellation of shares outright, or the amendment,

modification or variation of the terms of the bank’s outstanding debt instruments, for example by way of a deferral of

payments or a reduction of the applicable interest rate. Furthermore, certain eligible unsecured liabilities, in particular

certain senior “non-preferred” debt instruments specified by the German Banking Act, may be written down, including to

zero, or converted into equity (commonly referred to as “bail-in”) if the bank becomes subject to resolution.

Resolution laws are also intended to eliminate, or reduce, the need for public support of troubled banks. Therefore,

financial public support for such banks, if any, would be used only as a last resort after having assessed and exploited, to

the maximum extent practicable, the resolution powers, including a bail-in. The taking of measures by the competent

authority to remove impediments to resolvability could materially affect the bank’s business operations. Resolution

actions could furthermore lead to a significant dilution of shareholders or even the total loss of shareholders’ or creditors’

investment.

Other regulatory reforms that have been adopted or proposed – for example, extensive new regulations governing

derivatives activities, compensation, bank levies, deposit protection and data protection – may materially increase

Deutsche Bank’s operating costs and negatively impact its business model.

Beyond capital requirements and the other requirements discussed above, Deutsche Bank is affected, or expects to be

affected, by various additional regulatory reforms, including, among other things, regulations governing its derivatives

activities, compensation, bank levies, deposit protection and data protection.

Deutsche Bank is subject to restrictions on compensation including caps on bonuses that may be awarded to “material

risk takers” and other employees as defined therein and in the German Banking Act and other applicable rules and

regulations such as the Remuneration Regulation for Institutions (Institutsvergütungsverordnung). Such restrictions on

compensation, whether by law or pursuant to any guidelines issued by the EBA, could put the bank at a disadvantage to

its competitors in attracting and retaining talented employees, especially compared to those outside the European Union

that are not subject to these caps and other constraints.

Bank levies are provided for in the EU member states participating in the SRM, including, among others, Germany. Since

the target level of the Single Resolution Fund (SRF) of 1% of insured deposits of all banks in member states participating

in the SRM was reached at the end of 2023, no ex-ante contributions to the SRF were required in 2025. Similarly, the

bank does not anticipate making contributions to the SRF in 2026. This assumption is subject to considerable

uncertainty, however, and the bank will closely monitor developments that may impact its financial obligations to the

SRF. In addition, Deutsche Bank may be required to pay bank levies in countries not participating in the SRM, such as the

United Kingdom.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Furthermore, Deutsche Bank must make contributions to the German Statutory Deposit Guarantee and Investor

Compensation Schemes under the recast European Union Deposit Guarantee Schemes Directive (“DGS Directive”) and

the European Union Directive on Investor Compensation Schemes. The German Statutory Deposit Protection Scheme

requires German banks to maintain a prefunding level of 0.8% of the covered deposits. This level has been reached by

July 2024, however, further levies may be imposed subsequent to a compensation event for the purpose of replenishing

the Deposit Guarantee Scheme’s resources. Deutsche Bank also participates in the German voluntary deposit protection

scheme operated by the Deposit Protection Fund (Einlagensicherungsfonds) for private banks in Germany, which is

funded through contributions by its members. While the total impact of future levies cannot currently be quantified,

there could also be certain market conditions or events that give rise to higher-than-expected contributions required by

members, which could have a material adverse effect on the bank’s business, financial condition and results of operations

in future periods. Failure of banks, resolution measures and a decline of the value of the assets held by the SRM or by the

relevant Deposit Guarantee Scheme can cause an increase of contributions in order to replenish the shortfall.

Deutsche Bank is subject to the General Data Protection Regulation (GDPR) which has increased its regulatory

obligations in connection with the processing of personal data, including requiring compliance with the GDPR’s data

protection principles, the increased number of data subject rights and strict data breach notification requirements. The

GDPR grants broad enforcement powers to supervisory authorities, including the potential to levy significant fines for

non-compliance, and provides for a private right of action for individuals who are affected by a violation of the GDPR.

Compliance with the GDPR requires investment in appropriate technical and organizational measures and the bank may

be required to devote significant resources to data protection on an ongoing basis. In the event that the bank is found to

have not met the standards required by the GDPR, the bank may incur damage to its reputation and the imposition by

data protection supervisory authorities of significant fines or restrictions on its ability to process personal data, and the

bank may be required to defend claims for compensation brought by affected individuals, all of which could have a

material adverse effect on the bank.

More generally, there continues to be scrutiny from both EU and non-EU authorities over financial services firms’

compliance with anti-money laundering (AML) and counter-terrorism financing rules, which has led to a number of

regulatory proceedings, criminal prosecutions and other enforcement action, including the imposition of significant fines,

against firms in various jurisdictions.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risks Relating to the Bank’s Internal Control Environment

A robust and effective internal control environment and adequate infrastructure (comprising people, policies and

procedures, controls, testing, IT systems and data) are necessary to ensure the bank conducts its business and performs

its processes in compliance with applicable laws, regulations, and associated supervisory expectations. While Deutsche

Bank seeks to enhance the effectiveness of its internal control environment to align with updated regulatory

requirements and to close gaps identified by the bank and/or by regulators and monitors, if progress is slower than

anticipated or the bank fails to deliver durable improvements, Deutsche Bank’s reputation, regulatory position and

financial results could be adversely affected.

Deutsche Bank’s businesses require effective controls to process and monitor a wide range of complex, high-volume

transactions across diverse markets, and the effectiveness of the controls is dependent on the strength of the bank's

policies, control testing protocols, IT systems and employee capabilities. If these systems do not identify, monitor,

aggregate, measure, mitigate and report all risks critical for comprehensive risk management and regulatory reporting,

Deutsche Bank's results of operations and regulatory position could be negatively impacted.

Although improvements have been made, certain elements of the bank's control environment and supporting

infrastructure remain below target state, with legacy technology, data fragmentation and manual processes persisting in

some areas. These conditions can impede the timeliness and quality of internal and regulatory reporting and hinder

consistent risk aggregation across businesses and legal entities. The bank is executing multi-year initiatives to simplify

architecture, strengthen data governance and automate controls, but structural complexity, dependency on end-user

tools and uneven system integration continue to pose operational risks. Materialization of these risks could result in

disruptions to core processes, delay in implementation of strategic change programs, and reduced operational resilience

to challenges in the external operating environment, resulting in a negative impact on Deutsche Bank from a client,

regulatory, and reputational risk perspective.

Retaining specialist expertise across control disciplines, including information technology and security, financial crime

and data governance, remains challenging, and increased reliance on third-party and cloud service providers introduces

additional oversight and resilience considerations. Any inability to retain key personnel or effectively manage third-party

risks may impair the bank's ability to maintain sound controls or close regulatory findings.

Deutsche Bank's principal regulators, including BaFin, ECB, UK Prudential Regulation Authority and Federal Reserve

Board, along with Deutsche Bank's Management Board and Group Audit function, continue to review internal controls

and infrastructure closely. These assessments have identified enhancements needed in areas such as financial crime,

information security, IT resiliency, transaction processing, data management and credit processes. While remediation is

underway, the breadth of these programs and their interdependencies mean execution risk remains elevated until

improvements are completed, validated and operate effectively over time.

To address these risks, the bank is investing in technology modernization and resiliency, including cloud adoption,

advanced analytics to enhance risk and control testing, however it cannot be assured that these measures will be

successfully integrated or successfully remediate risks. While these capabilities may support improved oversight, they

introduce new risks such as data quality, AI governance and cyber resilience that require strong controls and assurance.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

The bank’s AML and KYC processes and controls aimed at preventing misuse of the bank's products and services to

commit financial crime have been and continue to be the subject of regulatory reviews, investigations, and enforcement

actions in several jurisdictions. If Deutsche Bank is unable to significantly improve its infrastructure and control

environment by the set deadlines, the bank’s results of operations, financial condition and reputation could be materially

and adversely affected.

In September 2018, BaFin ordered Deutsche Bank to implement internal safeguards and comply with general due

diligence obligations to prevent money laundering and terrorist financing. In February 2019, BaFin extended the order

with regards to the review of its group-wide risk management processes in correspondent banking and adjust them as

necessary. In April 2021, BaFin further expanded its order, requiring additional internal safeguards and sustainable

compliance with due diligence obligations, including those for correspondent relationships. The April 2021 order was

subsequently extended to include enhancements to the bank’s transaction monitoring systems. In 2023, BaFin issued an

additional order instructing Deutsche Bank to implement specific improvements to data processing systems for

transaction monitoring and warned of potential financial penalties in case of non-fulfillment. To monitor the

implementation of the ordered measures, BaFin appointed a Special Representative in 2018, whose mandate was

prolonged following each order extension to ensure continued monitoring and progress assessment. This mandate

concluded on October 30, 2024. The bank continues to fully cooperate with BaFin and remains committed to allocating

the necessary resources to implement the remaining measures within the deadlines.

In July 2023, Deutsche Bank, Deutsche Bank AG New York Branch, DB USA Corporation, Deutsche Bank Trust Company

Americas and DWS USA Corporation entered into a consent order and written agreement with the Federal Reserve Board

concerning adherence to prior orders and settlements related to sanctions and embargoes and AML compliance, and

remedial agreements and obligations related to risk management issues. The 2023 consent order alleges insufficient and

delayed implementation of the post-settlement sanctions and embargoes and AML control enhancement undertakings

required by prior consent orders the bank entered into with the Federal Reserve Board in 2015 and 2017. The 2023

consent order further provides that the material failure to remediate the unsafe and unsound practices or violations

described therein may require additional and escalated formal actions by the Federal Reserve Board against Deutsche

Bank, including additional penalties or additional affirmative corrective actions. In the event the bank is unable to timely

complete the sanctions and embargoes and AML control enhancement undertakings required by the Federal Reserve

Board, the damages could be substantial and the impact on the bank’s results of operations, financial condition and

reputation could be material.

If Deutsche Bank is unable to improve its infrastructure and control environment to the satisfaction of the Federal

Reserve Board, the bank’s results of operations, financial condition and reputation could be materially and adversely

affected. Regulators can impose fines or require the bank to reduce its exposure to or terminate certain kinds of products

or businesses or relationships with counterparties or regions. The bank may also face additional legal proceedings,

investigations or regulatory actions in the future, including in other jurisdictions, with material impact on the bank´s

business and profitability. These could, depending on the extent of any resulting requirements, significantly challenge

the bank’s reputation and its ability to operate profitably under its current business model.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risks Relating to Technology, Data and Innovation

The speed of innovation and new market entrants may increase competition, disrupt Deutsche Bank's businesses and

increase investment costs.

Digitalization and the speed of innovation in areas such as AI may offer market entry opportunities for new competitors

such as cross-industry entrants, global tech companies and financial technology companies. In addition, banking

competitors may develop their business models to enter the bank’s core markets with largely digital offerings. Therefore,

Deutsche Bank expects its businesses to have an increased need for investments in digital products, AI and process

resources. If the above investments are not made, or if Deutsche Bank is not otherwise able to compete with these new

entrants, there is a risk Deutsche Bank could lose market share, which could have a material adverse effect on its

financial results.

Through the bank's strategic partnership with Google Cloud, Deutsche Bank is migrating parts of its application

landscape to the public cloud with the goal of improving IT flexibility and resilience. The adoption of public cloud

services remains an area of significant regulatory interest, and the bank must ensure and adopt applicable standards of

data privacy and security to protect client and bank information. Failure to do so can compromise client trust, lead to

financial losses and result in regulatory penalties, litigation and compensation obligations.

AI has the potential to be a transformative technology for the bank, while at the same time posing new challenges such

as hallucination or bias and thereby requiring validation of accuracy and explainability, as well as data privacy and

sovereignty. The emergence of agentic AI solutions has the potential to enable autonomous decision making within

processes, increasing the probability of undetected mistakes. Deutsche Bank has has incorporated AI risk into its control

framework, but as these technologies evolve additional risks to the bank may arise. For example, autonomous AI agents

could distort or override defined objectives and optimize in ways that undermine regulatory, ethical, or operational

safeguards, such as prioritizing speed or performance metrics over compliance obligations, fairness standards, or critical

quality controls. If Deutsche Bank does not address these emerging risks, it may face compliance issues, operational

inefficiencies and potential losses, along with reputational risks that could weaken the market’s confidence in Deutsche

Bank’s ability to apply responsible use of AI.

Deutsche Bank actively tracks threats which have the potential to exploit security vulnerabilities, including activities by

nation-state actors and evolving risks, such as those introduced by technological advancements in artificial intelligence

and quantum computing. The bank also continues to closely observe common attack scenarios, including ransomware

and denial of service. Although Deutsche Bank maintains insurance for such cyber events, there can be no assurance that

such coverage will be adequate to cover all losses or liabilities arising from a cyber event.

Data management risk can arise if there are weaknesses in processes for how data is collected, stored, processed,

governed and used. This can negatively impact financial, reputational, or regulatory outcomes for the bank or its

stakeholders. The bank’s ability to make informed decisions, personalize services, drive innovation and deploy AI at scale

depends on having trusted, accessible, and well-governed data across the organization. Deutsche Bank has established

an organization-wide data management function and is now focused on implementing a robust data management

framework. However, residual data management risks include potential gaps in data quality, system integration, and

regulatory non-compliance that may persist during or after the transition.

Deutsche Bank operates in a highly regulated environment that is continuously evolving, requiring our technology

landscape to adapt and remain aligned with these regulatory changes. Recent changes in the regulations such as the

Digital Operational Resilience Act (DORA) may require additional efforts and reprioritization of certain tasks. Failure in

doing so creates the risk of non-compliance with new regulations, which could lead to fines, litigation and other

enforcement actions, as well as reputational damage.

Major technology transformations in the bank’s business and infrastructure areas are executed via dedicated initiatives.

However, there are risks in executing these programs, such as, talent and financial constraints, dependencies on other

programs and key deliverables, extended implementation timelines or adverse change related impacts activity on the

control environment and functionality issues within upgraded applications or their underlying technologies. Failure to

adequately and timely implement such major technology transformations could have a material adverse effect on

Deutsche Bank’s business and results of operations.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Risks Relating to Litigation, Regulatory Enforcement Matters, Investigations and Tax Examinations

Deutsche Bank operates in a highly regulated and litigious environment, potentially exposing the bank to liability and

other costs, the amounts of which may be substantial and difficult to estimate, as well as to legal and regulatory

sanctions and reputational harm.

The financial services industry is among the most highly regulated industries. The bank’s operations throughout the

world are regulated and supervised by the central banks and regulatory authorities in the jurisdictions in which Deutsche

Bank operates. In recent years, regulation and supervision in a number of areas has increased, and regulators, law

enforcement authorities, governmental bodies and others have sought to subject financial services providers to

increasing oversight and scrutiny, which in turn has led to additional regulatory investigations or enforcement actions

which are often followed by civil litigation. There has been a steep escalation in the severity of the terms which

regulatory and law enforcement authorities have required to settle legal and regulatory proceedings against financial

institutions, with settlements in recent years including unprecedented monetary penalties as well as criminal sanctions.

As a result, Deutsche Bank may continue to be subject to increasing levels of liability and regulatory sanctions and may

be required to make greater expenditures and devote additional resources to addressing these liabilities and sanctions.

Regulatory sanctions may include status changes to local licenses or orders to discontinue certain business practices.

The bank and its subsidiaries are involved in various litigation proceedings, including civil class action lawsuits, arbitration

proceedings and other disputes with third parties, as well as regulatory proceedings and investigations by both civil and

criminal authorities in jurisdictions around the world. While Deutsche Bank has made progress in resolving litigation and

regulatory enforcement matters, remaining unresolved or new litigation, enforcement or similar matters pending against

the bank could result in significant costs against Deutsche Bank in the near to medium term and could adversely affect

its business, financial condition and results of operations, if these matters develop in an adverse manner. Litigation and

regulatory matters are subject to many uncertainties, and the outcome of individual matters is not predictable with

assurance. The bank may settle litigation or regulatory proceedings prior to a final judgment or determination of liability.

Deutsche Bank may do so for a number of reasons, including to avoid the cost, management efforts or negative business,

regulatory or reputational consequences of continuing to contest liability, even when the bank believes it has valid

defenses to liability. Deutsche Bank may also do so when the potential consequences of failing to prevail would be

disproportionate to the costs of settlement. Furthermore, it may, for similar reasons, reimburse counterparties for their

losses even in situations where the bank does not believe it is compelled to do so. The financial impact of legal risks

might be considerable but may be difficult or impossible to estimate and to quantify, so that amounts eventually paid

may exceed the amount of provisions made or contingent liabilities assessed for such risks.

Guilty pleas by or convictions of the bank or its affiliates in criminal proceedings, or regulatory or enforcement orders,

settlements or agreements to which the bank or its affiliates become subject, may have consequences that have adverse

effects on certain of its businesses. Moreover, if these matters are resolved on terms that are more adverse to the bank

than expected, in terms of the costs or necessary changes to the bank’s businesses, or if related negative perceptions

concerning its business and prospects and related business impacts increase, Deutsche Bank may not be able to achieve

its strategic objectives or may be required to change them.

Actions currently pending against Deutsche Bank or its current or former employees may not only result in judgments,

settlements, fines or penalties, but may also cause substantial reputational harm to the bank. The risk of damage to the

bank’s reputation arising from such proceedings is also difficult or impossible to quantify.

Regulators have increasingly sought admissions of wrongdoing in connection with settlement of matters brought by

them. This could lead to increased exposure in subsequent civil litigation or in consequences under so-called "bad actor"

laws, in which persons or entities determined to have committed offenses under some laws can be subject to limitations

on business activities under other laws, as well as adverse reputational consequences. In addition, the U.S. Department of

Justice (DOJ) conditions the granting of cooperation credit in civil and criminal investigations of corporate wrongdoing

on the company involved having provided to investigators all relevant facts relating to the individuals responsible for the

alleged misconduct. This policy may result in increased fines and penalties if the DOJ determines that the bank has not

provided sufficient information about applicable individuals in connection with an investigation. Other governmental

authorities could adopt similar policies.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

In addition, the financial impact of legal risks arising out of matters similar to some of those the bank faces have been

very large for a number of participants in the financial services industry, with fines and settlement payments greatly

exceeding what market participants may have expected and, as noted above, escalating steeply in recent years to

unprecedented levels. The experience of others, including settlement terms, in similar cases is among the factors the

bank takes into consideration in determining the level of provisions the bank maintains in respect of these legal risks.

Developments in cases involving other financial institutions in recent years have led to greater uncertainty as to the

predictability of outcomes and could lead Deutsche Bank to add provisions. Moreover, if these matters are resolved on

terms that are more adverse to the bank than expected, in terms of the costs or necessary changes to the bank’s

businesses, or if related negative perceptions concerning its business and prospects and related business impacts

increase, Deutsche Bank may not be able to achieve its strategic objectives or may be required to change them. In

addition, the costs of the bank’s investigations and defenses relating to these matters are themselves substantial. Further

uncertainty may arise as a result of a lack of coordination among regulators from different jurisdictions or among

regulators with varying competencies in a single jurisdiction, which may make it difficult for the bank to reach concurrent

settlements with each regulator. Should Deutsche Bank be subject to financial impacts arising out of litigation and

regulatory matters to which the bank is subject in excess of those it has calculated in accordance with its expectations

and the relevant accounting rules, provisions in respect of such risks may prove to be materially insufficient to cover

these impacts. This could have a material adverse effect on the bank’s results of operations, financial condition or

reputation as well as on the bank’s ability to maintain capital, leverage and liquidity ratios at levels expected by market

participants and regulators. In such an event, the bank could find it necessary to reduce its risk-weighted assets

(including on terms disadvantageous to the bank) or substantially cut costs to improve these ratios, in an amount

corresponding to the adverse effects of the provisioning shortfall.

Deutsche Bank is currently involved in civil proceedings in connection with its voluntary takeover offer for the acquisition

of all shares of Postbank. The extent of the bank’s financial exposure to this matter, including any exposure in excess of

the provision the bank has taken, could be material, and the bank’s reputation may be harmed.

In 2010, Deutsche Bank announced the decision to make a voluntary takeover offer for the acquisition of all shares in

Deutsche Postbank AG ("Postbank"). Deutsche Bank offered Postbank shareholders a consideration of € 25 for each

Postbank share. This offer was accepted for a total of approximately 48.2 million Postbank shares.

A significant number of former shareholders of Postbank who had accepted the takeover offer brought claims against

Deutsche Bank alleging that Deutsche Bank had been obliged to make a mandatory takeover offer at the latest, in 2009.

The plaintiffs allege that the consideration offered for the shares in Postbank needed to be raised to € 57.25 or even €

64.25 per share. As of December 31, 2025, Deutsche Bank has reached settlements with 90% of the plaintiffs’ claims by

value in the litigation (calculated based on the asserted shareholdings) and retains a provision for the residual plaintiff

claims of € 112 million (including interest). For additional details see Note 27 – “Provisions” in the consolidated financial

statements.

The legal question of whether Deutsche Bank had been obliged to make a mandatory takeover offer for all Postbank

shares prior to its 2010 voluntary takeover may impact two pending appraisal proceedings (Spruchverfahren). These

proceedings were initiated by former Postbank shareholders with the aim to increase the cash compensation of € 35.05

paid in connection with the squeeze-out of Postbank shareholders in 2015 and the cash compensation of € 25.18 offered

and annual compensation of € 1.66 paid in connection with the execution of a domination and profit and loss transfer

agreement (Beherrschungs- und Gewinnabführungsvertrag) between DB Finanz-Holding AG (now DB Beteiligungs-

Holding GmbH) and Postbank in 2012. The compensation of € 25.18 in connection with the domination and profit and

loss transfer agreement was accepted for approximately 0.5 million Postbank shares. The compensation of € 35.05 paid

in connection with the squeeze-out in 2015 was relevant for approximately 7 million Postbank shares.

The applicants in the appraisal proceedings claim that a potential obligation of Deutsche Bank to make a mandatory

takeover offer for Postbank at an offer price of € 57.25 should be decisive when determining the adequate cash

compensation in the appraisal proceedings. The Regional Court Cologne had originally followed this legal view of the

applicants in two resolutions. In a decision dated June 2019, the Regional Court Cologne expressly rejected this legal

view in the appraisal proceedings in connection with the execution of a domination and profit and loss transfer

agreement and concluded that whether Deutsche Bank was obliged to make a mandatory offer for all Postbank shares

prior to its voluntary takeover offer in 2010 shall not be relevant for determining the appropriate cash compensation.

Deutsche Bank expect the Regional Court Cologne will take the same legal position in the appraisal proceedings in

connection with the squeeze-out.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

In October 2020, the Regional Court Cologne handed down a decision in the appraisal proceeding concerning the

domination and profit and loss transfer agreement according to which the annual compensation pursuant to Sec. 304

German Stock Corporation Act shall be increased by € 0.12 to € 1.78 per Postbank share and the compensation pursuant

to Sec. 305 of the German Stock Corporation Act shall be increased from € 25.18 to € 29.74 per Postbank share. The

increase of the settlement amount is of relevance for approximately 0.5 million former Postbank shares whereas the

increase of the annual compensation is of relevance for approximately 7 million former Postbank shares. Deutsche Bank

as well as the applicants have lodged an appeal against this decision which remains outstanding. On December 12, 2025,

the Higher Regional Court Düsseldorf (HRC) issued an indicative order (“Hinweisbeschluss”) in the appraisal proceedings

regarding the domination and profit and loss transfer agreement concluded in 2012. The HRC rejected the argument of

the applicants that the initially paid compensation of € 25.18 per share should be increased to the allegedly appropriate

offer price under the 2010 takeover offer (of at least € 57.25 per share).

Additionally, the HRC requested a further expert report on specific valuation aspects and made a settlement proposal

which is lower than the compensation fixed by the Regional Court Cologne ruling (proposed compensation of € 28.00

instead of € 29.74 per share ruled by the Regional Court Cologne). In January 2026, the bank stated its consent to the

settlement proposal of the HRC, however, not all applicants consented, as required to reach a settlement ending the

appraisal proceeding. Therefore, the HRC appointed a new independent expert on February 4, 2026. The expert has been

asked to provide a supplementary opinion on the remaining valuation aspects identified by the HRC. The HRC further

instructed the expert to prepare a revised calculation of the appropriate annual compensation on the basis of the

supplementary valuation opinion.

The extent of Deutsche Bank’s financial exposure to these matters, including beyond provisions the bank has taken,

could be material and the bank’s reputation may be harmed.

Deutsche Bank is currently the subject of industry-wide inquiries and investigations by regulatory and law enforcement

authorities relating to transactions of clients in German shares around the dividend record dates for the purpose of

obtaining German tax credits or refunds in relation to withholding tax levied on dividend payments (so-called cum-ex

transactions). In addition, the bank is exposed to potential tax liabilities and to the assertion of potential civil law claims

by third parties, e.g., former counterparties, custodian banks, investors and other market participants, including as a

consequence of criminal judgements in criminal proceedings in which the bank is not directly involved. The eventual

outcome of these matters is unpredictable and may materially and adversely affect Deutsche Bank’s results of

operations, financial condition and reputation.

Deutsche Bank Group is subject to ongoing criminal investigations by the Public Prosecutor in Cologne

(Staatsanwaltschaft Köln, “CPP”) and civil law claims in relation to cum-ex. In addition, current and former Deutsche Bank

employees and seven former Management Board members are under criminal investigation by the CPP, as are unnamed

personnel of former Deutsche Postbank AG. Ongoing media attention surrounding the cum-ex topic as well as any future

criminal judgement that is unfavorable to the bank or its former employees and Management Board members could

create reputational risks. The imposition of fines and the disgorgement of profits or criminal confiscations could have a

material adverse effect on the bank’s financial condition, results of operations and reputation.

The bank is further exposed to the assertion of potential tax and civil law recourse and compensation claims by German

tax authorities and third parties.

The risks arising from the cum-ex topic are difficult to quantify and the likelihood of these risks materializing is hard to

predict. In the event that Deutsche Bank is eventually liable under the civil law claims already asserted or under claims

that will potentially be asserted by third parties in the future, this may materially and adversely affect the bank’s financial

condition or results of operations. For additional details on the specific cases, see Note 27 – “Provisions” in the

consolidated financial statements.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Deutsche Bank is involved in proceedings with regulatory and law enforcement authorities concerning its anti-financial

crime controls, including in the United States and Germany. In the event that violations of law or regulation are found to

have occurred, legal and regulatory sanctions in respect thereof may materially and adversely affect the bank’s results of

operations, financial condition and reputation.

Deutsche Bank is involved in proceedings with regulatory and law enforcement authorities concerning its anti-financial

crime controls over the past several years, both generally and in connection with specific clients, counterparties or

incidents, including in the United States and Germany. Among the areas within the scope of these inquiries are client

onboarding and KYC processes, transaction monitoring systems and procedures, processes concerning the decision to

file or not to file a suspicious activity report, escalation procedures, and other related processes and procedures. In the

event that violations of law or regulation are found to have occurred, legal and regulatory sanctions in respect thereof

may materially and adversely affect the bank’s results of operations, financial condition and reputation.

The Frankfurt prosecutor is currently conducting investigations in the context of anti-financial-crime control related

allegations, particularly regarding late filing of suspicious activity reports. Deutsche Bank’s offices were searched by the

Frankfurt prosecutor in connection with these investigations.

Deutsche Bank is under continuous examination by tax authorities in the jurisdictions in which it operates. Tax laws are

increasingly complex and are evolving. The cost to the bank arising from the resolution of routine tax examinations, tax

litigation and other forms of tax proceedings or tax disputes may increase and may adversely affect the bank’s business,

financial condition and results of operation.

Deutsche Bank is under continuous examination by tax authorities in the jurisdictions in which it operates. Tax laws are

becoming increasingly more complex. In the current political and regulatory environment, tax administrations' and

courts' interpretation of tax laws and regulations and their application are evolving, and scrutiny by tax authorities has

intensified. Wide ranging and continuous changes in the principles of international taxation emanating from the OECD's

Base Erosion and Profit Shifting agenda are generating significant uncertainties for the bank and its subsidiaries and may

result in an increase in instances of tax disputes or instances of double taxation, as member states may take different

approaches in transposing these requirements into national law or may choose to implement unilateral measures. This

includes, for example, the OECD global minimum taxation rules which have been in effect since tax year 2024. Tax

administrations, including Germany, have also been focusing on the eligibility of taxpayers for reduced withholding taxes

on dividends in connection with certain cross-border lending or derivative transactions. Some uncertainties also remain

in the application of the Base Erosion Anti-Abuse Tax provisions introduced by the U.S. tax reform in 2017, the corporate

alternative minimum tax enacted by the U.S. Inflation Reduction Act of 2022 and the provisions of the U.S. One Big

Beautiful Bill Act of 2025. These developments have led to an increase in the number of tax periods that remain open

and therefore subject to potential adjustment. As a result, the cost to the bank arising from the resolution of routine tax

examinations, tax litigation and other forms of tax proceedings or tax disputes, as well as from rapidly changing and

increasingly more complex and uncertain tax laws and principles, may increase and may adversely affect the bank’s

business, financial condition and results of operation.

Deutsche Bank’s subsidiary, Deutsche Bank Polska S.A., is subject to numerous demands for reimbursement in respect of

mortgage loans agreements in foreign currency, based on allegations that they are unfair and invalid.

Starting in 2016, certain clients of Deutsche Bank Polska S.A. have reached out to Deutsche Bank Polska S.A. alleging

that their mortgage loan agreements in foreign currency include unfair clauses and are invalid. These clients have

demanded reimbursement of the alleged overpayments under such agreements totaling over € 1.1 billion with over

8,791 civil claims having been commenced in Polish courts as of December 31, 2025. These cases are an industry wide

issue in Poland and other banks are facing similar claims. The bank’s total portfolio provision for this matter, which

includes both Swiss Franc and EUR mortgage cases, is € 736 million as of December 31, 2025. The outcome of this

matter is uncertain and future changes to assumptions included in the model or resolutions of claims could result in a

significant increase in the provision beyond the amount established, which could materially and adversely affect the

bank's results of operations or financial condition.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Deutsche Bank’s Malaysian subsidiary is currently involved in civil proceedings in connection with transactions relating to

1Malaysia Development Berhad (1MDB). The extent of the bank’s financial exposure to this matter could be material, and

the bank’s reputation may be harmed.

In 2021, 1MDB commenced proceedings at the Malaysian Courts against Deutsche Bank Malaysia Berhad (DBMB) with

respect to three wire transfers carried out by DBMB on 1MDB’s behalf in 2009 and 2011. 1MDB claims damages in the

amount of U.S. $ 1.1 billion (representing the total amount of the transactions) excluding interest claimed from the date

of the wire transfers, which could be significant due to the long duration since the transactions. At a hearing on July 11,

2025, the Court declined DBMB’s application for summary dismissal on time-bar grounds, ruling that the issue requires a

full trial which is currently scheduled for October and December 2026. The risks arising from this matter are uncertain

and the likelihood of these risks materializing is hard to predict, but could negatively affect Deutsche Bank's financial

results.

Guilty pleas by or convictions of the bank or its affiliates in criminal proceedings, or regulatory or enforcement orders,

settlements or agreements to which the bank or its affiliates become subject, may have consequences that have adverse

effects on certain of Deutsche Bank’s businesses.

Deutsche Bank and its affiliates have been and are subjects of criminal and regulatory enforcement proceedings. Guilty

pleas or convictions against the bank or its affiliates, or regulatory or enforcement orders, settlements or agreements to

which the bank or its affiliates become subject, could lead to the bank’s ineligibility to conduct certain business activities.

In particular, such guilty pleas or convictions could cause its asset management affiliates to no longer qualify as

“qualified professional asset managers” (QPAMs) under the QPAM Prohibited Transaction Exemption under the U.S.

Employee Retirement Income Security Act of 1974 (ERISA), which exemption is relied on to provide asset management

services to certain pension plans in connection with certain asset management strategies. While there are a number of

statutory exemptions and numerous other administrative exemptions that the bank’s asset management affiliates may

use to trade on behalf of ERISA plans, and in many instances they may do so in lieu of relying on the QPAM exemption,

loss of QPAM status could cause customers who rely on such status (whether because they are legally required to do so

or because the bank has agreed contractually with them to maintain such status) to cease to do business or refrain from

doing business with the bank and could negatively impact its reputation more generally. For example, clients may

mistakenly see the loss as a signal that the bank’s asset management affiliates are somehow no longer approved as asset

managers generally by the U.S. Department of Labor (DOL), the agency responsible for ERISA, and cease to do business

or refrain from doing business with the bank for that reason. This could have a material adverse effect on the bank’s

results of operations, particularly those of its asset management business in the United States. The DOL has granted an

individual exemption permitting certain of the bank’s affiliates to retain their QPAM status despite both the conviction of

DB Group Services (UK) Limited and the conviction of Deutsche Securities Korea Co. (the latter conviction has been

subsequently overturned). This exemption has been extended by the DOL until April 17, 2027, which is the end of the

disqualification period. The extension would terminate if, among other things, Deutsche Bank or its affiliates were to be

convicted of crimes in other matters.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Climate Change and Other Risks Relating to Environmental, Social and Governance (ESG) Related Matters

The impacts of rising global temperatures, nature degradation and the associated policy, technology and behavioral

changes required to limit global warming to no greater than 1.5 °C above pre-industrial levels have led to emerging

sources of financial and non-financial risks. These include the physical risk impacts from extreme weather events, and

transition risks as carbon-intensive sectors are faced with higher costs, potentially reduced demand and restricted access

to financing. More rapid than currently expected emergence of transition and/or physical climate and nature risks may

lead to increased credit and market losses as well as operational disruptions due to impacts on vendors and the bank’s

own operations.

Instances of extreme weather events have increased in frequency and severity. Future extreme weather events could

lead to higher credit loss provisions, property loss, rising insurance costs and operational resilience risks. Extreme

weather events can also impact Deutsche Bank’s revenue generating capabilities and costs and result in impairments of

non-financial assets.

Financial institutions are facing increased scrutiny on climate and ESG-related issues from governments, regulators,

shareholders and other bodies (including non-governmental organizations). Banks must navigate an increasingly complex

and heterogeneous policy environment with U.S. led challenges to their collaborative efforts to reduce greenhouse gas

emissions leading to accusations of unlawful practice and anti-trust violations with potential for restrictions on access to

certain clients and potential litigation. The Net Zero Banking Alliance has seen the departure of U.S. and Canadian peers

and subsequently European peers in response to these concerns. In contrast, many organizations and individuals expect

banks to support the transition to a lower carbon economy, to limit nature-related risks such as biodiversity and habitat

loss, and to protect human rights. The emergence of significantly diverging (and sometimes conflicting) ESG regulatory

and/or disclosure standards across jurisdictions could lead to higher costs of compliance and risks of failing to meet

requirements. Of note is the interconnectedness between transition, other environmental, and social risks where

supporting the transition could lead to increased demand for transition minerals which are obtained via mining.

The IEA’s 2025 World Energy Outlook (WEO) indicates that the NZE2050 pathway now involves a prolonged overshoot of

the 1.5 °C target, with warming peaking near 1.65 °C around 2050 and only returning to 1.5 °C by 2100 through carbon

removal. This reflects a global economy which is transitioning at a slower pace which reduces transition risk in the short

term but increases the risk of a disorderly transition over the longer term. Furthermore, it creates tension between the

updated International Energy Agency Net Zero Emissions (IEA NZE) decarbonization pathways which are less ambitious

and the existing voluntary decarbonization commitments calibrated against earlier WEO reports. Deutsche Bank

considers its net zero targets as one of the key climate risk management tools and the bank intends to periodically review

the targets in line with the latest science and economic progress, and if necessary, may revise its targets against the

backdrop of legal or regulatory changes. In the case that revised interim targets are less ambitious, this will increase the

risk that third parties raise allegations of greenwashing, including through civil litigation, regulatory investigations or

enforcement actions.

In the United States, state legislators and regulators are issuing potentially conflicting laws and certification

requirements regarding ESG matters, reflecting a polarized political context within the U.S. This may result in the risk of

loss of business or licenses if the bank cannot meet the certification requirements, while also requiring the bank to

analyze and balance positions.

Certain jurisdictions have begun to develop anti-ESG measures including requiring financial institutions that wish to do

business with them to certify their non-adherence to aspects of the transition agenda. Failing to comply with these

requirements may result in the termination of existing business and the inability to conduct new business with those

jurisdictions, while complying may lead to reputational risks and potential lawsuits. The scope and enforceability of such

requirements, and their application to the bank, remain uncertain.

Deutsche Bank is rated by a number of ESG rating providers, with the ratings increasingly utilized as criteria to determine

eligibility for sustainable investments and to assess management of ESG risks and opportunities. Should the bank’s

ratings materially deteriorate, this could lead to negative reputational impacts.

Data, methodologies and industry standards for measuring and assessing climate and other environmental risks are still

evolving or, in certain cases, are not yet available. This, combined with a lack of comprehensive and consistent climate

and other environmental risk disclosures by its clients, means that the bank, in line with the wider industry, is heavily

reliant on proxy estimates and/or proprietary approaches for risk assessment and modelling and for the bank’s climate

and environmental risk management disclosures. The high degree of uncertainty that this creates increases the risk that

third parties may assert that the bank’s sustainability-related disclosures constitute greenwashing. In addition to the

reputational risks associated with such allegations, competent supervisory authorities and law enforcement agencies

may commence investigations based on such allegations.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Deutsche Bank is committed to managing its business activities and operations in a sustainable manner, including

aligning portfolios with net zero emissions by 2050. The bank continues to develop and implement its approach to

environmental risk assessments and management in order to promote the integration of environmental-related factors

across its business activities. This includes the ability to identify, monitor and manage risks and to conduct regular

scenario analysis and stress testing. Rapidly changing regulatory as well as stakeholder demands, combined with

significant focus by stakeholders, may adversely affect Deutsche Bank's businesses if it fails to adopt such demands or

appropriately implement its plans.

Deutsche Bank recently updated its target for sustainable financing and investment volumes to € 900 billion in

sustainable and transition finance for the period from 2020 to the end of 2030, after nearly achieving its 2025 target of €

500 billion. Deutsche Bank may face significant headwinds in achieving these targets, including market competition,

evolving regulatory requirements, and the scarcity of green and social assets for compliant funding. If ambitions or

targets are missed, this could impact, among other things, revenues and the reputation of the bank, whereas scarcity of

green and social assets may reduce Deutsche Bank’s ability to issue compliant funding that qualifies. An economy

transitioning at a slower pace may result in significant deviations from the bank’s net zero-aligned emissions pathways

toward its targets. This would come to reduce transition risk in the short to medium term but increase it significantly over

the longer term. The bank continues to consider its net zero targets as one of the key climate risk management tools.

Other Risks

The bank’s risk management policies, procedures and methods leave the bank exposed to unidentified or unanticipated

risks, which could lead to material losses.

Deutsche Bank has devoted significant resources to develop its risk management policies, procedures and methods,

including with respect to market, credit, liquidity, operational as well as reputational and model risk. However, the bank

may not be fully effective in mitigating these risk exposures in all economic or market environments or against all types

of risk, including risks that the bank fails to identify or anticipate. Where Deutsche Bank uses models to calculate risk-

weighted assets for regulatory purposes, potential deficiencies may also lead regulators to impose a recalibration of

input parameters or a complete review of the model.

Some of the bank’s quantitative tools and metrics for managing risk are based upon its use of observed historical market

behavior. The bank applies statistical and other tools to these observations to arrive at quantifications of its risk

exposures. In a financial crisis, the financial markets may experience extreme levels of volatility (rapid changes in price

direction) and the breakdown of historically observed correlations (the extent to which prices move in tandem) across

asset classes, compounded by extremely limited liquidity. In such a volatile market environment, the bank’s risk

management tools and metrics may fail to predict important risk exposures. In addition, Deutsche Bank’s quantitative

modeling does not take all risks into account and makes numerous assumptions regarding the overall environment, which

may not be borne out by events. As a result, risk exposures have arisen and could continue to arise from factors the bank

did not anticipate or correctly evaluate in its models. This has limited and could continue to limit the bank’s ability to

manage its risks especially in light of geopolitical developments, many of the outcomes of which are currently

unforeseeable. The bank’s losses thus have been and may in the future be significantly greater than the historical

measures indicate, which could materially and adversely affect its results of operations, financial condition or capital

position.

In addition, the bank’s more qualitative approach to managing those risks not taken into account by the quantitative

methods could also prove insufficient, exposing the bank to material unanticipated losses. Also, if existing or potential

customers or counterparties believe its risk management is inadequate, they could take their business elsewhere or seek

to limit their transactions with Deutsche Bank. This could harm the bank’s reputation as well as its revenues and profits.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

As Deutsche Bank is dependent on legacy infrastructure providers with challenged business models, the bank therefore

has become more reliant on cloud based and data intensive platforms which increases concentration risk

As the bank continues to modernize its technology landscape and increases reliance on cloud‑based and data‑intensive

platforms, operational resilience remains a priority for senior management. Growing dependence on a small number of

global cloud and data center providers, many concentrated in the United States, heightens concentration and systemic

risk, as seen in recent market wide outages. Given the scale, specialization and integration of such providers, the bank

may not be able to readily substitute alternative providers, execute upon the bank's remediation rights or migrate critical

workloads without significant costs, disruption or delay. Geopolitical, regulatory or policy developments could further

affect service continuity or data access.

While these platforms provide significant scalability and efficiency benefits, disruptions from provider outages,

data‑center incidents, infrastructure constraints or geopolitical events could affect the bank’s ability to deliver critical

services. Rising demand for computing power, including analytics and AI workloads, is also increasing pressure on

underlying power and network infrastructure.

The accelerating pace of technological advances is heightening cyber risk, with threat actors leveraging increasingly

sophisticated and frequent attacks. Geopolitical tensions continue to fuel persistent cyber activity, a trend expected to

intensify as AI amplifies both capability and scale. Hybrid warfare which combines cyber operations, disinformation, and

targeted disruption of critical digital infrastructure by state and non‑state actors, further elevates operational and

systemic risks. These converging tactics blur the boundaries between physical and digital conflict, increasing the

likelihood of multi‑vector disruptions that could impair the bank’s technology environment and threaten service

continuity.

Deutsche Bank utilizes a variety of third parties in support of its business and operations. Services provided by third

parties pose risks to the bank comparable to those it bears if Deutsche Bank performed the services itself, and the bank

remains ultimately responsible for the services its third parties provide. Furthermore, if a third party does not conduct

business in accordance with applicable standards or Deutsche Bank’s expectations, the bank could be exposed to

material losses, regulatory action, litigation, reputational damage, or fail to achieve the benefits it sought from the

relationship.

Financial institutions rely on third-party and intragroup service providers for a range of services, some of which support

their critical operations. These dependencies have grown in recent years as part of the increasing trend in digitalization of

the financial services sector which can bring multiple benefits including flexibility, innovation and improved operational

resilience. However, if not properly managed, disruption to service providers could pose risks to critical services provided

by financial institutions, and in some cases, financial stability.

The regulatory framework for managing third party risk continues to evolve and becomes increasingly complex as

regulators seek to address various objectives. Two main areas of focus are how financial institutions identify and manage

their third-party risks and how systemic risks caused by concentration of services provided by critical third parties and

subcontractors are addressed.

When using third-party service providers, the bank remains fully responsible and accountable for complying with all the

regulatory obligations, including the ability to oversee the outsourcing of critical or important functions. The bank may

face risks of material losses or reputational damage if third parties fail to provide services as agreed with the bank and/or

in line with regulatory requirements.

Similar to cybersecurity threats to Deutsche Bank, a successful cyberattack on a third party vendor could have a

significant negative impact on the bank that may result in the disclosure or misuse of client as well as proprietary

information, damage or inability to access information technology systems, financial losses, additional costs, personal

data breach notification obligations, reputational damage, client dissatisfaction and potential regulatory penalties or

litigation exposure.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Operational risks, which may arise from errors in the performance of the bank’s processes, the conduct of its employees,

shortfalls in access management, instability, malfunction or outage of its IT system and infrastructure, or loss of business

continuity, or comparable issues with respect to the bank’s vendors, may disrupt the bank's businesses and lead to

material losses.

Deutsche Bank faces operational risk arising from errors, inadvertent or intentional, made in the execution, confirmation

or settlement of transactions or from transactions not being properly recorded, evaluated or accounted for. An example

of this risk concerns derivative contracts, which are not always confirmed with the counterparties on a timely basis. For

so long as the transaction remains unconfirmed, the bank is subject to heightened credit and operational risk and in the

event of a default may find it more difficult to enforce the contract.

In addition, Deutsche Bank’s businesses are highly dependent on its ability to process manually or through its systems a

large number of transactions on a daily basis, across numerous and diverse markets in many currencies. Some of the

transactions have become increasingly complex. Moreover, management relies heavily on its financial, accounting and

other data processing systems that include manual processing components. If any of these processes or systems do not

operate properly, or are disabled, or subject to intentional or inadvertent human error, the bank could suffer financial

loss, a disruption of its businesses, liability to clients, regulatory intervention or reputational damage.

The bank is also dependent on its employees to conduct its business in accordance with applicable laws, regulations and

generally accepted business standards. If the bank’s employees do not conduct its business in this manner, the bank may

be exposed to material losses. Furthermore, if an employee’s misconduct reflects fraudulent intent, the bank could also

be exposed to reputational damage. The bank categorizes these risks as conduct risk, a term used to describe the risks

associated with behavior by employees and agents, including third parties, that could harm clients, customers or the

integrity of the markets, such as selling products that are not suitable for a particular customer, fraud, unauthorized

trading and failure to comply with applicable regulations, laws and internal policies. U.S. regulators in particular have

been increasingly focused on conduct risk, and such heightened regulatory scrutiny and expectations could lead to

investigations and other inquiries, as well as remediation requirements, more regulatory or other enforcement

proceedings, civil litigation and higher compliance and other risks and costs.

The bank is required to monitor, evaluate, and observe laws and other requirements relating to financial and trade

sanctions and embargoes set by the EU, the Deutsche Bundesbank, Germany’s Federal Office for Economic Affairs and

Export Control, and other authorities, such as the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC)

and the UK Treasury Department’s Office of Financial Sanctions Implementation (OFSI), or local authorities of Deutsche

Bank's locations. Sanctions are subject to rapid change, and it is also possible that new direct or indirect secondary

sanctions or similar restrictive measures could be imposed by the United States or other jurisdictions without warning, as

a result of geopolitical developments. Should the bank fail to comply timely and in all respects with these sanctions, the

bank could be exposed to legal penalties or other adverse action and its reputation could suffer.

The bank in particular faces the risk of loss events due to the instability, malfunction or outage of its IT system and IT

infrastructure, as well as breaches in IT system and infrastructure (including cyber-attacks). Such losses could materially

affect the bank’s ability to perform business processes and may, for example, arise from the erroneous or delayed

execution of processes as a result of system outages, degraded services in systems and IT applications or the

inaccessibility of its IT systems. A delay in processing a transaction, for example, could result in an operational loss if

market conditions worsen during the period after the error. IT-related errors may also result in the mishandling of

confidential information, damage to the bank’s computer systems, financial losses, additional costs for repairing systems,

reputational damage, customer dissatisfaction or potential regulatory or litigation exposure (including under data

protection laws such as the GDPR). Additionally, there is a heightened emphasis and growing expectations of data

management and the risks posed by poor data management standards and data quality, and the potential impact to key

control, decision-making and reporting processes.

Global industries continue to conduct business from home and away from primary office locations, which has changed

business practices compared to historic trends. The demand on the bank’s technology infrastructure and the risk of

cyber-attacks could lead to technology failures, security breaches, unauthorized access, loss or destruction of data or

unavailability of services, as well as increase the likelihood of conduct breaches.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Business continuity risk is the risk of incurring losses resulting from the interruption of normal business activities. The

bank operates in many geographic locations and is frequently subject to the occurrence of events outside of its control.

Despite the contingency plans the bank has in place, its ability to conduct business in any of these locations may be

adversely impacted by a disruption to the infrastructure that supports the bank’s business, whether as a result of, for

example, events that affect the bank’s third-party vendors or the community or public infrastructure in which the bank

operates. Any number of events could cause such a disruption including deliberate acts such as acts of war or other

military action, sabotage, terrorist activities, bomb threats, strikes, riots and assaults on the bank’s staff; natural

calamities such as hurricanes, snowstorms, floods, disease pandemics (such as the COVID-19 pandemic) and

earthquakes; or other unforeseen incidents such as accidents, fires, explosions, utility outages and political unrest. Any

such disruption could have a material adverse effect on the bank’s business and financial position.

As a global bank, Deutsche Bank is often the subject of news reports. Deutsche Bank conducts its media dialogue

through official teams. However, members of the media sometimes approach Deutsche Bank staff outside of these

channels and Deutsche Bank-internal information, including confidential matters, have been subject to external news

media coverage, which may result in publication of confidential information. Leaks to the media can have severe

consequences for Deutsche Bank, particularly when they involve inaccurate statements, rumors, speculation or

unsanctioned opinions. This can result in financial consequences such as the loss of confidence or business with clients

and may impact the bank’s share price or capital instruments by undermining investor confidence. The bank’s ability to

protect itself against these risks is limited.

Deutsche Bank’s large clearing and settlement business poses risks if it fails to operate properly for even short periods.

The bank has large clearing and settlement businesses and an increasingly complex and interconnected IT landscape.

These give rise to the risk that the bank’s customers or other third parties could lose substantial sums if the systems fail

to operate properly for even short periods. This will be the case even where the reason for the interruption is external to

the bank. In such a case, the bank might suffer harm to its reputation even if no material loss of money occurs. This could

cause customers to take their business elsewhere, which could materially harm the bank’s revenues and profits.

Deutsche Bank must test goodwill and other intangible assets at least annually for impairment or each reporting period if

indicators of impairment exist. In the event the test determines that impairment exists, the bank must write down the

value of the asset.

Goodwill arises on the acquisition of subsidiaries and associates and represents the excess of the aggregate of the cost of

an acquisition and any noncontrolling interests in the acquiree over the fair value of the identifiable net assets acquired

at the date of the acquisition. Goodwill on the acquisition of subsidiaries is capitalized and reviewed for impairment

annually or more frequently if there are indications that impairment may have occurred. Intangible assets are recognized

separately from goodwill when they are separable or arise from contractual or other legal rights and their fair value can

be measured reliably. These assets are tested for impairment and useful life reaffirmed at least annually. The

determination of the recoverable amount in the impairment assessment of non-financial assets requires estimates based

on quoted market prices, prices of comparable businesses, present value or other valuation techniques, or a combination

thereof, necessitating management to make subjective judgments and assumptions. These estimates and assumptions

could result in significant differences to the amounts reported if underlying circumstances were to change. Impairments

of goodwill and other intangible assets have had and may have in the future a material adverse effect on the bank’s

profitability and results of operations.

In addition to Deutsche Bank’s traditional banking businesses of deposit-taking and lending, the bank may also engage in

nontraditional credit businesses in which credit is extended via transactions that may materially increase the bank’s

exposure to credit risk.

As a financial institution, Deutsche Bank is exposed to the risk that third parties who owe claims to the bank will not

perform on their obligations. Many of the bank’s businesses extend beyond the traditional banking businesses of deposit-

taking and lending and also expose the bank to credit risk.

In particular, much of the business in the Investment Bank entails credit transactions, frequently ancillary to traditional

banking transactions. Nontraditional sources of credit risk can arise, for example, from holding securities of third parties;

entering into swap or other derivative contracts under which counterparties have obligations to make payments to the

bank; executing securities, futures, or currency trades that fail to settle at the required time due to non-delivery by the

counterparty or systems failure by clearing agents, exchanges, clearing houses or other financial intermediaries; and

extending credit through other arrangements. Parties to these transactions may default on their obligations which would

result in Deutsche Bank incurring significant losses.

In the past, exceptionally difficult market conditions severely adversely affected certain areas in which the bank does

nontraditional credit risk business, including leveraged finance and structured credit markets. If similar market conditions

occur in the future, the bank may experience adverse effects.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

A substantial proportion of the bank’s assets and liabilities comprise financial instruments carried at fair value, with

changes in fair value recognized in the income statement. Fair value changes have in the past and could in the future

result in significant losses.

Fair value is defined as the price at which an asset or liability could be exchanged in an arm's length transaction between

knowledgeable, willing parties, other than in a forced or liquidation sale. If the value of an asset carried at fair value

declines (or the value of a liability carried at fair value increases) a corresponding loss in fair value is recognized in the

income statement. If observable prices or inputs are not available for certain classes of financial instruments, fair value is

determined using valuation techniques the bank believes to be appropriate for the particular instrument. The application

of valuation techniques to determine fair value involves estimation and management judgment, the extent of which will

vary with the degree of complexity of the instrument and liquidity in the market. Management judgment is required in the

selection and application of the appropriate parameters, assumptions and modeling techniques. If any of the

assumptions change due to negative market conditions or for other reasons, subsequent valuations may result in

significant changes in the fair values of the bank’s financial instruments and which have in the past and may in the future

result in significant losses.

Deutsche Bank’s exposure and related changes in fair value are reported net of any fair value gains that may be recorded

in connection with hedging transactions related to the underlying assets. However, the bank may never realize these

gains, and the fair value of the hedges may change in future periods for a number of reasons, including deterioration in

the credit of hedging counterparties. Such declines may be independent of the fair values of the underlying hedged

assets or liabilities and may result in future losses.

Deutsche Bank must review its deferred tax assets at the end of each reporting period. To the extent that it is no longer

probable that sufficient taxable income will be available to allow all or a portion of the bank’s deferred tax assets to be

utilized, the bank must reduce the carrying amounts. These reductions have had and may in the future have material

adverse effects on Deutsche Bank’s profitability, equity, and financial condition.

The bank recognizes deferred tax assets for future tax consequences attributable to temporary differences between the

financial statement carrying amounts of existing assets and liabilities and their respective tax bases, unused tax losses

and unused tax credits. To the extent that it is no longer probable that sufficient taxable profits will be available to allow

all or a portion of the deferred tax assets to be utilized, the bank must reduce the carrying amounts. Each quarter, the

bank re-evaluates its estimate related to deferred tax assets, which can change from period to period and requires

significant management judgment. Furthermore, deferred tax assets are measured based on tax rates that are expected

to apply in the period that the asset is realized, based on the tax rates and tax laws that have been enacted or

substantially enacted at the balance sheet date. Reductions in the amount of deferred tax assets from a change in

estimate or a change in tax law have had and may in the future have material adverse effects on its profitability, equity

and financial condition.

Deutsche Bank is exposed to pension risks which can materially impact the measurement of its pension obligations,

including interest rate, inflation, longevity and liquidity risks that can materially impact the bank’s earnings.

Deutsche Bank sponsors a number of post-employment benefit plans on behalf of its employees, including defined

benefit plans. For further details on Deutsche Bank’s employee benefit plans see Note 33 – “Employee Benefits” in the

consolidated financial statements.

The bank develops and maintains guidelines for governance and risk management, including funding, asset allocation

and actuarial assumption setting. In this regard, risk management means the management and control of risks for the

bank related to market developments (e.g., interest rate, credit spread, price inflation), asset investment, regulatory or

legislative requirements, as well as monitoring demographic changes (e.g., longevity). To the extent that pension plans

are funded, the assets held mitigate some of the liability risks, but introduce investment risk. In its key pension countries,

the bank’s largest post-employment benefit plan risk exposures relate to potential changes in credit spreads, interest

rates, price inflation, longevity risk and liquidity risk, although these have been partially mitigated through the

investment strategy adopted. Overall, the bank seeks to minimize the impact of pensions on its financial position from

market movements, subject to balancing the trade-offs involved in financing post-employment benefits, regulatory

capital and constraints from local funding or accounting requirements.

The bank’s investment objective in funding the plans and its obligations in respect of them is to protect the bank from

adverse impacts of its defined benefit pension plans on key financial metrics. The bank seeks to allocate plan assets

closely to the market risk factor exposures of the pension liability to interest rates, credit spreads and inflation and,

thereby, plan assets broadly reflect the underlying risk profile and currency of the pension obligations.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

To the extent that the factors that drive the bank’s pension liabilities move in a manner adverse to the bank, or that its

assumptions regarding key variables prove incorrect, or that funding of the pension liabilities does not sufficiently hedge

those liabilities, the bank could be required to make additional contributions or be exposed to actuarial or accounting

losses in respect of its pension plans.

In Germany, the Group is a member of the BVV Versicherungsverein des Bankgewerbes a.G. (BVV), a multi-employer

defined benefit plan, together with other financial institutions. In line with industry practice, the Group accounts for it as

a defined contribution plan since insufficient information is available to identify assets and liabilities relating to the

Group’s current and former employees, primarily because the BVV does not fully allocate plan assets to beneficiaries nor

to member companies. The Group may be exposed to significant financial risk should the residual risks materialize or if

the assumptions that form the basis of the benefit obligation related to this multi-employer defined benefit plan prove to

be unrealistic.

The evolution of digital assets increases operational, liquidity and financial risks and could impact Deutsche Bank's

results of operations

The continued evolution of digital assets and their potential applicability in payment and treasury processes as well as

for other types of financial services presents operational, liquidity and financial risks. For example, the bank is exposed to

risks arising from shifts in the global payments landscape, including the increasing use of regulated forms of tokenized

money such as stablecoins issued by both banking and non-banking entities, as well as the introduction of central bank

digital currencies (CBDCs) for retail and wholesale use cases. The growth and acceptance of these instruments could

furthermore displace elements of the bank’s traditional product offering, such as trading, custody and clearing, and

payments, with consequential impacts on Deutsche Bank’s business model and deposit base, and potentially increasing

Deutsche Bank’s operational and liquidity risk landscape. In addition, new competitors may introduce tokenized asset

products and services that the bank does not provide, which may result in the loss of revenue or clients.

Deutsche Bank is subject to laws and other requirements relating to financial and trade sanctions and embargoes. If the

bank breaches such laws and requirements, it can be subject, and in the past has been subject, to material regulatory

enforcement actions and penalties.

The bank is required to monitor, evaluate, and observe laws and other requirements relating to financial and trade

sanctions and embargoes set by the EU, the Deutsche Bundesbank, Germany’s Federal Office for Economic Affairs and

Export Control, and other authorities, such as the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC)

and the UK Treasury Department’s Office of Financial Sanctions Implementation (OFSI), or local authorities of Deutsche

Bank locations. Sanctions are subject to rapid change, and it is also possible that new direct or indirect secondary

sanctions (including as a result of U.S. secondary sanctions risks for financial institutions that engage in certain dealings

relating to Russia) could be imposed by the United States or other jurisdictions without warning as a result of geopolitical

developments. New and far-reaching sanctions against Russian entities and individuals have been, and may continue to

be, imposed by the United States, the EU, the United Kingdom and other individual countries as a result of the

continuation of Russia’s war in Ukraine, and many of these sanctions require very rapid implementation. Should the bank

fail to comply timely and in all respects with these or new or preexisting laws and requirements, it can be subject, and has

in the past been subject, to material regulatory enforcement actions and penalties, and its reputation could suffer.

Transactions with persons targeted by U.S. economic sanctions or counterparties in countries designated by the U.S.

State Department as state sponsors of terrorism may lead potential customers and investors to avoid doing business with

the bank or investing in the bank’s securities, harm its reputation or result in regulatory or enforcement action which

could materially and adversely affect its business.

The bank engages or has engaged in a limited amount of business with counterparties, including government-owned or -

controlled counterparties, in certain countries or territories that are subject to comprehensive U.S. sanctions (referred to

as “Sanctioned Territories”), or with persons or entities targeted by U.S. economic sanctions (referred to as “Sanctioned

Persons”). U.S. law generally prohibits U.S. persons or any other persons acting within U.S. jurisdiction (which includes

business with a U.S. nexus) from dealings with or relating to Sanctioned Territories or Sanctioned Persons. Additionally,

U.S. indirect or “secondary” sanctions threaten the imposition of sanctions against non-U.S. persons entirely outside of

U.S. jurisdiction for engaging in certain activities deemed contrary to U.S. interests. For example, the U.S. has targeted

foreign financial institutions with respect to a number of activities, including knowingly or unknowingly facilitating

transactions or providing services relating to Russia’s military-industrial base. The bank’s U.S. subsidiaries, branch offices,

and employees are, and, in some cases, its non-U.S. subsidiaries, branch offices, and employees are or may become,

subject to such prohibitions and other regulations.


Deutsche Bank	Item 3: Key Information
Annual Report 2025 on Form 20-F	Risk Factors

Deutsche Bank is a German bank and its activities with respect to Sanctioned Territories and Sanctioned Persons have

been subject to policies and procedures designed to exclude the involvement of U.S. jurisdiction, including U.S. persons

acting in any managerial or operational role and to ensure compliance with United Nations Security Council, European

Union and German sanctions and embargoes; in reflection of legal developments in recent years, the bank has further

developed its policies and procedures with the aim of promoting – to the extent legally permitted – compliance with

regulatory requirements extending to other geographic areas regardless of jurisdiction. However, the regulatory

requirements themselves may change rapidly, and should its policies prove to be, or have been, ineffective, the bank may

be subject to regulatory or enforcement action that could materially and adversely affect its reputation, financial

condition, or business.

Further, in response to the war in Ukraine, the United States, as well as other nations and the EU, have continued to

expand sanctions on Russia, Russian entities and third-country entities supporting sanctions avoidance; such sanctions

could have a material impact on the bank’s business activities. In response, the bank took a range of preparatory and

responsive actions to implement the high number of, and in part newly developed, sanctions by inter alia filter and

control updates, additional due diligence steps in transaction and client reviews with a nexus to Russia and by restricting

its policy significantly and adjusting processes. Furthermore, additional transactions with Russia and Belarus have been

prohibited by bank policy starting from March 2025 and April 2025, respectively. Even though Deutsche Bank believes

that it reacted quickly and thoroughly to these challenges, the sheer amount and complexity of changes and the broad

discretion that U.S. authorities may exercise in interpreting and enforcing U.S. sanctions have increased the operational

risk relating to regulatory compliance. Given the strict liability applied in areas of this regulatory environment and the

extraterritorial reach of U.S. secondary sanctions, such operational risk may translate into regulatory risks for the bank

leading to consequential losses. There can be no assurances that U.S. authorities will not bring enforcement actions

against the bank or impose secondary sanctions or other adverse consequences. Any such actions could have a material

impact on the bank’s business and harm its reputation.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	History and development of the company

Item 4: Information on the company

History and development of the company

The legal and commercial name of the company is Deutsche Bank Aktiengesellschaft. It is a stock corporation organized

under the laws of Germany.

Deutsche Bank Aktiengesellschaft originated from the reunification of Norddeutsche Bank Aktiengesellschaft, Hamburg,

Rheinisch-Westfälische Bank Aktiengesellschaft, Düsseldorf, and Süddeutsche Bank Aktiengesellschaft, Munich.

Pursuant to the Law on the Regional Scope of Credit Institutions, these were disincorporated in 1952 from Deutsche

Bank, which had been founded in 1870. The merger and the name were entered in the Commercial Register of the

District Court Frankfurt am Main on May 2, 1957.

Deutsche Bank is registered under registration number HRB 30 000. Deutsche Bank’s registered address is Taunusanlage

12, 60325 Frankfurt am Main, Germany, and its telephone number is +49-69-910-00. The bank’s agent in the United

States is: DB USA Corporation, c/o Office of the Secretary, 1 Columbus Circle, Mail Stop NYC01-1950, New York, New

York 10019-8735.

For information on significant capital expenditures and divestitures, please see “Combined Management Report:

Operating and financial review: Deutsche Bank Group: Significant capital expenditures and divestitures” in the Annual

Report 2025.

The Securities and Exchange Commission (“SEC”) maintains an Internet site that contains reports, proxy and information

statements, and other information regarding issuers that file electronically with the SEC, such as Deutsche Bank

Aktiengesellschaft, with the address http://www.sec.gov. Deutsche Bank’s filings are available on the SEC’s Internet site

under File Number 001-15242 and Internet address is http://www.db.com.

Business Overview

Deutsche Bank’s organization

Please see “Combined Management Report: Operating and financial review: Deutsche Bank Group: Deutsche Bank’s

organization” in the Annual Report 2025. For information on net revenues by geographic area and by corporate division

please see Note 4 “Business Segments and related information: Entity-wide disclosures” to the consolidated financial

statements and “Combined Management Report: Operating and financial review: Results of operations: Segment results

of operations” in the Annual Report 2025.

Management structure

Please see “Combined Management Report: Operating and financial review: Deutsche Bank Group: Management

structure” in the Annual Report 2025.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Business Strategy

The information presented in this section is based on IFRS as issued by the IASB (IASB IFRS), whereas Deutsche Bank’s

financial targets and capital objectives are based on financial results prepared in accordance with IFRS as issued by the

IASB and endorsed by the EU (EU IFRS). The IASB IFRS financial results may materially differ from the EU-IFRS results as

Deutsche Bank applies hedge accounting under the EU carve-out. Deutsche Bank does not use the IASB IFRS financial

results as a basis for measuring the bank’s progress towards its financial targets or capital objectives. For additional

details, please refer to “Note 01 – Material Accounting Policies and Critical Accounting Estimates – EU carve-out” to the

consolidated financial statements.

Global Hausbank

Deutsche Bank’s strategic and financial roadmap for 2025 aimed to position the bank as the Global Hausbank,

underpinned by strong European foundations and a broad international network. The strategy focused on achieving the

2025 financial targets and capital objectives and was built on three core pillars: risk management, sustainability and

technology, priorities that have become even more important amid persistent geopolitical and macroeconomic

uncertainty. By the end of 2025, the bank had met or surpassed its key financial targets and capital objectives, measured

on the financial results prepared in accordance with IFRS as issued by the IASB and endorsed by the EU (EU IFRS),

thereby laying a firm foundation to scale the Global Hausbank.

At the Investor Deep Dive in November 2025, Deutsche Bank announced the next phase of its strategy and financial

targets and capital objectives for 2028. Having restored the bank’s profitability and strengthened its foundations, the

bank’s focus will be on accelerating value creation by scaling the Global Hausbank. Deutsche Bank’s goal is to tap

significant further growth potential, building on its position as the trusted partner for clients in a changing environment.

The bank’s long‑term vision is to become the European Champion in banking, marked by leadership in key business

segments on a European level, market-leading returns, a deep and scaled global presence and an AI-powered and

innovation-focused organization.

Deutsche Bank’s key performance indicators for 2025

Financial targets:

–Post-tax return on average tangible equity of above 10% for the Group

–Compound annual growth rate of revenues between 2021 and 2025 of 5.5% to 6.5%

–Cost/income ratio of below 65%

Capital objectives:

–Common Equity Tier 1 (CET1) capital ratio within an operating range of 13.5% to 14.0%, with a 200 basis points

distance to the Maximum Distributable Amount (MDA) as a floor

–50% Total payout ratio from 2025

When used with respect to future periods, non-GAAP financial measures Deutsche Bank uses are forward-looking

statements. Deutsche Bank cannot predict or quantify the levels of the most directly comparable financial measures

under IFRS that would correspond to these measures for future periods. This is because neither the magnitude of such

IFRS financial measures, nor the magnitude of the adjustments to be used to calculate the related non-GAAP financial

measures from such IFRS financial measures, can be predicted. Such adjustments, if any, will relate to specific, currently

unknown, events and in most cases can be positive or negative, so that it is not possible to predict whether, for a future

period, the non-GAAP financial measure will be greater than or less than the related IFRS financial measure.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Sustainability

Sustainability is a fundamental aspect of Deutsche Bank’s strategy. In 2025, the bank continued to focus on the four

pillars of its sustainability strategy: Sustainable Finance, Policies & Commitments, People & Own Operations, and

Thought Leadership & Stakeholder Engagement.

Deutsche Bank set ambitious targets to maximize its contribution to achieving the Paris Climate Agreement’s targets and

the United Nations (UN) Sustainable Development Goals. The key targets and goals relate to the following sustainability

matters:

–Deutsche Bank set new cumulative € 900 billion sustainable and transition finance target for the period from 2020 to

the end of 2030, reinforcing its role as a trusted partner for the bank’s clients in the global transformation. The bank

aimed to achieve a total of € 500 billion cumulative sustainable finance and ESG investments volumes from January

2020 to end of 2025 (excluding Asset Management (DWS)). Although the original target was not achieved by the end

of 2025, Deutsche Bank remains committed to providing sustainable financing and ESG investment solutions to its

clients and expects to surpass € 500 billion in the first half of 2026. Progress towards the original target was impacted

by several factors over the period, including higher interest rates, regulatory developments as well as changes in the

policy environment

–Deutsche Bank introduced a nature ambition to facilitate 300 transactions by the end of 2027, supporting biodiversity

as well as ecosystem conservation and restoration in alignment with the United Nations Sustainable Development

Goals

–Deutsche Bank is committed to achieving net zero emissions by 2050. In the previous years, Deutsche Bank has set

net zero targets for eight carbon-intensive sectors in its corporate loan book, with interim goals by end of 2030 and

final targets by end of 2050

–Deutsche Bank planned to source 100% of its electricity from renewable sources by 2025 and has achieved this target

–In 2021, the bank committed to an aspirational goal to have women represent at least 35% of its Managing Director,

Director and Vice President population globally (excluding Asset Management) by year end 2025, known as the ’35 by

25’ program. By year end 2025, women represented 34.1% of the bank’s Managing Director, Director and Vice

President population globally, with the female representation on senior corporate titles increasing from 2021 to 2025

by 4.2 percentage points

–The bank aims to increase gender diversity at the two levels below the Management Board (MB-1 and MB-2) with a

goal of 30% of positions to be held by women by year end 2025, thereby promoting equal opportunity within the

Management Board succession pipeline. The bank effectively met the goal for MB-1 and reached 28.2% at MB-2. In

line with German legal requirements, the bank will retain goals beyond 2025 for the two layers below the

Management Board with a goal of 32.5% women at both MB-1 and MB-2 by year end 2026, having regard to local law

In 2025, Deutsche Bank published its initial Transition Finance Framework, defining clear rules for financing net zero

transitions in hard-to-abate sectors. Furthermore, the bank updated its Transition Plan with the latest data and main

achievements and updated the Sustainable Instruments Framework to align with relevant adjustments to the Sustainable

Finance Framework, effective from January 1, 2026.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Scaling the Global Hausbank

The bank believes that the progress made in transforming Deutsche Bank laid a strong foundation for delivering

sustainable growth through 2028. At the Investor Deep Dive in November 2025, Deutsche Bank presented its strategic

and financial roadmap for the period to 2028, outlining plans to further scale the bank’s position as a Global Hausbank

and setting out its financial targets and capital objectives for 2028.

Deutsche Bank’s key financial targets and capital objectives for 2028

Financial targets:

–Post-tax return on average tangible equity of greater than 13% for the Group

–Cost/income ratio of below 60%

Capital objectives:

–CET1 capital ratio within an operating range of 13.5% to 14.0%, with a 200 basis points distance to the Maximum

Distributable Amount (MDA) as a floor

–60% Total payout ratio from 2026 and distribution of excess capital when CET1 capital ratio is sustainably above 14%

When used with respect to future periods, non-GAAP financial measures Deutsche Bank uses are forward-looking

statements. Deutsche Bank cannot predict or quantify the levels of the most directly comparable financial measures under

IFRS that would correspond to these measures for future periods. This is because neither the magnitude of such IFRS

financial measures, nor the magnitude of the adjustments to be used to calculate the related non-GAAP financial measures

from such IFRS financial measures, can be predicted. Such adjustments, if any, will relate to specific, currently unknown,

events and in most cases can be positive or negative, so that it is not possible to predict whether, for a future period, the

non-GAAP financial measure will be greater than or less than the related IFRS financial measure.

Accelerating value creation through three strategic levers

The next phase of Deutsche Bank’s strategy is centered around three levers: focused growth, disciplined capital

management and a scalable operating model. These levers are anchored in a firm commitment to shareholder‑value‑add

(SVA) as the central steering principle, aiming at sharpening decision‑making, aligning resource allocation with value

creation and strengthening a culture of accountability. Anchored in its ambition to scale the Global Hausbank, Deutsche

Bank aims to deepen client engagement and strengthen collaboration across segments to deliver its full capabilities.

Focused growth: Focused growth is a core driver of Deutsche Bank’s strategic ambition through 2028. The bank expects

focused growth areas to contribute meaningfully to long term revenue expansion, targeted to deliver approximately €

5 billion in incremental revenues, increasing Group revenues from € 32 billion to approximately € 37 billion by 2028. This

trajectory reflects a balanced uplift across fee generating and interest sensitive activities, including roughly € 2.6 billion in

additional net commission and fee income and € 2.3 billion in net interest income, underpinned by the structural hedge

rollover, the strength of the German deposit franchise and targeted loan growth across the bank. Growth is expected to be

reinforced by more coordinated client coverage, with the Corporate Bank and Investment Bank jointly supporting corporate

and institutional clients, the Private Bank and Asset Management enhancing investment and retirement solutions, and the

segments contributing to a greater share of client business.

Disciplined capital management: Deutsche Bank manages capital as a strategic lever, ensuring it is deployed where returns

are strongest and aligned with the bank’s SVA guiding principles. The bank’s capital strategy is grounded in disciplined

balance sheet management, focused on reallocating resources toward capital accretive activities. By the end of 2028,

Deutsche Bank aims to deliver a more than 100 basis point uplift in revenues over RWA (excluding operational risk RWA),

supported by strengthened pricing discipline, enhanced balance sheet velocity and expanded risk transfer and

securitization channels. The bank aims to maintain a CET1 capital ratio of 13.5% to 14.0%, with a 200 basis points distance

to the MDA as a floor. The bank targets a 60% total payout ratio from 2026, and to distribute excess capital when its CET1

capital ratio is sustainably above 14%.

Scalable operating model: Deutsche Bank intends to strengthen the scalability and resilience of its operating model to

support long-term growth and improved productivity across the Group. The bank’s objective is to deliver around 6%

operating leverage in 2028, enabled by a balanced combination of forward-looking investments and disciplined cost

management. Targeted € 1.5 billion of incremental investments, including technology, artificial intelligence and business-

led initiatives, are designed to unlock early efficiency gains while modernizing core platforms of the bank. These

investments are expected to be more than offset by at least € 2 billion in operating efficiencies, driven by front to back

process optimization, enhanced IT architecture and transformation across infrastructure functions. This approach supports

a sustained improvement in the cost/income ratio with a target below 60% by 2028, while maintaining cost discipline, with

expenses excluding business-led investments expected to rise only modestly.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Post-tax return on average tangible equity is a Non-GAAP financial measure. Please refer to “Supplementary financial

information (Unaudited): Non-GAAP financial measures” of this report for the definitions of such measures and

reconciliations to the IFRS numbers on which they are based. With effect from the first quarter of 2026, Deutsche Bank

will discontinue the separate reporting of adjusted costs and nonoperating costs.

Deutsche Bank Business segments

Corporate Bank

Corporate Bank’s capabilities in Cash Management, Trade Finance and Lending, and Trust and Securities Services are intended to

enable the segment to serve the core needs of its clients. Corporate Bank helps clients optimize their working capital and liquidity,

secure global supply chains and distribution channels, and manage their risks, in close collaboration with Foreign Exchange within

the Investment Bank. Furthermore, Corporate Bank acts as a specialized provider of services to financial institutions, offering

Correspondent Banking and Trust and Securities Services. Corporate Bank combined its Trust and Agency Services and Securities

Services businesses into a new unified Trust and Securities Services organization in mid-2025. Finally, Deutsche Bank provides

Business Banking services to small corporate and entrepreneur clients in Germany through a standardized product suite.

In 2025, Corporate Bank continued to make progress on its strategic objectives, notably by growing net commission and fee

income across all regions, while interest hedging and strong deposit growth partly offset deposit margin normalization. Corporate

Bank was awarded “No. 1 Best Trade Finance Bank” by the FINANCE Banken-Survey and “World’s Best Corporate Trust Bank” by

the IJ Global Awards. Deutsche Bank believes that these awards recognize Corporate Bank’s deep client relationships and client-

centric solutions offering.

Corporate Bank’s strategy is anchored around focused growth, strict capital discipline and a scalable operating model, supporting

Deutsche Bank’s Scaling the Global Hausbank strategy. In line with the direction set out at the 2025 Investor Deep Dive,

Deutsche Bank expects meaningful expansion across its core client groups: corporates, institutions as well as small and

medium‑sized enterprises. The bank also aims to broaden its platforms and deliver tailored solutions that address clients’ strategic

requirements. Building on its strong leadership in Germany, Corporate Bank aims to deepen its position as the trusted partner to

the German and European economies, supported by fiscal expansion and strengthened collaboration across Deutsche Bank’s

business segments.

Corporate Treasury Services aims to further scale its platform across core products, enabling increased density and a greater

range of client offerings, while reallocating capital from sub-hurdle businesses. Institutional Client Services aims to grow its client

base in collaboration with the Investment Bank, increase penetration with an extended product offering, and win back U.S. dollar

market share in correspondent banking. Business Banking aims to grow its client base, especially gaining from digital sales and by

leveraging artificial intelligence and data-driven automated campaigning initiatives that enable more targeted outreach and

higher conversion rates.

As a transition partner, Deutsche Bank supports clients across sector value chains in achieving strategic goals, strengthening

competitiveness and resilience, and managing financial operations, while integrating sustainable finance capabilities into treasury

and financing activities. The bank continues to adapt its sector-aligned sustainable finance capabilities to meet evolving client

needs and to enable transition across business models, facilitating progress toward net-zero objectives by combining deep

industry knowledge with tailored financial solutions.

To support this ambition, Corporate Bank is building a scalable operating model that increases efficiency, enhances client delivery

and positions the business for sustainable growth. The segment is investing in technology‑enabled solutions, strengthened

payment capabilities and faster execution enabled by artificial intelligence and automation. These initiatives are complemented

by process redesign and platform integration to improve reliability, standardization and speed across the global franchise.

Corporate Bank aims to further leverage its extensive international network across more than 140 countries, combining global

reach with deep local expertise. This approach supports seamless delivery across Corporate and Institutional Cash Management,

Trade Finance & Lending, Trust & Securities Services and Business Banking. Through scalable technology deployment and

increased operational integration, Corporate Bank aims to enhance productivity, improve resilience and reinforce its competitive

differentiation in an evolving market environment.

Aligned with its strategic priorities, Corporate Bank remains committed to strict capital discipline and prudent risk management,

while maintaining high lending standards and preserve the quality of its loan portfolio. It plans to continue reallocating

risk‑weighted assets toward portfolios with stronger shareholder-value accretion and to increase balance‑sheet velocity through

expanded distribution‑led structuring and broader loan syndication. Through focused growth and a scalable platform across

Corporate Treasury Services, Institutional Client Services and Business Banking, Corporate Bank strengthens its contribution to

scaling the Global Hausbank and aims to deliver sustainable growth and disciplined returns for clients and shareholders.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Investment Bank

The Investment Bank is made up of two principal businesses: Fixed Income & Currencies (FIC) and Investment Banking &

Capital Markets (IBCM). Across these businesses, corporate and institutional clients are offered a comprehensive range of

services encompassing financing, market making, risk-management solutions, advisory and debt and equity issuance. The

segment regionally encompasses Europe, Americas and APAC/MEA.

In 2025, the Investment Bank delivered a strong performance, with a revenue increase of 9% compared to 2024, a

materially increased return on equity and improved cost/income ratio. This performance reflects the execution of

strategic priorities, enhancing the service offering for clients and building on the franchise development over recent

years. During the year, Deutsche Bank was also named “World’s Best FX Bank” in the 2025 Euromoney FX Awards,

reaffirming the bank’s position as one of the leading banks in this market and demonstrating an enhanced offering to

clients.

The Investment Bank intends to concentrate on areas of competitive strength to drive focused revenue growth across

the segment. The segment is pursuing this through three complementary priorities.

One area of focus is to position IBCM to become a leading European franchise and build on German leadership and a

focused global offering, with the aim of strengthening IBCM’s position in core sectors and expanding Advisory and Equity

Capital Markets capabilities, while maintaining the strength of the Debt franchise. This includes deepening corporate

client relationships closely aligned with the Corporate Bank and lending, acquiring new clients to broaden industry

coverage, and investing in sector and product expertise. A key priority is developing Equity distribution capability to

support Equity Capital Markets growth.

In parallel, the segment expects to further invest in the FIC platform to reinforce its strong global position. In the

Americas, growth is expected to come from targeted investments in selected business lines, while capital allocation to

Financing should help offset spread compression, supported by initiatives to deepen client relationships.

Complementing these efforts, the strategy intends to further leverage the Global Hausbank by driving cross-business

collaboration with the Corporate Bank to complete coverage across advisory and risk management, the Private Bank, and

Asset Management, thereby unlocking opportunities in asset origination, distribution, and joint product development.

The segment aims to harness technology and artificial intelligence to transform client service and offerings in a

controlled environment. This is expected to be supported by technology investment over the next three years, delivering

solutions that enhance client experience through advanced data analytics and execution. The implementation of

artificial intelligence enabled automation and end-to-end process redesign should create efficiencies, enabling more

time for client engagement and maintaining a competitive cost/income ratio, while strengthening control frameworks to

ensure safe and sustainable scalability.

Capital is planned to be deployed selectively to support priority growth areas and to develop capital-light franchises

such as Advisory and Equity Capital Markets. The segment plans to align this disciplined utilization of capital with high-

return opportunities while leveraging the segment’s capabilities and investor network to distribute risk effectively.

Finally, the Investment Bank intends to optimize the relationship lending book and enhance client level value creation

through advanced analytics.

By combining focused growth in core franchises, a scalable technology driven operating model, and disciplined capital

deployment, the Investment Bank reinforces its role in scaling the Global Hausbank and is positioned to deliver

sustainable profitability. This strategy supports Deutsche Bank’s ambition to create long-term value for clients and

shareholders through 2028 and beyond.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Private Bank

The Private Bank serves over 20 million clients across 60 markets worldwide. The Private Bank is organized into two client

sectors: Personal Banking and Wealth Management (formerly Wealth Management & Private Banking). In Germany,

Personal Banking leads the market with around 18 million clients and operates through two main, complementary retail

brands: Deutsche Bank as the Hausbank for financial advice and Postbank as a digital-first provider for everyday banking.

In addition, norisbank offers a fully digital banking proposition, while BHW specializes in home-finance solutions. In Italy,

Spain and India, Personal Banking supports retail and emerging affluent clients, acting as a feeder into Wealth

Management. In Germany and across international markets, Wealth Management delivers the Global Hausbank

proposition to high-net-worth and ultra-high-net-worth individuals and their family offices, while also serving affluent

clients in Europe.

In 2025, Personal Banking made significant progress in its transformation journey toward a digital-first, omni-channel

business model by right-sizing the physical sales network, investing in modern branch formats, upgrading remote

advisory, and accelerating the roll-out of digital and mobile services. A major milestone was the migration of Deutsche

Bank’s and norisbank's online, mobile, and telephone banking services to the cloud, enabling faster deployment of new

digital features. These upgrades strengthened client engagement across digital channels while also supporting

successful deposit campaigns.

In Wealth Management, revenues grew across both home and international markets, with robust asset gathering in

investment solutions, particularly in discretionary portfolio mandates. The franchise also expanded its alternative-

investment offering, supported by the launch of a new private markets fund in collaboration with DWS and Partners

Group, a Swiss-based alternative asset manager. Commercial momentum with entrepreneurs and family-office clients

remained strong, reinforced by deeper One-Bank collaboration with the Corporate Bank, the Investment Bank and DWS.

The evolution of the Wealth Management proposition was also recognized in the industry, earning 15 Euromoney ‘Best

Private Bank’ awards in 2025, including ‘Best Bank for Entrepreneurs’ for the third consecutive year, alongside regional

and market-specific accolades.

Private Bank has outlined its ambitions for 2028 to enhance shareholder value through focused growth, strict capital

discipline and a more scalable operating model.

Focused growth remains central to both client sectors. In Personal Banking, the deposit offering and new account

models are positioned as an entry point for prospective clients, while discretionary investments and pension solutions

aim to evolve customer relationships into long-term engagements. Omni-channel interaction and advisory, enriched by

artificial-intelligence-driven insights, are expected to further elevate client experience. In Wealth Management, the

priority is to grow client assets by expanding in core markets and deepening relationships with ultra-high-net-worth

individuals, family offices and family entrepreneurs. This ambition is supported by strategic hiring, strengthened lending

capabilities and an expanded suite of investment solutions.

To reinforce strict capital discipline, Personal Banking plans to free up capital through securitizations of retail loans and

the optimization of portfolios that do not meet targets for shareholder-value accretion. The released capital is expected

to be redeployed to self‑fund growth in Wealth Management and to accelerate investments in strategic initiatives.

Private Bank aims to streamline and scale its operating model by simplifying products, processes and IT. The plan

includes consolidating legacy infrastructure into modern, cloud‑based core banking platforms and deploying agentic

artificial intelligence to automate front‑to‑back workflows. In Personal Banking, the business is further optimizing its

sales network by reshaping the branch footprint in line with customer preferences and advancing efficiency initiatives to

support a more scalable, digitally enabled service model. Wealth Management expects to capture artificial-intelligence-

driven process and platform efficiencies across booking centers, while maintaining cost discipline and delivering a

globally consistent client experience.

Through focused growth, strict capital discipline, and a scalable operating model, the Private Bank is laying the

foundation for its long-term evolution to strengthen its overall contribution to the Global Hausbank.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Business Strategy

Asset Management

Deutsche Bank’s Asset Management segment comprises the consolidated results of its 79.5%-owned, listed affiliate

DWS Group GmbH & Co. KGaA (DWS). The segment advanced Deutsche Bank’s strategy by executing on its four

strategic pillars Growth, Value, Build and Reduce in 2025. At the same time, the segment prepared to apply the three

levers of focused growth, strict capital discipline and a scalable operating model by 2028.

In Growth, the Passive franchise, represented by the Xtrackers brand, expanded in Europe and the U.S. with sustainable,

thematic and actively managed ETFs, and Alternatives gained momentum in infrastructure and private markets. The

European Long-Term Investment Fund (ELTIF) launched by DWS, Deutsche Bank and Partners Group broadened access

for investors across private equity, private credit, real estate and infrastructure, reinforcing the franchise’s strength in this

area.

In Value, Asset Management delivered mature active strategies across equity and fixed income and continued to scale

multi-asset solutions, focusing on resilient offerings for institutional clients and the growing importance of pensions,

investment advisory and outsourced Chief Investment Officer (CIO) services.

In Build, the business advanced digitalization by developing embedded investment solutions and digital assets,

establishing an Application Programming Interface (API)-driven ecosystem with distribution partners, and progressing

AllUnity’s launch of a regulated euro-denominated stablecoin.

In Reduce, capital and resources were reallocated from lower-return or sub-scale products to priority areas, supported

by fund transfers, mergers and closures, enabling self-funded growth.

By 2028, Asset Management aims to support scaling the Global Hausbank by concentrating on focused growth on five

priorities, strict capital discipline and a more scalable operating model.

As Gateway to Europe, Asset Management intends to accelerate infrastructure investments and expand private credit

with the Corporate Bank and the Investment Bank, and aims to widen distribution through selective regional expansion

and the joint development of innovative products and digital investment solutions with the Private Bank.

Top 5 in Top 5 aims to build on the market leadership in Germany, enhance the strategic partnership in China with

Harvest Fund Management and start collaborations with local players to establish scalable positions in the five largest

global economies. Xtrackers benefits from its strong European footprint and thematic product demand in Asia/Pacific

and the U.S., while the solutions franchise expands in the institutional channel, including third party insurance mandates.

Future of Finance is expected to advance embedded investment via an API ecosystem, develop digital-asset services

including stablecoins and on-chain products, and apply artificial intelligence to portfolio construction, risk insights and

operations.

Under Bullish Germany and Global Hausbank, Asset Management expects to capture home-market opportunities in

Germany and leverage Deutsche Bank’s value chain across origination, structuring and distribution.

Asset Management maintains strict capital discipline by reallocating resources toward high‑return opportunities,

streamlining its product shelf and operating model, and advancing efficiency through talent optimization, automation,

AI, and near‑shoring, thereby driving scalable growth for the Global Hausbank and supporting improved earnings and

cost efficiency.

The scalable operating model is designed to convert growth into earnings with discipline. Asset Management continues

its strategy to optimize the platform, near-shore and internalize key functions, build enabling teams and make targeted

hires in Alternatives, while broadening the Xtrackers platform and investing in data and digital capabilities. The approach

is to limit additional costs despite growth so operating leverage improves the cost and income profile through 2028.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

The competitive environment

Geopolitical developments regarding the war in Ukraine continued to influence the economic environment and risk

perception, as did developments in the Middle East. In addition, U.S. administration trade policy caused market volatility

and affected trade flows throughout 2025.

The global economy maintained a steady growth momentum of 3.4%. In particular, trade policy compromises between

the U.S. and its trading partners, along with various tariff reductions, notably dampened trade policy uncertainty.

Inflation decelerated to 3.4%, supporting private consumption and allowing some central banks to implement further

interest rate cuts.

Developed economies benefited from the trade compromises and reduced uncertainty. Economic momentum varied

regionally in 2025, resulting in overall GDP growth of 1.7%. Inflation eased gradually to 2.6%. Some central banks further

lowered their key interest rates from previously restrictive levels.

Emerging markets showed greater resilience than expected despite negative growth and trade shocks from U.S. tariffs.

Emerging Markets maintained GDP growth of 4.4% in 2025. Central banks gained space to cut rates due to lower

inflation of 3.9% and reduced dollar strength. Additionally, improved fiscal impulses from external sources and lower

energy prices provided further support.

Despite external trade headwinds, the Eurozone economy showed robust growth of 1.4%, thanks to resilient domestic

demand. Nevertheless, GDP growth rates varied regionally. Inflation trended downwards to an annual average of 2.1%,

almost reaching the European Central Bank's 2% target. Therefore, the ECB was in a position to leave its deposit rate

unchanged at a neutral level in the second half of the year.

Germany's GDP almost stagnated, growing by a mere 0.2% in 2025. The economy continued to struggle with competitive

disadvantages in foreign trade. Despite initial positive impulses from the now expansionary fiscal policy, domestic

demand also lacked momentum. Inflation eased to 2.2%, supporting private consumption to a certain degree; yet

sentiment remained weak. The cooling of the robust labor market has slowed.

U.S. GDP growth slowed to 2.0% in 2025. The shutdown of the federal government adversely affected economic activity

in the second half of the year. However, AI-related investments supported growth. Reduced food import tariffs eased

some inflationary pressure. Consumer price inflation decelerated gradually to 2.8%. Labor market risks likely prompted

the Federal Reserve to further cut its key interest rate despite above-target inflation.

The impact of U.S. tariffs on the Japanese economy was limited. GDP growth accelerated to 1.4% in 2025. Business

sentiment remained robust. An increase in real employee compensation supported consumption recovery. Inflation

remained elevated at 3.2%, driven by rising food prices. Therefore, the Bank of Japan tightened its monetary policy.

Asian economies grew by an average of 5.4% in 2025. GDP momentum benefited primarily from strong growth in India, in

addition to impulses from China. Inflation decreased noticeably to 0.9%, which supported private consumption and

allowed some central banks to implement further interest rate cuts.

China reached its GDP growth target of 5.0% in 2025, though momentum slowed throughout the year. This was largely

due to policy efforts addressing overcapacity and excessive competition. The government's efforts to boost consumer

durable goods purchases through trade-in subsidies had a diminishing effect. Inflation decelerated somewhat to 0%.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

2026 Outlook

Statements in this section are based on Deutsche Bank's expectations regarding future economic developments in 2026,

and may not materialize. The outlook for the global economy in the following section reflects Deutsche Bank Research’s

general expectations regarding future economic developments. Economic assumptions the Group used in the bank’s

models are laid out separately in the respective sections.

Global growth is projected to slow to 3.3% in 2026, mainly due to an expected deceleration in emerging market

economies. Nevertheless, a reduction in trade-related uncertainties, increased investments in AI, and expanded

government spending in Europe are anticipated to boost GDP growth in developed countries. Global inflation is forecast

to remain stable at 3.3%.

Developed economies are likely to benefit from the easing of global trade tensions and maintain GDP growth of 1.9%.

Moreover, receding inflation to 2.2% could pave the way for further interest rate cuts by several central banks. While

some countries are fiscally consolidating, German fiscal policy will be expansive.

Growth momentum in emerging markets will likely fade to 4.2% given Asia's expected slowdown, while Europe

anticipates a slight pickup in GDP growth. Inflation should ease in Europe and Latin America, but rise in Asia, resulting in

an average of 4.0% in 2026. Lower inflation and a weaker USD should provide central banks with some scope to cut

interest rates.

In the Eurozone, German government spending on defense and infrastructure is expected to boost the economy.

However, only a moderate start to the year is expected to curb GDP growth momentum to 1.1% annually. At 1.7%,

headline inflation is likely to be below the ECB’s target of 2%. The ECB is expected to hold its key interest rates

unchanged in 2026.

Driven by expansionary fiscal policy, the German economy is expected to recover markedly and grow by 1.5%.

Government spending should also generate a "crowding-in" effect on private investment. However, exporters likely still

face headwinds from higher trade barriers and competition. Cooling in the labor market is likely to end as economic

momentum picks up. Private consumption is expected to gain momentum as inflation eases to 2.0%.

In the U.S., growth momentum should accelerate to 2.9%, driven by supportive financial conditions, tax relief, and

reduced trade policy uncertainty. Moreover, AI-related investments are expected to provide further impetus. The labor

market is likely to stabilize. Despite elevated inflation, the Federal Reserve is expected to cut its policy rate at least to a

neutral level due to labor market risks.

The Japanese economy is expected to maintain a moderate GDP growth rate of 0.9% in 2026. While the impact of U.S.

tariff policy on Japan is anticipated to be limited, rising wages and decelerating inflation are likely to support household

consumption. Headline inflation is expected to ease to 1.9%. The Bank of Japan is likely to implement a further interest

rate hike.

The Asian economy is expected to grow by 4.9% in 2026. Even with an anticipated deceleration in China and India,

growth momentum is likely to stay robust in the region. Easing trade tensions should offer continued support to

economic activity. An inflation rate of 2.2% and a softer USD are expected to provide central banks with some scope for

easing their monetary policy.

In China, GDP growth is likely to slow somewhat to 4.5% as "anti-involution policies" dampen overcapacity and

investment in machinery and equipment. Nevertheless, fiscal and monetary policies are expected to remain supportive.

The slow recovery of the real estate market remains a headwind for private consumption. Inflation is expected to pick up

to 1.5%.

There are a number of risks to the bank’s global economic outlook. From a trade policy perspective, tensions could

reignite, especially along strategically important supply chains, particularly between China and the U.S. geopolitical risks

remain elevated in various regions, for example, in Ukraine, Asia, and the Middle East. Financial market valuations

surrounding the progress of artificial intelligence and associated infrastructures could potentially be sources of market

volatility. Furthermore, high government debt ratios could, alongside questionable policy measures for consolidation,

lead to fluctuations in bond yields.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

Competitor landscape

Statements in this section are based on Deutsche Bank's expectations regarding future economic and industry

developments in 2026, and may not materialize. The industry outlook is based on Deutsche Bank Research’s general

assessments. The Group’s economic assumptions are described separately in the relevant sections.

Deutsche Bank competes in the financial services sector with a wide variety of competitors including other universal

banks, commercial banks, savings banks and other public sector banks, broker dealers, investment banking firms, asset

management firms, private banks, investment advisors, payments services providers, financial technology firms and

insurance companies. Some of the competitors are global like Deutsche Bank, while others have a regional, product or

niche client footprint. Deutsche Bank competes on a number of factors, including the quality of client relationships,

transaction execution, products and services, innovation, reputation and price.

In 2025, the strong performance of the European banking industry continued. Despite of lower interest rates, banks were

able to limit the pressure on net interest income, while strengthening non-interest income at the same time. Loan

volumes with the private sector in the Euro area picked up moderately, with more momentum in mortgages due to lower

rates than in corporate lending which in some countries such as Germany still struggled due to a weak macro economy.

Credit standards and loan demand were largely flat following the previous tightening in standards and decline in loan

demand. Surging demand for mortgages was the main exception. A benign capital markets environment provided

tailwinds for fee and commission income. Corporate finance revenues globally rose across the board, led by mergers &

acquisitions and equity capital markets. Trading volumes also improved, particularly for U.S. equities, not least because

of unusual geopolitical and economic policy uncertainty. With asset quality remaining sound and administrative

expenses contained, profitability stayed close to post-financial crisis highs. Capital ratios were broadly flat at record

levels, despite banks returning significant capital to shareholders via dividends and share buybacks.

The global banking industry is expected to continue to operate in a relatively favorable environment during 2026. While

economic growth may remain similar to 2025, it is likely to shift slightly between regions. Interest rates may slightly

decrease in the U.S., but are expected to stay unchanged in the Euro area, thus maintaining overall supportive conditions

for banks’ net interest income. Fee and commission income in investment banking and asset management could benefit

from a benign capital markets performance with contained volatility as economic policy uncertainty is expected to

decline from elevated levels in 2025. Asset quality may stay largely resilient, resulting in profitability remaining strong.

This should allow banks to continue returning significant capital to shareholders. On the back of robust earnings and

higher stock market valuations, bank merger & acquisition activity in selected markets will probably continue, especially

among smaller and mid-tier institutions. Meanwhile, ongoing geopolitical fragmentation poses downside risks for

international trade, growth and financial markets, simultaneously raising demand for banks’ hedging and advisory

services. Strong growth in private credit markets, foremost in the U.S., constitutes an opportunity for banks to extend

credit, while also intensifying competition and triggering financial stability concerns. Increasing adoption of artificial

intelligence might allow for efficiency gains and cost savings, but likewise requires considerable investments, strict

supervision and monitoring of possibly evolving implications, including for financial stability.

European banks are likely to see a moderate acceleration in demand for credit, both from corporates as economic growth

improves as well as from households as lower interest rates bolster the mortgage business. Surging defense spending by

governments may translate into tailwinds for European banks. The effect may be particularly pronounced in Germany

due to broader domestic fiscal expansion. Securing a level playing field in regulation compared to global and especially

U.S. peers will become increasingly important for EU banks as trends diverge (i.e., the U.S. are set for deregulation across

a broad range of areas, whereas prudential requirements in Europe are expected to rise over the coming years). Progress

on the EU’s Savings and Investments Union might support capital market integration and performance. A sustainable end

to Russia’s war against Ukraine would offer upside potential for the economy and financial markets, and therefore also

benefit the banking industry.

U.S. banks should benefit from a pickup in credit demand, lower cost of risk and lower unrealized losses on bond holdings

if economic growth edges higher and interest rates fall as expected. Even more beneficial in the longer term could be a

reduction in capital requirements currently being discussed by regulators. This might strengthen U.S. banks’ competitive

position particularly abroad, in corporate as well as investment banking. At the same time, domestic competition from

non-bank financial institutions such as private equity, asset management firms or crypto providers could intensify. Bank

performance in 2026 will also depend on whether recent capital market momentum persists.

Banks in China remain under pressure from slowing economic growth and deflationary pressures which should lessen

somewhat in 2026. Interest rates are likely to stay low, keeping a lid on banks’ net interest margin. Banks in Japan will

probably face a mixed environment: slowing economic expansion may hold back revenue growth, whereas rising interest

rates could offset the impact. In addition, Japanese banks could benefit from their significant U.S. exposure, if U.S.

growth were to pick up and regulation is loosened.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

In Deutsche Bank’s home market Germany, the retail banking market remains fragmented, and the competitive

environment is influenced by the three-pillar system of private banks, public banks and cooperative banks. In recent

years, competitive intensity remained elevated, particularly due to increased activity levels from foreign players and

digital-only actors such as digital banks, including new or recent entrants.

Looking at the wider banking ecosystem, the evolution of financial technology firms remains as much an opportunity as a

challenge for banks. While Deutsche Bank sees the risk of banking disruption primarily through big technology

companies and in select product areas, particularly the unregulated segments, many banks have also taken the

opportunity to partner with financial technology firms and leverage their solutions, including in the field of artificial

intelligence, to become more efficient and/or develop differentiated delivery channels for end clients. In addition,

private credit firms are increasingly becoming competitors for banks, especially in the U.S. market.

Regulatory environment

Various new legislative and regulatory proposals were issued in recent years, covering topics such as regulatory capital,

liquidity, resolution planning, central bank digital currencies and digital assets.

Capital, liquidity and leverage requirements: During 2025, the EU started the application of the comprehensive package

of reforms with respect to European Union banking rules which implement the Final Basel III set of global reforms,

changing how banks calculate their Risk Weighted Assets. The package amended the EU Capital Requirements

Regulation (CRR) and the Capital Requirements Directive (CRD).

The amendments of the CRR and CRD (commonly referred to as "CRR 3" and "CRD 6") include, among other things, a

gradually introduced output floor establishing minimum risk-weighted assets that will ultimately be set at 72.5% of the

risk-weighted assets calculated under the standardized approach, changes to standardized and internal ratings-based

approaches for determining credit risk, changes to the credit valuation adjustment, a revision of the approaches for

operational risks and reforms to the market risk framework as set out in the Fundamental Review of the Trading Book

(FRTB), adjustments to the Pillar 2 requirements (P2R) and the Systemic Risk Buffer (SyRB) and a “fit-and-proper” set of

rules for the senior staff managing banks. Other measures are aimed at addressing sustainability risks by requiring banks

to identify, disclose and manage environmental, social and governance risks as part of their risk management framework

and include regular climate stress testing by the banks’ supervisors. The implementation of the changes to CRR and CRD

has the potential to increase Deutsche Bank’s risk-weighted assets and will likely affect its business by raising its

regulatory capital and liquidity requirements and by leading to increased costs.

In connection with the Final Basel III package, the European Commission adopted in 2025 a Delegated Regulation

postponing the application of certain elements of the CRR 3 related to the market risk framework by one more year to

January 2027 and consulted on the way forward after January 2027. This was in order to ensure a level playing field for

these rules, given that other major jurisdictions would apply them later or were not clear about their implementation

timeline.

On the back of the CRR 3 and CRD 6 finalization and as empowered therein, the EBA continued to work on technical

elements through regulatory standards and guidance (regulatory products), by issuing consultations and, in some

instances, final regulatory products. These regulatory products have the potential to increase Deutsche Bank’s risk-

weighted assets and will likely affect its business by raising its regulatory capital and liquidity requirements, increasing

costs or impacting other parts of the business.

In parallel, the UK Prudential Regulation Authority (PRA) delayed the implementation of its package implementing the

Final Basel III reforms, known as Basel 3.1. until January 2027, and consulted on the way forward in particular for FRTB.

The European Commission also issued a legislative proposal with changes in the regulatory requirements for

securitizations of EU banks, including changes in the CRR and Securitization Regulation (SecReg). These changes have

the potential to change the regulatory treatment Deutsche Bank applies to its securitization business. The package is

now under negotiation by the EU co-legislators.

In 2025, the U.S. banking regulators have publicly stated they are undertaking a comprehensive review of the regulatory

and supervisory frameworks applicable to U.S. banks, bank holding companies and intermediate holding companies. The

U.S. banking regulators are actively considering changes to the regulatory capital rules to implement revisions to Basel III

finalized by the Basel Committee on Banking Supervision (the “Basel Committee”) in 2017. The future of any such

revisions is highly uncertain. In addition, the Federal Reserve Board has issued proposals to enhance the transparency,

accountability and predictability of its supervisory stress testing framework.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

The Basel Committee on Banking Supervision made several announcements and consulted on several topics, including

banks’ management of Counterparty Credit Risk (CCR). The final rules, if implemented by the bank’s supervisors, have

the potential to change the procedures around Deutsche Bank’s CCR management.

Central Clearing Counterparties (CCPs): A regulation amending the European Market Infrastructure Regulation and an

amending Directive (EMIR 3.0 package) came into force end of 2024 bringing changes to derivatives clearing thresholds,

reporting and transparency requirements and introducing a requirement for financial and non-financial counterparties to

open an active account at an EU CCP for certain derivative instruments and to clear a set number of representative

trades. Throughout 2025, European legislative authorities have consulted upon and progressed the development of

various level 2 technical standards relating to requirements introduced by EMIR 3.0, including technical standards on the

active account requirement which was adopted by the European Commission in October 2025 and was published in the

Official Journal of the EU and the European Union on February 6, 2026 and enters into force on February 20, 2026, i.e.

twenty days after the publication.

In terms of equivalence and recognition determinations for third country CCPs, the European Securities and Markets

Authority (ESMA) and the Reserve Bank of India have signed an updated Memorandum of Understanding (MoU) on

January 27, 2026, which opens the procedure for Indian CCPs to be re-recognised by ESMA. Deutsche Bank expects this

process to be finalized over the next few months. Until then, the BaFin continues to allow German credit institutions

including Deutsche Bank the possibility to remain members of six Indian CCPs. In January 2025, the European

Commission extended time-limited equivalence for U.K. CCPs for an additional period of three years until June 30, 2028.

Savings and Investments Union: The European Commission published its strategy for the Savings and Investments Union

(SIU) on March 19, 2025, setting out the Commission’s priorities for the ongoing development of the EU’s capital markets

and banking sector, including its intention to encourage wider participation in investment products. Notably, the

Commission adopted a legislative package in December 2025 aimed at reforming aspects of EU financial market

supervision, facilitating innovation in the EU’s financial markets (including the use of distributed ledger technology), and

reducing obstacles to market integration such as those affecting the cross border distribution of investment funds

throughout the EU. The package will be scrutinized by the Council of the EU and the European Parliament throughout

2026.

Benchmarks: The European Commission’s legislative reform to the scope of the EU Benchmarks Regulation was

published in the Official Journal of the EU on May 19, 2025 and entered into force on June 8, 2025. Applying from

January 1, 2026, the scope of the original Benchmarks Regulation has been reduced to primarily concern so-called

‘critical’ or ‘significant’ benchmarks as well as EU Climate Transition and EU Paris-aligned benchmarks and certain

commodity benchmarks, with many non-significant benchmarks now excluded from the scope of the regulation.

Digital Transformation: Several jurisdictions progressed initiatives in 2025 to both address risks and capitalize on the

benefits associated with the digitalization of financial services and address the growing dependence on so-called critical

third parties. Work in this area is expected to continue with a focus on data protection, open data access, payment

innovation, e-privacy, cybersecurity, fraud prevention, operational resilience and capital treatment of crypto assets.

As of January 2025, EU financial entities are required to have in place enhanced governance and risk management

requirements in respect of ICT risks apply to EU financial entities under the EU’s Digital Operational Resilience Act

(DORA), and as of 2026 certain ‘designated critical ICT third-party service providers’ are subject to the direct supervision

and oversight of the European Supervisory Authorities.

The MiCA Regulation has been fully applicable since December 2024, and various guidance publications, Regulatory

Technical Standards and Implementing Technical Standards to supplement certain governance and compliance

requirements in the MiCA Regulation have been published by the EBA and ESMA throughout 2025.

The Data Act as a horizontal set of rules on data access and use that respects the protection of fundamental rights was

published in December 2023 and became fully applicable in September 2025, complementing the Data Governance Act

as part of the European data strategy. It aims to deliver wide-ranging benefits for the European economy and society by

encouraging data-driven innovation. It lays the foundation for so-called sectoral data spaces and data-sharing

agreements and introduces rules for switching of cloud service providers.

Specific to the financial sector, the European Commission published a proposal for Financial Data Access legislation

(FiDA) in June 2023. Building on lessons learned from the EU’s Second Payment Services Directive, FiDA seeks to

introduce mandatory data-sharing obligations among financial institutions across a broad range of financial products and

accounts, including investments, savings, loans and insurance. The proposed scope is not limited to account and

transaction data, but also covers customer onboarding information with the aim of facilitating comparability,

competition and switching of providers. The Council reached an agreement on the European Commission’s proposal in

December 2024. Trilogue negotiations with the European Parliament started in April 2025 and formal adoption of the

FiDA legislation is expected in the first half of 2026.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

The European AI Act was published in July 2024 and initial provisions for prohibited AI use cases became applicable on

February 2, 2025, and the remainder of the requirements will become applicable on August 2, 2026. In the U.S. the

Trump Administration published an AI Action Plan in July 2025 detailing its strategy for creating a reg-lite environment

to foster rapid AI development and deployment. A key focus of this strategy is restricting the ability of individual States

to impose burdensome AI regulations. In December 2025 the Administration issued an Executive Order calling for the

development of a federal AI reporting and disclosure framework that would also pre-empt any conflicting state laws.

This Order also directs the Attorney General to form a task force to identify restrictive AI laws and commence litigation to

block their enforcement. The SEC has also withdrawn its proposal that would have required investment advisers to

disclose conflicts of interest relating to AI-related technologies.

In March 2024, the final Instant Payments Regulation was published to make instant payments in Euro available to all

citizens and businesses. This regulation will become applicable in a staggered approach, starting with the initial

obligation for banks and payment service providers to be able to receive instant payments in euros which became

applicable in January 2025, followed by the obligation for banks and payment service providers to be able to send

instant payments and comply with the mandatory “verification of payee” service for incoming instant credit transfers

became applicable on October 9, 2025. Later stages of applicability extend these obligations to payments service

providers outside the Euro area that offer euro-denominated payment services. Furthermore, in November 2025, the EU

Parliament and Council reached an agreement on further changes to the EU’s payment services legislative framework

proposed as part of the third EU Payment Services Directive and a new Payment Services Regulation, focusing on the

prevention of and liability for fraud. Formal adoption of the legislative acts is still outstanding.

In addition, the European political and regulatory landscape continues to be driven by a desire to increase “digital

sovereignty”. This goal translates into active support for European initiatives in the field of digital identities and cloud

services, while at the same time it leads to greater scrutiny of non-European technologies and respective providers,

including calls for on-shoring of data and services.

The ECB is pursuing the possible issuance of the digital euro as a new form of digital central bank money (CBDC) to the

wider public. The ECB, in close cooperation with the digital euro scheme's Rulebook Development Group (RDG) is

advancing technical work to establish a rulebook for the digital euro and continuing to support the legislative process for

the introduction of the digital euro. The ECB estimates that if EU lawmakers adopt the legal framework for the digital

euro as a legal tender together with a proposed legal framework clarifying the role of euro banknotes and coins as a legal

tender and their interplay with the digital euro, the digital euro could be issued during 2029. Given that these legislative

uncertainties are ongoing, it is challenging to assess the actual impact of the digital euro on banks. The Bank of England

and the U.K. government continue to explore the feasibility for a digital pound, with the project now in its ‘design phase’

but with no final decision on whether to issue a digital pound yet made. In January 2025, President Trump signed an

executive order prohibiting federal agencies in the United States from undertaking action to establish or promote the use

of CBDCs.

Work by U.K. and U.S. authorities focused on cloud services and the role of critical third-party service providers that are

not regulated financial entities, but whose service provision is critical to the functioning of the financial market. In

November 2024, the UK FCA and the Bank of England (BoE) published a final oversight framework for critical third

parties which took effect from January 2025 with an initial step to assign the designation status of critical third parties. In

June 2023, the U.S. banking regulators jointly issued supervisory guidance related to third-party risk management

practices for banking organizations.

In October 2024, the U.S. Treasury Department issued a final rule implementing Executive Order 14105 by prohibiting or

requiring notification of certain outbound U.S. investments to China (including Hong Kong and Macau) in

semiconductors, quantum computing technology, and AI. The final rule came into effect on January 2, 2025, and

includes (1) prohibitions on certain investments made by U.S. persons and their controlled foreign entities in the Chinese

semiconductor, microelectronic, quantum information technology, and artificial intelligence sectors; and (2)

requirements for U.S. persons to notify Treasury of certain other investments in these sectors. In December 2025,

Congress codified and expanded Treasury’s outbound investment framework as part of the 2026 National Defense

Authorization Act (NDAA). Specifically, the law requires expansion of the framework to include i) Russia, Iran, Venezuela

(under the Maduro regime). North Korea, and Cuba and ii) super-computing and hypersonic systems. Treasury has 450

days after enactment of the NDAA (until the first quarter of 2027) to implement these changes, and additional updates

and clarifications are likely.

Changes in federal law as well as regulatory and supervisory posture are expected to continue in the United States,

including with respect to digital assets. In July 2025, the President’s Working Group on Digital Asset Markets published a

report providing recommendations for legislation and regulation to facilitate innovation related to digital assets in the

United States. In July 2025, President Trump signed the GENIUS Act into law, which provides a statutory framework for

the regulation of payment stablecoins. The U.S. Congress is also considering legislation to provide jurisdictional clarity

related to the regulation of digital assets in the United States.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

Anti-Money Laundering and Other Financial Crime: The new EU anti-money laundering (AML) and countering the

financing of terrorism (CFT) legislative package (referred to as the AML/CFT Package) entered into force (applicable from

July 10, 2027). The AML/CFT Package contains a regulation on AML/CFT establishing directly applicable rules (AML

Regulation), a sixth directive on AML/CFT, a regulation establishing the EU AML/CFT Authority (AMLA). One key element

of the AML/CFT Package is the establishment of an integrated European AML supervisory mechanism closely involving

national supervisors and the newly established AMLA as well as the creation of a unified AML/CFT regulatory framework

which includes directly applicable AML/CFT rules and requirements throughout the EU (single EU rulebook). The single

rulebook expands the list of obliged entities and includes harmonized, more detailed and granular rules for requirements

such as customer due diligence, beneficial ownership, and AML/CFT risk management.

Climate change, environmental and social issues

2025 saw a continuation in the global development of sustainability-related regulation, some of which will become

applicable to Deutsche Bank from 2026 onwards. Key themes over the course of the year included ongoing

conversations surrounding supply chain due diligence legislation, deforestation guidelines, a proposed Omnibus

simplification proposal to ensure more streamlined and transparent reporting standards, as well as a proposed reworking

of the Sustainable Finance Disclosure Regulation 2.0 (SFDR).

ESG ratings proposals and reporting requirements: The EU ESG Ratings Regulation was published in the Official Journal

of the European Union in December 2024 and will apply from July 2, 2026. In the U.K., the FCA is preparing to implement

a new regulatory framework for ESG ratings, which is expected to take effect on June 29, 2028. This initiative follows the

release of draft legislation in October 2025, designed to bring ESG ratings under FCA supervision. On December 1, 2025,

the FCA published a consultation paper outlining proposed rules and guidance for ESG ratings providers. The

consultation will remain open until March 31, 2026, with final rules anticipated in the fourth quarter of 2026.

The German Act Against Unfair Competition (UWG) and the EU Empowering Consumers for the Green Transition

Directive (EmpCo) play an increasingly significant role in shaping ESG claims. The UWG already prohibits misleading

commercial practices. Upon transposition of EmpCo, the German “blacklist” (implementing the Annex to the Unfair

Commercial Practices Directive) will be expanded to include additional practices. Specifically, “generic environmental

claims" (e.g. “climate neutral” or “eco‑friendly”) are prohibited in principle unless they are appropriately specified and

substantiated. Also, the use of sustainability labels, which are not based on a public authority scheme or a third party

certification system will be restricted. Furthermore, product-related climate claims implying a neutral/reduced/positive

greenhouse gas impact will be prohibited where they rely on compensation/offsetting outside the product's value chain.

At the EU level, EmpCo forms part of the EU's anti-greenwashing framework and must be transposed into national law

from March 27, 2026, with application from September 27, 2026. In Germany, the Unfair Commercial Practices Directive-

related changes are expected to be implemented primarily through amendments to the UWG (including its Annex), while

the Consumer Rights Directive related information duties will require changes in parallel consumer information rules.

Overall, companies should expect heightened scrutiny; environmental and sustainability‑related claims should be clear,

specific, and supported by robust, verifiable evidence to avoid giving misleading impressions and triggering related legal

challenges. Enforcement under the UWG will follow national mechanisms (e.g. via complaints brought by competitors or

associations).


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	The competitive environment

ESG Reporting Requirements: 2025 saw firms implementing the Corporate Sustainability Reporting Directive (CSRD) and

its associated European Sustainability Reporting Standards (ESRS), which extended reporting requirements for

corporates and banks. Provided that the CSRD has been transposed into the respective national laws in line with the

initial implementation deadline in 2024, companies previously subject to the Non-Financial Reporting Directive (NFRD),

were required to report for the first time under ESRS for the financial year 2024, with a first Sustainability Statement to

be published in 2025. The so-called Stop-the-Clock Directive adopted in April 2025, among other things, postponed by

two years the entry into application of the CSRD requirements for large companies that had not yet started reporting as

well as listed SMEs. Although Germany has further postponed the adoption of the CSRD implementing law pending the

adoption of the so-called Omnibus Package, which is meant, among other things, to simplify sustainability reporting

requirements and significantly increase the thresholds for companies falling within the scope of the CSRD, the bank

voluntarily applied ESRS as reporting framework for the Sustainability Statement in 2025. Should the Omnibus Package

be adopted in the form of the provisional agreement reached between the European Parliament and the Council of the

EU in December 2025, only companies with more than 1,000 employees on average during the fiscal year and annual net

turnover of more than € 450 million would be subject to a streamlined sustainability reporting regime from 2028

(reporting on fiscal year 2027). Member states would have the option to exempt from the reporting requirements for the

fiscal years 2025 and 2026 companies that had to start reporting for fiscal year 2024 and will no longer be in scope

under the revised CSRD.

In the U.S., the California Air Resources Board (CARB) published two climate-related reporting regulations: SB 253

(Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Act), which require both public

and private U.S.-based companies (including U.S. subsidiaries of non-U.S. companies) that do business in California to

publish and submit climate-related financial risk reports with the CARB and report greenhouse gas emissions data in

2026. However, in response to an injunction granted by the Ninth Circuit Court of Appeals in the ongoing litigation

against SB 261 and SB 253, CARB confirmed on December 1, 2025 that it would not take enforcement action against

any entity that does not post and submit a climate-related financial risk report pursuant to SB 261 by the January 1, 2026

statutory deadline. The injunction does not affect SB253 and hence, the CARB proposed deadline of August 10, 2026 for

compliance with this Act remains intact.

In March 2024, the SEC adopted rules that would have required U.S. listed companies (such as Deutsche Bank) to provide

certain climate-related information in their registration statements and annual reports. These rules have now been

stayed by the SEC pending the outcome of ongoing litigation, which the SEC has declined to defend. However, bills

proposed or adopted by the legislatures of certain U.S. states may still impose disclosure or other sustainability

requirements.

Environmental legislation: The EU Deforestation Regulation (EUDR) initially issued in June 2023 will begin applying to

certain companies in 2026. EUDR requires companies trading in cattle, cocoa, coffee, oil palm, rubber, soya and wood -

and products derived from these commodities (e.g., meat products, leather, chocolate, glycerol, soybeans, wood and

products such as books) to conduct extensive due diligence on the value chain. On December 23, 2024, a regulation

amending EUDR to introduce a 12-month delay in implementation of the Deforestation regulation, which was scheduled

to apply from December 30, 2024, was published in the Official Journal of the European Union. On December 23, 2025,

another regulation revising EUDR, introducing a one-year postponement for medium/large companies to December

2026 and micro/small companies to June 30, 2027 was published in the Official Journal of the European Union. The

European Commission is expected to review the administrative burden by April 30, 2026.

Sustainability Due-Diligence: At an EU level, the Corporate Sustainability Due Diligence Directive (CSDDD) was

provisionally agreed by the Member States and the European Parliament in December 2023 and finalized in July 2024.

The CSDDD outlines obligations for corporations to identify, mitigate, minimize and prevent adverse impacts on the

environment and human rights for their business chain of activities. Should the Omnibus Package be adopted in the form

of the provisional agreement reached between the European Parliament and the Council of the EU in December 2025,

the CSDDD would have to be implemented into national law by EU member states by July 26, 2028 and would be

applicable to companies in scope from July 2029. Only companies with more than 5,000 employees on average during

the fiscal year and an annual net turnover exceeding € 1.5 billion would fall under the CSDDD. The due diligence

obligations under the revised CSDDD would be significantly cut back, including the obligation to adopt a climate

transition plan.

In Germany, the starting date for reporting under Supply Chain Due Diligence Act (SCDDA) or

Lieferkettensorgfaltspflichtengesetz "LkSG"), which has been in force since January 1, 2023, was pushed out from April

30, 2024 to December 31, 2025, to align with CSRD and ESRS requirements. On October 1, 2025, the German Federal

Office for Economic Affairs and Export Control announced that it will not be reviewing the submission and publication of

reports under SCDDA. While the failure to submit reports will not be subject to sanctions, other due diligence obligations

under SCDDA continue to apply and a failure to comply will be subject to sanctions.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Regulation and Supervision

Deutsche Bank’s operations throughout the world are regulated and supervised by the relevant authorities in each of the

jurisdictions where the bank conducts business. Such regulation relates to licensing, capital adequacy, liquidity, risk

concentration, conduct of business as well as organizational and reporting requirements. It affects the type and scope of

the business the bank conducts in a country and how it structures its operations.

Highlights

As part of the Banking Package 2021, the amendment of the Capital Requirements Regulation and the Capital

Requirements Directive (commonly referred to as “CRR 3” and “CRD 6”) finalize, in particular, the implementation of the

Basel III framework in the European Union. CRR 3 and CRD 6 were published in the EU Official Journal in June 2024. CRR

3 was applicable from January 1, 2025, with certain elements of the regulation being phased in over subsequent years.

With some exceptions regarding transposition and application dates, the European Member States shall, in principle,

adopt and publish, by January 10, 2026, the laws, regulations and administrative provisions necessary to comply with

CRD 6 and apply those measures from January 11, 2026. The German Banking Directive Implementation and

Bureaucracy Reduction Act (BRUBEG) has already been adopted by the German Parliament. Pending completion of the

legislative process, BRUBEG is expected to be published in the Federal Gazette in the first half of 2026, with the

effective dates of the various parts of BRUBEG being scheduled between the day after publication and January 11, 2027.

CRR 3 and CRD 6 include, among other things, a gradually introduced output floor establishing minimum risk-weighted

assets that will ultimately be set at 72.5% of the risk weighted assets calculated under the standardized approach,

changes to standardized and internal ratings-based approaches for determining credit risk, changes to the credit

valuation adjustment, a revision of the approaches for operational risks and reforms to the market risk framework as set

out in the FRTB, adjustments to the Pillar 2 requirements and the systemic risk buffer (SyRB), a “fit-and-proper” set of

rules for the senior staff managing banks, minimum requirements for the prudential supervision of third-country

branches, and a provision for future dedicated legislation on the prudential treatment of crypto asset exposures and

interim own-funds requirements for certain crypto-asset exposures. Other measures address sustainability risks by

requiring banks to identify, disclose and manage environmental, social and governance risks as part of their risk

management framework and include regular climate stress testing by the banks’ supervisors. CRR 3 and CRD 6 do not

entail any adjustments to the capital requirements for green or brown assets. Rather, climate-related risks are captured

by the existing EU risk-based prudential framework. The implementation of CRR 3 and CRD 6 has the potential to

increase Deutsche Bank’s risk-weighted assets and will likely affect its business by raising its regulatory capital and

liquidity requirements and by leading to increased costs.

Deutsche Bank AG is authorized and regulated by the European Central Bank (ECB) and the German Federal Financial

Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht or “BaFin”). Following the departure of the United

Kingdom (U.K.) from the European Union as a result of Brexit, and European Union law ceasing to be applicable in the U.K.

as from end of 2020, Deutsche Bank AG received a new UK authorization (Part 4A) from the PRA in December 2022.

Pursuant to that authorization, Deutsche Bank AG continues to provide banking and other financial services in the U.K.

both from its London Branch and also on a cross-border basis. Divergence between U.K. and European Union law will

potentially, and increasingly, pose challenges for both Deutsche Bank AG and the financial services industry generally.

The following sections present a description of the regulation and supervision of Deutsche Bank’s business in its home

market Germany under the European Union framework of regulation, in the United Kingdom and in the United States.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Regulation in Germany under the Regulatory Framework of the European Union

Deutsche Bank is subject to comprehensive regulation under German law and regulations promulgated by the European

Union which are directly applicable law in Germany.

The German Banking Act (Kreditwesengesetz) and the CRR are important sources of regulation for German banks with

respect to prudential regulation, licensing requirements, and the business activities of financial institutions. In particular,

the German Banking Act requires that an enterprise which engages in one or more of the activities categorized in the

German Banking Act as “banking business” or “financial services” in Germany must be licensed as a credit institution

(Kreditinstitut) or financial services institution (Finanzdienstleistungsinstitut), as the case may be. Deutsche Bank AG is

licensed as a credit institution and is authorized to conduct banking business and to provide financial services.

Significant parts of the regulatory framework for banks in the European Union are governed by the CRR. The CRR

includes requirements relating to regulatory capital, risk-based capital adequacy, monitoring and control of large

exposures, consolidated supervision, leverage, liquidity and public disclosure, including Basel III standards.

Certain other requirements that apply to Deutsche Bank, including those with respect to capital buffers, organizational

and risk management requirements, are set forth in the German Banking Act and other German laws, partly implementing

European Union directives such as the CRD.

Deutsche Bank AG, headquartered in Frankfurt am Main, Germany, is the parent institution of Deutsche Bank Group.

Under the CRR, Deutsche Bank AG, as credit institution and parent company, is responsible for regulatory consolidation

of all subsidiary credit institutions, financial institutions, asset management companies and ancillary services

undertakings. Generally, the bank regulatory requirements under the CRR and the German Banking Act apply both on a

stand-alone and a consolidated basis. However, banks forming part of a consolidated group may receive a waiver with

respect to the application of specific regulatory requirements on an unconsolidated basis if certain conditions are met.

As of December 31, 2025, Deutsche Bank AG benefited from such a waiver, according to which Deutsche Bank AG needs

to apply the requirements relating to own funds, large exposures, exposures to transferred credit risks, leverage and

disclosure by institutions, as well as certain risk management requirements, only on a consolidated basis.

Capital Adequacy Requirements

Minimum Capital Adequacy Requirements (Pillar 1)

The minimum capital adequacy requirements for banks are primarily set forth in the CRR. The CRR requires German

banks to maintain an adequate level of regulatory capital in relation to the total of their risk positions, referred to as total

exposure amount. Risk positions include credit risk positions, market risk positions and operational risk positions

(including, among other things, risks related to certain external factors, as well as to technical errors and errors of

employees). The most important type of capital for compliance with the capital requirements under the CRR is Common

Equity Tier 1 capital. Common Equity Tier 1 capital primarily consists of share capital, retained earnings and other

reserves, subject to certain regulatory adjustments. Another component of regulatory capital is Additional Tier 1 capital,

which includes, for example, certain unsecured subordinated perpetual capital instruments and related share premium

accounts. An important feature of Additional Tier 1 capital is that the principal amount of the instruments will be written

down, or converted into Common Equity Tier 1 capital, when the Common Equity Tier 1 capital ratio of the financial

institution falls below a minimum of 5.125% (or such higher level as the issuing bank may determine). Common Equity

Tier 1 capital and Additional Tier 1 capital together constitute Tier 1 capital. An additional type of regulatory capital is

Tier 2 capital which generally consists of long-term subordinated debt instruments. Tier 1 capital and Tier 2 capital

together constitute own funds.

Under the CRR, banks are required to maintain a minimum ratio of Tier 1 capital to total risk exposure amount of 6% and a

minimum ratio of Common Equity Tier 1 capital to total risk exposure of 4.5%. The minimum total capital ratio of own

funds to total risk exposure is 8%.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Capital Buffers

The German Banking Act also requires banks to build up a mandatory capital conservation buffer (Common Equity Tier 1

capital amounting to 2.5% of total risk exposure), and authorizes the BaFin to set a domestic countercyclical capital

buffer (CCyB) for Germany (Common Equity Tier 1 capital of generally 0% to 2.5% of total risk exposure, or more in

particular circumstances) during periods of high credit growth. The CCyB for Germany is currently set at 0.75%. In order

to comply with the CCyB requirement, banks must calculate their institution-specific CCyB as the weighted average of

the CCyBs that apply to them in the jurisdictions where their relevant credit exposures are located. Accordingly, the total

CCyB requirement, if any, with which Deutsche Bank needs to comply also depends on the corresponding buffer

requirements in other jurisdictions. In addition, BaFin may require banks to build up a capital buffer to prevent and

mitigate long term non-cyclical systemic or macro-prudential risks not otherwise covered by CRR/CRD (SyRB) (Common

Equity Tier 1 capital of a minimum of 0.5% of the total risk exposure amount). Any SyRB determined by BaFin in excess of

5% would require prior authorization of the European Commission. A SyRB with regard to residential real estate financing

is currently set in Germany at 1%. Furthermore, since December 31, 2023, BaFin has imposed an additional SyRB of 4.5%

to all risk exposure amounts in Norway and with effect from June 30, 2025, the reciprocal application of the sectoral

systemic risk buffer of 1% ordered by the Banca d'Italia in Italy with respect to all credit risk exposures and counterparty

credit risk exposures located in Italy entered into effect. G-SIIs are subject to an additional capital buffer (Common

Equity Tier 1 capital of up to 3.5% of the total risk exposure amount, which the BaFin determines for German banks based

on a scoring system measuring the bank’s global systemic importance. Deutsche Bank’s current G-SII capital risk buffer is

1.5% until December 31, 2025 and has been reduced to 1% effective January 1, 2026. BaFin can also determine a capital

buffer of Common Equity Tier 1 capital of up to 3% of the total risk exposure amount for other systemically important

banks (so-called O-SIIs) in Germany, based on criteria measuring, among others, the bank’s importance for the economy

in Germany and the European Economic Area (EEA). Deutsche Bank is subject to treatment both as a G-SII, as well as an

O-SII (on a consolidated basis). Any risk buffer for O-SIIs that exceeds the threshold of 3% requires prior authorization by

the European Commission. Deutsche Bank’s current O-SII capital buffer is 2%. The buffers for G-SIIs and the buffer for O-

SIIs are not cumulative; only the higher of these buffers applies. However, such higher buffer and the SyRB are

cumulative. If the total buffer is higher than 5%, BaFin needs to seek approval by the European Commission. If a bank fails

to build up the required capital buffers, it will be subject to restrictions on the pay-out of dividends, share buybacks and

discretionary compensation payments. Also, within the single supervisory mechanism (SSM), the ECB may require banks

to maintain higher capital buffers than those required by the BaFin.

Leverage Ratio

The CRR also provides for a Tier 1 capital-based binding minimum leverage ratio requirement of 3%. The minimum

leverage ratio requirement is calculated on a non-risk basis and complements the other risk-based capital requirements.

In addition to the minimum leverage ratio requirement, the CRR provides for a leverage ratio buffer requirement for G-

SIIs (such as Deutsche Bank), which must be met with Tier 1 capital and is set at 50% of the G-SII's risk-weighted capital

buffer rate. Certain aspects relating to the leverage ratio buffer requirement as contained in the CRD (such as, among

others, restrictions on the pay out of dividends if the requirements are not met) must be implemented in the laws of the

individual Member States.

Pillar 2 Capital Requirements and Guidance

Furthermore, the ECB may impose capital and leverage ratio requirements on individual significant credit institutions

which are more stringent than the statutory minimum requirements set forth in the CRR, the German Banking Act or the

related regulations. Upon completion of the supervisory review and evaluation process (SREP) discussed in greater detail

below, the competent supervisory authority makes a SREP decision in relation to each relevant bank, which may include

specific capital and liquidity requirements for each affected bank. Any such additional bank-specific capital

requirements resulting from the SREP are referred to as Pillar 2 requirements for its solvency and leverage ratios in

addition to the statutory minimum capital and buffer requirements. Institutions must meet their Pillar 2 requirements for

solvency ratios with at least 75% of Tier 1 capital and at least 56.25% of Common Equity Tier 1 capital and for the

leverage ratio with Tier 1 capital, respectively.

In addition, the ECB may decide following the SREP to communicate to individual banks an expectation to hold a further

Pillar 2 add-on, the so-called Pillar 2 guidance, to its Common Equity Tier 1 and leverage ratio. The ECB has stated that it

generally expects banks to meet the Pillar 2 guidance, although it is not legally binding and failure to meet the Pillar 2

guidance does not automatically have legal consequences. The competent supervisory authority may take a range of

other measures based on the SREP outcome to address shortcomings in a bank’s governance and risk management

processes or its capital or liquidity position, such as prohibiting dividend payments to shareholders or distributions to

holders of regulatory capital instruments.

For details of Deutsche Bank’s regulatory capital, see “Management Report: Risk Report: Risk and Capital Performance”

in Deutsche Bank’s Annual Report 2025.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

MREL Requirements

As discussed below under “Recovery and Resolution”, to ensure that European banks have a sufficient amount of

liabilities with loss-absorbing capacity, they are required to meet MREL determined for each institution individually on a

case-by-case basis. The European Union implemented the Financial Stability Board’s (FSB) TLAC standard for global

systemically important banks (“G-SIBs”, such as Deutsche Bank) by introducing a Pillar 1 MREL requirement for G-SIIs

(the European equivalent term for G-SIBs). This requirement is based on both risk-based and non-risk-based

denominators and will be set at the higher of 18% of total risk exposure and 6.75% of the leverage ratio exposure

measure. It can be met with Tier 1 or Tier 2 capital or debt that meets specific eligibility criteria. Deduction rules apply for

holdings by G-SIIs of TLAC instruments of other G-SIIs. In addition, the competent authorities have the ability to impose

on G-SIIs individual MREL requirements that exceed the statutory minimum requirements.

Limitations on Large Exposures

The CRR also contains the primary restrictions on large exposures, which limit a bank’s concentration of credit risks. The

German Banking Act and the German Large Exposure Regulation (Großkredit- und Millionenkreditverordnung)

supplement the CRR in this regard. Under the CRR, Deutsche Bank’s exposure to a customer and any customers affiliated

with such customer ("group of connected clients") is deemed to be a “large exposure” when the value of such exposure is

equal to or exceeds 10% of its Tier 1 capital. All exposures to customers forming a group of connected clients are

aggregated for these purposes. In general, no large exposure may exceed 25% of Deutsche Bank’s Tier 1 capital, or, in

case the customer is a bank designated as G-SII, 15% of its Tier 1 capital. For exposures in the trading book, the large

exposure regime may give greater latitude, subject to an additional own funds requirement.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Liquidity Requirements

The CRR introduced a liquidity coverage requirement intended to ensure that banks have an adequate stock of

unencumbered high quality liquid assets that can be easily and quickly converted into cash to meet their liquidity needs

for a 30-calendar day liquidity stress scenario. The required liquidity coverage ratio (LCR) is calculated as the ratio of a

bank’s liquidity buffer to its net liquidity outflows. Also, banks must regularly report the composition of the liquid assets

in their liquidity buffer to their competent authorities.

In addition, the CRR provides for a net stable funding ratio (NSFR) to reduce medium- to long-term funding risks by

requiring banks to fund their activities with sufficiently stable sources of funding over a one-year period. The NSFR is

defined as the ratio of a bank’s available stable funding relative to the amount of required stable funding over a one-year

period. Banks must maintain an NSFR of at least 100%. The NSFR applies to both the Group as a whole and to individual

SSM regulated entities, including the parent entity Deutsche Bank AG.

The ECB may impose on individual banks liquidity requirements which are more stringent than the general statutory

requirements if the bank’s continuous liquidity would otherwise not be ensured.

Separation of Proprietary Trading Activities by Universal Banks

The German Separation Act (Gesetz zur Abschirmung von Risiken und zur Planung der Sanierung und Abwicklung von

Kreditinstituten und Finanzgruppen) provides that deposit-taking banks and their affiliates are prohibited from engaging

in proprietary trading that does not constitute a service for others, high-frequency trading, and credit or guarantee

transactions with hedge funds and comparable enterprises that are substantially leveraged, unless such activities are

exempt or excluded, or in the case where no such exemption or exclusion is available, is transferred to a separate legal

entity, referred to as a financial trading institution (Finanzhandelsinstitut). The separation requirement applies if certain

thresholds are exceeded, which is the case for Deutsche Bank. In addition, the German Separation Act authorizes the

BaFin to prohibit the deposit-taking bank and its affiliates, on a case-by-case basis, from engaging in market-making and

other activities that are comparable to the activities prohibited by law, if these activities may put the solvency of the

deposit-taking bank or any of its affiliates at risk. In the event that the BaFin orders such a prohibition, the respective

activities must be discontinued or transferred to a separate financial trading institution. The financial trading institution

may be established in the form of an investment firm or a bank and may be part of the same group as the deposit-taking

bank. However, it must be economically and organizationally independent from the deposit-taking bank and its other

affiliates, and it has to comply with enhanced risk management requirements. Deutsche Bank has established a

compliance and control framework to ensure that no prohibited activities are conducted. As a result, Deutsche Bank has

not established a financial trading institution.

Anti-Financial Crime, Money Laundering, Sanctions, Fraud, Bribery and

Corruption

Financial sector participants are required to take steps to prevent the abuse of the financial system through money

laundering and other financial crime. The European Union has continually sought to strengthen its framework for anti-

money laundering and combating the financing of terrorism, in line with international standards set by the Financial

Action Task Force. To that end, a set of legal instruments (the “AML/CFT Package”) was published in the EU Official

Journal with a July 2024 effective date. One key element of the AML/CFT Package is the establishment of an integrated

European AML supervisory mechanism closely involving national supervisors and the newly established EU Anti-Money

Laundering Authority (AMLA) as well as the creation of a single rulebook. The single rulebook expands the list of obliged

entities and includes harmonized, more detailed and granular rules on requirements such as customer due diligence,

beneficial ownership, and AML/CFT risk management. The requirements of the Anti-Money Laundering Regulation and

Anti-Money Laundering Directive 6 will be applicable from July 10, 2027. Eventually, once the AML/CFT Package has

been implemented, AMLA will directly supervise certain cross-border financial sector entities in the highest risk category,

which is expected to include Deutsche Bank, facilitate cooperation among financial intelligence units and coordinate

national authorities. Generally, the requirements (such as know-your-customer requirements) currently set out in the

German AML Act (Geldwäschegesetz) and the German Banking Act apply to all business lines and infrastructure units as

well as all subsidiaries and affiliates that undertake AML-relevant business and in which Deutsche Bank AG has a

dominating influence. A robust and effective internal control environment and adequate infrastructure (comprising

people, policies and procedures, controls, testing, IT systems and data) are necessary to ensure that the bank conducts

its business and performs its processes in compliance with applicable laws, regulations, and associated supervisory

expectations. The bank continually enhances the effectiveness of its internal control environment and improves its

infrastructure to align with updated regulatory requirements and to close gaps identified by the bank and/or by

regulators and monitors.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Preventing, detecting and reporting financial crime and complying with applicable laws and regulations is vital to

ensuring the stability of banks, such as Deutsche Bank, and the integrity of the international financial system.

Deutsche Bank is required to comply with economic sanctions laws and regulations in the jurisdictions in which it

operates, including sanctions administered and enforced by the United Nations Security Council, the European Union,

the United States, the United Kingdom, and other sanctions measures imposed by governments in jurisdictions where the

bank operates, as applicable. Deutsche Bank therefore operates a sanctions program reasonably designed to comply

with applicable sanctions. As sanctions continue to increase in breadth and complexity, this necessitates continued

updating of the bank’s policies, procedures, processes, and controls.

Deutsche Bank, its management board and supervisory board members and its employees are subject to fraud, bribery

and corruption laws and regulations under the German Criminal Code (Strafgesetzbuch) and in the other countries in

which it conducts business. The UK Bribery Act 2010 has extraterritorial reach and requires Deutsche Bank to design and

develop appropriate measures to mitigate bribery and corruption risk and to establish controls and safeguards to

mitigate such risks.

Data Protection and Cyber Risk

Deutsche Bank has to comply with all applicable data protection laws in the countries in which it operates. In Germany

and the other European Union Member States, the regulation on the protection of natural persons with regard to the

processing of personal data and on the free movement of such data, also referred to as the General Data Protection

Regulation (GDPR), became applicable in the European Union in May 2018. It relates to data protection and privacy

rights of individuals within the European Union and addresses the export of personal data to other jurisdictions. The

GDPR primarily aims at giving individuals control over their personal data and to unifying the regulatory environment for

cross-border business. The GDPR contains provisions and requirements pertaining to the processing of personal data of

individuals and applies to businesses inside the European Union that are processing personal data. The regulation

furthermore applies to businesses outside of the European Union if goods or services are offered to data subjects in the

European Union, or if the behavior of data subjects in the European Union is being monitored. The GDPR imposes

compliance obligations and grants broad enforcement powers to supervisory authorities, including the authority to levy

significant fines for non-compliance. For the U.S., Deutsche Bank maintains a cyber security and data privacy program

that complies with the Gramm Leach Bliley Act as well as SEC and New York Department of Financial Services rules.

Under the German Banking Act (Gesetz über das Kreditwesen) and the BaFin’s Minimum Requirements for Risk

Management for Banks (Mindestanforderungen an das Risikomanagement), information security needs to be an integral

part of a financial institution’s IT strategy and risk management. The BaFin requires that financial institutions establish a

comprehensive information and cyber security program, define standards, implement controls and adhere to their

resulting security policies and standards in accordance with evolving business requirements, regulatory guidance, and an

emerging threat landscape. In addition, the Digital Operational Resilience Act (DORA), applicable since January 17, 2025,

and its pertinent Regulatory Technical Standards (RTS) and Implementing Technical Standards (ITS) provide for a

comprehensive framework of rules on digital operational resilience for regulated financial institutions, including

Deutsche Bank AG, in a harmonized form throughout the European Union. Information security risk management within

Deutsche Bank is part of vendor risk management for any procurement if information technology or outsourcing activity

include the use of new technologies like cloud services. Information security risk (also referred to as cyber risk) is a

component of operational risk assessed in the context of the SREP under Guidelines on ICT Risk Assessment issued by

the EBA, which expects financial institutions to protect the confidentiality, integrity, and availability of customer data

and information assets. Such guidelines are complemented by the EBA’s Guidelines on ICT and Security Risk

Management an updated version of which was issued on February 11, 2025 in the context of the application of DORA.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Remuneration Rules

Under the German Banking Act and the German Credit Institution Remuneration Regulation

(Institutsvergütungsverordnung), as well as the directly applicable EBA Guidelines on sound remuneration policies under

Directive 2013/36/EU, Deutsche Bank AG is subject to certain restrictions on the remuneration it pays to its management

board members and employees. These remuneration rules implement requirements of the CRD and impose a cap on

bonuses. Pursuant to this cap, the variable remuneration for management board members and employees must not

exceed the fixed remuneration. The maximum variable remuneration may be increased to twice the management board

member's or employee’s fixed remuneration if expressly approved by the shareholders’ meeting with the required

majority. In addition, Deutsche Bank AG is obliged to identify individuals who have a material impact on the bank’s risk

profile (“material risk takers”). Such material risk takers are subject to additional rules, such as the requirement that at

least 40% or, as the case may be, up to 60% of the variable remuneration granted to them must be on a deferred basis.

The minimum deferral period is four years and may increase to five years depending on certain factors. For certain

material risk takers the minimum deferral period is set at five years. Also, at least 50% of the variable remuneration for

material risk takers must be paid in shares of the bank or instruments linked to shares of the bank. Variable compensation

of material risk takers has to be subject to an ex-post risk adjustment mechanism and to a claw back provision in case of

personal wrongdoing. These deferral and claw back provisions do not apply to a material risk taker whose variable

remuneration does not exceed € 50,000 gross and 1/3 of the total annual remuneration. Finally, Deutsche Bank is

required to comply with certain disclosure requirements relating to the remuneration it pays to, and its remuneration

principles in respect of, its material risk takers and other affected employees.

In addition, as an issuer whose shares are listed on the New York Stock Exchange (NYSE), the bank has adopted

compensation recovery mechanisms to recoup previously awarded compensation in the event of an accounting

restatement. See below under “Regulation and Supervision in the United States”.

For details of Deutsche Bank’s remuneration system, see “3 - Compensation Report” in Deutsche Bank’s Annual

Report 2025.

Deposit Protection and Investor Compensation in Germany

The Deposit Protection Act and the Investor Compensation Act

The German Deposit Protection Act (Einlagensicherungsgesetz) and the German Investor Compensation Act

(Anlegerentschädigungsgesetz) provide for a mandatory deposit protection and investor compensation system in

Germany, based on a European Union directive on deposit guarantee schemes (DGS Directive) and a European Union

directive on investor compensation schemes.

The German Deposit Protection Act (which implements the DGS Directive into German law) requires that each German

bank participates in one of the statutory government-controlled deposit protection schemes

(Entschädigungseinrichtungen). Since October 2021, the Entschädigungseinrichtung deutscher Banken GmbH (EdB),

which has been commissioned by the German Federal Ministry of Finance to operate the mandatory deposit protection

scheme, is the sole German deposit protection scheme for all German banks. The EdB collects and administers the

contributions of the member banks, and settles any compensation claims of depositors in accordance with the German

Deposit Protection Act.

Under the German Deposit Protection Act, deposit protection schemes are generally liable for obligations resulting from

deposits denominated in any currency in an amount of up to € 100,000 per depositor and bank. Certain depositors, such

as banks, insurance companies, investment funds and governmental bodies, are excluded from coverage.

Deposit protection schemes are financed by annual contributions of the participating banks proportionate to their

potential liabilities, depending on the amount of covered deposits and the degree of risk the bank is exposed to. The

target level of 0.8% of the total covered deposits of the participating banks has been reached by July 3, 2024. Deposit

protection schemes may also levy special contributions if required to settle compensation claims.

Deposit protection schemes will be required to contribute to bank resolution costs if resolution tools are used. The

contribution made by the deposit protection scheme is limited to the compensation it would have to pay if the affected

bank had become subject to insolvency proceedings. Furthermore, deposit protection schemes may provide funding to

its participating banks to avoid their failure under certain circumstances.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Under the German Investor Compensation Act, in the event that the BaFin ascertains a compensation case, EdB as

Deutsche Bank AG’s deposit protection scheme is also required to compensate 90% of the aggregate claims of each

covered creditor arising from securities transactions denominated in Euro or in a currency of any other Member State up

to an amount of the equivalent of € 20,000. Many financial markets participants such as banks, insurance companies,

investment funds, governmental bodies or medium-sized and large corporations, however, do not benefit from this

coverage.

Voluntary Deposit Protection System

Liabilities to creditors that are not covered by a statutory compensation scheme may be covered by the Deposit

Protection Fund (Einlagensicherungsfonds) set up by the Association of German Banks (Bundesverband deutscher

Banken e.V.) of which Deutsche Bank AG is a member. The Deposit Protection Fund protects deposits, i.e., generally

credit balances credited to an account or resulting from interim positions which the bank is required to repay, up to

certain maximum amounts and subject to certain exclusions, of private individuals, foundations and corporates. Deposits

of banks, broker-dealers and other financial sector entities, such as insurance and re-insurance undertakings or

investment funds as well as governmental agencies, are excluded.

The financial resources of the Deposit Protection Fund are funded by contributions of the participating banks. If the

resources of the Fund are insufficient, banks may be required to make special contributions, in particular if the resources

of the Deposit Protection Fund become stretched due to bank insolvencies or otherwise. In order to avoid the need for

special contributions in the context of the failure of a member of the Deposit Protection Fund, Deutsche Bank may on

occasion participate in solutions to address such bank failure outside of the statutory or voluntary deposit protection

system.

In 2021, the Association of German Banks launched a far-reaching reform project for its Deposit Protection Fund that has

started phasing in from 2023 onwards. Deposits held with non-German branches of Deutsche Bank AG are no longer

covered unless grandfathering rules apply. Also, absolute cover limit amounts will apply to all depositors. These amounts

were € 5 million per depositor from January 1, 2023 onwards which have been reduced to € 3 million from January 1,

2025 and will be further reduced to € 1 million from January 1, 2030. For corporates the limits will be ten times higher

but limited to deposits with a maturity of up to twelve months.

Market Conduct, Investor Protection and Infrastructure Regulation

Under the German Securities Trading Act (Wertpapierhandelsgesetz), the BaFin regulates and supervises securities

trading, including the provision of investment services, in Germany. The German Securities Trading Act contains, among

other things, disclosure and transparency rules for issuers of securities that are listed on a German exchange and

organizational requirements as well as rules of conduct which apply to all businesses that provide investment services.

Investment services include, in particular, the purchase and sale of securities or derivatives for others and the

intermediation of transactions in securities or derivatives as well as investment advice. The BaFin has broad powers to

investigate businesses providing investment services to monitor their compliance with the organizational requirements,

rules of conduct and reporting requirements. In addition, the German Securities Trading Act requires an independent

auditor to perform an annual audit of the investment services provider’s compliance with its obligations under the

German Securities Trading Act.

A related area is the Market Abuse Regulation (MAR) which establishes a common European Union framework for, inter

alia, insider dealing, the public disclosure of inside information, market manipulation, and managers’ transactions. The

German Securities Trading Act, which had contained rules on market abuse prior to the entering into force of the MAR,

continues to supplement the MAR in this respect, for example by providing for sanctions in case of violations of the MAR.

In addition, the Markets in Financial Instruments Directive (MiFID), implemented primarily by the German Securities

Trading Act, and the Markets in Financial Instruments Regulation (MiFIR) provide for more far-reaching regulation and

oversight of financial firms providing investment services or activities in the European Union by covering additional

markets and instruments, the extension of pre- and post-trade transparency rules from equities to all financial

instruments, greater restrictions on operating trading platforms, and greater sanctioning powers. The trading venues

under supervision include organized trading facilities. In addition, MiFID/MiFIR, also provide for a trading obligation for

over-the-counter (OTC) derivatives subject to mandatory clearing and which are sufficiently standardized, and investor

protection rules that significantly impact the way investment firms distribute products.

The Regulation on Key Information Documents for Packaged Retail and Insurance-based Investment Products (PRIIPs)

imposes disclosure and transparency requirements when advising on or selling to clients classified as “retail” structured

products and other complex and packaged investment products and aims at increasing investor protection.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Beyond the infrastructure-related provisions of MiFID, PRIIPs and MiFIR, market infrastructure has been the focus of

other regulatory initiatives of the European Union that are relevant for Deutsche Bank. The Regulation on Transparency

of Securities Financing Transactions aims at increasing transparency and reducing risks associated with such

transactions. The regulation requires that repos, securities lending transactions and transactions with equivalent effect

and margin lending transactions be reported to trade repositories and requires risk disclosures and consent before assets

are reused or re-hypothecated. For the OTC derivatives markets, the European Regulation on OTC Derivatives, CCPs and

Trade Repositories, also referred to as EMIR, pursues the goals of reducing system, counterparty and operational risk and

increase transparency in the OTC derivatives markets. The regulation introduced requirements for standardized OTC

derivatives, such as central clearing, margining, portfolio reconciliation or reporting to trade repositories.

In addition, the European Union’s Regulation on Financial Benchmarks seeks to ensure the integrity and accuracy of

indices used as benchmarks for financial instruments and contracts, and prevent their manipulation. Benchmark

administrators are required to obtain authorization or registration in respect of certain benchmarks (including critical and

significant benchmarks) and are subject to rules and oversight regarding their organization, governance and conduct,

although as of January 1, 2026, many ‘non-significant’ benchmarks are no longer in scope of the EU’s benchmark

regulation. European Union-regulated banks, investment firms, fund managers and certain other supervised entities are

only permitted to use benchmarks provided in accordance with the regulation.

Legal Requirements relating to Financial Statements and Audits

As required by the German Commercial Code (Handelsgesetzbuch), Deutsche Bank AG prepares its non-consolidated

financial statements in accordance with German GAAP. Deutsche Bank Group’s consolidated financial statements are

prepared in accordance with International Financial Reporting Standards (IFRS) as endorsed by the European Union, and

the bank’s compliance with capital adequacy requirements and large exposure limits is determined solely based upon

such consolidated financial statements.

Under German law, Deutsche Bank AG is required to be audited annually by a certified public accountant

(Wirtschaftsprüfer). Deutsche Bank AG’s auditor is appointed each year at the annual shareholders’ meeting. However,

the supervisory board mandates the auditor and supervises the audit. The BaFin and the Deutsche Bundesbank

(“Bundesbank”), the German central bank, must be informed of the appointment and the BaFin may reject the auditor’s

appointment. The German Banking Act requires that a bank’s auditor inform the BaFin and the Bundesbank of any facts

that come to the auditor’s attention which would cause it to refuse to certify or to limit its certification of the bank’s

annual financial statements or which would adversely affect the bank’s financial position. The auditor is also required to

notify the BaFin and the Bundesbank in the event of a material breach by management of the articles of association or of

any applicable law. The auditor is required to prepare a detailed and comprehensive annual audit report

(Prüfungsbericht) for submission to the bank’s supervisory board, the BaFin and the Bundesbank. The BaFin and the

Bundesbank share their information with the ECB. In addition to the statutory audit directive and its amendment that has

been implemented into national law, Deutsche Bank is also subject to the European Union’s Regulation on Specific

Requirements regarding Statutory Audit of Public-Interest Entities which includes requirements for mandatory audit firm

rotation and restrictions on non-audit services.

Banking Supervision under the Single Supervisory Mechanism

Under the European Union’s system of financial supervision referred to as SSM, the ECB is the primary supervisor of all

systemically important or significant credit institutions (such as Deutsche Bank AG) and their banking affiliates in the

relevant Member States. The competent national authorities supervise the remaining, less significant banks under the

oversight of the ECB. As a result, Deutsche Bank AG is supervised by the ECB, the BaFin and the Bundesbank.

With respect to Deutsche Bank and other significant credit institutions, the ECB is the primary supervisor and is

responsible for most tasks of prudential supervision, such as compliance with regulatory requirements concerning own

funds, large exposure limits, leverage, liquidity, securitizations, corporate governance, business organization and risk

management requirements. The ECB carries out its day-to-day supervisory functions through a joint supervisory team

(JST) established for Deutsche Bank Group. The JST is led by the ECB and comprises staff from the ECB and national

supervisory authorities, including the BaFin and the Bundesbank. In addition, and regardless of whether an institution is

significant or not, the ECB is responsible for issuing new licenses to credit institutions and for assessing the acquisition

and increase of significant participations (also referred to as qualifying holdings) in credit institutions established in those

Member States of the European Union that participate in the SSM and where notification of such changes must be filed.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

The BaFin is Deutsche Bank’s principal supervisor for regulatory matters with respect to which the bank is not supervised

by the ECB. These include business conduct in the securities markets, in particular when providing investment services to

clients, payment services and implementing measures against money laundering and terrorist financing, and they also

include certain special areas of bank regulation, such as those related to the issuance of covered bonds (Pfandbriefe) and

the supervision of German home loan banks (Bausparkassen) with regard to certain regulatory requirements specifically

applicable to such home loan banks. Generally, the BaFin also supervises Deutsche Bank with respect to those

requirements under the German Banking Act that are not based upon European law. The Bundesbank supports the BaFin

and the ECB and closely cooperates with them. The cooperation includes the ongoing review and evaluation of reports

submitted by Deutsche Bank and of its audit reports as well as assessments of the adequacy of the bank’s capital base

and risk management systems. The ECB, the BaFin and the Bundesbank receive comprehensive information from

Deutsche Bank in order to monitor its compliance with applicable legal requirements and to obtain information on its

financial condition.

Supervisory Review and Evaluation Process (SREP)

For significant institutions such as Deutsche Bank, the JST conducts the SREP for an ongoing assessment of risks,

governance arrangements and the capital and liquidity situation. The SREP requires that the JSTs review the

arrangements, strategies, processes and mechanisms of supervised banks on a regular basis, in order to evaluate risks to

which these banks are or might be exposed, risks they could pose to the financial system, and risks revealed by stress

testing.

The SREP framework consists of a business model analysis, an assessment of internal governance and institution-wide

control arrangements, an assessment of risks to capital and adequacy of capital to cover these risks; and an assessment

of risks to liquidity and adequacy of liquidity resources to cover these risks. The SREP can result in Pillar 2 capital and

liquidity requirements or guidance for the relevant institution (see above “Pillar 2 Capital Requirements and Guidance”).

Audits, Investigations and Enforcement

Investigations and Supervisory Audits

The ECB and the BaFin may conduct audits of banks on a discretionary basis, as well as for cause. In particular, the ECB

may audit Deutsche Bank’s compliance with requirements with respect to which it supervises Deutsche Bank, such as

those set forth in the CRR/CRD. Findings that result from such audits may deviate from or reflect interpretations of the

laws or regulatory technical standards that differ from the bank’s or industry practice, so that the remediation of these

findings may be costly and impose restrictions on how the bank conducts its business. The BaFin may also decide to

audit the bank’s compliance with requirements with respect to which it supervises the bank, such as those relating to

business conduct in the securities markets and the regulation of anti-money laundering, to counter terrorist financing

and payment services, as well as certain special areas of bank regulation, such as those related to the issuance of covered

bonds and the supervision of German home loan banks.

The ECB as well as the BaFin may require a bank to furnish information and documents in order to ensure that the bank is

complying with applicable bank supervisory laws. The ECB and the BaFin may conduct investigations without having to

state a reason therefor. Such investigations may also take place at a foreign entity that is part of a bank’s group for

regulatory purposes. Investigations of foreign entities are limited to the extent that the law of the jurisdiction where the

entity is located restricts such investigations.

The ECB and the BaFin may attend meetings of a bank’s supervisory board and shareholders meetings. They also have

the authority to require that such meetings be convened.

Supervisory and Enforcement Powers

The ECB has a wide range of enforcement powers in the event it discovers any irregularities concerning adherence to

requirements with respect to which it supervises Deutsche Bank.

It may, for example,

–Impose additional own funds or liquidity requirements in excess of statutory minimum requirements;

–Restrict or limit a bank’s business;

–Require the cessation of activities to reduce risk;

–Require a bank to use net profits to strengthen its own funds;

–Restrict or prohibit dividend payments to shareholders or distributions to holders of Additional Tier 1 instruments; or

–Remove the members of the bank’s management or supervisory board members from office.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

To the extent necessary to carry out the tasks granted to it, the ECB may also require national supervisory authorities to

make use of their powers under national law. If these measures are inadequate, the ECB may revoke the bank’s license.

Furthermore, the ECB has the power to impose administrative fines in case of breaches of directly applicable European

Union laws, such as the CRR, or of applicable ECB regulations and decisions. Fines imposed by the ECB may amount to

up to twice the amount of profits gained or losses avoided because of the violation, or up to 10% of the total annual

turnover of the relevant entity in the preceding business year or such other amounts as may be provided for in relevant

European Union law. In addition, where necessary to carry out the tasks granted to it, the ECB may also require that the

BaFin initiate proceedings to ensure that appropriate penalties are imposed on the affected bank.

The BaFin also retains a wide range of enforcement powers. As discussed above, it may take action if instructed by the

ECB in connection with supervisory tasks granted to the ECB. With respect to supervisory tasks remaining with the BaFin,

the BaFin may take action upon its own initiative. In particular, if a bank is in danger of defaulting on its obligations to

creditors, the BaFin may take emergency measures to avert default. These emergency measures may include:

–Issuing instructions relating to the management of the bank;

–Prohibiting the acceptance of deposits and the granting of loans;

–Prohibiting or restricting the bank’s managers from carrying on their functions;

–Prohibiting payments and disposals of assets;

–Closing the bank’s customer services; and

–Prohibiting the bank from accepting any payments other than payments of debts owed to the bank.

The BaFin may also impose administrative fines under the German Banking Act and other German laws. Fines under the

German Banking Act may amount to generally up to € 5 million or, in certain cases, € 20 million, depending on the type of

offense. If the economic benefit derived from the offense is higher, the BaFin may impose fines of up to 10% of the net

turnover of the preceding business year or twice the amount of the economic benefit derived from the violation.

Finally, violations of the German Banking Act may result in criminal penalties against the members of the Management

Board or senior management.

Recovery and Resolution

Germany participates in the European Union’s single resolution mechanism (SRM), which centralizes at a European level the key

competences and resources for managing the failure of banks in Member States of the European Union participating in the

banking union. The SRM is based on the SRM Regulation and the BRRD, which in Germany are mainly implemented through the

German Recovery and Resolution Act (Sanierungs- und Abwicklungsgesetz).

Under the SRM, broad resolution powers with respect to banks domiciled in the participating Member States are granted to the

Single Resolution Board (SRB) as the central European resolution authority and to the competent national resolution authorities.

Resolution powers in particular include the power to reduce, including to zero, the nominal value of shares, or to cancel shares

outright, and to write down certain eligible subordinated and unsubordinated unsecured liabilities, including to zero, or convert

them into equity (commonly referred to as “bail-in”).

For a bank directly supervised by the ECB, such as Deutsche Bank, the SRB draws up the resolution plan, assesses the bank’s

resolvability and may require legal and operational changes to the bank’s structure to ensure its resolvability. In the event that a

bank is failing or likely to fail and certain other conditions are met, in particular where there is no reasonable prospect that any

alternative private sector measures would prevent the failure and resolution measures are necessary in the public interest, the

SRB is responsible for adopting a resolution scheme for resolving the bank pursuant to the SRM Regulation. The European

Commission and, to a lesser extent, the Council of the European Union, have a role in endorsing or objecting to the resolution

scheme proposed by the SRB. The resolution scheme would be addressed to and implemented by the competent national

resolution authorities (the BaFin in Germany).

Resolution measures that could be imposed on a failing bank may consist of a range of measures including the transfer of

shares, assets or liabilities of the bank to another legal entity, the reduction, including to zero, of the nominal value of shares, the

dilution of shareholders of a failing bank or the outright cancellation of shares, or the amendment, modification or variation of

the terms of the bank’s outstanding debt instruments, for example by way of deferral of payments or a reduction of the

applicable interest rate. Furthermore, by way of a “bail-in”, certain liabilities may be written down, including to zero, or

converted into equity after the bank’s regulatory capital has been exhausted.

To ensure that resolution measures can be taken effectively, contractual obligations governed by the laws of a non-EU country

or that are subject to jurisdiction outside the European Union are required to include contractual provisions that ensure that the

relevant obligation can be bailed in. In the case of financial contracts governed by the laws of a non-EU country or that are

subject to jurisdiction outside the European Union, stay acceptance clauses need to be included.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

To ensure sufficient availability of liabilities with loss-absorbing capacity that could be bailed in, the SRM Regulation and the

German Recovery and Resolution Act introduced a requirement for banks to meet Minimum Requirements for Own Funds and

Eligible Liabilities (MREL). The required level of MREL is determined by the competent resolution authorities for each supervised

bank individually on a case-by-case basis, depending on the preferred resolution strategy. In the case of Deutsche Bank AG,

MREL is determined by the SRB.

In addition, G-SIIs are subject to a special Pillar 1 MREL requirement that implements the FSB’s TLAC standard for G-SIBs (see

“MREL Requirements” above).

G-SIIs will need to predominantly rely on capital instruments or eligible subordinated debt for this purpose. Effective January 1,

2017, the German Banking Act provided for a new class of statutorily subordinated debt securities that rank as senior non-

preferred below the bank’s other senior liabilities (but in priority to the bank’s contractually subordinated liabilities, such as

those qualifying as Tier 2 instruments). Following a harmonization effort by the European Union implemented in Germany

effective July 21, 2018, banks are permitted to decide if a specific issuance of eligible senior debt will rank as senior non-

preferred debt or as senior preferred debt.

The SRB is charged with administering the Single Resolution Fund (SRF), a pool of money which is financed by bank levies in the

form of annual ex-ante contributions raised at national level, with the target level being 1% of insured deposits of all banks in

Member States participating in the SRM. The target level was reached for the first time at the end of the initial build-up period

which started in 2016 and ended on December 31, 2023. The SRB continues to verify on an annual basis whether the SRF’s

available financial means have diminished below the target level in the relevant contribution period. Based on the 2025

verification exercise, no ex-ante contributions to the SRF were collected from banks in the collection period 2025. At the

beginning of 2026, the SRB verified that at the reference date (31 December 2025), the SRF amounted to more than € 81

billion, which is above the 1% of covered deposits. Therefore, unless needed, no collection of annual contributions is foreseen

until the next verification exercise

In early 2027, the SRB will verify, again, whether the available financial means in the Single Resolution Fund equal at least 1% of

covered deposits held in the banking union. Should that not be the case, the SRB will decide whether ex ante contributions to

the SRF will be calculated and restarted to be collected in the 2027 contribution period. The SRF will be used for resolving

failing banks after other options, such as the bail-in tool, have been exhausted. In line with the German Recovery and Resolution

Act, public financial support for a failing bank should only be used as a last resort, after having assessed and exploited, to the

maximum extent possible, resolution measures set forth in the SRM Regulation and the German Recovery and Resolution Act,

including the bail-in tool.

Regulation in the EEA and Brexit

The European Union pursues common standards of laws and regulations to create consistency across the internal market

and reduce compliance and regulatory burdens for businesses operating on a cross-border basis. The EEA Agreement

extends this objective to Iceland, Liechtenstein and Norway. Within the EEA, Deutsche Bank AG generally operates in a

branch structure (and on a cross-border basis from its headquarters in Frankfurt am Main) throughout the EU Member

States under the “European Passport” legislative provisions enacted within the EU. To the extent that any Member State

deems the regulated activities of Deutsche Bank AG to be carried out within its supervisory jurisdiction, the national

competent authorities of that Member State supervise the conduct of such regulated activities. This includes, for

example, rules on treating clients fairly and rules governing a bank’s conduct in the securities market.

As a result of Brexit, the U.K. ceased to be a Member State of the European Union and European law ceased to be

applicable within the U.K. as from December 31, 2020. This meant, therefore, for the purposes of Deutsche Bank AG’s

continuation of regulated activities in the U.K., the European Passport provisions were no longer available and it was

obliged to rely upon temporary regulatory permissions while it sought new regulatory (Part 4A) permissions from the U.K.

national competent authority, namely the PRA. Deutsche Bank AG received its (Part 4A) authorization from the PRA on

December 19, 2022. With respect to its regulated activities in the U.K., and the continued operation of its London Branch,

Deutsche Bank AG is currently authorized by the PRA and subject to regulation by the FCA and limited regulation by the

PRA.

Deutsche Bank AG continues to provide banking and other financial services in the U.K. both from its London Branch and

also on a cross-border basis. In June 2023, the U.K. enacted the Financial Services and Markets Act 2023, which provides

for the eventual repeal of EU financial services laws that were retained and subsequently “assimilated” into U.K. law in

the U.K. post-Brexit, and eventual replacement with U.K. rules under a new regulatory framework. Such laws have since

been subject to consultation and varying degrees of amendment, repeal and replacement following Brexit. The growing

divergence between the financial services laws and regulations in the U.K. and the EEA gives rise to new challenges for

both Deutsche Bank AG and the financial services industry generally.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

Since Brexit, other Deutsche Bank Group entities have also had to assess whether they conduct regulated activities in the

U.K. (e.g., by providing U.K. regulated services to U.K. based clients), and where so, determine whether to seek

authorization in the U.K., or otherwise ensure such activity can be conducted pursuant to a U.K. licensing exemption (i.e.,

the “overseas persons exclusion”) or outside of U.K. licensing requirements.

Regulation and Supervision in the United States

Deutsche Bank’s operations are subject to extensive federal and state banking, securities and derivatives regulation and

supervision in the United States. Deutsche Bank engages in U.S. banking activities directly through its New York branch.

It also controls U.S. bank subsidiaries, such as Deutsche Bank Trust Company Americas (DBTCA), a U.S. broker-dealer,

Deutsche Bank Securities Inc., U.S. non-depository trust companies and other subsidiaries. Deutsche Bank holds its U.S.

subsidiaries through two intermediate holding companies, DB USA Corporation, through which Deutsche Bank’s U.S.

banking subsidiaries and the large majority of its other U.S. subsidiaries are held, and DWS USA Corporation, through

which Deutsche Bank’s U.S. asset management subsidiaries are held.

Deutsche Bank’s operations are subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-

Frank Act”) and its implementing regulations, including the Dodd-Frank Act provisions known as the “Volcker Rule,”

which limit the ability of banking entities and their affiliates to engage as principal in certain types of proprietary trading

and to sponsor or invest in private equity or hedge funds or similar funds (“covered funds”), subject to certain exclusions

and exemptions. In the case of non-U.S. banking entities such as Deutsche Bank AG, these exemptions permit certain

activities conducted outside the United States, provided that certain criteria are satisfied. The Volcker Rule also limits the

ability of banking entities and their affiliates to enter into certain transactions with covered funds with which they or their

affiliates have certain relationships. The Volcker Rule also requires banking entities to establish comprehensive

compliance programs designed to help ensure and monitor compliance with restrictions under the Volcker Rule.

The Dodd-Frank Act also mandates that regulators provide for greater capital, leverage and liquidity requirements and

other prudential standards, particularly for financial institutions that pose significant systemic risk. U.S. regulators are

also able to restrict the size and growth of systemically significant non-bank financial companies and large

interconnected bank holding companies. U.S. regulators are also required to impose bright-line debt-to-equity ratio

limits on financial companies that the Financial Stability Oversight Council determines pose a grave threat to financial

stability if it determines that the imposition of such limits is necessary to minimize the risk.

Federal Reserve Board rules set forth how the U.S. operations of certain foreign banking organizations (FBOs), such as

Deutsche Bank AG, are required to be structured, as well as impose enhanced prudential standards that apply to their

U.S. operations. Under these rules, a large FBO with combined U.S. assets of U.S. $100 billion or more and U.S. non-

branch assets of US$ 50 billion or more, such as Deutsche Bank, is required to establish or designate a separately

capitalized top-tier U.S. intermediate holding company (an “IHC”) that holds substantially all of the FBO’s ownership

interests in its U.S. subsidiaries. The Federal Reserve Board may permit an FBO subject to the U.S. IHC requirement to

establish or designate multiple IHCs upon written request. Deutsche Bank AG submitted such a request and received

Federal Reserve Board approval to designate two IHCs: DB USA Corporation and DWS USA Corporation. DWS USA

Corporation is a subsidiary of DWS Group GmbH & Co. KGaA, which is approximately 80% owned by Deutsche Bank AG

and holds the bank’s Asset Management division and subsidiaries. Each IHC is subject, on a consolidated basis, to the

risk-based and leverage capital requirements under the U.S. Basel III capital framework, capital planning and stress

testing requirements, U.S. liquidity buffer requirements and other enhanced prudential standards comparable to those

applicable to large U.S. banking organizations. They are also subject to supplementary leverage ratio requirements,

requirements on the maintenance of TLAC and long-term debt, liquidity coverage ratio and net stable funding ratio

requirements.

The Federal Reserve Board’s October 2019 final rules categorize the U.S. operations of large FBOs based on size,

complexity and risk for purposes of tailoring the application of the U.S. enhanced prudential standards (the “Tailoring

Rules”). The Tailoring Rules did not significantly change the capital requirements that apply to DB USA Corporation or

DWS USA Corporation, though the Tailoring Rules did provide modest relief for such companies with respect to

applicable liquidity requirements so long as their combined weighted short term wholesale funding remains below US$

75 billion.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

In July 2023, the U.S. federal banking agencies issued a Notice of Proposed Rulemaking (“2023 NPR”) to implement in the

United States the Basel III reforms finalized by the Basel Committee in 2017. The 2023 NPR would have required

Category I-IV banking organizations, including DB USA Corporation, and their depository institution subsidiaries to

calculate risk-weighted assets under both the current standardized approach and a new, more risk sensitive, approach.

The risk sensitive approach in the 2023 NPR included standardized approaches for credit risk, operational risk and credit

valuation adjustment risk, as well as a new approach for market risk that would be based on internal models and

standardized supervisory models. Changes in policy priorities and personnel at the U.S. federal banking agencies in 2025

have made it uncertain when a final rule will be adopted, and how and to what extent any new proposal will differ from

the 2023 NPR. Recent public statements by the U.S. federal banking agencies indicate that they are actively

reconsidering their approach to implement the final Basel III reforms. As a result, the timing and content of any final rule,

and the potential effects of any final rule on DB USA Corporation and its depository institution subsidiaries, remain

uncertain.

The Federal Reserve Board has the authority to supervise and examine an IHC, such as DB USA Corporation and DWS

USA Corporation, and its subsidiaries, as well as U.S. branches and agencies of FBOs, such as Deutsche Bank’s New York

branch. An FBO’s U.S. branches and agencies are not required to be held beneath an IHC; however, the U.S. branches and

agencies of an FBO are subject to certain separate liquidity requirements, as well as other enhanced prudential standards

applicable to the combined U.S. operations, such as risk management and oversight and, under certain circumstances,

asset maintenance requirements. Additionally, the FBO itself is subject to certain requirements related to the adequacy

and reporting of the FBO’s home country capital and stress testing regime.

The Federal Reserve Board's single counterparty credit limits rules, which apply to the combined U.S. operations and

IHCs of certain large FBOs, including Deutsche Bank, prohibit Deutsche Bank’s IHCs from having net credit exposure to a

single unaffiliated counterparty in excess of 25 percent of the respective IHC’s Tier 1 capital. Deutsche Bank’s combined

U.S. operations (including its IHCs and New York branch) would have become separately subject to similar restrictions

beginning July 1, 2021, unless Deutsche Bank AG certified compliance with a home country large exposure regime that is

consistent with the Basel large exposure framework. Deutsche Bank AG has availed itself of substituted compliance

through certification for its combined U.S. operations, as the European Union’s framework became effective on June 28,

2021.

As a bank holding company with assets of U.S.$ 250 billion or more whose combined U.S. operations meet the criteria for

a “triennial full filer”, Deutsche Bank AG is required under Title I of the Dodd-Frank Act to prepare and submit to the

Federal Reserve Board and the Federal Deposit Insurance Corporation (FDIC) a resolution plan (the “U.S. Resolution

Plan”) on a timeline prescribed by such agencies, alternating between filing a full plan and a targeted plan. The U.S.

Resolution Plan must demonstrate that Deutsche Bank AG has the ability to execute a strategy for the orderly resolution

of its designated U.S. material entities and operations. For FBOs subject to these resolution planning requirements such

as Deutsche Bank AG, the U.S. Resolution Plan relates only to subsidiaries, branches, agencies and businesses that are

domiciled in or whose activities are carried out in whole or in material part in the United States. Deutsche Bank’s U.S.

Resolution Plan describes the single point of entry strategy for Deutsche Bank’s U.S. material entities and operations and

prescribes that DB USA Corporation would provide liquidity and capital support to its U.S. material entity subsidiaries

and ensure their partial sale or solvent wind-down outside of applicable resolution proceedings. Deutsche Bank

submitted its most recent full U.S. Resolution Plan by the October 1, 2025 due date. Deutsche Bank's next resolution

plan submission is a targeted U.S. Resolution Plan that is due by July 1, 2028.

The Dodd-Frank Act also established a new regime for the orderly liquidation of failing financial companies through the

appointment of the FDIC as receiver that is available only if the U.S. Secretary of the Treasury determines in consultation

with the U.S. President that certain criteria are met, including that the failure of the company and its resolution under

otherwise applicable federal or state law would have serious adverse effects on U.S. financial stability.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

DB USA Corporation and DWS USA Corporation are each subject, on an annual basis, to the Federal Reserve Board’s

supervisory stress testing and capital requirements. DB USA Corporation and DWS USA Corporation are also each

subject to the Federal Reserve Board’s Comprehensive Capital Analysis and Review (CCAR), which is an annual

supervisory exercise that assesses the capital positions and planning practices of large bank holding companies and

IHCs. On June 27, 2025, the Federal Reserve Board publicly released the results of its annual supervisory stress test,

which showed that DB USA Corporation and DWS USA Corporation would continue to have capital levels above

minimum requirements even under the stress test’s severely adverse scenario. DB USA Corporation and DWS USA

Corporation submitted their annual capital plans in April 2025 and will make their next capital plan submissions to the

Federal Reserve Board in April 2026. The CCAR process combines the CCAR quantitative assessment and the buffer

requirements in the Federal Reserve Board’s capital rules to create an institution-specific stress capital buffer (SCB),

which is floored at 2.5%. The SCB equals (i) a bank holding company's projected peak-to-trough decline in Common

Equity Tier 1 capital under the annual CCAR supervisory severely adverse stress testing scenario prior to any planned

capital actions, plus (ii) one year of planned common stock dividends. The SCB is reset each year. On August 29, 2025,

the Federal Reserve Board announced an SCB for each CCAR firm based on 2025 supervisory stress testing results,

which for DB USA Corporation was 11.5% and for DWS USA Corporation was 5.3%. This SCB became effective October 1,

2025. As discussed below, in October 2025 the Federal Reserve Board proposed a rule to disclose and seek public

comments on the supervisory stress testing models. Because this proposal remains subject to public comment, the

Federal Reserve Board is maintaining the SCB requirements for all participating firms at their current levels.

Consequently, absent further action from the Federal Reserve Board, DB USA Corporation’s and DWS USA Corporation’s

SCB is scheduled to be recalibrated in 2027. In April 2025, the Federal Reserve Board issued an NPR that proposed

amendments to the SCB rule (“Proposed SCB Averaging Rule”) intended to reduce volatility in the SCB requirement by

averaging the stress test results across the current and previous capital planning cycles.

In October 2025, the Federal Reserve Board also proposed a rule to enhance the transparency and accountability of its

annual stress test (“Proposed Stress Test Transparency Rule”). Under the proposal, the Federal Reserve Board would

codify an enhanced process for annually disclosing and seeking public comments on the supervisory stress testing

models and the annual supervisory stress test scenarios and make targeted changes to reporting requirements related to

stress testing. The Proposed Stress Test Transparency Rule would also amend the Federal Reserve Board’s framework for

designing stress testing scenarios and amend the Federal Reserve Board’s stress testing policy statement. The Federal

Reserve Board disclosed for public comment the 2026 supervisory stress testing models and scenarios.

Under the Proposed Stress Test Transparency Rule, the Federal Reserve Board would disclose proposed scenarios by

October 15 of the year prior to the year in which the stress test is performed. The Federal Reserve Board would disclose

all details of the final scenarios by March 1 of the year in which the stress test is performed. The Federal Reserve Board

would also publish the supervisory stress testing models, including any material proposed changes to the models, by May

15 of the year in which the stress test is performed. To accommodate the public comment process for proposed

scenarios and set the balance sheet date prior to the release of the proposed scenarios, the proposal would move the

jump-off date for the annual supervisory and company-run stress tests from December 31 to September 30, before the

proposed scenarios are disclosed. Under the proposal, the Federal Reserve Board would continue to publish the results

of the annual supervisory stress test by June 30 of each year.

Large U.S. bank holding companies and certain of their subsidiary depositary institutions are subject to U.S. LCR and net

stable funding ratio (NSFR) requirements that are generally consistent with the Basel Committee’s revised Basel III

liquidity standards. These requirements are each applicable to DB USA Corporation, DWS USA Corporation and DBTCA.

The current U.S. LCR requirements applicable to these entities provide for 85 percent coverage of net outflows over a

projected 30-day period. The current U.S. NSFR requirements applicable to these entities provide for 85 percent

coverage of the required amount of stable funding, so long as the IHCs’ combined weighted short term wholesale

funding remains below US$ 75 billion. These entities are required to publicly report LCR information on a quarterly basis

and NSFR information on a semi-annual basis.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

The Federal Reserve Board’s TLAC rules require, among other things, the U.S. IHCs of non-U.S. G-SIBs, including DB USA

Corporation and DWS USA Corporation, to maintain a minimum TLAC amount, and separately require them to maintain a

minimum amount of eligible long-term debt. The required TLAC amount and the ability or inability of the IHC to count

long-term debt issued externally towards the requirements varies depending on the G-SIB’s planned resolution strategy.

DB USA Corporation and DWS USA Corporation are each considered a “non-resolution covered IHC”, which means that

they are intended, under the planned global resolution strategy of their G-SIB parent (Deutsche Bank AG), to continue to

operate outside of resolution proceedings while the G-SIB parent is subject to a bail-in under the applicable European

resolution regime. The TLAC rules require a “non-resolution covered IHC” to maintain (i) internal minimum TLAC of at

least 16% of its risk-weighted assets, 6% of its Basel III leverage ratio denominator and 8% of its average total

consolidated assets, and (ii) internal eligible long-term debt of at least 6% of its risk-weighted assets, 2.5% of its Basel III

leverage ratio denominator and 3.5% of its average total consolidated assets. Eligible long-term debt instruments for

non-resolution covered IHCs are required to meet certain criteria, including issuance to a foreign company that controls

directly or indirectly the covered IHC or a foreign affiliate (a non-U.S. entity that is wholly owned, directly or indirectly, by

the non-U.S. G-SIB) and the inclusion of a contractual trigger allowing for, in limited circumstances, the immediate

conversion or exchange of some or all of the instrument into Common Equity Tier 1 instruments upon an order by the

Federal Reserve Board. Internal TLAC requirements may be satisfied with a combination of eligible long-term debt

instruments and Tier 1 capital. Each of DB USA Corporation and DWS USA Corporation would also face restrictions on its

discretionary bonus payments and capital distributions if it fails to maintain a TLAC buffer consisting of Common Equity

Tier 1 capital above the minimum TLAC requirement equal to 2.5% of risk-weighted assets. The TLAC rules also prohibit

or limit the ability of DB USA Corporation and DWS USA Corporation to engage in certain types of financial transactions.

In August 2023, the FDIC, Federal Reserve Board, and Office of the Comptroller of the Currency issued a joint NPR on

long-term debt requirements that would make limited amendments to the existing TLAC rules and would extend the

long term debt and clean-holding company portions of the Federal Reserve Board’s existing TLAC rule for U.S. G-SIBs

and U.S. IHCs of foreign G-SIBs to all large banking organizations with US$ 100 billion or more in total assets, with

virtually no tailoring and only a few other amendments to the existing TLAC rule. The timing and content of any final rule,

and the potential effects of any final rule, remain uncertain.

Furthermore, the Dodd-Frank Act provides for an extensive framework for the regulation of OTC derivatives, including

mandatory clearing, exchange trading and transaction reporting of certain OTC derivatives, as well as rules regarding

registration, capital, margin, business conduct standards, recordkeeping and other requirements for swap dealers,

security-based swap dealers, major swap participants and major security-based swap participants. The Commodity

Futures Trading Commission (CFTC) has adopted rules implementing the most significant provisions of the Dodd-Frank

Act. Pursuant to the Dodd-Frank Act, the CFTC imposes position limits on certain commodities and economically

equivalent swaps, futures and options. In addition, the CFTC's cross-border application of U.S. swap rules build on the

CFTC’s cross-border guidance from 2013 and related no-action relief letters. The Securities and Exchange Commission's

(SEC) rules regarding registration, capital, margin, risk-mitigation techniques, trade reporting, business conduct

standards, trade acknowledgement and verification requirements, recordkeeping and financial reporting, and cross-

border requirements for security-based swap dealers generally came into effect in November 2021, the first compliance

date for registration of security-based swap dealers and major security-based swap participants. Finally, the Federal

Reserve Board, the FDIC, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal

Housing Finance Agency impose rules establishing margin requirements for non-cleared swaps and security-based

swaps on swap dealers and security-based swap dealers that are subject to U.S. prudential regulations in lieu of the

CFTC’s and SEC’s margin rules.

In addition, the Dodd-Frank Act requires U.S. regulatory agencies to prescribe regulations with respect to incentive-

based compensation at financial institutions in order to prevent inappropriate behavior that could lead to a material

financial loss; such rules were proposed in 2011 and 2016, but were not finalized. Other provisions require issuers with

securities listed on U.S. stock exchanges to establish a “claw back” policy to recoup previously awarded executive

compensation in the event of an accounting restatement; in November 2022, the SEC adopted rules to implement these

provisions that cover foreign private issuers such as Deutsche Bank. The New York Stock Exchange (NYSE), on which

Deutsche Bank’s ordinary shares are listed, has adopted listing standards to implement these rules, pursuant to which

NYSE-listed issuers, including Deutsche Bank, were required to adopt a compensation recovery policy by December 1,

2023. The compensation recovery policies the bank has adopted are attached as Exhibits 97.1 and 97.2 hereto.

The Dodd-Frank Act also grants the SEC discretionary rule-making authority to impose a new fiduciary standard on

brokers, dealers and investment advisers, which the SEC has implemented through rules and interpretive guidance

applicable to the relationships between such entities and their retail customers. The Dodd-Frank Act also expands the

extraterritorial jurisdiction of U.S. courts over actions brought by the SEC or the United States with respect to violations

of the antifraud provisions of the Securities Act of 1933, the Securities Exchange Act of 1934 and the Investment

Advisers Act of 1940.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

In March 2024, the SEC adopted rules that would have required U.S.-listed companies (such as Deutsche Bank) to

provide certain climate-related information in their registration statements and annual reports, including climate-related

risks that have materially impacted, or are reasonably likely to have a material impact on, its business strategy, results of

operations, or financial condition. The rules also would have required disclosures related to climate-related risks, Scope 1

and Scope 2 greenhouse gas (GHG) emissions and climate-related financial metrics. These rules have now been stayed

by the SEC pending the outcome of ongoing litigation, which the SEC has declined to defend. However, bills proposed or

adopted by the legislatures of certain U.S. states may still impose disclosure or other sustainability requirements.

Deutsche Bank is monitoring such legislative developments and their impact on Deutsche Bank’s U.S. operations and

reporting obligations.

Regulatory Authorities

Deutsche Bank AG as well as its wholly owned subsidiary DB USA Corporation are bank holding companies under the U.S.

Bank Holding Company Act of 1956, as amended (the “Bank Holding Company Act“), by virtue of, among other things,

their ownership of DBTCA. Deutsche Bank AG and DB USA Corporation have elected to be financial holding companies

pursuant to the provisions of the Gramm-Leach-Bliley Act (the “GLB Act”). As such, Deutsche Bank’s U.S. operations are

subject to regulation, supervision and examination by the Federal Reserve Board as Deutsche Bank’s U.S. “umbrella

supervisor”.

DBTCA is a New York state-chartered bank whose deposits are insured by the FDIC to the extent permitted by law.

DBTCA is subject to regulation, supervision and examination by the Federal Reserve Board and the New York State

Department of Financial Services and to applicable FDIC rules. In addition, DBTCA is also subject to regulation by the

Consumer Financial Protection Bureau in relation to retail products and services offered to its customers. Deutsche Bank

Trust Company Delaware is a Delaware state-chartered bank which is subject to regulation, supervision and examination

by the FDIC and the Office of the State Bank Commissioner of Delaware. Deutsche Bank AG’s New York branch is

supervised by the Federal Reserve Board and the New York State Department of Financial Services. Deutsche Bank’s

federally chartered non-depository trust companies are subject to regulation, supervision and examination by the Office

of the Comptroller of the Currency. Deutsche Bank and its subsidiaries are also subject to regulation, supervision and

examination by state banking regulators of certain states in which they conduct banking operations.

Restrictions on Activities

As described below, federal and state banking laws, regulations and supervisory authorities restrict Deutsche Bank’s

ability to engage, directly or indirectly through subsidiaries, in activities in the United States. Among other requirements,

Deutsche Bank and its subsidiaries are required to obtain the prior approval of the Federal Reserve Board before directly

or indirectly acquiring the ownership or control of more than 5% of any class of voting shares of U.S. banks, certain other

depository institutions, and bank or depository institution holding companies. Under applicable U.S. federal banking law,

Deutsche Bank’s U.S. banking operations are also restricted from engaging in certain “tying” arrangements involving

products and services.

Deutsche Bank’s two U.S. FDIC-insured bank subsidiaries, as well as its New York branch, are subject to requirements and

restrictions under federal and state law, including requirements to maintain reserves against deposits, restrictions on the

types and amounts of loans that may be made and the interest that may be charged thereon, and limitations on the types

of investments that may be made and the types of services that may be offered.

The Federal Reserve Board has implemented a supervisory rating system for bank holding companies with U.S.

$ 100 billion or more in total consolidated assets and for IHCs with U.S.$ 50 billion or more in total consolidated assets,

such as DB USA Corporation (the "LFI Rating System"). The LFI Rating System also generally applies to DWS USA

Corporation. Under the LFI Rating System, covered companies receive separate ratings from the Federal Reserve Board

for (i) capital planning and positions, (ii) liquidity risk management and positions and (iii) governance and controls. Each of

these component areas will receive one of the following four ratings: (i) Broadly Meets Expectations, (ii) Conditionally

Meets Expectations, (iii) Deficient-1, and (iv) Deficient-2. In November 2025, the Federal Reserve Board revised the LFI

Rating System, which is effective as of January 16, 2026. Following these revisions, a covered company with at least two

Broadly Meets Expectations or Conditionally Meets Expectations component ratings and no more than one Deficient-1

component rating would be considered “well managed.” The Federal Reserve Board’s revisions to the LFI Rating System

also removed the presumption that the Federal Reserve Board would bring a formal or informal enforcement action

against a covered company that receives one or more Deficient-1 ratings.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

A financial institution’s status as a financial holding company, and resulting ability to engage in a broader range of non-

banking activities, are dependent on the institution and its subsidiary IHCs and insured U.S. depository institutions

qualifying as “well capitalized” and “well managed” under applicable regulations and upon the insured U.S. depository

institutions meeting certain requirements under the Community Reinvestment Act. The Federal Reserve Board’s and

other U.S. regulators’ “well capitalized” standards are generally based on specified quantitative thresholds set at levels

above the minimum requirements to be considered “adequately capitalized.” For Deutsche Bank’s two insured depository

institution subsidiaries, DBTCA and Deutsche Bank Trust Company Delaware, the well-capitalized thresholds under the

U.S. Basel III framework are a Common Equity Tier 1 capital ratio of 6.5%, a Tier 1 capital ratio of 8%, a Total capital ratio

of 10%, and a U.S. leverage ratio of 5%. For bank holding companies, including Deutsche Bank AG and DB USA

Corporation, the well-capitalized thresholds are a Tier 1 capital ratio of 6% and a Total capital ratio of 10%, both of which

in the case of Deutsche Bank AG are calculated for Deutsche Bank AG under its home country standards.

State-chartered banks (such as DBTCA) and state-licensed branches and agencies of foreign banks (such as the New

York branch) may not, with certain exceptions that require prior regulatory approval, engage as principal in any type of

activity not permissible for their federally chartered or licensed counterparts. In addition, DBTCA and Deutsche Bank

Trust Company Delaware are subject to their respective state banking laws pertaining to legal lending limits and

permissible investments and activities. Likewise, the United States federal banking laws also subject state-licensed

branches and agencies of foreign banking organizations to the single-borrower lending limits that apply to federally

licensed branches or agencies, which are substantially similar to the lending limits applicable to national banks. The

single-borrower lending limits applicable to branches and agencies are calculated based on the dollar equivalent of the

capital of the foreign bank (i.e., Deutsche Bank AG in the case of the New York branch).

The Federal Reserve Board may terminate the activities of any U.S. office of a foreign bank if it determines that the

foreign bank is not subject to comprehensive supervision on a consolidated basis in its home country or that there is

reasonable cause to believe that such foreign bank or its affiliate has violated the law or engaged in an unsafe or unsound

banking practice in the United States or, for a foreign bank that presents a risk to the stability of the United States

financial system, the home country of the foreign bank has not adopted, or made demonstrable progress toward

adopting, an appropriate system of financial regulation to mitigate such risk.

Also, under the so-called swaps “push-out” provisions of the Dodd-Frank Act, certain structured finance derivatives

activities of FDIC-insured banks and U.S. branch offices of foreign banks (including Deutsche Bank’s New York branch)

are restricted.

There are various qualitative and quantitative restrictions on the extent to which Deutsche Bank and its non-bank

subsidiaries can borrow or otherwise obtain credit from Deutsche Bank’s U.S. banking subsidiaries or engage in certain

other transactions involving those subsidiaries, including derivative transactions and securities borrowing or lending

transactions. In general, these transactions must be on terms that would ordinarily be offered to unaffiliated entities,

must be secured by designated amounts of specified collateral and are subject to volume limitations. These restrictions

also apply to certain transactions of Deutsche Bank’s New York branch with its U.S. broker-dealers and certain of its other

U.S. affiliates.

A major focus of U.S. governmental policy relating to financial institutions is aimed at preventing money laundering and

terrorist financing and compliance with economic sanctions in respect of designated countries, persons or activities.

Failure of an institution to have policies and procedures and controls in place to prevent, detect and report money

laundering and terrorist financing could in some cases have serious legal, financial and reputational consequences for

the institution.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

New York Branch

The New York branch of Deutsche Bank AG is licensed by the Superintendent of the New York State Department of

Financial Services to conduct a commercial banking business and is required to maintain and pledge eligible high-quality

assets with banks in the State of New York. The Superintendent of Financial Services may also impose asset maintenance

requirements on foreign banks with branch offices in New York. In addition, the Federal Reserve Board is authorized to

impose institution-specific asset maintenance requirements under certain conditions, pursuant to the Tailoring Rules.

The New York State Banking Law authorizes the Superintendent of Financial Services to take possession of the business

and property of a New York branch of a foreign bank under certain circumstances, generally involving violation of law,

conduct of business in an unsafe manner, impairment of capital, suspension of payment of obligations, or initiation of

liquidation proceedings against the foreign bank at its domicile or elsewhere. In liquidating or dealing with a branch’s

business after taking possession of a branch, only the claims of depositors and other creditors which arose out of

transactions with a branch are to be accepted by the Superintendent of Financial Services for payment out of the

business and property of the foreign bank in the State of New York or in the United States and reflected on the books of

the New York branch, without prejudice to the rights of the holders of such claims to be satisfied out of other assets of

the foreign bank. After such claims are paid, the Superintendent of Financial Services will turn over the remaining assets,

if any, first to the liquidators of other offices of the foreign bank that are being liquidated in the United States and then, if

any assets remain, to the foreign bank or its duly appointed liquidator or receiver.

The New York branch’s deposits and other note obligations are not insured by the FDIC. In general, under the

International Banking Act and FDIC regulations, the New York branch is not permitted to engage in domestic retail

deposit activity (accepting an initial deposit of less than US$250,000). The New York branch may not engage as principal

in any type of activity that is not permissible for a federally licensed branch of a foreign bank unless the Federal Reserve

Board has determined that such activity is consistent with sound banking practice. The New York branch must also

comply with the same single borrower (or issuer) lending and investment limits applicable to federally licensed branches,

which are substantially similar to the lending limits applicable to national banks, as well as those imposed by the New

York State Banking Law. The lending limits applicable to the New York branch take into account credit exposures from

derivative transactions. These limits are based on the foreign bank's worldwide capital. In addition, regulations that the

U.S. Financial Stability Oversight Council or other regulators may adopt could affect the nature of the activities which

the New York branch may conduct, and may impose restrictions and limitations on the conduct of such activities.

Deutsche Bank Trust Company Americas

The Federal Deposit Insurance Corporation Improvement Act of 1991 (FDICIA) provides for extensive regulation of

depository institutions (such as DBTCA and its direct and indirect parent companies), including requiring federal banking

regulators to take “prompt corrective action” with respect to FDIC-insured banks that do not meet minimum capital

requirements. As an insured bank’s capital level declines and the bank falls into lower categories (or if it is placed in a

lower category by the discretionary action of its supervisor), greater limits are placed on its activities and federal banking

regulators are authorized (and, in many cases, required) to take increasingly more stringent supervisory actions, which

could ultimately include the appointment of a conservator or receiver for the bank (even if it is solvent). In addition,

FDICIA generally prohibits an FDIC-insured bank from making any capital distribution (including payment of a dividend)

or payment of a management fee to its holding company if the bank would thereafter be undercapitalized. If an insured

bank becomes “undercapitalized”, it is required to submit to federal regulators a capital restoration plan guaranteed by

the bank’s holding company. Since the enactment of FDICIA, both of Deutsche Bank’s U.S. insured bank subsidiaries have

maintained capital above the “well capitalized” standards, the highest capital category under applicable regulations.

DBTCA, like other FDIC-insured banks, is required to pay assessments to the FDIC for deposit insurance under the FDIC’s

Deposit Insurance Fund (calculated using the FDIC’s risk-based assessment system). The minimum reserve ratio for the

Deposit Insurance Fund was increased under the Dodd-Frank Act from 1.15% to 1.35%. After having reached 1.35% as of

September 30, 2018, the reserve ratio had declined below that amount following extraordinary growth in insured

deposits across the banking industry in the first and second quarters of 2020. In response to this, the FDIC adopted a

restoration plan to restore the Deposit Insurance Fund to 1.35% by September 28, 2028. The restoration plan, as

amended, incorporates an increase in initial base deposit assessment rate schedules uniformly by two basis points

beginning in the first quarterly assessment period of 2023. Such increase is applicable to insured depositary institutions

generally, including to DBTCA.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Regulation and Supervision

In November 2023, the FDIC approved a final rule to implement a special assessment to recover the loss to the Deposit

Insurance Fund associated with protecting uninsured depositors following the closures of Silicon Valley Bank and

Signature Bank. The special assessment allows banking organizations to deduct US$ 5 billion of uninsured deposits from

their insured depository institutions’ assessment bases. For banking organizations like DB USA Corporation that have

multiple insured depository institutions, the deduction is distributed across the affiliated insured depository institutions.

On December 16, 2025, the FDIC issued an interim final rule providing that the FDIC collect the special assessment at an

annual rate of approximately 13.4 basis points through the quarter with a payment date of December 31, 2025, and

reduce the special assessment for the eighth and final assessment period to 2.97 basis points, payable on March 30,

2026. Under the interim final rule, upon termination of the FDIC’s receiverships of Silicon Valley Bank and Signature

Bank, the FDIC will either provide an offset to insured depository institutions, if the special assessment amount then-

collected exceeds losses, or collect from insured depository institutions a one-time final shortfall special assessment, if

losses exceed the special assessment amount then-collected. In addition, the FDIC will provide an offset to regular

quarterly deposit insurance assessments for banks subject to the special assessment if, following the final resolution of

litigation between the FDIC and SVB Financial Trust, the total amount collected through the special assessment exceeds

the loss estimate at that time.

In addition, the FDIC has set the designated reserve ratio at 2% as a long-term goal.

The FDIC’s standard maximum deposit insurance amount per depositor at an insured depository institution is

US$ 250,000.

Other

In the United States, Deutsche Bank’s U.S. registered broker-dealer subsidiaries are regulated by the SEC. Broker-dealers

are subject to regulations that cover all aspects of the securities business, including sales methods, trade practices

among broker-dealers, use and safekeeping of customers’ funds and securities, capital structure, recordkeeping, the

financing of customers’ purchases and the conduct of directors, officers and employees.

Deutsche Bank’s principal U.S. SEC-registered broker-dealer subsidiary, Deutsche Bank Securities Inc., is a member of

the NYSE (and other securities exchanges) and is regulated by the Financial Industry Regulatory Authority, Inc. (FINRA)

and the individual state securities authorities in the states in which it operates. The U.S. government agencies and self-

regulatory organizations, as well as state securities authorities in the United States having jurisdiction over Deutsche

Bank’s U.S. broker-dealer affiliates, are empowered to conduct administrative proceedings that can result in censure,

fine, the issuance of cease-and-desist orders or the suspension or expulsion of a broker-dealer or its directors, officers or

employees. Deutsche Bank Securities Inc. is also registered with and regulated by the SEC as an investment adviser, and

by the CFTC and the National Futures Association as a futures commission merchant and commodity pool operator.

Under the Dodd-Frank Act, entities that are swap dealers or major swap participants are required to register with the

CFTC and entities that are security-based swap dealers or major security-based swap participants are required to register

with the SEC. Deutsche Bank AG is registered as a swap dealer with the CFTC and a security-based swap dealer with the

SEC. As a registrant, Deutsche Bank AG is subject to certain requirements relating to capital, margin, business conduct

standards and recordkeeping, among others.


Deutsche Bank	Item 4: Information on the company
Annual Report 2025 on Form 20-F	Organizational Structure

Organizational Structure

In 2025, Deutsche Bank operated its business along the structure of four corporate divisions. Deutsche Bank AG is the

direct or indirect holding company for its subsidiaries. The following table sets forth the significant subsidiaries the

Group owns, directly or indirectly, as of December 31, 2025. Deutsche Bank used the three-part test set out in Section

1-02 (w) of Regulation S-X under the U.S. Securities Exchange Act of 1934 to determine significance. The bank does not

have any other subsidiaries it believes are material based on other less quantifiable factors.

Deutsche Bank owns 100% of the equity and voting interests in these subsidiaries except for DWS Group GmbH & Co.

KGaA, of which it owns 79.49% of equity and voting interests. These subsidiaries are included in the consolidated

financial statements and prepare standalone financial statements as of December 31, 2025. The principal countries of

operations are the same as the countries of incorporation.


Subsidiary		Place of Incorporation
DB USA Corporation1		Delaware, United States
Deutsche Bank Americas Holding Corporation2		Delaware, United States
DB U.S. Financial Markets Holding Corporation3		Delaware, United States
Deutsche Bank Securities Inc.4		Delaware, United States
Deutsche Bank Trust Corporation5		New York, United States
Deutsche Bank Trust Company Americas6		New York, United States
Deutsche Bank Luxembourg S.A.7		Luxembourg
DB Beteiligungs-Holding GmbH8		Frankfurt am Main, Germany
DWS Group GmbH & Co. KGaA9		Frankfurt am Main, Germany

1DB USA Corporation is the top-level holding company for its subsidiaries in the United States.

2Deutsche Bank Americas Holding Corporation is a second tier holding company for subsidiaries in the United States.

3DB U.S. Financial Markets Holding Corporation is a second tier holding company for subsidiaries in the United States.

4Deutsche Bank Securities Inc. is a U.S. company registered as a broker dealer and investment advisor with the Securities and Exchange Commission and as a futures

commission merchant with the Commodities Futures Trading Commission.

5Deutsche Bank Trust Corporation is a bank holding company under Federal Reserve Board regulations.

6Deutsche Bank Trust Company Americas is a New York State-chartered bank and member of the Federal Reserve System. It originates loans and other forms of credit,

accepts deposits, arranges financings and provides numerous other commercial banking and financial services.

7The company's primary business model comprises loan business with international clients (Corporate Bank & Investment Bank), where the bank acts globally as lending

office and as risk transfer hub for the Strategic Corporate Lending of Deutsche Bank, as well as structured finance activities covering long-term infrastructure projects

and high quality investment goods. Furthermore, the bank offers tailor-made solutions with a wide range of products and services to their ultra-high-net-worth (UHNW)

clients.

8The company holds the majority stake in DWS Group GmbH & Co. KGaA.

9The company is a partnership limited by shares (Kommanditgesellschaft auf Aktien) with a German limited liability company (Gesellschaft mit beschränkter Haftung) as a

general partner. The business purpose of the company is the holding of participations in as well as the management and support of a group of financial services providers.

Following the public listing on March 23, 2018 on the Frankfurt Stock Exchange Deutsche Bank Group owns 79.49% of equity and voting interests in the entity.

Property and Equipment

As of December 31, 2025, Deutsche Bank operated in 55 countries out of 1,179 branches around the world, of which

64% were located in Germany. The Group leases a majority of its offices and branches under long-term agreements.

Deutsche Bank continues to review its property requirements worldwide taking into account cost containment measures

as well as growth initiatives in selected businesses. Please see Note 21 “Property and Equipment” to the consolidated

financial statements for further information.

Information required by subpart 1400 of SEC Regulation S-K

Please see pages S-1 through S-13 of the Supplemental Financial Information (Unaudited), which pages are included

herein, for information required by subpart 1400 of SEC Regulation S-K.


Deutsche Bank	Item 5: Operating and Financial Review and Prospects
Annual Report 2025 on Form 20-F	Material accounting policies and critical accounting estimates

Item 4A: Unresolved Staff Comments

Deutsche Bank has not received written comments from the Securities and Exchange Commission regarding its periodic

reports under the Exchange Act, as of any day 180 days or more before the end of the fiscal year to which this Annual

Report relates, which remain unresolved.

Item 5: Operating and Financial Review and

Prospects

Overview

The following discussion and analysis should be read in conjunction with the consolidated financial statements and the

related notes to them included in “Item 18: Financial Statements” of this document, on which Deutsche Bank has based

this discussion and analysis.

The Group has prepared its consolidated financial statements in accordance with IFRS as issued by the International

Accounting Standards Board.

Material accounting policies and critical accounting estimates

The Group’s material accounting policies are essential to understanding its reported results of operations and financial

condition. Certain of these accounting policies require critical accounting estimates that involve complex and subjective

judgments and the use of assumptions, some of which may be for matters that are inherently uncertain and susceptible

to change. Such critical accounting estimates could change from period to period and have a material impact on the

bank’s financial condition, changes in financial condition or results of operations. Critical accounting estimates could also

involve estimates where management could have reasonably used another estimate in the current accounting period.

Actual results may differ from these estimates if conditions or underlying circumstances were to change. See Note 01

“Material accounting policies and critical accounting estimates” to the consolidated financial statements for a discussion

on the Group’s material accounting policies and critical accounting estimates.

Deutsche Bank has identified the following material accounting policies that involve critical accounting estimates:

–The impairment of loans and provisions for off-balance sheet positions

–The impairment of financial assets at fair value through other comprehensive income

–The determination of fair value

–The recognition of trade date profit

–The impairment of goodwill and other intangibles

–The recognition and measurement of deferred tax assets

–The accounting for legal and regulatory contingencies and uncertain tax positions

Recently adopted accounting pronouncements and new

accounting pronouncements

See Note 2 “Recently adopted and new accounting pronouncements” to the consolidated financial statements for a

discussion on the Group’s recently adopted and new accounting pronouncements.


Deutsche Bank	Item 5: Operating and Financial Review and Prospects
Annual Report 2025 on Form 20-F	Operating results

Operating results

The following discussion and analysis should be read in conjunction with the bank’s consolidated financial statements.

Executive summary

Please see “Combined Management Report: Operating and financial review: Executive summary” in the Annual Report

2025.

Trends and uncertainties

For insight into the trends impacting the bank’s performance please see the “Combined Management Report: Operating

and financial review” section of the Annual Report 2025. Key risks and uncertainties for the bank are discussed in “Item 3:

Key Information – Risk Factors”.

The Group’s aspirations are subject to various external and internal factors, some of which the bank cannot influence.

Successful achievement of the bank’s strategic targets may be adversely impacted by reduced revenue generating

capacities of some of the bank’s core businesses should downside risks crystallize. These risks include but are not limited

to uncertainty around U.S. trade policy, the wider implications of U.S. actions in Venezuela and discourse on Greenland,

Russia’s ongoing war in Ukraine, cyber events, the ongoing headwinds posed by regulatory reforms or regulatory actions

to address perceived weaknesses in the financial sector and potential impacts on the bank’s legal and regulatory

proceedings.

While the Group continuously plans and adapts to changing situations, the bank runs the risk that a significant

deterioration in the global macroeconomic environment, an adverse change in market confidence in the banking sector

and/or client behavior, as well as higher competition, inflation or unforeseen costs could lead to the bank missing its

financial targets and capital objectives. As such, Deutsche Bank may incur unexpected losses including impairments and

provisions, experience lower than planned profitability or an erosion of the bank’s capital or liquidity base and broader

financial condition, leading to a material adverse effect on Deutsche Bank’s results of operations and share price.

In addition to the risks outlined above, risks to the divisional outlook include second order effects on energy and supply

chain disruptions from geopolitical uncertainty which may also have an adverse impact on client activity. Client activity

and investors’ confidence could also be impacted by market uncertainties including higher than expected volatility in

equity and credit markets.

Results of operations

Please see “Combined Management Report: Operating and financial review: Results of operations” in the Annual Report

2025 and the Group’s discussion of Non-GAAP financial measures in the “Supplementary Information (Unaudited): Non-

GAAP financial measures”.

Financial position

Please see “Combined Management Report: Operating and financial review: Financial position” in the Annual Report

2025.


Deutsche Bank	Item 5: Operating and Financial Review and Prospects
Annual Report 2025 on Form 20-F	Liquidity and capital resources

Liquidity and capital resources

Deutsche Bank believes that its working capital is sufficient for the bank’s present requirements.

For a detailed discussion of the bank’s liquidity risk management, see “Combined Management Report: Risk Report:

Liquidity risk” in the Annual Report 2025.

For a detailed discussion of the Group’s capital management, see “Combined Management Report: Risk Report: Capital

management” in the Annual Report 2025.

Post-employment benefit plans

Please see “Combined Management Report: Employees: Post-employment benefit plans” in the Annual Report 2025.

Off-balance sheet arrangements

For information on the nature, purpose and extent of the Group’s off-balance sheet arrangements, please see Note 38

“Structured entities” to the consolidated financial statements. For further information on off-balance sheet

arrangements, including allowances for off-balance sheet positions, please refer to “Combined Management Report: Risk

Report: Asset quality: Allowance for credit losses” in the Annual Report 2025 and Note 19 “Allowance for credit losses”

to the consolidated financial statements. For information on irrevocable lending commitments and contingent liabilities

with respect to third parties, please see Note 28 “Credit related commitments and contingent liabilities” to the

consolidated financial statements.

Tabular disclosure of contractual obligations

Please see “Combined Management Report: Operating and financial review: Tabular disclosure of contractual

obligations” in the Annual Report 2025.

Research and development, patents and licenses

Not applicable.


Deutsche Bank	Item 6: Directors, Senior Management and Employees
Annual Report 2025 on Form 20-F	Directors and Senior Management

Item 6: Directors, Senior Management and

Employees

Directors and Senior Management

In accordance with the German Stock Corporation Act (Aktiengesetz), Deutsche Bank has a Management Board

(Vorstand) and a Supervisory Board (Aufsichtsrat). The German Stock Corporation Act prohibits simultaneous

membership on both the Management Board and the Supervisory Board. The members of the Management Board are the

executive officers of the company. The Management Board is responsible for managing the company and representing

the bank in dealings with third parties. The Supervisory Board oversees the Management Board, appoints and recalls its

members and determines their remuneration and other compensation components, including pension benefits.

According to German law, the Supervisory Board represents Deutsche Bank in dealings with members of the

Management Board. Therefore, no members of the Management Board may enter into any agreement with Deutsche

Bank without the prior consent of the Supervisory Board.

The Supervisory Board has defined that, in general, a Management Board member should not be older at the end of his or

her appointment period than the regular retirement age according to the rules of the German statutory pension

insurance scheme applicable in Germany for the long-time insured to claim an early retirement pension

(“Renteneineintrittsalter zur vorzeitigen Inanspruchnahme der Altersrente für langjährig Versicherte”), which is currently

63 years of age. Age limits also exist for the members of the Supervisory Board according to the terms of reference

(Geschäftsordnung) for the Supervisory Board. There is a maximum age limit of 70 years for members of the Supervisory

Board. In exceptional cases, a Supervisory Board member can be elected or appointed for a period that extends no longer

than until the end of the fourth ordinary general meeting that takes place after he/she has reached the age of 70.

The Supervisory Board may not make management decisions. However, German law and Deutsche Bank’s Articles of

Association (Satzung) require the Management Board to obtain the approval of the Supervisory Board for certain actions.

The most important of these actions are:

–Granting of general powers of attorney (Generalvollmachten). A general power of attorney authorizes its holder to

represent the company in substantially all legal matters without limitation to the affairs of a specific office

–Acquisitions and disposals (including transactions carried out by a dependent company) of real estate insofar as the

object involves more than € 500,000,000

–Granting of credits, including the acquisition of participations in other companies, where the German Banking Act

(Kreditwesengesetz) requires approval by the Supervisory Board. In particular, pursuant to the German Banking Act, it

requires of the Supervisory Board inter alia the approval if the bank grants a loan (to the extent legally permissible) to

a member of the Management Board or the Supervisory Board or one of the bank’s employees who holds a

procuration (Prokura) or general power of attorney, and

–Acquisitions and disposals (including transactions carried out by a dependent company) of other participations,

insofar as the object involves more than € 1 billion. The Supervisory Board must be informed without delay of any

acquisition or disposal of such participations involving more than € 500,000,000

The Management Board must submit regular reports or ad-hoc reports, as the case may be, to the Supervisory Board on

its current operations and future business planning as well as on its risk situation. The Supervisory Board may also request

special reports from the Management Board at any time.

With respect to voting powers, a member of the Supervisory Board or the Management Board may not vote on

resolutions open to a vote at a board meeting if the proposed resolution concerns:

–A legal transaction between Deutsche Bank and the respective member, or

–Commencement, settlement or completion of legal proceedings between Deutsche Bank and the respective member

A member of the Supervisory Board or the Management Board may not directly or indirectly exercise voting rights on

resolutions open to a vote at a shareholders’ meeting (Hauptversammlung, which the bank refers to as the General

Meeting) if the proposed resolution concerns:

–Ratification of the member’s acts

–A discharge of liability of the member, or

–Enforcement of a claim against the member by the bank.


Deutsche Bank	Item 6: Directors, Senior Management and Employees
Annual Report 2025 on Form 20-F	Directors and Senior Management

Supervisory Board and Management Board

In carrying out their duties, members of both the Management Board and the Supervisory Board must exercise the

standard of care of a prudent and diligent businessperson, and they are liable to the bank for damages if they fail to do

so.

The liability of the members of the Management Board or the Supervisory Board under the German Stock Corporation

Act for breach of their fiduciary duties is to the company rather than individual shareholders. However, individual

shareholders that hold at least 1% or € 100,000 of the subscribed capital and are granted standing by the court may also

invoke such liability to the company. The underlying concept is that all shareholders should benefit equally from

amounts received under this liability by adding such amounts to the company’s assets rather than disbursing them to

plaintiff shareholders. Deutsche Bank may waive the right to claim damages or settle these claims if at least three years

have passed since the alleged breach and if the shareholders approve the waiver or settlement at the General Meeting

with a simple majority of the votes cast, and provided that opposing shareholders holding, in the aggregate, one tenth or

more of its share capital do not have their opposition formally noted in the minutes.

Supervisory Board

The German Co-Determination Act of 1976 (Mitbestimmungsgesetz) requires the bank’s Supervisory Board to have

twenty members, which is also reflected in the Articles of Association. In the event that the number of members of the

Supervisory Board falls below twenty, upon application to a competent court, the court must appoint replacement

members to serve on the board until regular appointments are made by the General Meeting (with respect to shareholder

representatives) or the employees and their representatives (with respect to employee representatives).

The German Co-Determination Act of 1976 (Mitbestimmungsgesetz) requires that the shareholders elect half of the

members of the supervisory board of large German companies, such as Deutsche Bank, and that employees in Germany

elect the other half. None of the current members of either of the bank’s boards were selected pursuant to any

arrangement or understandings with major shareholders, customers or others.

Each member of the Supervisory Board generally serves for a fixed term of approximately five years. For the election of

shareholder representatives, the term of shareholder representatives is usually limited to approximately four years by the

General Meeting since 2021. Pursuant to German law, the term expires at the latest at the end of the Annual General

Meeting that approves and ratifies such member’s actions in the fourth fiscal year after the year in which the Supervisory

Board member was elected. Supervisory Board members may also be re-elected. The shareholders may, by a majority of

the votes cast in a General Meeting, remove any member of the Supervisory Board the shareholders have elected in a

General Meeting. The employees may remove any member they have elected by a vote of three-quarters of the

employee votes cast.

The members of the Supervisory Board elect the chairperson and the deputy chairperson(s) of the Supervisory Board.

Traditionally, the chairperson is a representative of the shareholders, and the first deputy chairperson is a representative

of the employees. At least half of the members of the Supervisory Board must be present at a meeting or must have

submitted their vote in writing to constitute a quorum. In general, approval by a simple majority of the members of the

Supervisory Board present and voting is required to pass a resolution. In the case of a deadlock, the resolution is put to a

second vote. In the case of a second deadlock, the chairperson has the deciding vote.

For additional information on Deutsche Bank’s Supervisory Board, including a table providing the names of and

biographical information for the current members, see “Corporate Governance Statement: Supervisory Board:

Supervisory Board” in the Annual Report 2025.


Deutsche Bank	Item 6: Directors, Senior Management and Employees
Annual Report 2025 on Form 20-F	Directors and Senior Management

Committees of the Supervisory Board

For information on the committees of the bank’s Supervisory Board, please see “Corporate Governance Statement:

Supervisory Board: Committees of the Supervisory Board” in the Annual Report 2025.

The business address of the members of the Supervisory Board is the same as Deutsche Bank’s business address,

Taunusanlage 12, 60325 Frankfurt am Main, Germany.

Management Board

Deutsche Bank’s Articles of Association require the Management Board to have at least three members. The

Management Board currently has ten members. The Supervisory Board has also appointed a Chairman (CEO) and a

Deputy Chairman (President) of the Management Board.

The Supervisory Board appoints and oversees the members of the Management Board. The initial appointment is for a

maximum of three years. Members may be re-appointed or have their terms extended for one or more terms of up to a

maximum of five years each, although also re-appointments, as a rule, shall be for a maximum of three years. The

Supervisory Board may remove a member of the Management Board prior to the expiration of his or her term for good

reason.

Pursuant to Deutsche Bank’s Articles of Association, two members of the Management Board, or one member of the

Management Board together with a holder of procuration, may represent the bank for legal purposes. A holder of

procuration is an attorney-in-fact who holds a legally defined power of attorney under German law, which cannot be

restricted with respect to third parties. However, pursuant to German law, the Management Board as a whole must

resolve on certain matters and may neither delegate the decision to one or more individual members. In particular, the

Management Board may not delegate the determination of the bank’s business and risk strategies, and the coordinating

or controlling responsibilities. The Management Board is required to ensure that shareholders are treated on an equal

basis and receive equal information. The Management Board is also responsible for ensuring proper business

organization, which includes appropriate and effective risk management as well as compliance with legal requirements

and internal guidelines, and for taking the necessary measures to ensure that adequate internal guidelines are developed

and implemented.

Other selected responsibilities of the Management Board in accordance with the Terms of Reference for the

Management Board and/or German law are:

–Appointing key personnel at the level directly below the Management Board, in particular, appointing the Global Key

Function Holders employed by the bank

–Making decisions regarding significant credit exposures or other risks which have not been delegated to individual risk

management units

–Acquisition and disposal of equity investments, including capital measures in all cases in which (i) the law or the

Articles of Association require approval by the Supervisory Board, or (ii) the equivalent of € 100 million is exceeded

–Acquisition and disposal of real estate – directly or by separate legal entities, in all cases in which: (i) the law or the

Articles of Association require approval by the Supervisory Board, or (ii) the real estate’s equivalent exceeds

€ 100 million

–Individual vendor or intra Group-outsourcings (or material changes to those outsourcings) in all cases in which the

equivalent of € 100 million is exceeded on an annual basis or include the delegation of core organizational duties of

the Management Board

–Calling shareholders’ meetings

–Filing petitions to set aside shareholders’ resolutions

–Preparing and executing shareholders’ resolutions and

–Reporting to the Supervisory Board

For additional information on Deutsche Bank’s Management Board, including the names of and biographical information

for the current members, see “Corporate Governance Statement: Management Board: Composition of the Management

Board” in the Annual Report 2025. The Terms of Reference of the Management Board are published on the bank’s

website www.db.com/ir/en/documents.htm.


Deutsche Bank	Item 6: Directors, Senior Management and Employees
Annual Report 2025 on Form 20-F	Board practices of the Management Board

Board practices of the Management Board

The Terms of Reference for the Management Board are in accordance with the Supervisory Board resolution of

September 5, 2025. These Terms of Reference provide that the members of the Management Board have the collective

responsibility for managing Deutsche Bank. Notwithstanding this principle, the allocation of functional responsibilities to

the individual members of the Management Board and member substitutions (in case of temporary absence) are set out

in the Business Allocation Plan for the Management Board in accordance with the Supervisory Board resolution of

December 10, 2025. The allocation of functional responsibilities does not exempt any member of the Management Board

from collective responsibility for the management of the business. The members of the Management Board are

responsible for the proper performance and/or delegation of its duties and the clear allocation of accountabilities and

responsibilities within the area of its functional responsibility (so-called “Ressort”) in accordance with the Business

Allocation Plan.

Members of the Management Board are bound to the corporate interest of Deutsche Bank. No member of the

Management Board may pursue personal interests in his or her decisions or use business opportunities intended for the

company for himself/herself. To the extent permitted by German law, individual members of the Management Board may

assume mandates outside of Deutsche Bank Group, honorary offices or special assignments. In order to effectively

prevent any conflicts of interest, the members of the Management Board may accept such positions only upon the

approval of the other members of the Management Board and the Chairman’s Committee of the Supervisory Board.

Management Board members generally do not accept the role of chair of supervisory boards of companies outside the

Group. Board members are required to disclose any perceived, or foreseeable conflicts of interest within their area of

responsibility as allocated in the Business Allocation Plan to the Chief Executive Officer, ensuring proper assessment and

management under the bank's overarching conflicts framework. Also, all members of the Management Board shall

disclose any existing or foreseeable conflicts between their own personal interests or the interests of persons they are

close to or companies they are associated with and the interests of the Group to the Chairperson of the Supervisory

Board and the Chief Executive Officer without undue delay and shall inform the other members of the Management

Board thereof, as appropriate.

Section 161 of the German Stock Corporation Act requires that the management board and supervisory board of any

German stock exchange-listed company declare annually that the company complies with the recommendations of the

German Corporate Governance Code or, if not, which recommendations the company does not comply with and why it

does not comply with these recommendations (so-called “comply or explain”-principle). On some points, these

recommendations go beyond the requirements of the German Stock Corporation Act. The Management Board and

Supervisory Board issued a new Declaration of Conformity in accordance with Section 161 of the German Stock

Corporation Act in October 2025, which is available on the bank’s internet website at www.db.com/ir/en/documents.htm

under the heading “Declaration of Conformity pursuant to Section 161 German Stock Corporation Act (AktG), Oct 2025”.

For information on the Management Board’s terms of office, please see “Corporate Governance Statement: Management

Board: Composition of the Management Board” in the Annual Report 2025. For details of the Management Board’s

service contracts providing benefits upon termination, please see “Compensation Report: Benefits as of the end of the

mandate” and “Compensation Report: Benefits upon Early Termination” in the Management Report of the Annual Report

2025.

The allocation of functional responsibilities to the individual members of the Management Board is described in the

Business Allocation Plan for the Management Board, which sets the framework for the delegation of responsibilities to

senior management below the Management Board. The Management Board endorses individual accountability of senior

position holders as opposed to joint decision-taking in committees. At the same time, the Management Board recognizes

the importance of having comprehensive and robust information across all businesses in order to take well informed

decisions and established, in addition to Infrastructure Committees, Business Executive Committees and Regional

Committees, the “Group Management Committee” which aims to improve the information flow across the Corporate

Divisions and between the Corporate Divisions and the Management Board. The Group Management Committee as a

senior platform, which is not required by the German Stock Corporation Act, is composed of all Management Board

members as well as most senior business representatives to exchange information and discuss business, growth and

profitability.


Deutsche Bank	Item 6: Directors, Senior Management and Employees
Annual Report 2025 on Form 20-F	Compensation

Compensation

For information on the compensation of the members of the bank’s Management Board, see "Compensation Report:

Management Board Compensation Report” in the Annual Report 2025.

For information on the compensation of the members of the bank’s employees, see "Compensation Report: Employee

Compensation Report” in the Annual Report 2025.

For information on the compensation of the members of the bank’s Supervisory Board, see "Compensation Report:

Compensation System for Supervisory Board Members” in the Annual Report 2025.

Employees

Labor Relations

In Germany, labor unions and employers’ associations generally negotiate collective bargaining agreements on salaries and

benefits for employees below the management level. Many companies in Germany, including Deutsche Bank and its material

German subsidiaries, are members of the employers’ association and are bound by collective bargaining agreements.

Accordingly, the bank’s employers’ association, the “Arbeitgeberverband des privaten Bankgewerbes e.V.”, regularly

renegotiates the collective bargaining agreements that cover many of the Group’s employees. The last agreement was

reached in July 2024. As part of the final package, salaries were increased in three steps by in total 10.5%, the first step

being 5.5% from August 2024, the second step being 3.0% from August 2025 and the third step being 2.0% from July

2026. This collective wage agreement will last until end of September 2026.

Deutsche Bank’s employers’ association negotiates with the following unions:

–ver.di (Vereinte Dienstleistungsgewerkschaft)

–Deutscher Bankangestellten Verband (DBV – Gewerkschaft der Finanzdienstleister)

Many employees of Deutsche Bank, who are former employees of the merged Postbank, are covered by in-house

collective bargaining agreements that are agreed between Deutsche Bank and trade unions directly.

The last agreement was reached in May 2024. As part of the final package, salaries were increased in two steps by a total

of 11.5%, the first step being 7.0% but at least € 270 from June 2024 and the second step being 4.5% from July 2025.

This collective wage agreement will last until end of March 2026.

In the aforementioned context, Deutsche Bank negotiates with the following unions:

–ver.di (Vereinte Dienstleistungsgewerkschaft)

–Deutscher Bankangestellten Verband (DBV – Gewerkschaft der Finanzdienstleister)

–Kommunikationsgewerkschaft DPV (DPVKOM)

–komba gewerkschaft (komba)

As German law prohibits the bank from asking its employees whether they are members of labor unions, there is no

record of how many of the bank’s employees are union members.

On the basis of the agreement on cross-border information and consultation of Deutsche Bank employees in the EU

concluded on September 10, 1996, all employees in the EU are represented by the European Works Council. This adds

up to around 48% of the Group's total workforce.

Share Ownership

For the share ownership of the Group’s Management Board, see “Management Report: Compensation Report:

Shareholding Guidelines” in the Annual Report 2025.

For the share ownership of the members of the Supervisory Board, see “Corporate Governance Statement: Supervisory

Board: Share ownership of Supervisory Board members ” in the Annual Report 2025.

For a description of the Group’s employee share programs, please see Note 33 “Employee Benefits” to the consolidated

financial statements.


Deutsche Bank	Item 7: Major Shareholders and Related Party Transactions
Annual Report 2025 on Form 20-F	Major Shareholders

Item 7: Major Shareholders and Related Party

Transactions

Major Shareholders

On December 31, 2025, Deutsche Bank’s issued share capital amounted to €4,891,082,181.12 divided into

1,910,578,977 no par value ordinary registered shares.

On December 19, 2025, Deutsche Bank cancelled 37,673,908 of no par value ordinary registered shares owned by

Deutsche Bank, representing € 96,445,204.48. Following this cancellation, Deutsche Bank’s issued share capital

amounted to € 4,981,082,181.12 divided into 1,910,578,977 no par value ordinary registered shares.

On December 31, 2025, Deutsche Bank had 519,416 registered shareholders. 855,864,529 of the bank’s shares were

registered in the names of 509,565 shareholders resident in Germany, representing 44.80% of the share capital.

264,517,200 of Deutsche Bank’s shares were registered in the names of 531 shareholders resident in the United States,

representing 13.84% of the share capital.

The German Securities Trading Act (Wertpapierhandelsgesetz) requires investors in publicly-traded corporations whose

investments reach or cross certain thresholds to notify both the corporation and the BaFin of such change within four

trading days. The minimum disclosure threshold is 3% of the corporation’s issued voting share capital.

BlackRock, Inc., Wilmington, DE, has notified Deutsche Bank that as of January 19, 2026 it held 7.92% of the bank’s

shares. Deutsche Bank has received no further notification by BlackRock, Inc., Wilmington, DE, through February 16,

2026.

The Capital Group Companies, Inc., Los Angeles, CA, has notified Deutsche Bank that as of August 22, 2025 it held 4.94%

of the bank’s shares. Deutsche Bank has received no further notification by The Capital Group Companies, Inc., Los

Angeles, CA, through February 16, 2026.

Paramount Service Holding Ltd. S.ÀR.L., British Virgin Islands, has notified Deutsche Bank that as of January 25, 2023 it

held 4.54% of the bank’s shares. Deutsche Bank has received no further notification by Paramount Service Holding Ltd.

S.ÀR.L., British Virgin Islands, through February 16, 2026.

Supreme Universal Holdings Ltd., Cayman Islands, has notified Deutsche Bank that as of August 20, 2015 it held 3.05% of

the bank’s shares. Deutsche Bank has received no further notification by Supreme Universal Holdings Ltd., Cayman

Islands, through February 16, 2026.

Amundi S.A., Paris, France, has notified Deutsche Bank that as of December 23, 2025 it held 3.00% of the bank's shares.

Deutsche Bank has received no further notification by Amundi S.A., Paris, France, through February 16, 2026.

Over the last three years, Deutsche Bank has been notified of the following changes with regards to the minimum

disclosure threshold.


Deutsche Bank	Item 7: Major Shareholders and Related Party Transactions
Annual Report 2025 on Form 20-F	Major Shareholders


	Disclosure date	% of outstanding shares held at disclosure date
Amundi S.A.	December 23, 2025	3.00
	November 24, 2025	2.88
	November 20, 2025	3.02
	November 11, 2025	2.84
	November 10, 2025	3.00
	October 23, 2025	2.88
	October 22, 2025	3.00
	February 1, 2023	2.97

BlackRock, Inc.	January 19, 2026	7.92
	October 2, 2025	7.23
	October 1, 2025	7.21
	September 25, 2025	7.21
	September 24, 2025	7.20
	September 19, 2025	7.49
	July 1, 2025	6.90
	June 25, 2025	6.89
	June 4, 2025	6.86
	May 8, 2025	6.79
	April 9, 2025	6.70
	March 25, 2025	6.78
	March 21, 2025	6.75
	March 18, 2025	6.76
	October 1, 2024	6.01
	February 9, 2024	5.86
	February 8, 2024	5.78
	March 31, 2023	5.38
	March 30, 2023	5.01
	March 24, 2023	3.81

The Capital Group Companies, Inc.	August 22, 2025	4.94
	January 7, 2025	5.06
	April 10, 2024	3.04

Douglas L. Braunstein (Hudson Executive Capital LP)1	January 25, 2024	0.92

Paramount Service Holding Ltd. S.ÀR.L.2	January 25, 2023	4.54

1From previously 3.18% of Deutsche Bank shares as of November 20, 2020

2From previously 3.05% of Deutsche Bank shares as of August 20, 2015

Deutsche Bank is neither directly nor indirectly owned nor controlled by any other corporation, by any government or by

any other natural or legal person severally or jointly.

Pursuant to German law and our Articles of Association, to the extent that Deutsche Bank may have major shareholders

at any time, Deutsche Bank may not give them voting rights different from those of any of its other shareholders. Even if

the bank’s articles of association were amended to allow for the issuance of shares with multiple voting rights, the

issuance of such shares would require the consent of all affected shareholders.

Deutsche Bank is aware of no arrangements which may at a subsequent date result in a change in control of the

company.


Deutsche Bank	Item 7: Major Shareholders and Related Party Transactions
Annual Report 2025 on Form 20-F	Related Party Transactions

Related Party Transactions

Deutsche Bank has business relationships with a number of the companies in which the bank owns significant equity

interests. Deutsche Bank also has business relationships with a number of companies where members of the bank’s

Management Board also hold positions on boards of directors. Deutsche Bank’s business relationships with these

companies cover many of the financial services the bank provides to their clients generally. For more detailed

information, refer to Note 36 “Related Party Transactions” to the consolidated financial statements.

Deutsche Bank conducts its business with these companies on terms equivalent to those that would prevail if the bank

did not have equity holdings in them or management members in common, and the bank has conducted business with

these companies on that basis in 2025 and prior years. None of these transactions is or was material to the bank.

Among Deutsche Bank’s business with related party companies in 2025, there have been and currently are loans,

guarantees and commitments, which totaled € 70 million (including loans amounting to € 66 million) as of December 31,

2025, compared to € 77 million (including loans amounting to € 73 million) as of December 31, 2024.

All these credit exposures

–Were made in the ordinary course of business

–Were made on substantially the same terms, including interest rates and collateral, as those prevailing at the time for

comparable transactions with other persons, and

–Did not involve more than the normal risk of collectability or present other unfavorable features compared to loans to

nonrelated parties at their initiation

Related Party Impaired Loans

The Group did not have any impaired loans to related parties in 2025 and 2024.

Interests of Experts and Counsel

Not required because this document is filed as an Annual Report.


Deutsche Bank	Item 8: Financial Information
Annual Report 2025 on Form 20-F	Consolidated statements and other financial information

Item 8: Financial Information

Consolidated statements and other financial information

Consolidated financial statements

The financial statements of this Annual Report on Form 20-F consist of the consolidated financial statements including

Notes 1 to 42 thereto, which are set forth as Part 2 of the Annual Report 2025, and, as described in Note 01 “Material

accounting policies and critical accounting estimates” thereto under “Basis of accounting”, certain parts of the

Combined Management Report set forth as Part 1 of the Annual Report 2025. Such consolidated financial statements

have been audited by EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft, as described in their “Report of Independent

Registered Public Accounting Firm” included in the Annual Report 2025.

Legal proceedings

Deutsche Bank and its subsidiaries operate in a legal and regulatory environment that exposes them to significant

litigation risks. As a result, they are involved in litigation, arbitration and regulatory proceedings and investigations in

Germany and in a number of jurisdictions outside Germany, including the United States. Please refer to Note 27

“Provisions” to the consolidated financial statements for descriptions of material legal proceedings and certain other

significant legal proceedings.

Dividend policy

Deutsche Bank’s financial and regulatory targets are based on the financial results prepared in accordance with IFRS as

issued by the IASB and endorsed by the EU. For further details, please refer to Note 01 "Material accounting policies and

critical accounting estimates – EU carve-out” to the consolidated financial statements.

Deutsche Bank plans to sustainably grow cash dividends and, over time, return excess capital to shareholders through

share buybacks.

In respect of financial year 2025, the Management Board intends to propose to the Annual General Meeting a dividend of

€ 1.00 per share, representing an increase in dividend per share of around 50% for the fourth consecutive year. In

addition, the bank received supervisory approval for a share repurchase of € 1 billion in respect of financial year 2025.

This share repurchase, together with the anticipated dividend, would result in distributions in respect of financial year

2025 of € 2.9 billion, completing distributions in relation to financial year 2025.

For financial year 2026 and subsequent years, the bank targets a payout ratio of 60% of net income attributable to

Deutsche Bank shareholders measured on the financial results prepared in accordance with IFRS as issued by the IASB

and endorsed by the EU (EU IFRS), delivered through a combination of cash dividends and share buybacks. Starting with

financial year 2026, Deutsche Bank aims for modest but continuous growth in dividend per share, relative to the 50% per

annum growth over the past four years. Furthermore, the bank sees scope to deploy and distribute excess capital when

the CET1 capital ratio is sustainably above 14%.

These distributions to shareholders are subject to corporate decisions, shareholder authorization and German corporate

law requirements, and in the case of share buybacks supervisory approval.

In respect of financial years 2021 to 2024 cumulative distributions to shareholders amounted to € 5.6 billion. The bank

completed share repurchases of € 1 billion in 2025, € 675 million in 2024, € 450 million in 2023 and € 300 million in

2022. In addition, cash dividends per share of € 0.68 for 2024, € 0.45 for 2023 and € 0.30 for 2022 were paid.

The bank set a capital distribution goal of € 8 billion in respect of the financial years 2021 - 2025, to be paid in 2022 to

2026. With the proposed shareholder distributions in relation to financial year 2025 the cumulative distributions for 2021

to 2025 would reach € 8.5 billion.


Deutsche Bank	Item 8: Financial Information
Annual Report 2025 on Form 20-F	Consolidated statements and other financial information

However, Deutsche Bank cannot assure investors that it will pay dividends or conduct share buybacks as it did in previous

years, nor at any other level, or at all, in any future period. If Deutsche Bank AG is not profitable enough, it may not pay

dividends or conduct share buybacks at all. Furthermore, if Deutsche Bank AG fails to meet the regulatory capital

adequacy requirements under CRR/CRD (including individually imposed capital requirements (“Pillar 2” requirements)

and the combined buffer requirement), it may be prohibited from making, and the ECB or the BaFin may suspend or limit,

the payment of dividends or execution of share buybacks. In particular, a credit institution, such as Deutsche Bank, will

be considered as failing to meet the combined buffer requirement when it does not have sufficient own funds in an

amount and of the quality needed to meet at the same time (i) its minimum capital requirements under the CRR, (ii)

certain Pillar 2 capital requirements, and (iii) the sum of the capital buffers applicable to the relevant credit institution. In

calculating the respective amounts that may be distributed (“Maximum Distributable Amount” or “MDA”), the bank will

have to take into account certain Pillar 2 capital requirements. Since January 2022, the Group has also been subject to

MDA restrictions, including a Pillar 2 capital requirement for the leverage ratio, in instances of non-compliance with its

leverage ratio buffer introduced in the CRR. In addition, Deutsche Bank is subject to additional restrictions on

distributions if it breaches the harmonized minimum TLAC requirement under the CRR or its institution-specific minimum

requirement for own funds and eligible liabilities (MREL) set by the Single Resolution Board.

In addition, the ECB expects banks to meet Pillar 2 guidance. If Deutsche Bank AG operates or expects to operate below

Pillar 2 guidance, the ECB will review the reasons why the bank’s capital level has fallen or is expected to fall and may

take appropriate and proportionate measures in connection with such shortfall. Any such measures might have an impact

on Deutsche Bank AG’s willingness or ability to pay dividends or conduct share buybacks. For further information on

regulatory capital adequacy requirements and the powers of Deutsche Bank AG’s regulators to suspend dividend

payments or share buybacks, see “Item 4: Information on the Company – Regulation and Supervision – Capital Adequacy

Requirements” and “— Investigative and Enforcement Powers.”

In order to meet the German corporate law requirements, Deutsche Bank AG’s dividends and capacity to conduct share

buybacks are based on the unconsolidated results of Deutsche Bank AG as prepared in accordance with the German

Commercial Code (HGB). Deutsche Bank AG’s Management Board, which prepares the Annual Financial Statements of

Deutsche Bank AG on an unconsolidated basis, and its Supervisory Board, which reviews the financial statements, first

allocate part of Deutsche Bank AG’s annual surplus (if any) to Deutsche Bank AG’s statutory reserves and to any losses

carried forward, in accordance with applicable legal requirements. Deutsche Bank then allocates the remainder of any

surplus to other revenue reserves (or retained earnings) and balance sheet profit. Deutsche Bank AG may allocate up to

one-half of this remainder to other revenue reserves and must allocate at least one-half to balance sheet profit. A profit

distribution from the balance sheet profit is only permitted to the extent that the balance sheet profit plus distributable

earnings exceed potential dividend blocking items, which consist primarily of deferred tax assets, self-developed

software and unrealized gains on plan assets, all net of respective deferred tax liabilities.

Deutsche Bank AG may then distribute as dividend a portion of or all the amount of the balance sheet profit not subject

to dividend blocking of Deutsche Bank AG if the Annual General Meeting so resolves. The Annual General Meeting may

resolve a non-cash distribution instead of, or in addition to, a cash dividend. However, Deutsche Bank AG is not legally

required to distribute its balance sheet profit to its shareholders to the extent that it has issued participatory rights

(Genussrechte) or granted a silent participation (stille Beteiligung) that accord their holders the right to a portion of

Deutsche Bank AG’s distributable profit.

Deutsche Bank AG declares dividends by resolution of the Annual General Meeting and pays them (if any) once a year.

Dividends approved at a General Meeting are payable on the third business day after that meeting, unless a later date has

been determined at that meeting or by the Articles of Association. In accordance with the German Stock Corporation

Act, the relevant date for determining which holders of Deutsche Bank AG’s ordinary shares are entitled to the payment

of dividends, if any, or other distributions whether cash, stock or property, is the date of the General Meeting at which

such dividends or other distributions are declared.

Significant changes

Except as otherwise stated in this document, there have been no significant changes subsequent to December 31, 2025.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Memorandum and Articles of Association

Item 10: Additional Information

Share Capital

Not required because this document is filed as an Annual Report.

Memorandum and Articles of Association

The following is a summary of certain information relating to certain provisions of Deutsche Bank’s Articles of

Association, its share capital and German law. This summary is not complete and is qualified by reference to its Articles of

Association and German law in effect at the date of this filing. Copies of the bank’s Articles of Association are publicly

available at the Commercial Register (Handelsregister) in Frankfurt am Main, and an English translation is filed as

Exhibit 1.1 to this Annual Report.

Deutsche Bank’s Business Objectives

Section 2 of the Articles of Association sets out the objectives of the Group’s business:

–To transact all aspects of banking business

–To provide financial and other services and

–To promote international economic relations

The bank’s Articles of Association permit it to pursue these objectives directly or through subsidiaries and affiliated

companies.

The Articles of Association also provide that, to the extent permitted by law, the Group may transact all business and

take all steps that appear likely to promote the bank’s business objectives. In particular, the bank may:

–Acquire and dispose of real estate

–Establish branches in Germany and abroad

–Acquire, administer and dispose of participations in other enterprises and

–Conclude intercompany agreements (Unternehmensverträge)

Supervisory Board and Management Board

For more information on the Supervisory Board and Management Board, see “Item 6: Directors, Senior Management and

Employees.”

Voting Rights and Shareholders' Meetings

Each of the bank’s shares entitles its registered holder to one vote at Deutsche Bank’s General Meeting. The Annual

General Meeting takes place within the first eight months of the fiscal year. Pursuant to the Articles of Association,

Deutsche Bank may hold the meeting in Frankfurt am Main, Düsseldorf or any other German city with over 250,000

inhabitants. Unless a shorter period is permitted by law, the Group must give the notice convening the General Meeting

at least 30 days before the last day on which shareholders can register their attendance of the General Meeting (which is

the sixth day immediately preceding that General Meeting). Shorter periods apply if the General Meeting is called to

adopt a resolution on a capital increase in the context of early intervention measures pursuant to the Act on the

Recovery and Resolution of Institutions and Financial Groups (Gesetz zur Sanierung und Abwicklung von Instituten und

Finanzgruppen).

The Management Board or the Supervisory Board may also call an extraordinary General Meeting. Shareholders holding

in aggregate at least 5% of the nominal value of Deutsche Bank’s share capital may also request that such a meeting be

called. The bank’s Articles of Association authorize the Management Board, with the consent of the Supervisory Board, to

hold any General Meeting taking place on or before August 31, 2027 in virtual form without physical attendance of the

shareholders or their authorized representatives.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Memorandum and Articles of Association

According to the Articles of Association, Deutsche Bank’s shares are issued in the form of registered shares. For purposes

of registration in the share register, all shareholders are required to notify the bank of the number of shares they hold

and, in the case of natural persons, of their surname, first name, address and date of birth and, in the case of legal

persons, of their registered name, business address and registered domicile, and in both cases should add an electronic

address. Both being registered in the bank’s share register and the timely registration for attendance at the General

Meeting constitute prerequisite conditions for any shareholder’s attendance and exercise of voting rights at the General

Meeting. Shareholders may register their attendance of a General Meeting with Deutsche Bank as further described in

the invitation by written notice or electronically, and no later than the sixth day immediately preceding the date of that

General Meeting. Any shareholders who have failed to comply with certain notification requirements summarized under

“Notification Requirements” below are precluded from exercising any rights attached to their shares, including voting

rights.

Under German law, upon the bank’s request a registered shareholder must inform the bank whether that shareholder

owns the shares registered in its name or whether that shareholder holds the shares for any other person as a nominee

shareholder. Both the nominee shareholder and the person for whom the shares are held have an obligation to provide

the same personal data as required for registration in the share register with respect to the person for whom the shares

are held.

Shareholders may appoint proxies to represent them at General Meetings. As a matter of German law, a proxy relating to

voting rights granted by shares may be revoked at any time.

As a foreign private issuer, Deutsche Bank is not required to file a proxy statement under U.S. securities law. The proxy

voting process for the bank’s shareholders in the United States is substantially similar to the process for publicly held

companies incorporated in the United States.

The Annual General Meeting normally adopts resolutions on the following matters:

–Appropriation of distributable balance sheet profits (Bilanzgewinn) from the preceding fiscal year;

–Formal ratification of the acts (Entlastung) of the members of the Management Board and the members of the

Supervisory Board in the preceding fiscal year and

–Appointment of independent auditors for the current fiscal year

A simple majority of votes cast is generally sufficient to approve a measure, except in cases where a greater majority is

otherwise required by the bank’s Articles of Association or by law. Under the German Stock Corporation Act and the

German Transformation Act (Umwandlungsgesetz), certain resolutions of fundamental importance require a majority of

at least 75% of the share capital represented at the General Meeting adopting the resolution, in addition to a majority of

the votes cast. Such resolutions include the following matters, among others:

–Amendments to the Articles of Association changing the Group’s business objectives

–Capital increases that exclude preemptive rights

–Capital reductions

–Creation of authorized or conditional capital

–Deutsche Bank’s dissolution

–“Transformations” under the German Transformation Act such as mergers, spin-offs and changes in the bank’s legal

form

–Transfer of all the bank’s assets and

–Intercompany agreements (in particular, domination and profit-transfer agreements)

Under certain circumstances, such as when a resolution violates the Articles of Association or the German Stock

Corporation Act, shareholders may file a shareholder action with the appropriate Regional Court (Landgericht) in

Germany to set aside resolutions adopted at the General Meeting.

Under German law, the rights of shareholders as a group can be changed by amendment of the company's articles of

association. Any amendment of the Articles of Association requires a resolution of the General Meeting. The authority to

amend the Articles of Association, insofar as such amendments merely relate to the wording, such as changes of the

share capital as a result of the issuance of shares from authorized capital, has been assigned to the Supervisory Board by

the Articles of Association. Pursuant to the Articles of Association, the resolutions of the General Meeting are taken by a

simple majority of votes and, insofar as a majority of capital stock is required, by a simple majority of capital stock, except

where law or the Articles of Association determine otherwise. The rights of individual shareholders can only be changed

with their consent. Amendments to the Articles of Association become effective upon their registration in the

Commercial Register.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Memorandum and Articles of Association

Share Register

Deutsche Bank maintains a share register with Computershare Deutschland GmbH & Co. KG and its New York transfer

agent, pursuant to an agency agreement between Deutsche Bank and Computershare Deutschland GmbH & Co. KG and

a sub-agency agreement between Computershare Deutschland GmbH & Co. KG and the New York transfer agent.

Any shareholder may request information about the data concerning its person that have been entered in the share

register. The share register generally contains each shareholder's surname, first name, date of birth, address, electronic

address, if any, and the number or the quantity of the shares held. Shareholders may prevent their personal information

from appearing in the share register by holding their securities through a bank or custodian. Although the shareholder

would remain the beneficial owner of the securities, only the bank's or custodian's name would appear in the share

register. In this case, the exercise of certain shareholder rights will depend on the cooperation of the bank or custodian.

Dividend Rights

For a summary of Deutsche Bank’s dividend policy and legal basis for dividends under German law, see “Item 8: Financial

Information – Dividend Policy.”

Increases in Share Capital

German law permits Deutsche Bank to increase its share capital in any of three ways:

–Resolution by the General Meeting authorizing the issuance of new shares

–Resolution by the General Meeting authorizing the Management Board, subject to the approval of the Supervisory

Board, to issue new shares up to a specified amount (no more than 50% of existing share capital) within a specified

period, which may not exceed five years. This is referred to as authorized capital (genehmigtes Kapital)

–Resolution by the General Meeting authorizing the issuance of new shares up to a specified amount (no more than

60% of existing share capital) for specific purposes, such as for employee stock options (additional limit of no more

than 20% of existing share capital), for use as consideration in a merger or to issue to holders of convertible bonds or

other convertible securities (additional limit of no more than 50% of existing share capital). This is referred to as

conditional capital (bedingtes Kapital)

The issuance of new ordinary shares by resolution of the General Meeting requires the simple majority of the votes cast

and of the share capital represented at the General Meeting. Should the resolution of the General Meeting provide for

the exclusion of shareholders’ preemptive rights in full or in part, the simple majority of the votes cast and a majority of at

least 75% of the share capital represented at the General Meeting are required. Similarly, resolutions of the General

Meeting concerning the creation of authorized or conditional capital require the simple majority of the votes cast and a

majority of at least 75% of the share capital represented at the General Meeting.

Liquidation Rights

The German Stock Corporation Act requires that if the bank is liquidated, any liquidation proceeds remaining after the

payment of all the bank’s liabilities will be distributed to the bank’s shareholders in proportion to their shareholdings.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Memorandum and Articles of Association

Preemptive Rights

In principle, holders of Deutsche Bank shares have preemptive rights allowing them to subscribe any shares, bonds

convertible into, or with attached warrants to subscribe for, the bank’s shares or participatory certificates it issues. Such

preemptive rights exist in proportion to the number of shares currently held by the shareholder. Preemptive rights of

shareholders may be excluded with respect to any capital increase, however, as part of the resolution by the General

Meeting on such capital increase. Such a resolution by the General Meeting on a capital increase that excludes the

shareholders’ preemptive rights with respect thereto requires both a majority of the votes cast and a majority of at least

75% of the share capital represented at the General Meeting. A resolution to exclude preemptive rights requires that the

proposed exclusion is expressly disclosed in the agenda to the General Meeting and that the Management Board

presents the reasons for the exclusion to the shareholders in a written report. Under the German Stock Corporation Act,

preemptive rights may in particular be excluded with respect to capital increases not exceeding 20% of the existing share

capital with an issue price payable in cash not significantly below the stock exchange price at the time of issuance. In

addition, shareholders may, in a resolution by the General Meeting on authorized capital, authorize the Management

Board to exclude the preemptive rights with respect to newly issued shares from authorized capital in specific

circumstances set forth in the resolution.

Shareholders are generally permitted to transfer their preemptive rights. Preemptive rights may be traded on one or

more German stock exchanges for a limited number of days prior to the final day the preemptive rights can be exercised.

Notices and Reports

Deutsche Bank publishes notices pertaining to its shares and the General Meeting in the German Federal Gazette

(Bundesanzeiger).

The bank sends its New York transfer agent, through publication or otherwise, a copy of each of its notices pertaining to

any General Meeting, any adjourned General Meeting or its actions with respect to any cash or other distributions or the

offering of any rights. The Group provides such notices in the form given or to be given to its shareholders. The bank’s

New York transfer agent is requested to arrange for the mailing of such notices to all shareholders registered in the New

York registry.

Charges of Transfer Agents

Deutsche Bank pays Computershare Deutschland GmbH & Co. KG and its New York transfer agent customary fees for

their services as transfer agents and registrars. The Group’s shareholders will not be required to pay Computershare

Deutschland GmbH & Co. KG or its New York transfer agent any fees or charges in connection with its transfers of shares

in the share register. The bank’s shareholders will also not be required to pay any fees in connection with the conversion

of dividends from euros to U.S. dollars.

Liability of Transfer Agents

Neither Computershare Deutschland GmbH & Co. KG nor the bank’s New York transfer agent will be liable to

shareholders if prevented or delayed by law, or any circumstances beyond its control, from performing its obligations as

transfer agents and registrars.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Notification Requirements

Notification Requirements

Disclosure of Interests in a Listed Stock Corporation

Disclosure Obligations under the German Securities Trading Act

Deutsche Bank AG, as a listed company, and its shareholders are subject to the shareholding disclosure obligations under

the German Securities Trading Act (Wertpapierhandelsgesetz). Pursuant to the German Securities Trading Act, any

shareholder whose voting interest in a listed company like Deutsche Bank AG, through acquisition, sale or by other

means, reaches, exceeds or falls below a 3%, 5%, 10%, 15%, 20%, 25%, 30%, 50% or 75% threshold must notify the bank

and the BaFin of its current aggregate voting interest in writing and without undue delay, but at the latest within four

trading days. In connection with this requirement, the German Securities Trading Act contains various provisions

regarding the attribution of voting rights to the person who actually controls the voting rights attached to the shares.

Furthermore, the voting rights attached to a third party’s shares are attributed to a shareholder if the shareholder

coordinates its conduct concerning the listed company with the third party (so-called “acting in concert”) either through

an agreement or other means. Acting in concert is deemed to exist if the parties coordinate their voting at the listed

company’s general meeting or, outside the general meeting, coordinate their actions with the goal of significantly and

permanently modifying the listed company’s corporate strategy. Each party’s voting rights are attributed to each of the

other parties acting in concert.

Shareholders failing to comply with their notification obligations are prevented from exercising any rights attached to

their shares (including voting rights and the right to receive dividends) until they have complied with the notification

requirements. If the failure to comply with the notification obligations specifically relates to the size of the voting

interest in Deutsche Bank AG and is the result of willful or grossly negligent conduct, the suspension of shareholder

rights is – subject to certain exceptions in case of an incorrect notification deviating no more than 10% from the actual

percentage of voting rights – extended by a six-month period commencing upon the submission of the required

notification.

Except for the 3% threshold, similar notification obligations exist for reaching, exceeding or falling below the thresholds

described above when a person holds, directly or indirectly, certain instruments other than shares. This applies to

instruments which grant upon maturity an unconditional right to acquire existing voting shares of Deutsche Bank AG, a

discretionary right to acquire such shares, as well as to instruments that refer to such shares and have an economic effect

similar to that of the aforementioned instruments, irrespective of whether such instruments are physically or cash-

settled. These instruments include, for example, transferable securities, options, futures contracts and swaps. Voting

rights to be attributed to a person based on any such instrument will generally be aggregated with the person’s other

voting rights deriving from shares or other instruments.

Notice must be given without undue delay, but within four trading days at the latest. The notice period commences as

soon as the person obliged to notify knows, or, under the circumstances should know, that his or her voting rights reach,

exceed or fall below any of the abovementioned relevant thresholds, but in any event no later than two trading days after

reaching, exceeding or falling below the threshold. Only in case that the voting rights reach, exceed or fall below any of

the thresholds as a result of an event affecting all voting rights, the notice period might commence at a later stage.

Deutsche Bank AG must publish the foregoing notifications without undue delay, but no later than within three trading

days after their receipt, and report such publication to the BaFin. Furthermore, Deutsche Bank AG must publish a

notification in case of any increase or decrease of the total number of voting rights without undue delay, but within two

trading days at the latest, and such notification must be reported to the BaFin and forwarded to the German Company

the issue of new shares from conditional capital. In this case, Deutsche Bank AG must publish the increase at the end of

the month in which it occurred. However, such increase must also be notified without undue delay, but within two

trading days at the latest, where any other increase or decrease of the total number of voting rights triggers the

aforementioned notification requirement.

Non-compliance with the disclosure requirements regarding shareholdings and holdings of other instruments may result

in a significant fine imposed by the BaFin. In addition, the BaFin publishes, on its website, sanctions imposed, and

measures taken indicating the person or entity responsible and the nature of the breach (so-called “naming and

shaming”).

Shareholders whose voting rights reach or exceed thresholds of 10% of the voting rights in a listed company, or higher

thresholds, are obliged to inform the company within 20 trading days of the purpose of their investment and the origin of

the funds used for such investment, unless the articles of association of the listed company provide otherwise. The

bank’s Articles of Association do not contain such a provision.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Notification Requirements

Disclosure Obligations under the German Securities Acquisition and Takeover Act

Pursuant to the German Securities Acquisition and Takeover Act (Wertpapiererwerbs- und Übernahmegesetz), any person

whose voting interest reaches or exceeds 30% of the voting shares of a listed stock corporation must, within seven

working days, publish this fact (including the percentage of its voting rights) on the Internet and by means of an

electronically operated financial information dissemination system. In addition, the person must subsequently make a

mandatory public tender offer within four weeks to all shareholders of the listed company unless an exemption has been

granted. The German Securities Acquisition and Takeover Act contains a number of provisions intended to ensure that

shareholdings are attributed to those persons who actually control the voting rights attached to the shares. The

provisions regarding coordinated conduct as part of the German Securities Acquisition and Takeover Act (so-called

“acting in concert”) and the rules on the attribution of voting rights attached to shares of third parties are the same as the

statutory securities trading provisions described above under “Disclosure Obligations under the German Securities

Trading Act” except with respect to voting rights of shares underlying instruments whose holders are vested with the

right to unilaterally acquire existing voting shares of the listed company or voting rights which may be acquired on the

basis of instruments with similar economic effect. If a shareholder fails to provide notice on reaching or exceeding the

30% threshold, or fails to make a public tender offer, the shareholder will be precluded from exercising any rights

associated with its shares (including voting and dividend rights) until it has complied with the requirements under the

German Securities Acquisition and Takeover Act. In addition, non-compliance with the disclosure requirement may result

in a fine.

Disclosure of Participations in a Credit Institution

The German Banking Act (Kreditwesengesetz) requires any person intending to acquire, alone or acting in concert with

another person, directly or indirectly, a qualifying holding (bedeutende Beteiligung) in a credit or financial services

institution to notify the BaFin and the Bundesbank without undue delay and in writing of the intended acquisition. A

qualifying holding is a direct or indirect holding in an undertaking which represents 10% or more of the capital or voting

rights or which makes it possible to exercise a significant influence over the management of such undertaking. The

required notice must contain information demonstrating, among other things, the reliability of the person or, in the case

of a corporation or other legal entity, the reliability of its directors and officers.

A person holding a qualifying holding shall also notify the BaFin and the Bundesbank without undue delay and in writing

if they intend to increase the amount of the qualifying holding up to or beyond the thresholds of 20%, 30% or 50% of the

voting rights or capital or in such way that the institution comes under such person’s control or if such person intends to

reduce the participation below 10% or below one of the other thresholds described above.

The BaFin will have to confirm the receipt of a complete notification within two working days in writing to the proposed

acquirer. Within a period of 60 working days from the BaFin’s written confirmation that a complete notification has been

received (assessment period), the BaFin will review and, in accordance with Council Regulation (EU) No 1024/2013 of

October 15, 2013 conferring specific tasks on the European Central Bank concerning policies relating to the prudential

supervision of credit institutions, forward the notification and a proposal for a decision whether or not to object to the

acquisition to the ECB. The ECB will decide whether or not to object to the acquisition on the basis of the applicable

assessment criteria. Within the assessment period the ECB may prohibit the intended acquisition in particular if there

appears to be reason to assume that the acquirer or its directors and officers are not reliable or that the acquirer is not

financially sound, that the participation would impair the effective supervision of the relevant credit institution, that a

prospective managing director (Geschäftsleiter) is not reliable or not qualified, that money laundering or financing of

terrorism has occurred or been attempted in connection with the intended acquisition, or that there would be an

increased risk of such illegal acts as a result of the intended acquisition. During the assessment period the BaFin may

request further information necessary for its or the ECB’s assessment. Generally, such a request delays the expiration of

the assessment period by up to 30 business days. If the information submitted is incomplete or incorrect the ECB may

prohibit the intended acquisition.

If a person acquires a qualifying holding despite such prohibition or without making the required notification, the

competent authority may prohibit the person from exercising the voting rights attached to the shares. In addition, non-

compliance with the disclosure requirement may result in the imposition of a fine in accordance with statutory

provisions. Moreover, the competent authority may order that any disposition of the shares requires its approval and may

ultimately appoint a trustee to exercise the voting rights attached to the shares or to sell the shares to the extent they

constitute a qualifying holding.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Notification Requirements

Disclosure of Participations in Regulated Subsidiaries

The acquisition of shares in Deutsche Bank AG may trigger an obligation to notify certain national competent authorities

in charge of the supervision of regulated subsidiaries of Deutsche Bank AG, provided that such acquisition of shares is

treated as an indirect acquisition of a stake in the relevant subsidiaries and the applicable threshold under local law is

reached or exceeded. This applies in particular to subsidiaries in a member state of the European Economic Area for

which the CRR sets forth a threshold of 10%. Other jurisdictions may apply lower thresholds. For example, because the

bank controls Deutsche Bank (Malaysia) Berhad, Section 87(1) of the Malaysian Financial Services Act 2013 requires

approval of Bank Negara Malaysia (the Malaysian central bank) of any acquisition of 5% or more of the bank’s ordinary

shares. Also, because Deutsche Bank controls bank subsidiaries in the United States, including Deutsche Bank Trust

Company Americas, and has securities registered under the U.S. Securities Exchange Act of 1934, the U.S. Change in

Bank Control Act requires that any person or any persons acting in concert may acquire control of 10% or more of the

bank’s ordinary shares only subject to the approval of the Federal Reserve Board and other U.S. regulators.

Review by the German Federal Ministry of Economic Affairs and Energy of

Acquisition of 10% of voting rights or more

Pursuant to the German Foreign Trade Act (Außenwirtschaftsgesetz) and the German Foreign Trade Regulation

(Außenwirtschaftsverordnung), acquisitions may be reviewed by the German Federal Ministry of Economic Affairs and

Energy (the “Ministry”) where the initial direct or indirect acquisition of voting rights in a German company by investors

from outside the European Union (EU) and the European Free Trade Association (Iceland, Lichtenstein, Norway and

Switzerland) exceed 10%, 20% or 25%, or where voting rights in a German company by investors outside the EU or

European Free Trade Association exceed 20%, 25%, 40%, 50% or 75% through direct or indirect subsequent acquisitions.

Both the thresholds for the applicable initial voting rights (10%, 20% or 25%) and whether a filing obligation exists or not,

depend on the industry sector the target company is active in. The Ministry must be notified in writing regarding the

conclusion of a contract where the direct or indirect acquisition by an investor from outside the European Union and the

European Free Trade Association is 10% or 20% (or where the direct or indirect subsequent acquisitions exceeding 20%,

25%, 40%, 50% or 75% of the voting rights) of the voting rights in a German company which operates certain critical

infrastructure (including inter alia certain services in the financial sector) or operates in other certain sensitive sectors

(including inter alia certain technologies, IT, telecommunication, healthcare or the media). The Ministry must also be

notified in writing regarding the conclusion of a contract where there is a direct or indirect acquisition by an investor

from outside Germany of 10% or more of the voting rights in a German company operating in the defense or cryptology

sectors (or where the direct or indirect subsequent acquisitions exceeds 20%, 25%, 40%, 50% or 75% of the voting rights).

If Deutsche Bank is considered to be a company which operates in any such critical infrastructure or sensitive sector, the

Ministry would need to be notified of an acquisition of voting rights in Deutsche Bank that meets the abovementioned

thresholds. Pending clearance by the Ministry, an acquisition subject to this notification requirement must not be

consummated without clearance and its implementation would be legally void, unless the acquisition is made via a stock

exchange in which case the acquisition of voting rights becomes legally effective but the voting rights must not be

exercised pending clearance.

Consummating such an acquisition without clearance may also result in administrative fines of up to € 500,000 (acting

negligently) or up to five years imprisonment or monetary fines (acting willfully). The acquirer may seek voluntary pre-

clearance of a proposed acquisition from the Ministry that is not subject to a mandatory filing. The Ministry may impose

conditions on the acquisition, prohibit the acquisition, or require that it is unwound, if the Ministry determines that the

acquisition will likely affect the public order or public security of Germany or another EU member state, or in relation to

certain projects or programs of interest for the European Union pursuant to the EU-Screening regulation, or likely affects

the essential security interests of Germany. The Ministry’s decision to review an acquisition must be made within two

months following the Ministry’s knowledge of the conclusion of the acquisition contract, of the publication of the

decision to launch a take-over bid or of the publication of the acquisition of control. The review must be completed

within four months following receipt of the complete set of acquisition documents and any additional information

requested by the Ministry. The Ministry can extend its review period up to an additional four months. A review is

precluded if more than five years have passed since the acquisition.


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Notification Requirements

EU Short Selling Regulation (ban on naked short selling)

Regulation (EU) No 236/2012 of the European Parliament and of the Council of March 14, 2012, on short selling and

certain aspects of credit default swaps (the “EU Short Selling Regulation”) came into force on November 1, 2012. The EU

Short Selling Regulation, the regulations adopted by the EU Commission implementing it, and the German act

implementing the EU Short Selling Regulation replace the previously applicable German federal provisions governing the

ban on naked short selling of shares and certain debt securities. (Short sales are sales of securities that the seller does not

own, with the intention of buying back an identical security at a later point in time in order to be able to deliver the

security. A short sale is “naked” when the seller has not borrowed the securities at the time of the short sale, or ensured

they can be borrowed or obtained under a similar arrangement.) Under the EU Short Selling Regulation, except for

certain exemptions, naked short sales of listed shares are not permitted. Short sales of listed shares that are covered by

borrowing or similar arrangements are subject to the following transparency requirements. Significant net short positions

in shares must be reported to the BaFin and, if a certain threshold is exceeded, they must also be publicly disclosed. Net

short positions are calculated by netting the long and short positions held by a natural or legal person in the issued

capital of the company concerned. The details are set forth in the EU Short Selling Regulation and the regulations

adopted by the EU Commission implementing it. In certain situations, described in greater detail in the EU Short Selling

Regulation, the BaFin is permitted to limit short selling and comparable transactions.

Disclosure of Transactions of Managers

Art. 19 of Regulation (EU) No 596/2014 of the European Parliament and of the Council of April 16, 2014 on market abuse

(the “EU Market Abuse Regulation”) requires persons with management responsibilities (“Managers”) in a listed company

like Deutsche Bank AG to notify the company and the BaFin of their own transactions in shares or debt instruments of the

company or financial instruments based thereon, in particular derivatives. Such notifications must be made promptly and

no later than three business days after the date of the transaction. The notification obligation also applies to persons who

are closely associated with a Manager. The obligation does not apply if the aggregate annual transactions by a Manager

or persons with whom he or she is closely associated do not, individually, exceed a certain threshold amount through the

end of a calendar year. The BaFin has made use of its authority to increase the threshold of € 20,000 set forth in the EU

Market Abuse Regulation to the amount of € 50,000.

Deutsche Bank AG is required to promptly publish any notification received but, in any case, no later than two business

days after receipt of such notification. The publication must be made in a manner which enables fast access to this

information on a non-discriminatory basis in accordance with the implementing standards published by the European

Securities and Markets Authority. Furthermore, Deutsche Bank AG must without undue delay notify the BaFin and

forward the notification to the Company Register (Unternehmensregister). For the purposes of the EU Market Abuse

Regulation, the bank identified the following persons to be a Manager: members of the Management Board and the

Supervisory Board of Deutsche Bank AG as well as holders of general power of attorney (Generalbevollmächtigte) of

Deutsche Bank AG. The following persons are deemed to be closely associated with a Manager: spouses, registered civil

partners (eingetragene Lebenspartner), dependent children and other relatives who at the time of the transaction

requiring notification have lived in the same household with the Manager for at least one year. Legal entities for which

the aforementioned persons have management responsibilities are also subject to the notification requirement. The

aforementioned provisions also apply to legal entities, companies and institutions directly or indirectly controlled by a

Manager or by a person closely associated with a Manager, which have been founded to the benefit of such a person, or

whose economic interests correspond to a considerable extent to those of such a person. Non-compliance with the

notification requirements may result in a fine.

The Holding Foreign Insiders Accountable Act (the “HFIAA”) was enacted on December 18, 2025 and requires officers

and directors of certain foreign private issuers, including Deutsche Bank, to publicly report their beneficial ownership of

such issuers' equity securities pursuant to Section 16(a) of the Exchange Act. Initial beneficial ownership reports must be

filed with the SEC by March 18, 2026, and any subsequent changes in beneficial ownership must be reported thereafter.

Any beneficial ownership reports (Forms 3, 4 and 5) filed by our officers and directors will be available on the SEC's

website and on the investor relations section of our website.

Material Contracts

In the usual course of the bank’s business, Deutsche Bank enters into numerous contracts with various other entities. The

bank has not, however, entered into any material contracts outside the ordinary course of its business within the past two

years.

100


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Exchange Controls

Exchange Controls

As in other member states of the European Union, regulations issued by the competent European Union authorities to

comply with United Nations Security Council resolutions have caused freeze orders in Germany on assets of certain legal

and natural persons designated in such regulations. In addition, the European Union maintained a wide range of

autonomous economic and financial sanctions on Iran. While all nuclear-related economic and financial EU sanctions

against Iran were repealed on January 16, 2016, pursuant to the Joint Comprehensive Plan of Action, the agreement

expired in October 2025, resulting in the reimposition of such sanctions.

Moreover, in response to the war in Ukraine the European Union, the United States, the United Kingdom and others

imposed broad-based sanctions against natural and legal persons residing in Russia, Belarus, and certain regions of

Ukraine and/or of Russian or Belarusian nationality.

With some exceptions, corporations or individuals residing in Germany are required to report to the Bundesbank any

payment received from, or made to or for the account of, a nonresident corporation or individual that exceeds € 12,500

(or the equivalent in a foreign currency). This reporting requirement is for statistical purposes.

Subject to the above-mentioned exceptions and the applicable sanctions, there are currently no German laws, decrees or

regulations that would prevent the transfer of capital or remittance of dividends or other payments to shareholders who

are not residents or citizens of Germany.

There are also no restrictions under German law or the bank’s Articles of Association concerning the right of nonresident

or foreign shareholders to hold the bank’s shares or to exercise any applicable voting rights. Where the investment

reaches or exceeds certain thresholds, however, certain reporting obligations apply and the investment may become

subject to review by the BaFin, the European Central Bank and other competent authorities. For more information see

“Item 10: Additional Information – Notification Requirements”.

Taxation

The following is a general summary of material German and United States federal income tax consequences of the

ownership and disposition of shares for a resident of the United States for purposes of the income tax convention

between the United States and Germany (the “Treaty”) who is fully eligible for benefits under the Treaty. A U.S. resident

will generally be entitled to Treaty benefits if it is:

–The beneficial owner of shares (and of the dividends paid with respect to the shares)

–An individual resident of the United States, a U.S. corporation, or a partnership, estate or trust to the extent its income

is subject to taxation in the United States in its hands or in the hands of its partners or beneficiaries.

–Not also a resident of Germany for German tax purposes and

–Not subject to “anti-treaty shopping” articles under German domestic law or the Treaty that apply in limited

circumstances

The Treaty benefits discussed below generally are not available to shareholders who hold shares in connection with the

conduct of business through a permanent establishment in Germany. The summary does not discuss the treatment of

those shareholders.

The summary does not purport to be a comprehensive description of all of the tax considerations that may be relevant to

any particular shareholder, including tax considerations that arise from rules of general application or that are generally

assumed to be known by shareholders. In particular, the summary deals only with shareholders that will hold shares as

capital assets and does not address the tax treatment of shareholders that are subject to special rules, such as fiduciaries

of pension (e.g. U.S. pension funds), profit-sharing or other employee benefit plans, banks, insurance companies, dealers

in securities or currencies, persons that hold shares as a position in a straddle, conversion transaction, synthetic security

or other integrated financial transaction, persons that elect mark-to-market treatment, persons that own, directly or

indirectly, 10% or more of our stock, measured by vote or value, persons that hold shares through a partnership or hybrid

entity and persons whose “functional currency” is not the U.S. dollar. The summary is based on German and U.S. laws, the

Treaty and regulatory interpretations, including in the current and proposed U.S. Treasury regulations as of the date

hereof, all of which are subject to change (possibly with retroactive effect).

Shareholders should consult their own advisors regarding the tax consequences of the ownership and disposition of

shares considering their circumstances, as well as the effect of any state, local or other national laws.

101


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Exchange Controls

Taxation of Dividends

In general, dividends that Deutsche Bank pays are subject to German withholding tax at an aggregate rate of 26.375%

(consisting of a 25% withholding tax and a 1.375% surcharge). Under the Treaty, a U.S. resident will be entitled to receive

a refund from the German tax authorities of 11.375 in respect of a declared dividend of 100. For example, for a declared

dividend of 100, a U.S. resident initially will receive 73.625 and may claim a refund from the German tax authorities of

11.375 and, therefore, receive a total cash payment of 85 (i.e., 85% of the declared dividend). According to the German

Investment Tax Act dividends received by an investment fund within the meaning of the German Investment Tax Act are

generally subject to 15% German withholding tax equal to the Treaty tax rate. U.S. residents who are entitled to a refund

of more than 11.375% (e.g., U.S. pension funds) must fulfil further requirements according to para. 50j German Income

Tax Act, in particular certain holding requirements.

For U.S. tax purposes, a U.S. resident will be deemed to have received total dividends of 100 in the example above. The

gross amount of dividends that a U.S. resident receives (which includes amounts withheld in respect of German

withholding tax) generally will be subject to U.S. federal income taxation as foreign source dividend income and will not

be eligible for the dividends received deduction generally allowed to U.S. corporations. German withholding tax at the

15% rate provided under the Treaty will be treated as a foreign income tax that, subject to generally applicable

limitations under U.S. tax law, is eligible for credit against a U.S. resident’s U.S. federal income tax liability or, at its

election, may be deducted in computing taxable income. Thus, for a declared dividend of 100, a U.S. resident will be

deemed to have paid German taxes of 15. A U.S. resident cannot claim credits for German taxes that would have been

refunded to it if it had filed a claim for refund. Foreign tax credits will not be allowed for withholding taxes imposed in

respect of certain short-term or hedged positions. The creditability of foreign withholding taxes may be limited in certain

situations. The foreign tax credit rules are complex. U.S. residents should consult their tax advisers regarding the

creditability of German taxes in their particular circumstances.

"Qualified dividends” received by certain non-corporate U.S. shareholders will generally be subject to taxation in the

United States at a lower rate than other ordinary income. Subject to certain exceptions for short-term and hedged

positions, dividends received will be qualified dividends if Deutsche Bank (i) is eligible for the benefits of a comprehensive

income tax treaty with the United States that the U.S. Internal Revenue Service (“IRS”) has approved for purposes of the

qualified dividend rules and (ii) was not, in the year prior to the year in which the dividend was paid, and is not, in the year

in which the dividend is paid, a passive foreign investment company (“PFIC”). The Treaty has been approved for purposes

of the qualified dividend rules, and Deutsche Bank believes it qualifies for benefits under the Treaty. The determination

of whether the bank is a PFIC must be made annually and is dependent on the particular facts and circumstances at the

time. It requires an analysis of the bank’s income and valuation of its assets, including goodwill and other intangible

assets. Based on the audited financial statements and relevant market and shareholder data, the bank believes that it

was not a PFIC for U.S. federal income tax purposes with respect to its taxable years ended December 31, 2024 or

December 31, 2025. In addition, based on the Group’s current expectations regarding the value and nature of its assets,

the sources and nature of its income, and relevant market and shareholder data, the bank does not currently anticipate

becoming a PFIC for its taxable year ending December 31, 2026, or for the foreseeable future. However, the PFIC rules

are complex and their application to financial services companies is unclear. Each U.S. shareholder should consult its own

tax advisor regarding the potential applicability of the PFIC regime to Deutsche Bank and its implications for their

particular circumstances.

If a U.S. resident receives a dividend paid in euros, it will recognize income in a U.S. dollar amount calculated by reference

to the exchange rate in effect on the date of receipt, regardless of whether the payment is in fact converted into U.S.

dollars. If dividends are converted into U.S. dollars on the date of receipt, a U.S. resident generally should not be required

to recognize foreign currency gain or loss in respect of the dividend income but may be required to recognize foreign

currency gain or loss on the receipt of a refund in respect of German withholding tax to the extent the U.S. dollar value of

the refund differs from the U.S. dollar equivalent of that amount on the date of receipt of the underlying dividend.

102


Deutsche Bank	Item 10: Additional Information
Annual Report 2025 on Form 20-F	Exchange Controls

Refund Procedures

To claim a refund, a U.S. resident must submit, within four years from the end of the calendar year in which the dividend

is received, a claim for refund to the German tax authorities. The claim for refund must be accompanied by a withholding

tax certificate (Kapitalertragsteuerbescheinigung) on an officially prescribed form and issued by the institution that

withheld the tax.

According to para. 50c (5) German Income Tax Act, claims for refunds have to be transmitted via the officially specified

interface according to the officially prescribed data set. The German claim for refund forms can be submitted to the

Bundeszentralamt für Steuern via the online portal of the Bundeszentralamt für Steuern (“BOP”): https://www.elster.de/

bportal/start. Every claimant needs a certificate file to login into the BOP. A U.S. resident must also submit to the

German tax authorities a certification (on IRS Form 6166) with respect to its last filed U.S. federal income tax return.

Requests for IRS Form 6166 are made on IRS Form 8802, which requires payment of a user fee. IRS Form 8802 and its

instructions can be obtained from the IRS website at www.irs.gov. The quick-refund procedure (“Datenträgerverfahren –

DTV”/“Data Medium Procedure – DMP”) was abolished from 01.01.2025 onwards and is no longer applicable.

The German tax authorities will issue refunds denominated in euros. In the case of shares held through banks or brokers

participating in the Depository Trust Company, the refunds will be issued to the Depository Trust Company, which will

convert the refunds to U.S. dollars. The resulting amounts will be paid to banks or brokers for the account of holders.

If a U.S. resident files a claim for refund directly with the German tax authorities, the time until the receipt of a refund is

uncertain and we can give no assurances as to when any refund will be received.

The Bundeszentralamt für Steuern published on its website information regarding the tax refund process in Germany..

Taxation of Capital Gains

Under the Treaty, a U.S. resident will generally not be subject to German capital gains tax in respect of a sale or other

disposition of shares. For U.S. federal income tax purposes, a U.S. holder will generally recognize capital gain or loss on

the sale or other disposition of shares in an amount equal to the difference between such holder’s tax basis in the shares

and the U.S. dollar value of the amount realized from their sale or other disposition. Such gain or loss will be long-term

capital gain or loss if the shares were held for more than one year. The net amount of long-term capital gain realized by

an individual generally is subject to taxation at a lower rate than ordinary income. Any such gain generally would be

treated as income arising from sources within the United States; any such loss would generally be allocated against U.S.

source income. The ability to offset capital losses against ordinary income is subject to limitations.

Shareholders whose shares are held in an account with a German bank or financial services institution (including a

German branch of a non-German bank or financial services institution) are urged to consult their own advisors. This

summary does not discuss their particular tax situation.

United States Information Reporting and Backup Withholding

Dividends and payments of the proceeds on a sale of shares, paid within the United States or through certain U.S. related

financial intermediaries are subject to information reporting and may be subject to backup withholding unless the U.S.

resident (i) is a corporation (other than an S corporation) or other exempt recipient or (ii) provides a taxpayer identification

number and certifies (on IRS Form W-9) that no loss of exemption from backup withholding has occurred. Shareholders

that are not U.S. persons generally are not subject to information reporting or backup withholding.

However, a non-U.S. person may be required to provide a certification (generally on IRS Form W-8BEN or W-8BEN-E) of

its non-U.S. status in connection with payments received in the United States or through a U.S. related financial

intermediary.

Backup withholding tax is not an additional tax, and any amounts withheld under the backup withholding rules will be

allowed as a refund or a credit against a holder’s U.S. federal income tax liability, provided the required information is

furnished to the IRS.

Shareholders may be subject to other U.S. information reporting requirements. Shareholders should consult their own

advisors regarding the application of U.S. information reporting rules considering their particular circumstances.

106


Deutsche Bank	Item 15: Controls and Procedures
Annual Report 2025 on Form 20-F	Disclosure Controls and Procedures

PART II

Item 13: Defaults, Dividend Arrearages and

Delinquencies

Not applicable.

Item 14: Material Modifications to the Rights of

Security Holders and Use of Proceeds

None.

Item 15: Controls and Procedures

Disclosure Controls and Procedures

An evaluation was carried out under the supervision and with the participation of Deutsche Bank’s management,

including the bank’s Chief Executive Officer and Chief Financial Officer, of the effectiveness of the design and operation

of the bank’s disclosure controls and procedures (as defined in Rule 13a-15(e) under the Securities Exchange Act of

1934) as of December 31, 2025. There are, as described below, inherent limitations to the effectiveness of any control

system, including disclosure controls and procedures. Accordingly, even effective disclosure controls and procedures

can provide only reasonable assurance of achieving their control objectives. Based upon such evaluation, the Chief

Executive Officer and Chief Financial Officer concluded that the design and operation of Deutsche Bank’s disclosure

controls and procedures were effective as of December 31, 2025.

Management’s Annual Report on Internal Control over

Financial Reporting

Management of Deutsche Bank Aktiengesellschaft, together with its consolidated subsidiaries, is responsible for

establishing and maintaining adequate internal control over financial reporting. Deutsche Bank’s internal control over

financial reporting is a process designed under the supervision of the bank’s Chief Executive Officer and its Chief

Financial Officer to provide reasonable assurance regarding the reliability of financial reporting and the preparation of

the Group’s financial statements for external reporting purposes in accordance with International Financial Reporting

Standards as issued by the International Accounting Standards Board and endorsed by the European Union. As of

December 31, 2025, Deutsche Bank management conducted an assessment of the effectiveness of the bank’s internal

control over financial reporting based on the framework established in Internal Control – Integrated Framework (2013)

issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Based on the assessment

performed, management has determined that Deutsche Bank’s internal control over financial reporting as of December

31, 2025, was effective based on the COSO framework (2013).

EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft, the registered public accounting firm that audited the financial

statements included in this document, has issued a report on Deutsche Bank’s internal control over financial reporting,

which is set forth below.

107


Deutsche Bank	Item 15: Controls and Procedures
Annual Report 2025 on Form 20-F	Report of Independent Registered Public Accounting Firm

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Supervisory Board of Deutsche Bank Aktiengesellschaft:

Opinion on Internal Control Over Financial Reporting

We have audited Deutsche Bank Aktiengesellschaft’s internal control over financial reporting as of December 31, 2025,

based on criteria established in Internal Control – Integrated Framework issued by the Committee of Sponsoring

Organizations of the Treadway Commission (2013 framework) (the COSO criteria). In our opinion, Deutsche Bank

Aktiengesellschaft (the Company) maintained, in all material respects, effective internal control over financial reporting

as of December 31, 2025, based on the COSO criteria.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United

States) (PCAOB), the consolidated balance sheets of the Company as of December 31, 2025 and 2024, the related

consolidated statements of income, comprehensive income, changes in equity and cash flows for each of the three years

in the period ended December 31, 2025, the related notes and the specific disclosures described in Note 1 to the

consolidated financial statements as being part of the financial statements, and our report dated March 9, 2026

expressed an unqualified opinion thereon.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its

assessment of the effectiveness of internal control over financial reporting included in the accompanying Management’s

Annual Report on Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Company’s

internal control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB

and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and

the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and

perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was

maintained in all material respects.

Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a

material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the

assessed risk, and performing such other procedures as we considered necessary in the circumstances. We believe that

our audit provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding

the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with

generally accepted accounting principles. A company’s internal control over financial reporting includes those policies

and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the

transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are

recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting

principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of

management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely

detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on

the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.

Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become

inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may

deteriorate.

/s/ EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft

Eschborn/Frankfurt am Main, Germany

March 9, 2026

108


Deutsche Bank	Item 15: Controls and Procedures
Annual Report 2025 on Form 20-F	Report of Independent Registered Public Accounting Firm

Change in internal control over financial reporting

There was no change in Deutsche Bank’s internal control over financial reporting identified in connection with the

evaluation referred to above that occurred during the year ended December 31, 2025, that has materially affected, or is

reasonably likely to materially affect, the bank’s internal control over financial reporting.

A control system, no matter how well conceived and operated, can provide only reasonable, not absolute, assurance that

the objectives of the control system are met. As such, disclosure controls and procedures or systems for internal control

over financial reporting may not prevent all error and all fraud. Further, the design of a control system must reflect the

fact that there are resource constraints, and the benefits of controls must be considered relative to their costs. Because

of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that all control

issues and instances of fraud, if any, within the company have been detected. These inherent limitations include the

realities that judgments in decision-making can be faulty, and that breakdowns can occur because of simple error or

mistake. Additionally, controls can be circumvented by the individual acts of some persons, by collusion of two or more

people, or by management override of the control. The design of any system of controls also is based in part upon certain

assumptions about the likelihood of future events, and any design may not succeed in achieving its stated goals under all

potential future conditions; over time, controls may become inadequate because of changes in conditions, or the degree

of compliance with the policies or procedures may deteriorate. Because of the inherent limitations in a cost-effective

control system, misstatements due to error or fraud may occur and not be detected.

109


Deutsche Bank	Item 16D: Exemptions from the Listing Standards for Audit Committees
Annual Report 2025 on Form 20-F

Item 16A: Audit Committee Financial Expert

Please see “Corporate Governance Statement according to Sections 289f and 315d of the German Commercial Code:

Supervisory Board Committee Experts: Audit Committee Financial Experts” in the Annual Report 2025.

Item 16B: Code of Ethics

Please see “Corporate Governance Statement according to Sections 289f and 315d of the German Commercial Code:

Value and Leadership Principles of Deutsche Bank AG and Deutsche Bank Group: Deutsche Bank Group Code of Conduct

and Code of Ethics for Senior Financial Officers” in the Annual Report 2025.

Item 16C: Principal accountant fees and services

Please see “Corporate Governance Statement according to Sections 289f and 315d of the German Commercial Code:

Supervisory Board: Principal accountant fees and services” in the Annual Report 2025.

Item 16D: Exemptions from the Listing Standards for

Audit Committees

Deutsche Bank’s common shares are listed on the New York Stock Exchange, the corporate governance rules of which

require a foreign private issuer such as the bank to have an audit committee that satisfies the requirements of Rule 10A-3

under the U.S. Securities Exchange Act of 1934. These requirements include a requirement that the audit committee be

composed of members that are “independent” of the issuer, as defined in the corporate governance rules of the New

York Stock Exchange, subject to certain exemptions, including an exemption for employees who are not executive

officers of the issuer if the employees are elected or named to the board of directors or audit committee pursuant to the

issuer’s governing law or documents, an employee collective bargaining or similar agreement or other home country

legal or listing requirements. The German Co-Determination Act of 1976 (Mitbestimmungsgesetz) requires that the

shareholders elect half of the members of the supervisory board of large German companies, such as Deutsche Bank, and

that employees in Germany elect the other half. Employee-elected members are typically themselves employees or

representatives of labor unions representing employees. Pursuant to law and practice, committees of the Supervisory

Board are typically composed of both shareholder- and employee-elected members. Of the current members of the

Audit Committee, four – Susanne Bleidt, Manja Eifert, Claudia Fieber and Stephan Szukalski – are current employees of

Deutsche Bank who have been elected as Supervisory Board members by the employees. None of them is an executive

officer. Accordingly, their service on the Audit Committee is permissible pursuant to the exemption from the

independence requirements provided for by paragraph (b)(1)(iv)(C) of the Rule. The Group does not believe the reliance

on such exemption would materially adversely affect the ability of the Audit Committee to act independently and to

satisfy the other requirements of the Rule.

110


Deutsche Bank	Item 16E: Purchases of Equity Securities by the Issuer and Affiliated Purchasers
Annual Report 2025 on Form 20-F

Item 16E: Purchases of Equity Securities by the Issuer

and Affiliated Purchasers

The Management Board was authorized by the 2024 Annual General Meeting to buy, on or before April 30, 2029, shares

of up to 10% of the share capital at the time the resolution was taken or, if lower, of the share capital at the respective

time the authorization was exercised. At the 2024 Annual General Meeting, this corresponded to a volume of

199.5 million shares. During the period from the 2024 Annual General Meeting until the 2025 Annual General Meeting,

34.6 million shares were purchased for equity compensation purposes in the same period or for upcoming periods.

Furthermore, 27.9 million shares were purchased for cancellation with the purpose of distributing capital to

shareholders. Thereof, 20.9 million shares acquired as part of the share buyback program of € 675 million in 2024 were

cancelled at the beginning of 2025. The remaining amount of 7.0 million shares relates to shares bought back until May

22, 2025 as part of the € 750 million share buyback program in 2025.

The 2025 Annual General Meeting on May 22, 2025, granted the Management Board the approval to buy, on or before

April 30, 2030, shares of up to 10% of the share capital at the time the resolution was taken or, if lower, of the share

capital at the respective time the authorization was exercised. At the 2025 Annual General Meeting, this corresponded to

194.8 million shares. This authorization replaced the authorization of the previous year. During the period from the 2025

Annual General Meeting until December 31, 2025, 4.6 million shares were purchased for equity compensation purposes

in upcoming periods and 30.6 million shares were purchased for cancellation with the purpose of distributing capital to

shareholders. Thereof 22.3 million shares were purchased as part of the € 750 million share buyback program and

8.4 million shares were acquired as part of the € 250 million share buyback program.

At December 31, 2025, the number of shares held in Treasury from buybacks totaled 7.7 million. This figure stems from a

starting balance of 49.6 million shares at the beginning of 2025 which was reduced by 46.4 million shares after the

cancellation of shares acquired in the 2024 share buyback program, plus 39.3 million shares purchased for equity

compensation purposes, less 34.7 million shares which were used to fulfill delivery obligations under the share-based

compensation for employees, plus 37.7 million shares acquired as part of the 2025 share buyback program for

cancellation which were legally cancelled at the end of the year.

The following table sets forth the total gross number of Deutsche Bank’s shares repurchased by the bank and its

affiliated purchasers (pursuant to both activities described above), on a monthly basis in 2025, the average price paid per

share (based on the gross shares repurchased), the number of shares that were purchased as part of publicly

announcement share buyback programs, the average price paid for the purchases under such programs as well as the

maximum number of shares that at that date could yet to be purchase under such programs.

Issuer Purchases of Equity Securities in 2025


Month	Total number of shares purchased1	Average price paid per share (in €)	Total number of shares purchased as part of publicly announced plans or programs2 & 3	Maximum Euro value of shares that may yet be purchased under the plans or program (€)
January	21,582,590	14.66	—	—
February	13,055,060	12.77	—	—
March	—	—	—	—
April	5,345,496	20.44	5,345,496	640,752,928
May	4,534,558	24.30	4,534,558	530,582,714
June	6,776,323	24.26	6,776,323	366,201,848
July	4,463,415	25.59	4,463,415	251,999,901
August	4,978,627	31.03	4,978,627	97,502,244
September	7,239,455	30.39	7,239,455	127,503,602
October	4,336,034	29.29	4,336,034	—
November	4,614,821	29.40	—	—
December	—	—	—	—
Total 2025	76,926,379	21.04	37,673,908

1 A total of 39.3 million shares were purchased for equity compensation purchases, i.e. other than pursuant to a publicly announced plan. Thereof 18.0 million shares were

purchased in open-market transactions and 21.3 million shares were acquired via the exercise of call options.

2 Share Buyback Program 2025-1 was announced on March 27, 2025, and provided for the purchase of up to € 750 million in shares. The program started on April 1, 2025,

and was completed on September 12, 2025. In this period 29,297,410 shares were acquired. The purchase price paid at the stock exchange was on average € 25.58 per

share.

3 Share Buyback Program 2025-2 was announced on September 16, 2025, and provided for the purchase of up to € 250 million in shares. The program started on

September 17, 2025, and was completed on Oct 20, 2025. In this period 8,376,498 shares were acquired. The purchase price paid at the stock exchange was on average

€ 29.85 per share.

111


Deutsche Bank	Item 16G: Corporate Governance
Annual Report 2025 on Form 20-F

Item 16F: Change in Registrant’s Certifying

Accountant

Not applicable.

Item 16G: Corporate Governance

Deutsche Bank’s common shares are listed on the New York Stock Exchange, as well as on all seven German stock

exchanges. Set forth below is a description of the significant ways in which the corporate governance practices differ

from those applicable to U.S. domestic companies under the New York Stock Exchange’s listing standards as set forth in

its Listed Company Manual (the “NYSE Manual”).

The Legal Framework. Corporate governance principles for German stock corporations (Aktiengesellschaften) are set

forth in the German Stock Corporation Act (Aktiengesetz), the German Co-Determination Act of 1976

(Mitbestimmungsgesetz) and the German Corporate Governance Code (Deutscher Corporate Governance Kodex, referred

to as the Code).

The Two-Tier Board System of a German Stock Corporation. The German Stock Corporation Act provides for a clear

separation of management and oversight functions. It therefore requires German stock corporations to have both a

Supervisory Board (Aufsichtsrat) and a Management Board (Vorstand). These boards are separate; no individual may be a

member of both. Both the members of the Management Board and the members of the Supervisory Board must exercise

the standard of care of a diligent businessperson to the company. In complying with this standard of care they are

required to take into account a broad range of considerations, including the interests of the company and others like

those of its shareholders, employees and creditors.

The Management Board is responsible for managing the company and representing the company in its dealings with

third parties. The Management Board is also required to ensure appropriate risk management within the corporation and

to establish an internal monitoring system. The members of the Management Board, including its chairperson or speaker,

are regarded as peers and share a collective responsibility for all management decisions.

The Supervisory Board appoints and recalls the members of the Management Board. It also may appoint a chairperson

(CEO) and one or more deputy chairpersons of the Management Board. Although the Supervisory Board is not allowed to

make management decisions, it has comprehensive monitoring functions with respect to the activities of the

Management Board, including advising the Management Board and participating in decisions of fundamental importance

to the company. To ensure that these monitoring functions are carried out properly, the Management Board must,

among other things, regularly report to the Supervisory Board with regard to current business operations and business

planning, including any deviation of actual developments from concrete and material targets previously presented to the

Supervisory Board. The Supervisory Board may also request special reports from the Management Board at any time.

Transactions of fundamental importance to the company, such as major strategic decisions or other actions that may

have a fundamental impact on the company’s assets and liabilities, financial condition or results of operations, may be

subject to the consent of the Supervisory Board. Pursuant to the bank’s Articles of Association (Satzung), such

transactions include the granting of general powers of attorney, granting of credits, including the acquisition of

participations in other companies for which the German Banking Act (Kreditwesengesetz) requires approval by the

Supervisory Board, as well as major acquisitions or disposals of real estate or other participations.

Pursuant to the German Co-Determination Act, Deutsche Bank’s Supervisory Board consists of representatives elected

by the shareholders and representatives elected by delegates of the employees in Germany. Based on the total number

of Deutsche Bank employees in Germany these employees have the right to elect one-half of the total of twenty

Supervisory Board members. The chairperson of the Supervisory Board of Deutsche Bank is a shareholder representative

who has the deciding vote in the event of a tie.

This two-tier board system contrasts with the unitary board of directors envisaged by the relevant laws of all U.S. states

and the New York Stock Exchange listing standards for U.S. companies.

German companies which have their shares listed on a stock exchange must each year issue a statement on the

company’s corporate governance (corporate governance statement) and either include such statement in their annual

management report or publish it separately on their website.

112


Deutsche Bank	Item 16G: Corporate Governance
Annual Report 2025 on Form 20-F

The Recommendations of the Code. The Code was issued in 2002 by a commission composed of German corporate

governance experts appointed by the German Federal Ministry of Justice in 2001. The Code was last amended in April

28, 2022 with effect as of June 27, 2022. It describes and summarizes the basic mandatory statutory corporate

governance principles found in the provisions of German law. In addition, it contains supplemental recommendations and

suggestions for standards on responsible corporate governance intended to reflect generally accepted best practice.

The Code is structured from a task perspective and addresses seven core areas of corporate governance. These are the

tasks of (a) management and supervision, (b) appointment to the Management Board, (c) composition of the Supervisory

Board, (d) Supervisory Board procedures, (e) conflicts of interest, (f) transparency and external reporting as well as (g) the

remuneration of the Management Board and the Supervisory Board. The Code contains three types of provisions. First,

the Code contains principles which reflect material legal requirements for responsible governance, and are used in the

Code to inform investors and other stakeholders. The second type of provisions is recommendations. While these are not

legally binding, Section 161 of the German Stock Corporation Act requires that any German exchange-listed company

declare annually that the company complies with the recommendations of the Code or, if not, which recommendations

the company does not comply with and the reasons for the non-compliance (“comply or explain”). The third type of Code

provisions comprises suggestions which companies may choose not to comply with without disclosure.

In its last Declaration of Conformity on October 24, 2025, the Management Board and the Supervisory Board of

Deutsche Bank stated that, since the last Declaration of Conformity issued on October 28, 2024, it has acted and will act

in the future in conformity with the recommendations of the Code, with certain specified exceptions. The Declaration of

Conformity is available on Deutsche Bank’s internet website at www.db.com/ir/en/documents.htm.

Supervisory Board Committees. The Supervisory Board may form committees. Pursuant to the German Stock

Corporation Act, any Supervisory Board committee must regularly report to the Supervisory Board.

The German Co-Determination Act requires that the Supervisory Board establishes a Mediation Committee to propose

candidates for the Management Board if the two-thirds majority of the members of the Supervisory Board required for

the appointment of Management Board members is not achieved.

Section 107 (4) of the German Stock Corporation Act also requires that companies of “public interest”, including, among

others, listed companies and credit institutions, establish an “Audit Committee” to deal with the supervision of

accounting processes, the efficiency of the internal control system the risk management system and the internal audit

system as well as with the annual auditing, in particular with the selection and the independence of the external auditor

and the additional services rendered by the external auditor. The Code also recommends establishing a “Nomination

Committee” comprised only of shareholder-elected Supervisory Board members to prepare the Supervisory Board’s

proposals for the election or appointment of new shareholder representatives to the Supervisory Board. In general, the

Code recommends that the Supervisory Board shall form, depending on the specific circumstances of the enterprise and

the number of Supervisory Board members, committees of members with relevant specialist expertise which can handle

subjects, such as corporate strategy, compensation of the members of the Management Board, investments and

financing.

Sections 25d (7) to (12) of the German Banking Act require, depending on the size and complexity of the respective

credit institution, the establishment of Supervisory Board committees with specific tasks to be performed as follows: Risk

Committee, Audit Committee, Nomination Committee (with tasks and composition requirements different from those set

out in the Code) and Compensation Control Committee. The Code’s recommendation that the Nomination Committee

shall only comprise shareholder representatives is not complied with by Deutsche Bank AG because of mandatory

special rules set forth in the German Banking Act, which assign further tasks to the Nomination Committee in addition to

the preparation of proposals for the appointment of new shareholder representatives to the Supervisory Board. These

further tasks do not justify the exclusion of employee representatives from the Nomination Committee. Based on an

earlier version of the Code, which was applicable until March 20, 2020, this non-compliance had to be disclosed and

justified in the annual Declaration of Conformity. The Code, as amended, provides that credit institutions and insurance

companies are exempt from recommendations of the Code which conflict with special rules or regulations applicable to

them. However, the Code recommends that in the case of such conflicts, companies indicate in their annual corporate

governance statement what recommendations of the Code were not applicable to them.

113


Deutsche Bank	Item 16G: Corporate Governance
Annual Report 2025 on Form 20-F

The Supervisory Board of Deutsche Bank has established a Chairman’s Committee (Präsidialausschuss) which is inter alia

responsible for conclusion, amendment and termination of employment and pension contracts with members of the

Management Board, taking into account the responsibility of the Supervisory Board as a whole for the remuneration of

the members of the Management Board, a Nomination Committee (Nominierungsausschuss), an Audit Committee

(Prüfungsausschuss), a Risk Committee (Risikoausschuss), a Compensation Control Committee (Vergütungskontroll-

ausschuss), a Strategy and Sustainability Committee (Strategie- und Nachhaltigkeitsausschuss), a Technology, Data and

Innovation Committee (Technologie-, Daten- und Innovationsausschuss) and a Mediation Committee

(Vermittlungsausschuss). The functions of a nominating/corporate governance committee and of a compensation

committee required by the NYSE Manual for U.S. companies listed on the NYSE are therefore performed by the

Supervisory Board or one of its committees, in particular the Chairman’s Committee, the Compensation Control

Committee and the Mediation Committee.

Independent Board Members. The NYSE Manual requires that a majority of the members of the board of directors of a

NYSE listed U.S. company and each member of its nominating/corporate governance, compensation and audit

committees be “independent” according to strict criteria and that the board of directors determines that such member

has no material direct or indirect relationship with the company.

As a foreign private issuer, Deutsche Bank is not subject to these requirements. However, its audit committee must meet

the more lenient independence requirement of Rule 10A-3 under the Securities Exchange Act of 1934. German

corporate law does not require an affirmative independence determination, meaning that the Supervisory Board need

not make affirmative findings that Audit Committee members are independent. However, the German Stock Corporation

Act and the Code, as the case may be, contain several rules, recommendations and suggestions to ensure the

Supervisory Board’s independent advice to, and supervision of, the Management Board. As noted above, no member of

the Management Board may serve on the Supervisory Board (and vice versa). Supervisory Board members will not be

bound by directions or instructions from third parties. Any advisory, service or similar contract between a member of the

Supervisory Board and the company is subject to the Supervisory Board’s approval. A similar requirement applies to loans

granted by the company to a Supervisory Board member or other persons, such as certain members of a Supervisory

Board member’s family. In addition, the German Stock Corporation Act prohibits a person who within the last two years

was a member of the Management board from becoming a member of the Supervisory Board of the same company

unless he or she is elected upon the proposal of shareholders holding more than 25% of the voting rights of the company.

The Code also recommends that each member of the Supervisory Board inform the Supervisory Board of any conflicts of

interest. In the case of material conflicts of interest or ongoing conflicts, the Code recommends that the mandate of the

Supervisory Board member shall end either as a result of such supervisory board member’s withdrawal or, failing which,

based on his or her removal from office by the shareholders’ meeting. The Code further recommends that any conflicts of

interest that have occurred be reported by the Supervisory Board at the annual general meeting, together with the

action taken, and that potential conflicts of interest also be taken into account in the nomination process for the election

of Supervisory Board members.

Audit Committee Procedures. Pursuant to the NYSE Manual the audit committee of a U.S. company listed on the NYSE

must have a written charter addressing its purpose, an annual performance evaluation, and the review of an auditor’s

report describing internal quality control issues and procedures and all relationships between the auditor and the

company. The Audit Committee of Deutsche Bank operates under written terms of reference and reviews the efficiency

of its activities regularly.

Disclosure of Corporate Governance Guidelines. Deutsche Bank discloses its Articles of Association, the Terms of

Reference of its Management Board, its Supervisory Board, the Chairman’s Committee, the Audit Committee, the Risk

Committee, the Compensation Control Committee, the Nomination Committee, the Strategy and Sustainability

Committee and the Technology, Data and Innovation Committee, its Declaration of Conformity under the Code pursuant

to Section 161 of the German Stock Corporation Act, the Corporate Governance Statement and other documents

pertaining to its corporate governance on its internet website at www.db.com/ir/en/documents.htm.

114


Deutsche Bank	Item 16J: Insider Trading Policies
Annual Report 2025 on Form 20-F

Item 16H: Mine Safety Disclosure

Not applicable

Item 16I: Disclosure Regarding Foreign Jurisdictions

that Prevent Inspections

Not applicable.

Item 16J: Insider Trading Policies

Deutsche Bank has adopted insider trading policies that govern the purchase, sale and other dispositions of the bank’s

securities by directors, senior management and employees that are reasonably designed to promote compliance with

applicable insider trading laws, rules and regulations, and listing standards applicable to the registrant.

In particular, all staff, including members of the bank’s Management Board, are subject to the bank’s Personal Account

Dealing Policy, as well as to the bank’s Code of Conduct, which refers to such policy. An essential requirement of such

policy is that such staff must pre-clear transactions in all relevant securities including shares and debt instruments issued

by Deutsche Bank AG. Trading derivatives, including those related to securities of Deutsche Bank AG, is prohibited.

Trading shares of Deutsche Bank AG or of DWS Group GmbH & Co. KGaA, the bank’s 79.49% owned, publicly traded

subsidiary (“DWS”), and related financial instruments is additionally prohibited during “Restricted Periods” prior to the

release of annual or quarterly earnings releases, with all staff being restricted from trading in the three days prior to the

release of earnings, staff designated as “private” being restricted in the 30 days up to and including the release of

earnings and staff designated as “permanent insiders” being restricted outside of a 30-day window following the release

of earnings.

The Personal Account Dealing Policy is filed as Exhibit 11.1 hereto. An excerpt from the Code of Conduct is filed as

Exhibit 11.2 hereto.

Item 16K: Cybersecurity

For information on Cybersecurity see “Combined Management Report: Risk Report: Information security” in the Annual

Report 2025.

115


Deutsche Bank	Disclosures Under Iran Threat Reduction and Syria Human Rights Act of 2012
Annual Report 2025 on Form 20-F

Disclosures Under Iran Threat Reduction and Syria

Human Rights Act of 2012

Under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13(r) of the

U.S. Securities Exchange Act of 1934, as amended, an issuer of securities registered under the Securities Exchange Act of

1934 is required to disclose in its periodic reports filed under the Securities Exchange Act of 1934 certain of its activities

and those of its affiliates relating to Iran and to other persons sanctioned by the U.S. under programs relating to terrorism

and proliferation of weapons of mass destruction that occurred during the period covered by the report. The bank

describes below a number of potentially disclosable activities of Deutsche Bank AG and its affiliates. Disclosure is

generally required regardless of whether the activities, transactions or dealings were conducted in compliance with

applicable law. Deutsche Bank also reports transactions in which other Iranian persons or entities listed on OFAC

sanctions lists were involved, whether or not they are directly or indirectly owned or controlled by the Iranian

government.

Legacy Contractual Obligations Related to Guarantees and Letters of Credit. Prior to 2007, Deutsche Bank provided

guarantees to a number of Iranian entities. In almost all of these cases, the bank issued counter-indemnities in support of

guarantees issued by Iranian banks because the Iranian beneficiaries of the guarantees required that they be backed

directly by Iranian banks. In 2007, the bank made a decision to discontinue issuing new guarantees to Iranian or Iran-

related beneficiaries. Although the pre-existing guarantees stipulate that they must be either extended or honored if the

bank receives such a demand and is legally not able to terminate these guarantees, the firm decided to reject any

“extend or pay” demands under such guarantees. Even though the bank had exited, where possible, many of these

guarantees, guarantees with an aggregate face amount of approximately € 6.7 million are still outstanding as of year-end

2025. The gross revenues from this business in 2025 which the bank received from non-Iranian parties were

approximately € 34,900 and the net profit derived from these activities was less than this amount.

Deutsche Bank also has outstanding legacy guarantees in relation to a Syrian bank that was sanctioned by the United

States under its non-proliferation program prior to such sanctions being terminated in mid-2025. The aggregate face

amount of these legacy guarantees was approximately € 7.0 million at such time, the gross revenues received from non-

Syrian parties for these guarantees during the portion of 2025 for which sanctions applied were approximately € 26,400

and the net profit derived from these activities was less than this amount.

Payments Executed. Deutsche Bank continues to severely restrict its policy on Iran and consequently the execution of

payments relating to Iran. In 2025, three outgoing payments were executed on behalf of Iranian parties outside of

Germany with involvement of DB Hungary related to electricity bills of the local Iranian embassy in a total amount of

€ 500. With regards to the Iranian Embassy in Germany, see below.

Operations of Iranian Bank Branches and Subsidiaries in Germany. Several Iranian banks, including Bank Melli Iran, Bank

Saderat, Bank Sepah, and Europäisch-Iranische Handelsbank, have branches or offices in Germany, even though their

funds and other economic resources had been frozen earlier under European law. As part of the payment clearing system

in Germany and other European countries, when these branches or offices needed to make payments in Germany or

Europe to cover their day-to-day operations such as rent, taxes, insurance premiums and salaries for their remaining staff,

or for any other kind of banking-related operations, fund transfers from these Iranian banks had been accepted through

Target2 or in SEPA format.

In 2025, Deutsche Bank executed approximately € 14 million (almost only in-coming) transfers through Target2 or SEPA

across approximately 670 transactions and credited the relevant amounts to the non-Iranian clients through September

29, 2025. The gross revenues derived from these payments were approximately € 130.

The bank does not consider the execution of such transactions to be significant and, after the European Union reinstated

the sanctions against Iran on September 29, 2025, the bank does not intend to make further payments unless such

payments are licensed by Bundesbank.

116


Deutsche Bank	Disclosures Under Iran Threat Reduction and Syria Human Rights Act of 2012
Annual Report 2025 on Form 20-F

Maintaining of Accounts for Iranian Consulates and Embassies. In 2025, Iranian embassies and consulates in Germany

held accounts with Deutsche Bank. The purpose of these accounts is the funding of day-to-day operational costs of the

embassies and consulates, such as salaries, rent and electricity. In 2025, the total volume of outgoing payments from

these accounts was approximately € 4.1 million which have been funded through € 13.1 million of incoming payments.

From these activities, the bank derived gross revenues of approximately € 0.26 million and net profits which were less

than this amount. The German government has requested that Deutsche Bank provide these services to enable the

government of Iran to conduct its diplomatic relations and the bank intends to continue maintenance of such accounts.

Activities of Entities in Which Deutsche Bank Has Interests. Section 13(r) requires the Group to provide the specified

disclosure with respect to Deutsche Bank and its “affiliates,” as defined in Exchange Act Rule 12b-2. Although the bank

has minority equity interests in certain entities that could arguably result in these entities being deemed “affiliates,” it

does not have the authority or the legal ability to acquire in every instance the information from these entities that would

be necessary to determine whether they are engaged in any disclosable activities under Section 13(r). In some cases,

legally independent entities are not permitted to disclose the details of their activities to the bank because of German

privacy and data protection laws or the applicable banking laws and regulations. In such cases, voluntary disclosure of

such details could violate such legal and/or regulatory requirements and subject the relevant entities to criminal

prosecution or regulatory investigations.


Deutsche Bank	Operating and financial review
Annual Report 2025	Executive summary

Operating and financial review

The following discussion and analysis should be read in conjunction with the consolidated financial statements and the

related notes. This operating and financial review includes qualitative and quantitative disclosures on segment results of

operations and entity-wide disclosures on net revenue components of Deutsche Bank as required by International

Financial Reporting Standard (IFRS) 8, “Operating Segments”. For additional business segment disclosure under IFRS 8,

please refer to Note 04 “Business segments and related information” of the consolidated financial statements.

Executive summary

The statements in the following section are based on latest available forecasts and assumptions at the time of

preparation. Actual developments may differ from these expectations.

Global economy


Economic growth (in %)¹	20252	20243	Main driver
Global Economy	3.4	3.4	In 2025, the global economy maintained a stable growth trajectory; progress in trade negotiations between the U.S. and its key trading partners, along with selective tariff reductions, contributed to a marked decline in trade policy uncertainty; at the same time, easing inflationary pressures supported household consumption and provided central banks with scope to implement further interest rate cuts
Of which: Developed countries	1.8	1.7	Developed countries benefited from the negotiated trade compromises, which helped reduce overall policy uncertainty; although GDP growth rates varied across countries, inflation moderated in most markets. In this environment, several central banks continued to lower their key policy rates from previously restrictive levels
Emerging Markets	4.5	4.5	Emerging Markets demonstrated stronger‑than‑expected resilience to adverse growth and trade shocks arising from U.S. tariff measures; the combination of subdued inflation and a moderation in U.S. dollar strength provided several central banks with additional scope to ease monetary policy; furthermore, improved external fiscal impulses and lower energy prices offered further support to overall economic activity
Eurozone Economy	1.5	0.8	Despite persistent external trade headwinds, the Eurozone economy continued to post robust growth, supported by resilient domestic demand; nonetheless, GDP growth rates varied across regions; inflation trended downwards towards the ECB's 2% target, thus, the ECB was able to maintain its deposit rate unchanged at a neutral level in the second half of the year
Of which: German economy	0.2	(0.5)	The German economy continued to face competitive disadvantages in foreign trade; while the expansionary fiscal stance provided some initial positive impetus, domestic demand remained subdued; moderating inflation supported private consumption; however, overall sentiment continued to be weak; the cooling of the robust labor market has slowed
U.S. Economy	2.2	2.8	In the U.S., federal government shutdown dampened economic activity in the second half of the year; nevertheless, investment, particularly in AI‑related technologies, provided meaningful support to growth; reductions in food import tariffs contributed to easing inflationary pressures; in light of emerging labour market risks, the Federal Reserve proceeded with further reductions of its key policy rate despite inflation remaining above target
Japanese Economy	1.2	(0.2)	The impact of U.S. tariff measures on the Japanese economy remained limited, and business sentiment continued to be robust; an increase in real employee compensation supported the recovery in private consumption; inflation, however, remained elevated, driven primarily by rising food prices; against this backdrop, the Bank of Japan proceeded to tighten its monetary policy stance
Asian Economy4	5.5	5.2	GDP growth in Asian economies was supported primarily by strong economic momentum in India, complemented by additional contributions from China; inflation declined noticeably across several economies, which bolstered private consumption and provided scope for certain central banks to implement further reductions in policy interest rates
Of which: Chinese Economy	5.0	5.0	China met its official growth target, although momentum slowed over the year, largely due to policy measures aimed at curbing overcapacity and excessive competition; the government's efforts to stimulate purchases of durable consumer goods also lost effectiveness over time

1Annual Real GDP Growth (% YoY). Sources: National Authorities unless stated otherwise

2Sources: Deutsche Bank Research

3Some economic data for 2024 were revised by public statistics authorities. As a result, this data may differ from that previously published

4Includes China, Hong Kong, India, Indonesia, Malaysia, Philippines, Singapore, Sri Lanka, South Korea, Taiwan, Thailand and Vietnam; excludes Japan


Deutsche Bank	Operating and financial review
Annual Report 2025	Executive summary

Banking Industry


	Dec 31, 2025
Growth year on year (in %)	Corporate Lending	Retail Lending	Corporate Deposits	Retail Deposits	Main driver
Eurozone	2.0	2.6	3.2	3.0	Buoyed by lower interest rates and stronger economic growth, both retail and corporate lending have picked up significantly over the course of the year, the former even more than the latter; However, growth rates did not yet exceed inflation to a meaningful extent; By contrast, deposits from households as well as firms largely maintained their momentum throughout 2025 and kept expanding at a robust pace
Of which: Germany	0.7	1.9	2.4	2.8	Private-sector credit dynamics have improved during 2025, with households more than with companies due to interest rate tailwinds in the mortgage business; Sluggish lending to firms may be the result of various factors impacting investment sentiment – from trade policy uncertainty to worries about Germany lacking international competitiveness, and transition challenges; Demand for credit rose in recent quarters, according to the bank lending survey; Growth remains higher in deposits from corporate and retail customers than in loans, despite a slowdown after the surge in 2024
U.S.1	3.3	2.8	4.21	4.21	Lending to the corporate as well as household sectors gained further traction as the year progressed; Nevertheless, the expansion is now only in line with inflation, i.e., the private sector is not deleveraging any more; Total deposit momentum accelerated substantially, bolstered by interest rates staying on an elevated level
China	9.0	0.5	3.7	9.7	Corporate lending maintained its robust pace in 2025, which nevertheless is the lowest since before the pandemic; By contrast, retail lending has come to a standstill and is the weakest on record (covering nearly two decades); On the deposit side, business with households continues to flourish, while it has picked up moderately with corporates, following a mild contraction in the prior year

1Total U.S. deposits as segment breakdown is not available

The global Investment Banking & Capital Markets fee pool increased by 12% to € 92 billion in 2025, making it the

second‑highest investment banking fee pool in the bank’s internal record, after 2021. This marked the second

consecutive year of double‑digit growth following the market downturn in 2022 and 2023, with the 2025 fee pool

standing 43% above 2023 levels. The Mergers & Acquisitions (M&A) fee pool was the primary driver of growth, reaching

€ 37 billion, marginally below the 2021 peak, and contributing € 5.3 billion of the € 9.7 billion total increase. Within M&A,

activity in “mega” deals exceeding € 10 billion rose sharply, with announced volumes more than doubling. Equity capital

markets, leveraged debt capital markets and debt capital markets also recorded higher fee pools, rising by 16%, 7% and

8% respectively, and together contributing the remaining € 4.4 billion increase. Regionally, the global fee pool shifted

away from Europe, Middle East and Africa (EMEA), which grew by 3%, towards the U.S. and Asia-Pacific (APAC), which

recorded growth of 14% and 16%, respectively. The United Kingdom & Ireland region continued to lag global trends, with

its fee pool declining by 2%. Global Sponsor activity increased by 6%, although corporate activity rose by a higher

amount at 14%. However, a 46% increase in announced Sponsor M&A volumes suggests a more constructive environment

for private equity heading into 2026. In Fixed Income, revenue pools remained at elevated levels in 2025, and Deutsche

Bank’s assessment is that they increased further compared to the previous year. Foreign exchange activity is expected to

have risen across the ten most‑traded currencies globally, supported by heightened volatility in the first half of the year

and broader growth in derivative activity. Rates revenues increased materially, reflecting strong client demand and a

more supportive market environment, and Emerging Markets revenues also improved year on year. In Credit Trading,

performance has been broadly in line with the prior year, with markets recovering strongly in the second half of 2025

following the reaction to U.S. tariff policy in the second quarter of 2025. In Financing, client demand remained robust,

supporting the expectation of a revenue pool above the prior‑year level.


Deutsche Bank	Operating and financial review
Annual Report 2025	Executive summary

Deutsche Bank performance

Deutsche Bank’s net profit was € 6.8 billion in 2025, up from € 4.5 billion in 2024. This year-on-year development

reflected strong operational performance in 2025 and the non-recurrence of specific litigation items which negatively

impacted 2024. Provision for credit losses was € 1.7 billion in 2025, down 7% from € 1.8 billion in 2024, or 36 basis points

of average loans.

In respect of financial year 2025, management plans to propose a dividend of € 1.00 per share, or € 1.9 billion, to

shareholders at its Annual General Meeting in May 2026, up by around 50% from € 0.68 per share for 2024. The bank has

secured the customary authorizations for € 1.0 billion in further share repurchases in respect of 2025. Together, these

measures would increase cumulative capital distributions to shareholders by a further € 2.9 billion. Cumulative capital

distributions in respect of the financial years 2021-2025, paid or payable in 2022-2026, would thereby reach € 8.5 billion.

Profit before tax was € 9.1 billion for the full year 2025 up 35% from € 6.7 billion in 2024. Revenues were € 31.4 billion,

essentially flat year on year compared to € 31.5 billion in 2024. Noninterest expenses were € 20.7 billion, down 10%, and

included € 0.4 billion in nonoperating costs compared to € 2.6 billion in 2024. Adjusted costs, which exclude

nonoperating costs, were down 1% to € 20.3 billion. The cost/income ratio was 66% compared to 73% in 2024. Post-tax

return on average shareholders’ equity was 8.5%, compared to 5.5% in the prior year. Post-tax return on average tangible

shareholders’ equity was 9.4% in 2025, compared to 6.2% in 2024. The year-on-year development in both ratios reflected

the strong operational performance achieved in 2025 as well as lower restructuring and severance charges and the non-

recurrence of specific litigation items compared to 2024.

Net revenues were € 31.4 billion in 2025, essentially flat compared to € 31.5 billion in 2024. Net commission and fee

income grew 5% to € 10.9 billion, while net interest income in key segments of the banking book remained resilient at

€ 13.7 billion, up 2%, reflecting higher deposit volumes. Compound annual revenue growth since 2021 was 5.3% through

the end of 2025.

Provision for credit losses was € 1.7 billion in 2025, or 35 basis points of average loans, a decrease of 7% from

€ 1.8 billion, or 38 basis points of average loans, in 2024, despite elevated macroeconomic and geopolitical uncertainty

and ongoing headwinds in Commercial Real Estate.

Noninterest expenses were € 20.7 billion in 2025, down 10% year on year. This development was primarily driven by a

decrease in nonoperating costs to € 0.4 billion, down 86%, from € 2.6 billion in 2024, which largely reflected the non-

recurrence of specific litigation items as well as lower restructuring and severance charges compared to 2024. Adjusted

costs were € 20.3 billion, down 1% compared to the prior year. Higher variable compensation expenses, reflecting the

bank’s performance, were offset by cost reductions in IT, professional services and other expenses.

Income tax expense was € 2.3 billion in 2025, compared to € 2.2 billion in the prior year. The effective tax rate of 25% in

2025 was positively impacted by the German Tax Reform and the geographical mix of income, compared to 33% in 2024,

which was mainly affected by litigation charges that were non-tax deductible.

Common Equity Tier 1 capital ratio was 14.2% at the end of 2025, slightly above the bank’s operating target range of

13.5% to 14.0%, and up from 13.8% at the end of 2024. Organic capital generation from increased profitability offset the

combined impacts of higher capital distributions and coupon payments, regulatory impacts and business growth during

the year.

Adjusted costs, nonoperating cost, net interest income in the key banking book segments, and post-tax return on

average tangible shareholders’ equity are Non-GAAP financial measures. Please refer to “Supplementary Information

(Unaudited): Non-GAAP Financial Measures” of this Annual Report for the definitions of such measures and

reconciliations to the IFRS measures on which they are based. With effect from the first quarter of 2026, Deutsche Bank

will discontinue the separate reporting of adjusted costs and nonoperating costs.


Deutsche Bank	Operating and financial review
Annual Report 2025	Deutsche Bank Group

Deutsche Bank Group

Deutsche Bank’s Organization

Headquartered in Frankfurt am Main, Germany, Deutsche Bank is the largest bank in Germany and one of the largest

financial institutions in the world, as measured by total assets of € 1,440 billion as of December 31, 2025. As of that date,

the bank had 89,879 full-time equivalent internal employees and operated in 55 countries with 1,179 branches, of which

64% were located in Germany.

Deutsche Bank Value Chain

Deutsche Bank’s business model considers impacts, risks and opportunities in relation to Environmental, Social and

Governance matters along the bank’s value chain, which comprises its upstream value chain, its own operations and its

downstream value chain. The following chart illustrates Deutsche Bank’s value chain and describes its components.

Intangible resources

The most important intangible resources for Deutsche Bank's business model from an economic point of view are its

customer relationships and its workforce. Other important intangible resources are the bank's brand name and its data

and software. When required by IFRS, intangible resources are recognized in the balance sheet and described in the

consolidated financial statements

Deutsche Bank’s organizational model

As of December 31, 2025, the bank was organized into the following business segments:

–Corporate Bank

–Investment Bank

–Private Bank

–Asset Management

–Corporate & Other

Deutsche Bank has a country and regional organizational layer to facilitate a consistent implementation of global

strategies.

The bank has operations or dealings with existing and potential customers in most countries in the world. These

operations and dealings include working through:

–Subsidiaries and branches

–Representative offices

–One or more representatives assigned to serve customers


Deutsche Bank	Operating and financial review
Annual Report 2025	Deutsche Bank Group

Capital expenditures or divestitures related to the business segments are included in the respective corporate division

overview below.

Management structure

The Management Board has structured the Group as a matrix organization, comprising business segments and

infrastructure functions operating in legal entities and branches across geographic locations.

The Management Board is responsible for the management of the company in accordance with the law, the Articles of

Association and the Terms of Reference for the Management Board with the objective of creating sustainable value in

the interests of the company. It considers the interests of shareholders, employees and other company-related

stakeholders. The Management Board manages Deutsche Bank Group in accordance with uniform guidelines; it exercises

general control over all entities and branches.

The Management Board decides on all matters prescribed by law and the Articles of Association and ensures compliance

with the legal requirements and internal guidelines (compliance) and also takes the necessary measures to ensure that

adequate internal guidelines are developed and implemented. The Management Board's responsibilities include the

bank’s strategic management and direction, the allocation of resources, financial accounting and reporting, control and

risk management, as well as corporate control and a properly functioning business organization. The members of the

Management Board are collectively responsible for managing the bank’s business.

The allocation of functional responsibilities to the individual members of the Management Board is described in its

Business Allocation Plan, which sets the framework for the delegation of responsibilities to senior management below

the Management Board. The Management Board endorses individual accountability of senior position holders as opposed

to joint decision-taking in committees. At the same time, the Management Board recognizes the importance of having

comprehensive and robust information across all businesses in order to take well informed decisions. Governance fora

are established across the bank with the purpose of providing the necessary information to support the accountable

individuals in their decision-making process.

Corporate Bank

Corporate division overview

Corporate Bank is primarily focused on serving corporate clients, including the German “Mittelstand”, larger and smaller

sized commercial and business banking clients in Germany as well as multinational companies. The division also provides

financial institutions with certain transaction banking services. Corporate Bank reports revenues based on three client

categories: Corporate Treasury Services, Institutional Client Services and Business Banking.

There have been no significant capital expenditures or divestitures since January 1, 2023.

Products and services

Corporate Bank is a global provider of cash management, lending, trade finance, trust and securities services, and risk

management solutions. Cash management services include integrated payments and FX solutions. Trade finance and

lending offering spans from documentary and guarantee business to structured trade finance and lending. Trust and

securities services cover depository receipts, corporate trust, document custody and securities services. Focusing on the

finance departments of corporate and commercial clients and financial institutions in Germany and across the globe, its

holistic expertise and global network allow the bank to offer integrated solutions.

In addition to Corporate Bank’s product suite, coverage teams provide clients with access to the expertise of Investment

Bank.

Distribution channels and marketing

The corporate coverage function of Corporate Bank focuses on international mid and large corporate clients and is

organized into three units: Global Coverage, MidCorps Coverage and Risk Management Solutions. Coverage includes

multi-product generalists covering headquarter level and subsidiaries via global, regional and local coverage teams for

multinational companies. MidCorps Coverage includes multi-product generalists with a special focus on medium sized

enterprises. Risk Management Solutions includes Foreign Exchange, Emerging Markets and Rates product specialists.

This unit is managed regionally in Asia Pacific, Middle East & Africa, Americas and Europe to ensure close connectivity to

clients.


Deutsche Bank	Operating and financial review
Annual Report 2025	Deutsche Bank Group

Corporate clients are served out of all three of the Corporate Bank’s client categories. Corporate Treasury Services

covers mid and large corporate clients across two brands, Deutsche Bank and Postbank, and offers the whole range of

solutions across cash, trade financing, lending and risk management for the corporate treasurer. Institutional Client

Services comprises of Cash Management for institutional clients and Trust and Securities Services. Business Banking

covers small corporates and entrepreneur clients and offers a largely standardized product suite and selected

contextual-banking partner offerings (e.g., accounting solutions).

Investment Bank

Corporate division overview

Investment Bank combines Deutsche Bank’s Fixed Income & Currencies and Investment Banking & Capital Markets

(renamed in the fourth quarter of 2025 from “Origination & Advisory”) businesses, as well as Deutsche Bank Research and

Other. The Investment Bank focuses on its traditional strengths in these markets, bringing together wholesale banking

expertise across risk management, sales and trading, investment banking and infrastructure. This enables the Investment

Bank to align resourcing and capital across its client and product perimeter to effectively support the bank’s strategic

goals.

In April 2023, Deutsche Bank announced that it reached an agreement on an all-cash offer for the acquisition of Numis

Corporation Plc (“Numis”). On October 13, 2023, Deutsche Bank completed the transaction and acquired a 100% interest

in Numis for a cash purchase price of GBP 397 million. After the initial purchase price allocation, goodwill of € 233 million

related to the transaction was identified. Deutsche Bank assigned the identified goodwill to the Investment Bank cash

generating unit (CGU). Given the value of the Investment Bank CGU, the goodwill was considered impaired and written

off in the fourth quarter of 2023.

There have been no significant divestitures since January 1, 2023.

Products and services

Fixed Income & Currencies is split into two sub-categories: “Fixed Income & Currencies: Financing”, which provides

comprehensive, customized financing solutions across industries and asset classes; and “Fixed Income & Currencies:

Markets” (renamed in the fourth quarter of 2025 from “Fixed Income & Currencies: Ex-Financing”), which combines

institutional sales, trading and structuring expertise across Foreign Exchange, Rates, Emerging Markets and Credit

Trading. The Fixed Income & Currencies business operates globally and provides both corporate and institutional clients

liquidity, market making services and a range of specialized risk management solutions across a broad range of Fixed

Income & Currencies products. The application of technology and continued innovation of the transaction lifecycle

processes is enabling Deutsche Bank to increase automation/electronification in order to respond to client and

regulatory requirements.

Investment Banking & Capital Markets is responsible for the bank’s Mergers and Acquisitions business and Capital

Markets businesses across Debt and Equity. The IBCM franchise comprises regional and industry-focused product and

coverage teams, leveraging senior relationships to deliver a range of advisory and financial products and services to the

bank’s clients in partnership with the Fixed Income & Currencies franchise and other divisions of the bank.

Distribution channels and marketing

Coverage of the Investment Bank’s clients is provided principally by three groups working in conjunction with each other:

The Institutional Client Group, which houses the debt sales team, Investment Banking Coverage within Investment

Banking & Capital Markets and Risk Management Solutions in Corporate Bank, which covers capital markets and treasury

solutions. The close cooperation between these groups helps to create enhanced synergies leading to increased cross

selling of products/solutions to clients.


Deutsche Bank	Operating and financial review
Annual Report 2025	Deutsche Bank Group

Private Bank

Corporate division overview

Private Bank serves personal and private clients, wealthy individuals, entrepreneurs and families. The international

businesses also focus on commercial clients in selected markets. Private Bank is organized along the client sectors

Wealth Management (renamed in the fourth quarter of 2025 from Wealth Management & Private Banking) and Personal

Banking.

This client-centric approach reflects the aim to serve clients in a more targeted and effective way across the Private

Bank. Wealth Management combines the coverage of private banking, high-net-worth and ultra-high-net-worth clients,

as well as business clients in selected international markets. The client sector Personal Banking serves retail and affluent

customers as well as commercial banking clients in Italy and Spain (i.e., all small business clients and small sized

corporate clients that are not covered as part of the Wealth Management client sector).

There have been no significant capital expenditures or divestitures since January 1, 2023.

Products and services

Private Bank’s offers a range of payment and account services, credit and deposit products as well as investment advice.

These offerings include products which provide its clients access to Sustainable Finance lending and ESG investment

solutions based on specified classification and due diligence methodologies including ESG strategies, ratings and

exclusion criteria.

Personal Banking Germany pursues a differentiated, customer-focused approach with two strong and complementary

main brands: Deutsche Bank and Postbank. The Deutsche Bank brand provides private customers with banking and

financial products and services, including individualized advisory solutions. The Postbank brand focuses on offering retail

customers standard products and daily retail banking services supported by direct banking capabilities. In cooperation

with Deutsche Post DHL AG, the retail bank in Germany also offers postal and parcel services in selected Postbank

branches. In the international markets of Italy, Spain and India, the bank provides retail customers with daily banking

services as well as investment advisory solutions.

Wealth Management globally offers private banking, high-net-worth and ultra-high-net-worth clients bespoke and

sophisticated services in planning, managing and investing wealth, financing personal and business interests and

servicing institutional and corporate needs.

Distribution channels and marketing

Private Bank pursues an omni-channel approach, enabling customers to choose flexibly among different ways to access

services and products.

The distribution channels include branch networks, supported by advisory and customer call centers, self-service

terminals and digital offerings, such as online and mobile banking. Private Bank also collaborates with self-employed

financial advisors and other sales and cooperation partners, including Business-to-Business-to-Consumer partners in

Germany. For Wealth Management clients, the Private Bank deploys a client coverage team model with relationship and

investment managers supported by client service executives, who assist with wealth management services and open-

architecture products. In Germany, Deutsche Oppenheim Family Office AG provides family office services, discretionary

funds and advisory solutions.

Expanding digital capabilities remains a strong focus across the businesses, as client behavior continues to shift towards

digital channels. The Private Bank will continue optimizing its omni-channel mix to provide customers with the most

convenient access to products and services.


Deutsche Bank	Operating and financial review
Annual Report 2025	Deutsche Bank Group

Asset Management

Corporate division overview

With € 1,085 billion of assets under management as of December 31, 2025, the Asset Management division, which

operates under the brand DWS, aspires to be a leading asset manager. DWS serves a diverse client base of retail and

institutional investors worldwide, with a strong presence in the bank’s home market in Germany. These clients include

large government institutions, corporations and foundations as well as individual investors. As a regulated asset manager,

DWS acts as a fiduciary for its clients. Responsible investing has been an important part of DWS’s heritage for decades,

and DWS is committed to acting and investing in its clients’ best interest.

Deutsche Bank Group retains 79.5% ownership interest in DWS, and asset management remains a core business for the

Group. The shares of DWS are listed on the Frankfurt stock exchange.

There have been no significant capital expenditures or divestitures since January 1, 2023.

Products and services

DWS offers individuals and institutions access to investment capabilities across all major asset classes in Active, Passive

including Xtrackers range and Alternatives. In addition, DWS’s solution strategies are targeted to client needs that

cannot be addressed by traditional asset classes alone.

Distribution channels and marketing

DWS product offerings are managed by a global investment platform and distributed across EMEA, the Americas and

Asia Pacific through a single global distribution network. DWS also leverages third-party distribution channels, including

other divisions of Deutsche Bank Group.

Infrastructure

The Infrastructure functions perform control and service activities for the businesses, including tasks relating to Group-

wide, cross-divisional resource-planning, steering and control, as well as tasks relating to risk, liquidity and capital

management.

The Infrastructure functions are organized into the following areas of responsibility linked to a dedicated member of the

Management Board:

–Chief Executive Office

–Chief Financial Office

–Chief Risk Office

–Chief Operating Office

–Compliance & Anti-Financial Crime

–Chief Technology, Data and Innovation

Infrastructure also includes Communications & Corporate Social Responsibility, Chief Sustainability Office, Group Audit,

Group Governance, Legal, Global Procurement, Global Real Estate, Human Resources and Investor Relations.

Significant capital expenditures and divestitures

Information on each business segment’s significant capital expenditures and divestitures for the last three financial years

has been included in the above descriptions of the corporate divisions.

Since January 1, 2023, there have been no public takeover offers by third parties with respect to Deutsche Bank’s shares.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Results of operations

Consolidated results of operations

The following discussion and analysis should be read in conjunction with the consolidated financial statements.

Condensed consolidated statement of income


in € m.				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
(unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net interest income	15,673	15,161	16,122	513	3	(961)	(6)
Provision for credit losses	1,707	1,830	1,505	(123)	(7)	325	22
Net interest income after provision for credit losses	13,967	13,331	14,617	636	5	(1,286)	(9)
Net commission and fee income	10,891	10,372	9,206	519	5	1,166	13
Net gains (losses) on financial assets/liabilities at fair value through profit or loss	4,577	5,655	5,575	(1,078)	(19)	81	1
Net gains (losses) on financial assets at fair value through other comprehensive income	49	48	—	1	2	49	N/M
Net gains (losses) on financial assets at amortized cost	9	(11)	(96)	20	N/M	85	(89)
Net income (loss) from equity method investments	(6)	12	(38)	(18)	N/M	49	N/M
Other income (loss)	240	267	387	(27)	(10)	(120)	(31)
Total noninterest income	15,761	16,344	15,033	(583)	(4)	1,310	9
Memo: Total net revenues	31,434	31,504	31,155	(70)	0	349	1
Compensation and benefits	11,813	11,731	11,131	82	1	601	5
General and administrative expenses	8,860	11,243	10,112	(2,383)	(21)	1,131	11
Impairment of goodwill and other intangible assets	—	—	233	—	N/M	(233)	N/M
Restructuring activities	(15)	(3)	220	(12)	N/M	(223)	N/M
Total noninterest expenses	20,658	22,971	21,695	(2,313)	(10)	1,276	6
Profit (loss) before tax	9,069	6,703	7,955	2,366	35	(1,251)	(16)
Income tax expense (benefit)	2,255	2,223	1,503	33	1	719	48
Profit (loss)	6,814	4,481	6,452	2,333	52	(1,971)	(31)
Profit (loss) attributable to noncontrolling interests	208	139	119	69	50	19	16
Profit (loss) attributable to Deutsche Bank shareholders and additional equity components	6,606	4,342	6,332	2,264	52	(1,990)	(31)
Profit (loss) attributable to additional equity components	809	668	560	141	21	108	19
Profit (loss) attributable to Deutsche Bank shareholders	5,797	3,674	5,772	2,123	58	(2,098)	(36)

N/M – Not meaningful


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Net interest income


in € m.				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
(unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Total interest and similar income	44,440	48,996	43,546	(4,556)	(9)	5,449	13
Total interest expenses	28,766	33,835	27,424	(5,069)	(15)	6,411	23
Net interest income	15,673	15,161	16,122	513	3	(961)	(6)
Average interest- earning assets1	1,040,986	1,001,695	977,624	39,291	4	24,071	2
Average interest- bearing liabilities1	848,862	797,184	735,956	51,678	6	61,228	8
Gross interest yield2	4.26%	4.88%	4.44%	(0.62)ppt	(13)	0.44ppt	10
Gross interest rate paid3	3.38%	4.24%	3.71%	(0.86)ppt	(20)	0.53ppt	14
Net interest spread4	0.88%	0.65%	0.73%	0.23ppt	35	(0.08)ppt	(11)
Net interest margin5	1.51%	1.51%	1.65%	0.00ppt	—	(0.14)ppt	(8)

ppt – Percentage points

1Average balances for the year calculated based on month-end balances

2Gross interest yield as the average interest rate earned on average interest-earning assets

3Gross interest rate paid as the average interest rate paid on average interest-bearing liabilities

4Net interest spread as the difference between the average interest rate earned on average interest-earning assets and the average interest rate paid on average interest-

bearing liabilities

5Net interest margin as net interest income as a percentage of average interest-earning assets

2025

Net interest income was € 15.7 billion in 2025, an increase of € 513 million or 3% compared to 2024. Lower interest

income on assets, mainly driven by the lower interest rate environment, was more than offset by lower interest expenses

on deposits. Net interest income included no interest expenses under the Targeted Long-Term Refinancing Operation III

(TLTRO III) program in 2025, whereas 2024 included interest expenses of € 144 million under this program. Overall, the

bank's net interest margin was 1.5% in 2025 and 2024.

2024

Net interest income was € 15.2 billion in 2024, down 6% compared to 2023. The decrease of € 1.0 billion was driven by

higher interest paid on deposits and partly offset by higher interest revenues. Net interest income included interest

expenses of € 144 million under the Targeted Long-Term Refinancing Operation III (TLTRO III) program in 2024, whereas

2023 included interest expenses of € 741 million under this program. Overall, the bank's net interest margin was 1.5% in

2024, up from 1.7% in 2023.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Net gains (losses) on financial assets/liabilities at fair value through profit or loss


in € m.				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
(unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Trading income	4,751	5,563	5,506	(811)	(15)	56	1
Net gains (losses) on non-trading financial assets mandatory at fair value through profit or loss	160	(65)	217	225	N/M	(282)	N/M
Net gains (losses) on financial assets/liabilities designated at fair value through profit or loss	(334)	158	(148)	(492)	N/M	306	N/M
Total net gains (losses) on financial assets/liabilities at fair value through profit or loss	4,577	5,655	5,575	(1,078)	(19)	81	1

N/M – Not meaningful

2025

Net gains on financial assets/liabilities at fair value through profit or loss amounted to € 4.6 billion in 2025, compared to

€ 5.7 billion in 2024, reflecting a decrease of € 1.1 billion, or 19%. The decrease was primarily driven by negative impacts

from interest rate hedges in Corporate & Other as well as changes in the market valuation of derivatives in the

Investment Bank. In addition, changes in valuation adjustments mainly on guaranteed funds in Asset Management, which

had a corresponding offset in other income, contributed to the decrease. These effects were partly offset by increased

mark-to-market impacts from hedge activities in the Corporate Bank and Private Bank.

2024

Net gains on financial assets/liabilities at fair value through profit or loss amounted to € 5.7 billion in 2024, compared to

€ 5.6 billion in 2023, reflecting an increase of € 81 million, or 1%. This increase was primarily driven by valuation

adjustments primarily on guaranteed funds in Asset Management, which had a corresponding offset in other income.

Corporate & Other also recorded an increase mainly due to higher interest rate hedges. These gains are partly offset by

changes in the market valuation of derivatives in the Investment Bank.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Net interest income and net gains (losses) on financial assets/liabilities at fair value through

profit or loss

The bank’s trading and risk management activities include interest rate instruments and related derivatives. Under IFRS,

interest and similar income earned from trading instruments and financial instruments at fair value through profit or loss

(i.e., coupon and dividend income) and the costs of funding net trading positions are part of net interest income. The

bank’s trading activities can periodically shift income between net interest income and net gains (losses) on financial

assets/liabilities at fair value through profit or loss depending on a variety of factors, including risk management

strategies.

In order to provide a more business focused discussion, the following table presents net interest income and net gains

(losses) on financial assets/liabilities at fair value through profit or loss by business segments.


in € m.				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
(unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net interest income	15,673	15,161	16,122	513	3	(961)	(6)
Total net gains (losses) on financial assets/ liabilities at fair value through profit or loss	4,577	5,655	5,575	(1,078)	(19)	81	1
Total net interest income and net gains (losses) on financial assets/liabilities at fair value through profit or loss	20,250	20,816	21,697	(566)	(3)	(881)	(4)

Breakdown by business segments:1
Corporate Bank	4,669	4,946	5,193	(277)	(6)	(247)	(5)
Investment Bank	9,308	8,368	7,976	939	11	393	5
Private Bank	6,470	5,998	6,377	472	8	(379)	(6)
Asset Management	180	269	(11)	(89)	(33)	280	N/M
Corporate & Other	(376)	1,235	2,163	(1,611)	N/M	(928)	(43)
Total net interest income and net gains (losses) on financial assets/liabilities at fair value through profit or loss	20,250	20,816	21,697	(566)	(3)	(881)	(4)

N/M – Not meaningful

Prior years’ comparatives aligned to presentation in the current year

1This breakdown reflects net interest income and net gains (losses) on financial assets/liabilities at fair value through profit or loss; for a discussion of the business

segments’ total revenues by product please refer to Note 04 “Business Segments and related information” of this report

2025

Total net interest income and net gains (losses) on financial assets/liabilities at fair value through profit or loss amounted

to € 20.3 billion in 2025, compared to € 20.8 billion in 2024, reflecting a decrease of € 566 million, or 3%. The decrease

was driven by lower net gains on financial assets/liabilities at fair value through profit or loss. The overall decrease was

predominantly driven by Corporate & Other, which recorded lower results of € 1.6 billion compared to prior year,

primarily driven by negative impacts from interest rate hedges. In the Corporate Bank, net interest income and net gains

(losses) decreased by € 277 million, as interest rate hedging, growth in business volumes and favorable changes in the

market valuation of derivatives were more than offset by margin normalization and foreign exchange movements. Net

interest income and net gains (losses) in Asset Management decreased by € 89 million, reflecting valuation adjustments

primarily on guaranteed funds being offset in other income. These decreases were partially offset by the Private Bank, for

which net interest income and net gains (losses) increased by € 472 million, mainly due to higher deposit volumes and

increased mark-to-market impacts from hedge activities, which had a partial offsetting effect in other income. In the

Investment Bank, there was an increase of € 939 million, primarily driven by volume growth combined with stronger

lending income in FIC, specifically in Foreign Exchange and Emerging Markets.

2024

Total net interest income and net gains (losses) on financial assets/liabilities at fair value through profit or loss amounted

to € 20.8 billion in 2024, compared to € 21.7 billion in 2023, reflecting a decrease of € 881 million. This decrease is driven

by lower net interest income. The overall decrease was predominantly driven by Corporate & Other, which recorded

lower results of € 928 million compared to prior year, primarily due to lower net interest income. In the Private Bank, net

interest income and net gains (losses) decreased by € 379 million mainly due to higher funding costs and hedging

activities partially offset by growth in deposits and lending. In the Corporate Bank, net interest income and net gains

(losses) decreased by € 247 million primarily due to lower interest income and higher funding costs. These decreases

were partially offset by the Investment Bank, which reported an increase of € 393 million primarily driven by higher net

interest income partly offset by lower net gains on financial assets/liabilities mainly from a lower mark-to-market from

derivatives in FIC Markets. Net interest income and net gains (losses) in Asset Management increased by € 280 million,

reflecting a more favorable valuation adjustment primarily on guaranteed funds with offset in other income.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Remaining noninterest income


in € m.				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
(unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net commission and fee income	10,891	10,372	9,206	519	5	1,166	13
Net gains (losses) on financial assets at fair value through other comprehensive income	49	48	—	1	2	49	N/M
Net gains (losses) on financial assets at amortized cost	9	(11)	(96)	20	N/M	85	(89)
Net income (loss) from equity method investments	(6)	12	(38)	(18)	N/M	49	N/M
Other income (loss)	240	267	387	(27)	(10)	(120)	(31)
Total remaining noninterest income	11,184	10,688	9,458	495	5	1,230	13

1 includes:
Net commission and fees from fiduciary activities:
Commissions for administration	318	317	280	1	0	37	13
Commissions for assets under management	4,451	4,022	3,700	430	11	322	9
Commissions for other securities	494	433	441	61	14	(8)	(2)
Total	5,264	4,772	4,421	492	10	351	8
Net commissions, broker’s fees, mark-ups on securities underwriting and other securities activities:
Underwriting and advisory fees	1,771	1,669	1,105	102	6	564	51
Brokerage fees	455	455	366	(1)	0	89	24
Total	2,226	2,124	1,471	102	5	653	44
Net fees for other customer services	3,402	3,476	3,314	(74)	(2)	162	5
Total net commission and fee income	10,891	10,372	9,206	519	5	1,166	13

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

Net commission and fee income

2025

Net commission and fee income was € 10.9 billion in 2025, an increase of € 519 million or 5% compared to 2024. The

increase was mainly driven by higher performance fees and management fees from higher average assets under

management, supported by positive market developments and net inflows in Asset Management as well as a strong

contribution from Trade Finance & Lending, Institutional Cash Management and Trust and Agency Services businesses in

the Corporate Bank. In addition, higher fee revenues in private credit lending and financing on balance sheet investment

in the Investment Bank as well as higher investment revenues, mainly from discretionary portfolio mandates and partly

offset by higher cards and payments costs in Private Bank, contributed to the increase.

2024

Net commission and fee income was € 10.4 billion in 2024, an increase of € 1.2 billion or 13% compared to 2023. The

increase was driven by higher underwriting and advisory fees in Investment Banking & Capital Markets in the Investment

Bank and a particularly strong contribution from the Trade Finance business in the Corporate Bank. In addition, higher

management fees in Asset Management from higher assets under management contributed to the increase.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Net gains (losses) on financial assets at fair value through other comprehensive income

2025

Net gains (losses) on financial assets at fair value through other comprehensive income were € 49 million in 2025 and

€ 48 million in 2024, driven by a sale of bonds and securities from the strategic liquidity reserve.

2024

Net gains (losses) on financial assets at fair value through other comprehensive income were € 48 million in 2024 and

€ (0) million in 2023, mainly driven by a sale of bonds and securities from the strategic liquidity reserve.

Net gains (losses) on financial assets at amortized cost

2025

Net gains (losses) on financial assets at amortized cost were € 9 million in 2025 compared to € (11) million in 2024, driven

by derecognition of loans held at amortized cost.

2024

Net gains (losses) on financial assets at amortized cost were € (11) million in 2024 compared to € (96) million in 2023,

driven by sales primarily related to the hold-to-collect portfolio.

Net income (loss) from equity method investments

2025

Net income (loss) from equity method investments was € (6) million in 2025 compared to € 12 million in 2024, a decrease

of € 18 million, mainly driven by losses related to the deconsolidation of an investment, partially offset by net profit on

the investments due to upward valuations.

2024

Net income (loss) from equity method investments was € 12 million in 2024 compared to € (38) million in 2023, an

increase of € 49 million, mainly related to an upward valuation of the underlying loan assets in Harvest Fund

Management Company Limited.

Other income (loss)

2025

Other income (loss) was € 240 million in 2025 compared to € 267 million in 2024. The decrease was primarily related to

the market movements in the hedge portfolio compared to gains in 2024 with an offset due to valuation adjustments

mainly on guaranteed funds in Asset Management.

2024

Other income (loss) was € 267 million in 2024 compared to € 387 million in 2023. The decrease was primarily related to

the market movements in the hedge portfolio compared to gains in 2023.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Noninterest expenses


in € m.				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
(unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Compensation and benefits	11,813	11,731	11,131	82	1	601	5
General and administrative expenses¹	8,860	11,243	10,112	(2,383)	(21)	1,131	11
Impairment of goodwill and other intangible assets	—	—	233	—	N/M	(233)	N/M
Restructuring activities	(15)	(3)	220	(12)	N/M	(223)	N/M
Total noninterest expenses	20,658	22,971	21,695	(2,313)	(10)	1,276	6
N/M – Not meaningful

1 includes:
Information Technology	3,504	3,610	3,755	(106)	(3)	(145)	(4)
Occupancy, furniture and equipment expenses	1,463	1,624	1,478	(161)	(10)	147	10
Regulatory, tax & insurance2	862	1,028	1,399	(165)	(16)	(371)	(27)
Professional services	671	763	899	(92)	(12)	(136)	(15)
Banking Services and outsourced operations	891	964	964	(73)	(8)	1	0
Market Data and Research services	410	400	374	11	3	26	7
Travel expenses	152	153	143	—	0	10	7
Marketing expenses	195	149	203	46	31	(54)	(26)
Other expenses3	710	2,552	899	(1,842)	(72)	1,654	184
Total general and administrative expenses	8,860	11,243	10,112	(2,383)	(21)	1,131	11

2Includes bank levy of € 148 million in 2025, € 172 million in 2024 and € 528 million in 2023

3Includes litigation related expenses of € 179 million in 2025 and € 2,035 million in 2024 and € 311 million in 2023; see Note 27 “Provisions”, for more details on litigation

Compensation and benefits

2025

Compensation and benefits increased by € 82 million or 1% to € 11.8 billion in 2025 compared to € 11.7 billion in 2024.

The increase was driven mainly by higher performance-related compensation, partially offset by lower severance costs.

2024

Compensation and benefits increased by € 601 million or 5% to € 11.7 billion in 2024 compared to € 11.1 billion in 2023.

The increase was driven mainly by higher performance-related compensation, wage growth and increases in internal

workforce related to the bank’s targeted investments as part of the bank’s Global Hausbank strategy as well as higher

severance costs.

General and administrative expenses

2025

General and administrative expenses decreased by € 2.4 billion, or 21%, to € 8.9 billion in 2025 compared to € 11.2 billion

in 2024. The decrease was mainly driven by the non-recurrence of litigation charges related to the Postbank takeover

litigation matter and the Polish FX Mortgage matters as well as the reversal of the RusChemAlliance indemnification

asset which impacted the prior year. The decrease was further supported by lower bank levies, reduced depreciation on

right‑of‑use assets within lease expenses, and lower information technology costs, mainly reflecting reduced vendor and

IT platform expenses.

2024

General and administrative expenses increased by € 1.1 billion, or 11%, to € 11.2 billion in 2024 compared to

€ 10.1 billion in 2023. The increase was driven by an increase in other expenses, mainly due to increased litigation

charges related to the Postbank takeover litigation matter and the Polish FX Mortgage matters as well as the reversal of

the RusChemAlliance indemnification asset. This was partly offset by a decrease in bank levies of € 355 million in 2024,

lower fees for professional services and lower expenses in information technology, mainly relating to lower vendor costs

and lower IT platform costs.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Impairment of goodwill and other intangible assets

2025

No impairment of goodwill or other intangible assets was recognized in either 2025 or 2024.

2024

Impairment of goodwill and other intangible assets was € 0 million in 2024 compared to € 233 million in 2023 relating to

the impaired goodwill of Numis in the Investment Bank.

Restructuring

2025

Restructuring activities were a release of € 15 million in 2025 compared to a release of € 3 million in 2024. The

development in both periods was primarily driven by Private Bank executing its strategic initiatives.

2024

Restructuring activities were a release of € 3 million in 2024 compared to charges of € 220 million in 2023. The

development in both periods was primarily driven by Private Bank in the context of the execution of strategic initiatives.

Income tax expense

2025

Income tax expense was € 2.3 billion in 2025, compared to € 2.2 billion in the prior year. The effective tax rate in 2025 of

25% primarily benefited from the positive impact of the German Tax Reform and the geographical mix of income.

2024

Income tax expense was € 2.2 billion in 2024, compared to € 1.5 billion in the prior year. The effective tax rate in 2024 of

33% was mainly affected by litigation charges that are non-tax deductible.

Net profit (loss)

2025

Net profit in 2025 was € 6.8 billion, compared to € 4.5 billion in the prior year. The increase in net profit reflected a strong

operational performance in 2025 and the non-recurrence of specific litigation items which negatively impacted 2024.

2024

Net profit in 2024 was € 4.5 billion, compared to € 6.5 billion in the prior year. The decrease in net profit was primarily

driven by the aforementioned increase in litigation expenses and higher income tax expenses compared to 2023.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Segment results of operations

The following section is a discussion of the results of the business segments. Please refer to Note 04 “Business Segments

and related information” to the consolidated financial statements for information regarding:

–Changes in the format of the bank’s segment disclosure

–The framework of the bank’s management reporting systems

Deutsche Bank’s segment reporting follows the organizational structure as reflected in the Group’s internal management

reporting systems, which are the basis for assessing the financial performance of the business segments and for

allocating resources to them. The segmentation is based on the structure of the Group as of December 31, 2025. Prior

year’s comparatives were aligned to the presentation in the current year.


	2025
in € m. (unless stated otherwise)	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total Consolidated
Net revenues1	7,400	11,541	9,665	3,077	(249)	31,434
Provision for credit losses	194	827	578	(2)	108	1,707
Noninterest expenses
Compensation and benefits	1,632	2,894	2,795	952	3,541	11,813
General and administrative expenses	2,971	3,782	3,958	871	(2,721)	8,860
Impairment of goodwill and other intangible assets	—	—	—	—	—	—
Restructuring activities	—	—	(15)	—	—	(15)
Total noninterest expenses	4,603	6,675	6,738	1,823	819	20,658
Noncontrolling interests	—	16	—	272	(289)	—
Profit (loss) before tax	2,603	4,022	2,348	983	(887)	9,069

Assets (in € bn)2	323	736	316	11	54	1,440
Loans (gross of allowance for loan losses, in € bn)	120	115	247	—	3	484
Additions to non-current assets	14	6	65	20	1,938	2,042
Deposits (in € bn)	329	28	329	—	8	695
Average allocated shareholders' equity	12,199	23,967	14,763	5,2183	12,396	68,543

Risk-weighted assets (in € bn)	72	136	92	16	31	347
of which: operational risk RWA (in € bn)4	11	18	15	5	14	63
Leverage exposure (in € bn)	358	602	326	10	32	1,327
Employees (full-time equivalent)	27,320	20,592	35,443	5,425	1,099	89,879

Post-tax return on average shareholders’ equity5,6	14.1%	10.8%	10.1%	12.9%	N/M	8.5%
Post-tax return on average tangible shareholders’ equity5,6	15.3%	11.2%	10.5%	29.1%	N/M	9.4%
Cost/income ratio7	62.2%	57.8%	69.7%	59.3%	N/M	65.7%


1 includes:
Net interest income	4,567	4,681	6,169	24	231	15,673
Net income (loss) from equity method investments	4	(69)	4	52	3	(6)
2 includes:
Equity method investments	101	264	102	453	5	924

N/M – Not meaningful

3 Starting from the fourth quarter 2025, the equity allocation framework for Asset Management has been updated. For more information, please refer to section “Note 04 -

Business segments and related information” of this report

4 Starting from the first quarter of 2024, the allocation of operational risk RWA has changed. For more information, please refer to section “Note 4 - Business segments and

related information” of this report

5 Starting from the first quarter of 2024, the equity allocation framework has been updated. For more information, please refer to section “Note 04 - Business segments and

related information” of this report

6 Post-tax return on average shareholders’ equity and average tangible shareholders’ equity at the Group level reflect the reported effective tax rate for the Group, which

was 25% for the year ended December 31, 2025; for post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the segments, the

Group effective tax rate was adjusted to exclude the impact of permanent differences not attributed to the segments, so that the segment tax rates were 28% for the

year ended December 31, 2025; for further information, please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this report

7Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations


	2024
in € m. (unless stated otherwise)	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total Consolidated
Net revenues1	7,506	10,557	9,386	2,649	1,406	31,504
Provision for credit losses	347	549	851	(1)	83	1,830
Noninterest expenses
Compensation and benefits	1,611	2,690	2,938	919	3,574	11,731
General and administrative expenses	3,448	3,970	4,395	904	(1,474)	11,243
Impairment of goodwill and other intangible assets	—	—	—	—	—	—
Restructuring activities	(1)	—	(3)	—	—	(3)
Total noninterest expenses	5,058	6,660	7,331	1,823	2,100	22,971
Noncontrolling interests	—	5	—	194	(199)	—
Profit (loss) before tax	2,101	3,344	1,204	632	(577)	6,703

Assets (in € bn)2	280	756	324	11	21	1,391
Loans (gross of allowance for loan losses, in € bn)	117	110	257	—	5	490
Additions to non-current assets	12	3	160	30	1,886	2,091
Deposits (in € bn)	313	22	320	—	13	668
Average allocated shareholders' equity	11,681	23,631	13,995	5,329	11,717	66,353

Risk-weighted assets (in € bn)	78	130	97	18	34	357
of which: operational risk RWA (in € bn)3	11	15	14	5	13	58
Leverage exposure (in € bn)	339	593	336	10	38	1,316
Employees (full-time equivalent)	26,280	20,065	37,059	5,166	1,183	89,753

Post-tax return on average shareholders’ equity4,5	11.9%	9.1%	5.1%	8.0%	N/M	5.5%
Post-tax return on average tangible shareholders’ equity4,5	12.7%	9.4%	5.1%	18.0%	N/M	6.2%
Cost/income ratio6	67.4%	63.1%	78.1%	68.8%	N/M	72.9%


1 includes:
Net interest income	4,987	3,372	5,786	25	991	15,161
Net income (loss) from equity method investments	(1)	(46)	21	36	2	12
2 includes:
Equity method investments	90	379	102	451	6	1,028

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

3Starting from the first quarter of 2024, the allocation of operational risk RWA has changed. Prior periods have been updated accordingly. For more information, please

refer to section “Note 04 - Business segments and related information” of this report

4Starting from the first quarter of 2024, the equity allocation framework has been updated. Prior periods have been updated accordingly. For more information, please

refer to section “Note 04 - Business segments and related information” of this report

5The post-tax return on average shareholders’ equity and average tangible shareholders’ equity at the Group level reflects the reported effective tax rate for the Group,

which was 33% for the year ended December 31, 2024; for the post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the

segments, the Group effective tax rate was adjusted to exclude the impact of permanent differences not attributed to the segments, so that the segment tax rates were

28% for the year ended December 31, 2024; for further information, please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this

report

6 Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations


	2023
in € m. (unless stated otherwise)	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total Consolidated
Net revenues1	7,718	9,160	9,571	2,383	2,324	31,155
Provision for credit losses	266	431	783	(1)	26	1,505
Noninterest expenses
Compensation and benefits	1,539	2,534	2,808	891	3,358	11,131
General and administrative expenses	3,088	4,082	4,718	934	(2,710)	10,112
Impairment of goodwill and other intangible assets	—	233	—	—	—	233
Restructuring activities	(4)	(3)	228	—	(1)	220
Total noninterest expenses	4,623	6,846	7,755	1,825	647	21,695
Noncontrolling interests	—	3	—	163	(166)	—
Profit (loss) before tax	2,828	1,880	1,032	396	1,817	7,955

Assets (in € bn)2	264	658	331	10	54	1,317
Loans (gross of allowance for loan losses, in € bn)	117	101	261	—	6	485
Additions to non-current assets	13	89	90	73	1,853	2,118
Deposits (in € bn)	289	18	308	—	10	625
Average allocated shareholders' equity	11,280	22,953	13,681	5,103	10,132	63,149

Risk-weighted assets (in € bn)	69	140	86	15	40	350
of which: operational risk RWA (in € bn)3	6	22	8	3	19	57
Leverage exposure (in € bn)	307	546	339	10	39	1,240
Employees (full-time equivalent)	25,356	19,899	38,465	4,961	1,449	90,130

Post-tax return on average shareholders’ equity4,5	17.1%	4.9%	4.5%	5.2%	N/M	9.1%
Post-tax return on average tangible shareholders’ equity4,5	18.5%	5.1%	4.8%	12.2%	N/M	10.2%
Cost/income ratio6	59.9%	74.7%	81.0%	76.6%	N/M	69.6%


1 includes:
Net interest income	5,241	2,887	6,156	(124)	1,963	16,122
Net income (loss) from equity method investments	(6)	(70)	(5)	42	2	(38)
2 includes:
Equity method investments	91	413	84	420	5	1,013

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

3Starting from the first quarter of 2024, the allocation of operational risk RWA has changed. Prior periods have been updated accordingly. For more information, please

refer to section “Note 04 - Business segments and related information” of this report

4Starting from the first quarter of 2024, the equity allocation framework has been updated. Prior periods have been updated accordingly. For more information, please

refer to section “Note 04 - Business segments and related information” of this report

5The post-tax return on average shareholders’ equity and average tangible shareholders’ equity at the Group level reflects the reported effective tax rate for the Group,

which was 19% for the year ended December 31, 2023; for the post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the

segments, the Group effective tax rate was adjusted to exclude the impact of permanent differences not attributed to the segments, so that the segment tax rates were

28% for the year ended December 31, 2023; for further information, please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this

report

6Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Corporate Bank


				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
in € m. (unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net revenues
Corporate Treasury Services1	4,220	4,197	4,381	23	1	(184)	(4)
Institutional Client Services	1,917	1,956	1,895	(39)	(2)	62	3
Business Banking1	1,263	1,352	1,442	(90)	(7)	(90)	(6)
Total net revenues	7,400	7,506	7,718	(106)	(1)	(212)	(3)
Of which:
Net interest income2	4,567	4,987	5,241	(419)	(8)	(254)	(5)
Net commission and fee income2	2,704	2,577	2,460	127	5	118	5
Remaining income2	129	(58)	18	186	N/M	(75)	N/M
Provision for credit losses	194	347	266	(153)	(44)	81	30
Noninterest expenses
Compensation and benefits	1,632	1,611	1,539	21	1	72	5
General and administrative expenses	2,971	3,448	3,088	(477)	(14)	359	12
Impairment of goodwill and other intangible assets	—	—	—	—	N/M	—	N/M
Restructuring activities	—	(1)	(4)	1	N/M	4	N/M
Total noninterest expenses	4,603	5,058	4,623	(455)	(9)	435	9
Noncontrolling interests	—	—	—	—	N/M	—	N/M
Profit (loss) before tax	2,603	2,101	2,828	502	24	(728)	(26)

Employees (front office, full-time equivalent)3	8,420	7,959	7,670	461	6	289	4
Employees (business-aligned operations, full- time equivalent)3	8,181	8,171	8,017	10	0	154	2
Employees (allocated central infrastructure, full-time equivalent)3	10,719	10,150	9,669	569	6	481	5
Total employees (full-time equivalent)3	27,320	26,280	25,356	1,040	4	924	4
Total assets (in € bn)3,4	323	280	264	44	16	16	6
Risk-weighted assets (in € bn)3	72	78	69	(6)	(8)	9	13
of which: operational risk RWA (in € bn)3,5	11	11	6	—	1	5	94
Leverage exposure (in € bn)3	358	339	307	18	5	33	11
Deposits (in € bn)3	329	313	289	17	5	23	8
Loans (gross of allowance for loan losses, in € bn)3	120	117	117	3	2	—	0
Cost/income ratio6	62.2%	67.4%	59.9%	(5.2)ppt	N/M	7.5ppt	N/M
Post-tax return on average shareholders' equity7,8	14.1%	11.9%	17.1%	2.2ppt	N/M	(5.2)ppt	N/M
Post-tax return on average tangible shareholders’ equity7,8	15.3%	12.7%	18.5%	2.6ppt	N/M	(5.8)ppt	N/M

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

1Starting from the first quarter of 2025, certain smaller non-complex clients previously recorded under Corporate Treasury Services are reported under Business Banking.

The reclassification follows a review and realignment of client coverage to provide clients with the most effective coverage within the Corporate Bank. Prior year’s

comparatives are presented in the current reporting structure

2Starting from the first quarter of 2025, the representation of revenue sharing between Corporate Bank and Investment Bank has changed. For more information, please

refer to section “Note 04 - Business segments and related information” of this report

3 As of year-end

4Segment assets are presented on a consolidated basis, i.e., the amounts do not include intersegment balances

5Starting from the first quarter of 2024, the allocation of operational risk RWA has changed. For more information, please refer to section “Note 04 - Business segments

and related information” of this report

6Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income

7Starting from the first quarter of 2024, the equity allocation framework has been updated. For more information, please refer to section “Note 04 - Business segments and

related information” of this report

8For the post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the segments, the Group effective tax rate was adjusted to exclude

the impact of permanent differences not attributed to the segments, so that the segment tax rates were 28% for the years 2025, 2024 and 2023; for further information,

please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this report


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

2025

Profit before tax was € 2.6 billion in 2025, up by 24% from 2024, primarily driven by lower noninterest expenses and

lower provision for credit losses, partly offset by lower revenues. Post-tax return on average shareholders’ equity was

14.1%, up from 11.9% in the prior year, and post-tax return on average tangible shareholders’ equity was 15.3%, up from

12.7% in the prior year. The cost/income ratio was 62%, down from 67% in 2024.

Net revenues were € 7.4 billion, 1% lower year on year as impacts from interest hedging, growth in business volumes and

net commission and fee income was more than offset by margin normalization and foreign exchange movements.

Corporate Treasury Services revenues were € 4.2 billion, up 1% year on year, as positive effects from interest hedging,

higher deposit volumes and growth in net commission and fee income were offset by lower deposit margins. Institutional

Client Services revenues declined by 2% year on year to € 1.9 billion, mainly driven by lower deposit volume in

Institutional Cash Management. Business Banking revenues were € 1.3 billion, down 7% year on year, driven by the

normalization of deposit margins, partly offset by growth in net commission and fee income.

Provision for credit losses was € 194 million in 2025, or 17 basis points of average loans, down from € 347 million in the

last year, driven by lower Stage 3 provisions and a smaller decline in Stage 1 and 2 mainly reflecting model releases.

Noninterest expenses were € 4.6 billion, down 9% driven by lower nonoperating expenses, while adjusted costs remained

flat year on year at € 4.6 billion.

2024

Profit before tax was € 2.1 billion in 2024, down by € 2.8 billion from 2023, primarily driven by higher noninterest

expenses. Post-tax return on average shareholders’ equity was 11.9%, down from 17.1% in the prior year, and post-tax

return on average tangible shareholders’ equity was 12.7%, down from 18.5% in the prior year. The cost/income ratio was

67%, up from 60% in 2023.

Net revenues were € 7.5 billion, 3% lower year on year as the normalization of deposit margins was mostly offset by

higher deposit volumes and growth in net commission and fee income. Corporate Treasury Services revenues were € 4.2

billion, down 4% year on year, driven by lower deposit margins mostly offset by higher deposit volumes and growth in net

commission and fee income. Institutional Client Services revenues rose 3% year on year to € 2.0 billion, driven by growth

in Securities Services and Trust and Agency Services. Business Banking revenues were € 1.4 billion, down 6% year on year,

driven by the normalization of deposit margins.

Provision for credit losses was € 347 million in 2024, or 30 basis points of average loans, up from € 266 million, in the last

year, mainly driven by certain larger corporate credit events.

Noninterest expenses were € 5.1 billion, up 9% year on year, driven by a litigation item, while adjusted costs rose 2% year

on year to € 4.6 billion driven by higher internal service cost allocations and front office investments.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Investment Bank


				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
in € m. (unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net revenues
Fixed Income & Currencies (FIC)	9,610	8,518	7,897	1,092	13	621	8
Fixed Income & Currencies: Financing	3,561	3,183	2,909	377	12	275	9
Fixed Income & Currencies: Markets1	6,050	5,335	4,989	715	13	346	7
Investment Banking & Capital Markets2	1,861	1,990	1,238	(129)	(6)	752	61
Debt Origination	1,100	1,274	837	(174)	(14)	437	52
Equity Origination	225	186	102	39	21	83	82
Advisory	536	531	299	5	1	232	77
Research and Other3	70	49	24	20	41	25	102
Total net revenues4	11,541	10,557	9,160	984	9	1,398	15
Provision for credit losses	827	549	431	278	51	119	28
Noninterest expenses
Compensation and benefits	2,894	2,690	2,534	204	8	156	6
General and administrative expenses	3,782	3,970	4,082	(188)	(5)	(112)	(3)
Impairment of goodwill and other intangible assets	—	—	233	—	N/M	(233)	N/M
Restructuring activities	—	—	(3)	—	38	3	N/M
Total noninterest expenses	6,675	6,660	6,846	15	0	(186)	(3)
Noncontrolling interests	16	5	3	12	N/M	2	52
Profit (loss) before tax	4,022	3,344	1,880	679	20	1,463	78

Employees (front office, full-time equivalent)5	5,037	4,888	4,856	149	3	32	1
Employees (business-aligned operations, full- time equivalent)5	3,151	3,168	3,146	(17)	(1)	22	1
Employees (allocated central infrastructure, full-time equivalent)5	12,404	12,009	11,898	395	3	111	1
Total employees (full-time equivalent)5	20,592	20,065	19,899	527	3	166	1
Total assets (in € bn)5,6	736	756	658	(20)	(3)	98	15
Risk-weighted assets (in € bn)5	136	130	140	7	5	(10)	(7)
of which: operational risk RWA (in € bn)5,7	18	15	22	3	21	(7)	(32)
Leverage exposure (in € bn)5	602	593	546	10	2	46	8
Deposits (in € bn)5	28	22	18	6	26	4	23
Loans (gross of allowance for loan losses, in € bn)5	115	110	101	5	5	9	9
Cost/income ratio8	57.8%	63.1%	74.7%	(5.2)ppt	N/M	(11.7)ppt	N/M
Post-tax return on average shareholders’ equity9,10	10.8%	9.1%	4.9%	1.7ppt	N/M	4.2ppt	N/M
Post-tax return on average tangible shareholders’ equity9,10	11.2%	9.4%	5.1%	1.8ppt	N/M	4.3ppt	N/M

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

1Starting from the fourth quarter of 2025, the additional sub-category “Fixed Income & Currencies: Ex Financing“ within Fixed Income & Currencies (FIC) was renamed to

“Fixed Income & Currencies: Markets“

2 Starting from the fourth quarter of 2025, Deutsche Bank renamed “Origination & Advisory” within the Investment Bank to “Investment Banking & Capital Markets”

3Historically, certain bank funding charges that were allocated to the Investment Bank but not directly attributable to specific balance sheet positions were reported

within “Research and Other”. Beginning the third quarter of 2025 these charges have been allocated to underlying businesses based on an agreed allocation key in order

to support ongoing refinement of business level reporting. Prior year’s comparatives are aligned to presentation in the current year

4Starting from the first quarter of 2025, the representation of revenue sharing between Corporate Bank and Investment Bank has changed. For more information, please

refer to section “Note 04 - Business segments and related information” of this report

5As of year-end

6Segment assets are presented on a consolidated basis, i.e., the amounts do not include intersegment balances

7 Starting from the first quarter of 2024, the allocation of operational risk RWA has changed. For more information, please refer to section “Note 04 - Business segments

and related information” of this report

8Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income

9 Starting from the first quarter of 2024, the equity allocation framework has been updated. For more information, please refer to section “Note 04 - Business segments and

related information” of this report

7For the post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the segments, the Group effective tax rate was adjusted to exclude

the impact of permanent differences not attributed to the segments, so that the segment tax rates were 28% for the years 2025, 2024 and 2023; for further information,

please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this report


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

2025

Profit before tax was € 4.0 billion in 2025, up by 20% year on year, with revenue growth of € 1.1 billion driven by Fixed

Income & Currencies (FIC), with Investment Banking & Capital Markets (IBCM) slightly lower. Post-tax return on average

shareholders’ equity was 10.8%, up from 9.1% in 2024, and post-tax return on average tangible shareholders’ equity was

11.2%, up from 9.4%. The cost/income ratio was 58%, down from 63% in 2024.

Net revenues were € 11.5 billion, 9% higher year on year reflecting strength in FIC. FIC Markets revenues were

€ 6.0 billion, an increase of 13% year on year, benefiting from strength across products, but primarily Rates and Foreign

Exchange driven by heightened client activity and strong risk management in volatile markets. FIC Financing revenues

grew 12% to € 3.6 billion, reflecting targeted balance sheet investment. IBCM revenues were down (6)% year on year to

€ 1.9 billion driven by Debt Origination, which included the impact of a loss on a specific loan in Leveraged Debt Capital

Markets in the first quarter of 2025, with Equity Origination and Advisory improving year on year.

Provision for credit losses was € 827 million in the year, or 74 basis points of average loans, and significantly increased

from € 549 million in the prior year, reflecting increased Stage 1 and 2 provisions and a smaller increase in Stage 3, all

impacting the commercial real estate (CRE) portfolio.

Noninterest expenses and adjusted costs were essentially flat at € 6.7 billion and € 6.6 billion compared to 2024, with the

cost of strategic growth initiatives and inflation offset by lower nonoperating costs and infrastructure allocations.

2024

Profit before tax was € 3.3 billion in 2024, up by 78% year on year, with growth across both Fixed Income & Currencies

(FIC) and Investment Banking & Capital Markets revenues, combined with the non-repeat of a goodwill impairment in

2023, partially offset by higher provision for credit losses in 2024. Post-tax return on average shareholders’ equity was

9.1%, up from 4.9% in 2023, and post-tax return on average tangible shareholders’ equity was 9.4%, up from 5.1% The

cost/income ratio was 63%, down from 75% in 2023.

Net revenues were € 10.6 billion, 15% higher year on year reflecting market share gains in a growing Investment Banking

& Capital Markets fee pool, as well as strength in FIC. FIC Markets revenues were € 5.3 billion, an increase of 7% year on

year benefiting from strength in Credit Trading and increased client engagement more broadly. FIC Financing revenues

grew 9% to € 3.2 billion, driven by both increased net interest income and higher commission and fees. Investment

Banking & Capital Markets revenues rose 61% year on year to € 2.0 billion primary due to increasing market share by

around 50 basis points, combined with industry fee pool growth during the year (source: Dealogic).Provision for credit

losses was € 549 million in the year, or 52 basis points of average loans, and significantly higher year on year, reflecting

increased Stage 3 provisions, primarily in CRE.

Noninterest expenses were € 6.7 billion in 2024 down 3% year on year, mainly reflecting the non-repeat of a goodwill

impairment in 2023. Adjusted costs were essentially flat at € 6.4 billion, with the full year impact of strategic investments

in the second half of 2023 and adverse FX impact largely offset by a reduction in bank levies.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Private Bank


				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
in € m. (unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net revenues:
Personal Banking1	5,284	5,253	5,442	31	1	(190)	(3)
Wealth Management1,2	4,381	4,133	4,128	248	6	5	0
Total net revenues	9,665	9,386	9,571	279	3	(185)	(2)
of which:
Net interest income	6,169	5,786	6,156	383	7	(370)	(6)
Net commission and fee income	2,999	2,956	2,852	43	1	104	4
Remaining income	497	643	563	(146)	(23)	80	14
Provision for credit losses	578	851	783	(273)	(32)	68	9
Noninterest expenses:
Compensation and benefits	2,795	2,938	2,808	(143)	(5)	130	5
General and administrative expenses	3,958	4,395	4,718	(438)	(10)	(323)	(7)
Impairment of goodwill and other intangible assets	—	—	—	—	N/M	—	N/M
Restructuring activities	(15)	(3)	228	(12)	N/M	(231)	N/M
Total noninterest expenses	6,738	7,331	7,755	(593)	(8)	(424)	(5)
Noncontrolling interests	—	—	—	—	45	—	(45)
Profit (loss) before tax	2,348	1,204	1,032	1,144	95	172	17

Employees (front office, full-time equivalent)3	15,840	17,053	18,483	(1,213)	(7)	(1,430)	(8)
Employees (business-aligned operations, full- time equivalent)3	7,497	7,842	7,780	(345)	(4)	62	1
Employees (allocated central infrastructure, full- time equivalent)3	12,106	12,164	12,202	(58)	N/M	(38)	0
Total employees (full-time equivalent)3	35,443	37,059	38,465	(1,616)	(4)	(1,406)	(4)
Total assets (in € bn)3,4	316	324	331	(8)	(2)	(7)	(2)
Risk-weighted assets (in € bn)3	92	97	86	(5)	(5)	11	13
of which: operational risk RWA (in € bn)3,5	15	14	8	—	2	7	89
Leverage exposure (in € bn)3	326	336	339	(10)	(3)	(2)	(1)
Deposits (in € bn)2	329	320	308	9	3	13	4
Loans (gross of allowance for loan losses, in € bn)3	247	257	261	(11)	(4)	(4)	(1)
Assets under Management (in € bn)3,6	685	634	579	51	8	55	9
Net flows (in € bn)	27	29	23	(2)	(7)	6	26
Cost/income ratio7	69.7%	78.1%	81.0%	(8.4)ppt	N/M	(2.9)ppt	N/M
Post-tax return on average shareholders' equity8,9	10.1%	5.1%	4.5%	5.1ppt	N/M	0.5ppt	N/M
Post-tax return on average tangible shareholders’ equity8,9	10.5%	5.1%	4.8%	5.4ppt	N/M	0.3ppt	N/M

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

1 Starting from the first quarter of 2025, a portion of certain European Personal Banking clients have been transferred to the Wealth Management segment. This change

reflects adjustments in the Private Bank client's classification to better align financial reporting with the underlying business structure. Prior year’s comparatives are

presented in the current reporting structure

2Starting from the fourth quarter of 2025, the Private Bank renamed “Wealth Management & Private Banking” to “Wealth Management”

3As of year-end

4Segment assets are presented on a consolidated basis, i.e., the amounts do not include intersegment balances

5Starting from the first quarter of 2024, the allocation of operational risk RWA has changed. For more information, please refer to section “Note 04 - Business segments

and related information” of this report

6Assets under Management include assets held on behalf of customers for investment purposes and/or client assets that are advised or managed by Deutsche Bank. They

are managed on a discretionary or advisory basis or are deposited with the bank. Deposits are considered Assets under Management if they serve investment purposes. In

Personal Banking, this includes Term deposits and Savings deposits. In Wealth Management (excl. Business Banking), it is assumed that all customer deposits are held

with the bank primarily for investment purposes and accordingly are classified as Assets under Management. In instances in which the Private Bank distributes investment

products qualifying as Assets under Management which are managed by DWS, these assets are reported as Assets under Management for Private Bank and for Asset

Management (DWS) because they are two distinct, independent qualifying services

7Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income

8Starting from the first quarter of 2024, the equity allocation framework has been updated. For more information, please refer to section “Note 04 - Business segments and

related information” of this report

9For the post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the segments, the Group effective tax rate was adjusted to exclude

the impact of permanent differences not attributed to the segments, so that the segment tax rates were 28% for the years 2025, 2024 and 2023; for further information,

please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this report


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

2025

Private Bank reported a profit before tax of € 2.3 billion in 2025, up € 1.1 billion or 95%, year on year mainly reflecting

lower noninterest expenses as well as significantly lower credit loss provisions. Post-tax return on average shareholders’

equity was 10.1% compared to 5.1% in 2024, while post-tax return on average tangible shareholders’ equity increased to

10.5%. The cost/income ratio of 70% improved compared to 78% in the prior year.

Net revenues were € 9.7 billion in 2025, up 3% year on year, driven by higher deposit and investment product revenues,

which were partially offset by lower revenues from other banking services. Lending revenues remained essentially flat.

In Personal Banking, net revenues were essentially flat year on year at € 5.3 billion in 2025, reflecting higher deposit and

investment product revenues. These developments were offset by slightly lower revenues from lending in line with the

strategic decision to focus on value-accretive products as well as lower revenues from other banking services in 2025.

In Wealth Management, net revenues grew by 6% year on year to € 4.4 billion in 2025, reflecting higher investment

product, as well as deposit revenues. Prior year deposit revenues included certain hedging costs.

Provision for credit losses was € 578 million, or 23 basis points of average loans, compared to 33 basis points of average

loans in the prior year. This development mainly reflects benefits from model updates this year, while the prior year was

impacted by continued elevated transitory effects from Postbank integration.

Noninterest expenses were € 6.7 billion in 2025, 8% lower year on year. Adjusted costs decreased by 5% to € 6.6 billion,

and nonoperating costs were significantly lower. Positive impacts from transformation initiatives including workforce

reductions and the closure of 126 branches in 2025, as well as significantly lower deposit protection costs, were partly

offset by inflationary impacts.

Assets under Management were € 685 billion at year end 2025, € 51 billion higher year on year, including € 27 billion of

net inflows and € 30 billion positive market movements, partially offset by € 16 billion of negative foreign exchange

movements.

2024

Private Bank reported a profit before tax of € 1.2 billion in 2024, up € 172 million or 17% year on year reflecting slightly

lower noninterest expenses. Post-tax return on average shareholders’ equity increased to 5.1% compared to 4.5% in 2023

while post-tax return on average tangible shareholders’ equity improved to 5.1% from 4.8%. The cost/income ratio of

78%, improved from 81% in the prior year.

Net revenues were € 9.4 billion in 2024, down 2% year on year. Net interest income declined by 6% in an environment of

normalizing interest rates; this was partly offset by growth in investment products, reflecting the Private Bank’s strategy

of growing noninterest income.

In Personal Banking, net revenues were down 3% year on year to € 5.3 billion in 2024, reflecting continued higher funding

costs, including the impact from minimum reserves and higher Group neutral central treasury allocation to the segment.

These impacts were partly offset by growth in deposit revenues during 2024.

In Wealth Management, net revenues remained essentially flat at € 4.1 billion in 2024. Higher investment product

revenues, as well as slightly higher lending revenues, were offset by lower deposit revenues including certain hedging

costs to the business.

Provision for credit losses was € 851 million compared to € 783 million, or 33 basis points of average loans, compared to

30 basis points of average loans in the prior year. The increase mainly reflected the continued elevated transitory effects

from Postbank integration. Overall, the quality of the segment’s portfolios remains very solid.

Noninterest expenses were € 7.3 billion in 2024, down 5% year on year including significantly lower restructuring

cost and the non-recurrence of provisions for individual litigation cases. The improvement in adjusted costs by 4% to

€ 7.0 billion in 2024 reflected normalized investment spend and positive impacts from transformation initiatives

including workforce reductions and the closure of 125 branches in 2024, as well as lower regulatory costs, partially

offset by inflation impacts.

Assets under Management were € 634.2 billion at year end 2024, up € 54.8 billion in the year. The increase was mainly

supported by net inflows of € 28.9 billion, as well as € 20.0 billion positive market movements, and € 9.0 billion of positive

foreign exchange movements.


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Asset Management


				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
in € m. (unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net revenues
Management fees	2,597	2,479	2,314	119	5	164	7
Performance and transaction fees	318	148	128	170	115	20	16
Other	162	23	(59)	139	N/M	82	N/M
Total net revenues	3,077	2,649	2,383	427	16	267	11
Provision for credit losses	(2)	(1)	(1)	(1)	172	—	(23)
Noninterest expenses
Compensation and benefits	952	919	891	33	4	28	3
General and administrative expenses	871	904	934	(34)	(4)	(29)	(3)
Impairment of goodwill and other intangible assets	—	—	—	—	N/M	—	N/M
Restructuring activities	—	—	—	—	N/M	—	N/M
Total noninterest expenses	1,823	1,823	1,825	—	0	(1)	0
Noncontrolling interests	272	194	163	78	40	32	20
Profit (loss) before tax	983	632	396	350	55	236	60

Employees (front office, full-time equivalent)1	2,103	2,065	2,044	38	2	21	1
Employees (business-aligned operations, full- time equivalent)1	2,732	2,510	2,343	222	9	167	7
Employees (allocated central infrastructure, full-time equivalent)1	590	591	574	(1)	0	17	3
Total employees (full-time equivalent)1	5,425	5,166	4,961	259	5	205	4
Total assets (in € bn)1,2	11	11	10	—	2	—	2
Risk-weighted assets (in € bn)1	16	18	15	(3)	(16)	3	22
of which: operational risk RWA (in € bn)1,3	5	5	3	1	13	1	35
Leverage exposure (in € bn)1	10	10	10	—	1	—	4
Assets under Management (in € bn)1,4	1,085	1,012	896	73	7	115	13
Net flows (in € bn)	51	26	28	25	98	(3)	(9)
Cost/income ratio5	59.26%	68.81%	76.57%	(9.6)ppt	N/M	(7.8)ppt	N/M
Post-tax return on average shareholders' equity6,7	12.93%	8.03%	5.16%	4.9ppt	N/M	2.9ppt	N/M
Post-tax return on average tangible shareholders’ equity6,7	29.1%8	18.0%	12.2%	11.0ppt	N/M	5.8ppt	N/M

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

1As of year-end

2Segment assets are presented on a consolidated basis, i.e., the amounts do not include intersegment balances

3Starting from the first quarter of 2024 the allocation of operational risk RWA has changed. For more information, please refer to section “Note 04 - Business segments

and related information” of this report

4Assets under Management (AuM) means assets (i) the segment manages on a discretionary or non-discretionary advisory basis; including where it is the management

company and portfolio management is outsourced to a third party; and (ii) a third party holds or manages and on which the segment provides, on the basis of contract,

advice of an ongoing nature including regular or periodic assessment, monitoring and/or review. AuM represent both collective investments (including mutual funds and

exchange-traded funds) and separate client mandates. AuM are measured at current market value based on the local regulatory rules for asset managers at each

reporting date, which might differ from the fair value rules applicable under IFRS. Measurable levels are available daily for most retail products but may only update

monthly, quarterly or even yearly for some products. While AuM do not include the segment’s investments accounted for under equity method, they do include seed

capital and any committed capital on which the segment earns management fees. In instances in which Private Bank distributes investment products qualifying as Assets

under Management which are managed by DWS, these assets are reported as Assets under Management for Private Bank and for Asset Management (DWS) because they

are two distinct, independent qualifying services

5Noninterest expenses as a percentage of total net revenues, which are defined as net interest income before provision for credit losses plus noninterest income

6Starting from the first quarter of 2024, the equity allocation framework has been updated. For more information, please refer to section “Note 04 - Business segments and

related information” of this report

7For the post-tax return on average shareholders’ equity and average tangible shareholders’ equity of the segments, the Group effective tax rate was adjusted to exclude

the impact of permanent differences not attributed to the segments, so that the segment tax rates were 28% for the years 2025, 2024 and 2023; for further information,

please refer to “Supplementary Information (Unaudited): Non-GAAP Financial Measures” of this report

8 Starting from the fourth quarter 2025 the equity allocation framework for Asset Management has been updated. For more information, please refer to section “Note 04 -

Business segments and related information” of this report


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

2025

Profit before tax was € 983 million, up 55% from 2024, mainly driven by higher revenues and stable noninterest expenses.

Post-tax return on average shareholders’ equity was 12.9%, up from 8.0% in the prior year. Post-tax return on average

tangible shareholders’ equity was 29.1%, up from 18.0% in the prior year. The cost/income ratio was 59%, down from 69%

in 2024.

Net revenues in 2025 were € 3.1 billion, up 16% compared to 2024. Management fees were € 2.6 billion, up 5% year on

year, driven by increasing average assets under management predominately in Passive products. Performance and

transaction fees increased significantly by 115% to € 318 million, driven primarily by higher performance fees from

Alternative investments, in particular infrastructure strategies. Other revenues increased by € 139 million to € 162 million

driven by favorable valuations of guaranteed products and higher investment income.

Noninterest expenses were € 1.8 billion in 2025, essentially flat year on year as higher compensation and benefits costs

were more than offset by lower general and administration expenses driven by lower transformation charges. Adjusted

costs increased by 1% to € 1.8 billion, mainly due to higher severance and litigation costs attributable to the prior year.

Assets under Management increased by € 73 billion, or 7%, to € 1,085 billion during 2025, driven by positive market

impact and net inflows, partly offset by negative foreign exchange effects.

Net flows were positive € 51 billion, primarily driven by net inflows in Passive, Cash, Systematic & Quantitative

Investments (SQI) and Alternatives products, partly offset by net outflows in Equity, Advisory Services and Multi Asset

products.

The following table provides the development of assets under management during 2025, broken down by product type

as well as the respective management fee margins:


in € bn.	Active Equity	Active Fixed Income	Active Multi Asset	Active SQI	Passive	Alternative s	Active Cash	Advisory Services	Assets under Management
Balance as of December 31, 2024	111	213	54	77	335	110	93	18	1,012
Inflows	13	36	6	15	137	14	770	4	995
Outflows	(16)	(36)	(8)	(11)	(104)	(12)	(750)	(7)	(944)
Net Flows	(3)	—	(2)	4	33	2	20	(3)	51
FX impact	(2)	(13)	(1)	(1)	(24)	(7)	(8)	—	(55)
Performance	11	6	2	2	52	3	1	—	77
Other	—	3	—	(2)	—	(—)	—	1	—
Balance as of December 31, 2025	117	209	54	80	395	108	106	16	1,085
Management fee margin (in bps)	69	11	40	33	16	46	6	4	25

From 2025, “Advisory Services” is presented as a separate asset class. Prior year’s comparatives aligned to presentation in the current year


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

2024

Profit before tax was € 632 million, up 60%, from 2023, mainly driven by higher revenues and stable noninterest

expenses. Post-tax return on average shareholders’ equity was 8.0%, up from 5.2% in the prior year. Post-tax return on

average tangible shareholders’ equity was 18.0%, up from 12.2% in the prior year. The cost/income ratio was 69%, down

from 77% in 2023.

Net revenues in 2024 were € 2.6 billion, up 11% compared to 2023. Management fees were € 2.5 billion, up 7% year on

year, driven by Active and Passive products from higher average assets under management. Performance and transaction

fees increased by 16% to € 148 million, predominately driven by a significant Multi Asset performance fee. Other

revenues increased by € 82 million to € 23 million driven by lower treasury funding charges, partly offset by unfavorable

outcome of fair value of guarantees.

Noninterest expenses were € 1.8 billion in 2024, essentially flat year on year. Adjusted costs increased by 1%, mainly due

to higher compensation and benefits, variable compensation and increasing number of employees, as well as higher

banking servicing costs driven by a rise in assets under management, partly offset by lower IT costs and professional

services fees from adopting an amended approach to the platform transformation. Non-operating costs were

significantly lower due to lower litigation costs and severance payments compared to 2023.

Net flows were positive € 26 billion, primarily in Passive, Systematic & Quantitative Investments (SQI) and Cash products.

This was partly offset by net outflows in Multi Assets, Equity, Alternatives and Fixed Income. ESG products attracted net

inflows of € 6 billion in 2024 primarily into Xtrackers.

Assets under Management increased by € 115 billion, or 13%, to € 1,012 billion during 2024, driven by positive market

developments, net inflows and foreign exchange rate movements.

The following table provides the development of assets under management during 2024, broken down by product type

as well as the respective management fee margins:


in € bn.	Active Equity	Active Fixed Income	Active Multi Asset	Active SQI	Passive	Alternatives	Active Cash	Advisory Services	Assets under Management
Balance as of December 31, 2023	103	202	56	66	246	109	85	28	896
Inflows	13	42	5	14	124	10	717	4	928
Outflows	(18)	(43)	(7)	(12)	(82)	(13)	(715)	(13)	(903)
Net Flows	(5)	(1)	(2)	2	42	(3)	2	(9)	26
FX impact	1	6	—	—	11	3	4	—	26
Performance	13	6	3	5	35	1	1	—	64
Other	—	—	(4)	3	1	(—)	—	—	—
Balance as of December 31, 2024	111	213	54	77	335	110	93	18	1,012
Management fee margin (in bps)	71	11	39	33	16	46	6	3	26

From 2025, “Advisory Services” is presented as a separate asset class. Prior year’s comparatives aligned to presentation in the current year


Deutsche Bank	Operating and financial review
Annual Report 2025	Results of operations

Corporate & Other


				2025 increase (decrease) from 2024		2024 increase (decrease) from 2023
in € m. (unless stated otherwise)	2025	2024	2023	in € m.	in %	in € m.	in %
Net revenues	(249)	1,406	2,324	(1,654)	N/M	(918)	(40)
Provision for credit losses	108	83	26	26	31	57	N/M
Noninterest expenses
Compensation and benefits	3,541	3,574	3,358	(33)	(1)	216	6
General and administrative expenses	(2,721)	(1,474)	(2,710)	(1,247)	85	1,236	(46)
Impairment of goodwill and other intangible assets	—	—	—	—	N/M	—	N/M
Restructuring activities	—	—	(1)	—	N/M	1	N/M
Total noninterest expenses	819	2,100	647	(1,280)	(61)	1,453	N/M
Noncontrolling interests	(289)	(199)	(166)	(89)	45	(33)	20
Profit (loss) before tax	(887)	(577)	1,817	(310)	54	(2,394)	N/M

Total Employees (full-time equivalent)1	36,918	36,097	35,792	821	2	305	1
Risk-weighted assets (in € bn)1	31	34	40	(3)	(7)	(6)	(15)
Leverage exposure (in € bn)1	32	38	39	(6)	(16)	(1)	(3)

N/M – Not meaningful

Prior year’s comparatives aligned to presentation in the current year

1As of year-end

2025

For the full year Corporate & Other reported a loss before tax of € 887 million, primarily driven by shareholders expenses

and other centrally retained items including funding and liquidity impacts partially offset by revenues from valuation and

timing differences. This compared to a loss before tax of € 577 million in the prior year.

Net revenues for the full year were negative € 249 million, compared to positive € 1.4 billion for the prior year, with the

year-on-year movement primarily driven by lower revenues in valuation and timing differences reflecting impacts from

portfolio hedges of interest rate risk, where fair value hedge accounting cannot be applied under IFRS as issued by the

IASB.

Noninterest expenses were negative € 819 million for the full year. This compares to negative € 2.1 billion in the prior

year which were primarily driven by legacy litigation matters including the Postbank takeover litigation and Polish FX

mortgages. Expenses associated with shareholder activities were € 638 million for the full year, compared to € 648

million in the prior year.

Noncontrolling interests are reversed in Corporate & Other after deduction from the divisional profit before tax. These

were positive € 289 million for the full year, compared to € 199 million in the prior year with the year-on-year movement

driven by higher earnings from DWS.

2024

Corporate & Other reported a loss before tax of € 577 million, primarily driven by legacy litigation matters including the

Postbank takeover litigation and Polish FX mortgages offset by positive valuation and timing revenues. This compared to

a profit before tax of € 1.8 billion in the prior year.

Net revenues for the full year were positive € 1.4 billion in 2024, compared to positive € 2.3 billion for the prior year,

primarily driven by revenues in valuation and timing differences reflecting gains on portfolio hedges of interest rate risk,

where fair value hedge accounting cannot be applied under IFRS as issued by the IASB.

Noninterest expenses were negative € 2.1 billion in 2024, driven by the aforementioned legacy litigation matters,

compared to negative € 646 million in the prior year. Expenses associated with shareholder activities were € 648 million

in 2024, compared to € 582 million in 2023.

Noncontrolling interests are reversed in Corporate & Other after deduction from the segmental profit before tax. These

were positive € 199 million in 2024, compared to € 166 million in 2023, mainly related to DWS.


Deutsche Bank	Operating and financial review
Annual Report 2025	Financial Position

Financial Position

Assets


in € m. (unless stated otherwise)	Dec 31, 2025	Dec 31, 2024	Absolute Change	Change in %
Cash, central bank and interbank balances	171,621	153,654	17,967	12
Central bank funds sold, securities purchased under resale agreements and securities borrowed	37,515	40,846	(3,332)	(8)
Financial assets at fair value through profit or loss	519,960	545,895	(25,935)	(5)
Of which: Trading assets	153,811	139,772	14,039	10
Of which: Positive market values from derivative financial instruments	241,654	291,800	(50,146)	(17)
Of which: Non-trading financial assets mandatory at fair value through profit and loss	124,495	114,324	10,171	9
Financial assets at fair value through other comprehensive income	43,644	42,090	1,553	4
Loans at amortized cost	478,214	483,897	(5,683)	(1)
Remaining assets	188,920	124,650	64,269	52
Of which: Brokerage and securities related receivables	105,424	60,690	44,734	74
Total assets	1,439,873	1,391,033	48,840	4

Liabilities and Equity


in € m. (unless stated otherwise)	Dec 31, 2025	Dec 31, 2024	Absolute Change	Change in %
Deposits	694,580	667,700	26,880	4
Central bank funds purchased, securities sold under repurchase agreements and securities loaned	4,179	3,742	437	12
Financial liabilities at fair value through profit or loss	384,230	412,409	(28,180)	(7)
Of which: Trading liabilities	42,879	43,498	(619)	(1)
Of which: Negative market values from derivative financial instruments	225,827	276,410	(50,583)	(18)
Of which: Financial liabilities designated at fair value through profit or loss	115,055	92,047	23,007	25
Other short-term borrowings	18,204	9,895	8,309	84
Long-term debt	114,754	114,899	(145)	0
Remaining liabilities	141,641	100,522	41,119	41
Of which: Brokerage and securities related payables	107,256	63,755	43,501	68
Total liabilities	1,357,588	1,309,168	48,420	4
Total equity	82,285	81,865	420	1
Total liabilities and equity	1,439,873	1,391,033	48,840	4


Deutsche Bank	Operating and financial review
Annual Report 2025	Financial Position

Movements in Assets and Liabilities

As of December 31, 2025, the total balance sheet of € 1.4 trillion was slightly higher compared to year-end 2024.

Cash, central bank and interbank balances increased by € 18.0 billion, primarily reflecting a € 26.9 billion rise in deposits,

driven by growth in Corporate Cash Management business in the Corporate Bank and higher inflows in the Private Bank

as a result of client acquisition campaigns

Trading assets increased by € 14.0 billion, primarily driven by an increase in bond positions in the bank’s debt securities

portfolio due to client flows and desk positioning, as well as an increase in precious metal inventory during the year.

Positive and negative market values of derivative financial instruments declined by € 50.1 billion and € 50.6 billion,

respectively, mainly driven by foreign exchange products due to market volatility, weakening of the U.S. dollar against

the euro and new trades booked at materially lower mark-to-market values.

Non-trading financial assets mandatory at fair value through profit and loss increased by € 10.2 billion, driven by an

increase in securities purchased under resale agreements measured under non-trading financial assets mandatory at fair

value through profit and loss, primarily due to increased trading activities.

Loans at amortized cost decreased by € 5.7 billion, mainly driven by a significant impact from foreign exchange

movements and strategic reductions in the Private Bank mortgage portfolio, partly offset by growth in Fixed Income &

Currencies business in the Investment Bank.

Remaining assets increased by € 64.3 billion, primarily driven by increases in brokerage and securities related receivables

of € 44.7 billion. This was mainly attributable to higher receivables from pending settlements of regular way trades

compared to low levels at year-end 2024. This trend also reflected in an increase in brokerage and securities related

payables by € 43.5 billion, driving the € 41.1 billion increase in remaining liabilities. The increase in remaining assets also

included growth in debt securities classified as hold to collect of € 18.6 billion, in line with the bank’s asset purchase

program initiative to expand the portfolio of European government bonds.

Financial liabilities designated at fair value through profit or loss increased by € 23.0 billion, mainly attributable to an

increase in securities sold under repurchase agreements as a result of increased secured funding of trading inventory and

client activities; as well as an increase in long-term debt driven by new issuances in FIC business in the Investment Bank.

Other short-term borrowings increased by € 8.3 billion, primarily due to newly issued commercial paper during the year.

The overall movement of the balance sheet included a decrease of € 69.3 billion due to foreign exchange rate

movements, mainly driven by weakening of the U.S. dollar versus the euro. The effects from foreign exchange rate

movements are embedded in the movement of the balance sheet line items discussed in this section.

Liquidity

Total High Quality Liquid Assets (HQLA) as defined by the Commission Delegated Regulation (EU) 2015/61 and amended

by Regulation (EU) 2018/1620 increased to € 260 billion as of December 31, 2025 compared to € 226 billion as of

December 31, 2024. The increase in HQLA is primarily on account of increased deposits. The Liquidity Coverage Ratio

was 144% at the end fourth quarter of 2025, a surplus to regulatory requirements of € 80 billion as compared to 131% as

at the end of fourth quarter of 2024, a surplus to regulatory requirements of € 53 billion.


Deutsche Bank	Operating and financial review
Annual Report 2025	Financial Position

Equity

Total equity as of December 31, 2025, was € 82.3 billion compared to € 81.9 billion as of December 31, 2024, an increase

of € 420 million. This change was driven by a number of factors including the profit attributable to Deutsche Bank

shareholders and additional equity components reported for the period of € 6.6 billion, the issuance of Additional Tier 1

equity instruments (AT1) treated as equity in accordance with IFRS of € 2.5 billion, treasury shares distributed under

share-based compensation plans of € 472 million as well as tax benefits related to share-based compensation plans of €

161 million.

Negative effects resulted from unrealized net losses on accumulated other comprehensive income, net of tax, of € 2.9

billion, mostly driven by foreign currency translation, net of tax, of negative € 3.2 billion, mainly reflecting the weakening

of the U.S. dollar against the euro, partly offset by a positive impact from unrealized net gains on financial assets at fair

value through other comprehensive income, net of tax, of € 377 million. Further contributing factors included the

redemption of AT1 instruments of € 2.4 billion, purchases of treasury shares of € 1.6 billion, cash dividends paid to

Deutsche Bank shareholders of € 1.3 billion, coupons paid on additional equity components of € 761 million as well as

remeasurement losses related to defined benefit plans, net of tax, of € 119 million.

On January 3, 2025, Deutsche Bank AG cancelled 46.4 million of its common shares, concluding its 2024 share buyback

program. The cancellation reduced the nominal value of the shares by € 119 million. The cancelled shares had been held

in common shares in treasury, at their acquisition cost of € 675 million. The difference between the common shares at

cost and their nominal value reduced additional paid-in capital by € 556 million. The shares had already been deducted

from the reported total equity on December 31, 2024. Therefore, the cancellation did not reduce total equity in 2025.

On December 19, 2025, Deutsche Bank AG cancelled 37.7 million of its common shares, concluding its two 2025 share

buyback programs. The cancellation reduced the nominal value of the shares by € 96 million. The cancelled shares had

been held in common shares in treasury, at their acquisition cost of € 1.0 billion. The difference between the common

shares at cost and their nominal value reduced additional paid-in capital by € 903 million.

The first 2025 share buyback program resolved by the Management Board of Deutsche Bank of up to € 750 million

started on April 1, 2025, and was completed on September 12, 2025. In this period, Deutsche Bank repurchased

29.3 million common shares. The repurchase of these shares has reduced total equity by € 750 million.

The second 2025 share buyback program resolved by the Management Board of Deutsche Bank of up to € 250 million

started on September 17, 2025, and was completed on October 20, 2025. In this period, Deutsche Bank repurchased

8.4 million common shares. The repurchase of these shares has reduced total equity by € 250 million.

Own Funds

Deutsche Bank’s CRR/CRD Common Equity Tier 1 capital as of December 31, 2025, decreased by € 0.2 billion to

€ 49.3 billion, compared to € 49.5 billion as of December 31, 2024. The Risk-weighted assets (RWA) decreased by

€ 10.3 billion to €347.1 billion as of December 31, 2025, compared to € 357.4 billion as of December 31, 2024. The CET

1 capital ratio as of December 31, 2025, increased to 14.2% compared to 13.8% as of December 31, 2024 (for additional

information please refer to the “Risk and capital performance” section).

The Bank’s Tier 1 capital as of December 31, 2025, amounted to € 60.8 billion, consisting of a CET 1 capital of

€ 49.3 billion and Additional Tier 1 capital of € 11.5 billion. The Tier 1 capital remained broadly stable compared to the

end of 2024. The Tier 1 capital ratio as of December 31, 2025, increased to 17.5% compared to 17.0% as of December 31,

2024.

Total capital as of December 31, 2025 amounted to € 67.8 billion compared to € 68.5 billion at the end of 2024. The

Total capital decreased by € 0.7 billion since 2024, mainly driven by a decrease in Tier 2 capital.2024 The Total capital

ratio as of December 31, 2025, increased to 19.5% compared to 19.2% as of December 31, 2024.


Deutsche Bank	Operating and financial review
Annual Report 2025	Liquidity and capital resources

Liquidity and capital resources

For a detailed discussion of the bank’s liquidity risk management, please see the Risk Report in this annual report.

Tabular disclosure of contractual obligations

Cash payment requirements outstanding as of December 31, 2025.


Contractual obligations					Payment due by period
in € m.	Total	Less than 1 year	1–3 years	3–5 years	More than 5 years
Long-term debt obligations¹	129,864	26,576	40,011	29,800	33,477
Trust preferred securities1,2	299	299	—	—	—
Long-term financial liabilities designated at fair value through profit or loss3	27,356	3,310	5,149	7,656	11,240
Future cash outflows not reflected in the measurement of Lease liabilities4	4,750	8	148	239	4,355
Lease liabilities1	5,145	699	907	907	2,632
Purchase obligations	3,737	617	1,420	992	708
Long-term deposits¹	26,629	0	11,817	3,036	11,777
Other long-term liabilities	172	96	8	25	43
Total	197,952	31,605	59,459	42,655	64,233

1Includes interest payments.

2Contractual payment date or first call date.

3Long-term debt and long-term deposits designated at fair value through profit or loss.

4For further detail please refer to Note 22 “Leases”.

Purchase obligations for goods and services include future payments for, among other things, information technology

services and facility management. Some figures above for purchase obligations represent minimum contractual

payments and actual future payments may be higher. Long-term deposits exclude contracts with a remaining maturity of

less than one year. Under certain conditions future payments for some long-term financial liabilities designated at fair

value through profit or loss may occur earlier. See the following notes to the consolidated financial statements for

further information: Note 05 “Net Interest Income and Net Gains (Losses) on Financial Assets/Liabilities at Fair Value

through Profit or Loss”, Note 22 “Leases”, Note 26 “Deposits” and Note 30 “Long-Term Debt and Trust Preferred

Securities”.


Deutsche Bank	Introduction
Annual Report 2025	Disclosures in line with IFRS 7

Introduction

Disclosures in line with IFRS 7

The following Risk Report provides qualitative and quantitative disclosures about credit, market and other risks in line

with the requirements of International Financial Reporting Standard 7 (IFRS 7) Financial Instruments: Disclosures. It also

considers the underlying classification and measurement and impairment requirements in IFRS 9 with further details to

be found in the “Credit Risk Management and Asset quality” section, the “Asset quality” section, the “Credit risk

mitigation” section and in Note 01 “Material accounting policies and critical accounting estimates” to the consolidated

financial statements. Information that forms part of and is incorporated by reference into the financial statements of this

report is marked by a light gray shading throughout this Risk Report.

Since June 30, 2020, the Group has applied the transitional arrangements in relation to IFRS 9 as provided in the current

CRR/CRD for all CET1 measures.

Disclosures according to Pillar 3 of the Basel III Capital

Framework

Deutsche Bank’s disclosures according to Pillar 3 of the Basel III Capital Framework, which are implemented in the

European Union by the Regulation (EU) No 575/2013 on prudential requirements for credit institutions (Capital

Requirements Regulation or CRR), including reforms introduced by Regulation (EU) 2024/1623 (CRR3), being applicable

since January 1, 2025; and supported by the respective EBA Implementing Technical Standards and EBA guideline

applicable to Pillar 3 disclosures, are published in the Group’s Pillar 3 Report, which can be found on Deutsche Bank’s

website.

Disclosure following Amendments to the Capital Requirements

Regulation

Regulation (EU) 2024/1623 (CRR3), generally applicable from January 1, 2025 implements a comprehensive package of

reforms based on the Final Basel III set of global reforms, changing how banks calculate their RWA. It includes, among

other things, an output floor establishing minimum RWA that until January 1, 2030 will gradually increase to 72.5% of the

RWA calculated under the standardized approaches, changes to standardized and internal ratings-based approaches for

determining credit risk, changes to the credit valuation adjustment, a revision of the approach for operational risks and

reforms to the market risk framework as set out in the Fundamental Review of the Trading Book (FRTB, applicable from

January 1, 2027). The implementation of the changes to CRR affects among others Deutsche Bank’s risk-weighted assets

and regulatory capital.


Deutsche Bank	Risk and capital overview
Annual Report 2025	Key risk metrics

Risk and capital overview

Key risk metrics

The following section provides qualitative and quantitative disclosures about credit, market, liquidity and other risk

metrics and their developments within the twelve months ended December 31, 2025 considering reforms introduced by

Regulation (EU) 2024/1623 (CRR3), being applicable since January 1, 2025. Disclosures according to Pillar 3 of the Basel

III Capital Framework, which are implemented in the European Union by the Capital Requirements Regulation (CRR) and

supported by EBA Implementing Technical Standards or the EBA Guideline, are published in the Group’s separate Pillar 3

Report.

The following selected key risk metrics form part of the bank’s holistic risk management across individual risk types. The

Common Equity Tier 1 (CET1) capital ratio, Economic Capital Adequacy (ECA) ratio, Leverage ratio, Total Loss Absorbing

Capacity (TLAC), Minimum Requirement for Own Funds and Eligible Liabilities (MREL), Liquidity Coverage Ratio (LCR),

Stressed Net Liquidity Position (sNLP) and Net Stable Funding Ratio (NSFR) serve as high-level metrics and are fully

integrated across strategic planning, risk appetite framework, stress testing as well as recovery and resolution planning

practices, which are reviewed and approved by the Management Board at least annually.


Common Equity Tier 1 capital ratio1		Total risk-weighted assets1
31.12.2025	14.2%	31.12.2025	€ 347.1bn
31.12.2024	13.8%	31.12.2024	€ 357.4bn

Economic capital adequacy ratio		Total economic capital demand
31.12.2025	194%	31.12.2025	€ 26.1bn
31.12.2024	199%	31.12.2024	€ 24.2bn

Leverage ratio1		Leverage exposure1
31.12.2025	4.6%	31.12.2025	€ 1,327bn
31.12.2024	4.6%	31.12.2024	€ 1,316bn

Total loss absorbing capacity		Minimum requirement for own funds and eligible liabilities
31.12.2025 (Risk Weighted Asset based)	33.1%	31.12.2025	37.7%
31.12.2025 (Leverage Exposure based)	8.7%	31.12.2024	37.5%
31.12.2024 (Risk Weighted Asset based)	33.2%
31.12.2024 (Leverage Exposure based)	9.0%

Liquidity coverage ratio		Net Stable Funding Ratio
31.12.2025	144%	31.12.2025	119.0%
31.12.2024	131%	31.12.2024	121.0%

Stressed net liquidity position
31.12.2025	€ 94.1bn
31.12.2024	€ 56.3bn

1Starting with the third quarter of 2024 until the discontinuation in the fourth quarter of 2025, Deutsche Bank had adopted the temporary treatment of unrealized gains

and losses measured at fair value through OCI in accordance with Article 468 CRR; for the shown comparative values as of December 31, 2024, without application of

this rule the CET1 ratio would have been 13.5% with respective CET1 capital of € 48.4 billion and RWA of € 358.6 billion and in addition, the leverage ratio would have

been 4.6% with respective Tier 1 capital of € 59.8 billion and leverage exposure of € 1,315 billion

Deutsche Bank regularly assesses the potential impacts of risks on its balance sheet and profitability through portfolio

reviews and stress tests. Stress tests are also used to test the resilience of Deutsche Bank’s strategic plans. The results of

these tests indicate that the currently available capital and liquidity reserves, in combination with available mitigation

measures, are sufficient to withstand periods of potential stress.

The Group concludes that the risks, as described above or in the following sections, to which Deutsche Bank is exposed

to, including potential impacts on its business strategy, provide a true and fair picture of its risk profile.

For further details, please refer to sections “Risk profile”, “Risk appetite and capacity”, “Risk and capital plan”, “Stress

testing”, “Recovery and resolution planning”, “Risk and capital management”, “Capital, leverage ratio, TLAC and MREL”,

“Liquidity coverage ratio”, and “Stress testing and scenario analysis”.


Deutsche Bank	Risk and capital overview
Annual Report 2025	Risk profile

Risk profile

Deutsche Bank’s mix of business activities results in diverse risk-taking. The Group measures key risks inherent to the

respective business models (credit, market, operational and strategic risk) through the economic capital metric, which

captures the business segment’s risk profile and considers cross-risk effects at Group level.

Corporate Bank’s risk profile mainly arises from the products and services offered in Corporate Treasury Services

(including Trade Finance, Lending and Corporate Cash Management), Strategic Corporate Lending and Business Banking.

Economic capital demand in these segments arises largely from credit risk.

Investment Bank’s risk profile is dominated by its financing and trading activities, which give rise to all major risk types.

Credit risk in the Investment Bank is broadly distributed across business units but most prominent in Fixed Income &

Currencies and Leveraged Debt Capital Markets. Market risk arises mainly from trading and market making activities.

Private Bank’s risk profile comprises credit risks from business with German and international retail clients, business

clients and wealth management clients as well as non-trading market risks mainly from modeling of client deposits.

Asset Management, as a fiduciary asset manager, invests money on behalf of clients. As such, the main risk drivers are of

operational nature. The economic capital demand for market risk is mainly driven by non-trading market risks, which arise

from guaranteed products and co-investments in the funds.

Corporate & Other’s risk profile embeds a range of different risk drivers including those pertaining to Treasury, certain

corporate items, and legacy portfolios. The economic capital demand mainly comprises non-trading market risk from

interest rate risk in Treasury, structural foreign exchange risk and equity compensation risk, credit risk from Treasury’s

investments, strategic risk from tax-related risks and software asset risks and operational risk from legacy portfolios.

The table below shows Deutsche Bank’s overall risk position as measured by the economic capital demand calculated for

the dates specified. Deutsche Bank’s overall economic risk position also considers diversification benefits across risk

types.


Deutsche Bank	Risk and capital overview
Annual Report 2025	Risk profile

Risk profile of Deutsche Bank’s business segments as measured by economic capital


	Dec 31, 2025
in € m. (unless stated otherwise)	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total	Total (in %)
Credit risk	3,720	4,650	2,255	45	2,725	13,395	51
Market risk	507	2,004	789	316	6,354	9,970	38
Operational risk	821	1,390	1,187	393	1,168	4,960	19
Strategic risk	—	—	—	—	1,980	1,980	8
Diversification benefit¹	(780)	(1,339)	(863)	(238)	(1,013)	(4,234)	(16)
Total EC	4,269	6,706	3,368	516	11,213	26,071	100
Total EC in %	16	26	13	2	43	100	N/M

1Diversification benefit across credit, market, operational and strategic risk


	Dec 31, 2024
in € m. (unless stated otherwise)	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total	Total (in %)
Credit risk	3,455	4,512	2,164	46	2,329	12,507	52
Market risk	1,040	2,086	1,561	304	3,676	8,667	36
Operational risk	863	1,182	1,155	376	1,069	4,645	19
Strategic risk	—	—	—	—	1,936	1,936	8
Diversification benefit¹	(715)	(1,007)	(803)	(190)	(814)	(3,530)	(15)
Total EC	4,643	6,772	4,077	536	8,196	24,225	100
Total EC in %	19	28	17	2	34	100	N/M

1 Diversification benefit across credit, market, operational and strategic risk

As of December 31, 2025, Deutsche Bank’s economic capital demand amounted to € 26.1 billion, which was € 1.8 billion

or 8% higher than € 24.2 billion economic capital demand as of December 31, 2024. Market risk increased by € 1.3 billion

mainly due to migration of economic capital model used for structural foreign exchange risk, including the application of

extended liquidity horizons, as well as transition of market risk economic capital from Monte Carlo simulation to historical

simulation. Credit risk increased by € 0.9 billion due to higher transfer risk driven by increase in exposures from

Investment Bank, Corporate Bank and Corporate & Other as well as higher counterparty risk driven by increase in

Treasury and sovereign exposures. Operational risk increased by € 0.3 billion primarily driven by model changes in the

forward-looking qualitative adjustment component as well as the simplification of the advanced measurement approach

model. These increases were partly offset by an increase in diversification benefit of € 0.7 billion due to the change in risk

type profile and market risk model changes.


Deutsche Bank	Risk and capital overview
Annual Report 2025	Key risk themes

Key risk themes

The latest developments and key uncertainties during 2025 are part of the bank’s ongoing credit risk management

activities and governance framework. These activities include, but are not limited to, regular emerging risk reviews

(amongst others macro-economic development and geopolitical conflict) as well as portfolio deep dives, day to day risk

management on the level of individual borrowers, and regular model validations. Portfolios which have been identified

for enhanced monitoring and downside risk assessment for the Group in 2025 included Commercial Real Estate (CRE),

clients vulnerable to U.S. Tariffs and sectors considered vulnerable to Climate transition and physical risks.

In addition, the bank is monitoring developing market trends, which currently relate to technology and Financial,

Insurance and Non-Bank Financial Institutions (NBFI) activities, particularly around Private Credit, and where the focus is

increasing.

CRE markets continue to face headwinds due to the impacts of higher interest rates, reduced market liquidity combined

with tightened lending conditions, and structural changes in the office sector. Market stress has been more pronounced

in the U.S, where property price indices show a more substantial decline in CRE asset values from recent peaks compared

to Europe and APAC. Especially, within the office segment, particularly the U.S. West Coast, the market weakness is most

evident in the U.S., reflected in subdued leasing activity and higher vacancy rates compared to Europe.

Although the U.S. administration’s tariff policy is still unpredictable, the macro-economic environment has improved

since the volatile market conditions post the U.S. administrations’ April 2, 2025 announcement of sweeping tariffs, A

longer period has also elapsed since the U.S. administration tariff announcements started, reducing the uncertainty

regarding potentially vulnerable clients. The bank expects any risk factors impacting ECL’s to be captured through

standard risk management procedures e.g., rating downgrades and watchlist inclusions and therefore no tariff related

overlays have been booked as of December 31, 2025. Although tariffs remain under close review, it would not be

considered a standalone key risk theme but rather integrated into the broader portfolio dynamics

Climate transition and physical risks present growing risks to the bank’s sectoral and regional portfolios. Managing

climate transition and physical risks is a key component of Deutsche Bank’s risk management and wider sustainability

strategy, where 2025 materiality assessments and climate stress test results conclude that potential credit risk impacts

are well-contained in the short term.

Further details are provided in the section “Focus areas in 2025”.

External developing themes

Developing risk themes in high focus externally, include (i) the rapid expansion, lack of transparency and potential

interconnected risks associated with Private Credit and wider NBFI exposure and (ii) increasing concerns around

Technology sector valuations and the sustainability of the current AI-led capital expenditure and its impact on business

models and potential credit risk implications to clients. 

Non-Bank Financial Institutions and Private Credit

Loans to Private Credit, generally categorized as NBFI Lending, are subject to heightened scrutiny due to recent default

events in the market. The bank’s Private Credit portfolio accounts for € 25.9 billion (2024: € 24.5 billion) of the loans at

amortized cost. Approximately 73% of this exposure is to multi-asset Lender facilities (ABS) collateralized by highly

diversified mid-market corporate loans in the U.S. and the EU, across industry sectors, with conservative advance rates of

~65% and almost entirely investment grade rated. The remainder is diversified across single and multi asset lenders Net

Asset Value (NAV) Financing, Single Asset Financing, non-bank CRE lending, business development companies (BDC) and

subscription finance.

The bank applies conservative underwriting standards to its Private Credit exposures, including assessment of sponsor and

investor quality and other structural features. Advance rates are linked to the overall risk profile of the underlying exposure.

Portfolios are managed under dedicated risk appetite frameworks with regular stress testing and active monitoring of credit

performance, collateral values and underlying diversification.

The above mentioned exposures are mainly a component of Deutsche Bank’s loans at amortized cost reported under the

Financial and Insurance Activities Industry Sector NACE which accounts for € 129.8 billion, while € 2.5 billion is spread

across other NACE categories. The Financial and Insurance Activities NACE constitutes a diverse range of exposures

including corporate, banking, wealth management, insurance and clearing obligors.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Risk management principles

Risk and capital framework

Risk management principles

Deutsche Bank’s business model inherently involves taking risks. Risks can be of financial or operational nature and

include on and off-balance sheet risks. Deutsche Bank’s objective is to create sustainable value in the interests of the

company taking into consideration shareholders, employees and other company-related stakeholders. The risk

management framework contributes to this by aligning planned and actual risk taking with risk appetite as expressed by

the Management Board, while being in line with available capital and liquidity.

Deutsche Bank’s risk management framework consists of various components, which include the established internal

control mechanisms. Principles and standards are set for each component:

–Risk governance structures provide oversight of the Bank’s risk profile against risk appetite

–Organizational structures follow the Three Lines of Defense (“3LoD”) model with a clear definition of roles and

responsibilities for all risk types

–The 1st Line of Defense (“1st LoD”) refers to those roles in the Bank whose activities generate risks, whether

financial or operational, and who own and are accountable for these risks. The 1st LoD manages these risks within

the defined risk appetite, establishes an appropriate risk governance, and adheres to the risk type frameworks

defined by the 2nd Line of Defense (“2nd LoD”)

–The 2nd LoD refers to the roles in the Bank who define the risk management framework for a specific risk type. The

2nd LoD independently assesses and challenges the implementation of the risk type framework and adherence to

the risk appetite, and acts as an advisor to the 1st LoD on how to identify, assess and manage risks.

–The 3rd Line of Defense (“3rd LoD”) is Group Audit. This function provides an independent and objective assurance

on the adequacy of the design, operating effectiveness and efficiency of the risk management system and systems

of internal control

–The Management Board-approved risk appetite must be cascaded and adhered to across all dimensions of the Group,

with appropriate consequences in the event of a breach

–Risks must be identified and assessed

–Risks must be actively managed including appropriate risk mitigation and effective internal control systems

–Risks must be measured and reported using accurate, complete and timely data using approved models

–Regular stress tests must be performed against adverse scenarios and appropriate crisis response planning must be

established

The Group promotes a strong risk culture in which every employee must fully understand and take a holistic view of the

risks which could result from their actions, understand the consequences and manage them appropriately against the

risk appetite of the bank. The bank expects employees to exhibit behaviors that support a strong risk culture in line with

the bank’s Code of Conduct. To promote this, Deutsche Bank’s policies require that risks taken (including against risk

appetite) must be considered during the bank’s performance assessment and compensation processes. This expectation

continues to be reinforced through communications campaigns and mandatory training courses for all DB employees. In

addition, Management Board members and senior management frequently communicate the importance of a strong risk

culture to support a consistent tone from the top.

Deutsche Bank’s risk management and internal control system is described in more detail in Deutsche Bank’s Pillar 3

Report. The risk management and internal control system also covers sustainability-related objectives.

The Management Board is of the opinion that a risk management framework and internal control system has been

established which is, in its entirety, appropriate and effective for the bank’s business model and risk profile.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Risk governance

Risk governance

Deutsche Bank’s operations throughout the world are regulated and supervised by relevant authorities in each of the

jurisdictions in which the bank conducts business. Such regulation focuses on licensing, capital adequacy, liquidity, risk

concentration, conduct of business as well as organizational and reporting requirements. The European Central Bank

(ECB) in connection with the competent authorities of EU countries which joined the Single Supervisory Mechanism via

the Joint Supervisory Team act in cooperation as Deutsche Bank’s primary supervisors to monitor the bank’s compliance

with the German Banking Act and other applicable laws and regulations.

Several layers of management provide cohesive risk governance:

Deutsche Bank’s Supervisory Board is informed regularly on the risk situation, risk management and risk controlling,

including reputational risk related items as well as material litigation cases; it has formed various committees to handle

specific topics (for a detailed description of these committees, please see the “Report of the Supervisory Board”, as well

as chapter “Supervisory Board” in the “Corporate Governance Statement according to Sec. 289f and 315d of the German

Commercial Code”)

–At the meetings of the Risk Committee, the Management Board reports on current and forward-looking risk

exposures, portfolios, on risk appetite and strategy and on matters deemed relevant for the assessment and oversight

of the risk situation of Deutsche Bank AG, including material legal and reputational risks; it also reports on loans

requiring a Supervisory Board resolution pursuant to law or the Articles of Association; the Risk Committee oversees

that the Management Board has in place processes to promote the adherence of Deutsche Bank AG to the applicable

risk policies and regulations, also covering legal and reputational risks; the Risk Committee advises on issues related to

the overall risk appetite, aggregate risk position and the risk strategy and keeps the Supervisory Board informed of its

activities

–The Audit Committee, among other matters, supports the Supervisory Board in monitoring the effectiveness of the

risk management system, particularly of the internal control system including the compliance management system as

well as sustainability-related issues and the internal audit system, as well as the Management Board’s remediation of

deficiencies identified

The Management Board is responsible for managing Deutsche Bank Group in accordance with the law, the Articles of

Association and its Terms of Reference with the objective of creating sustainable value in the interest of the company,

thus taking into consideration the interests of the shareholders, employees and other company related stakeholders; the

Management Board is responsible for ensuring a proper business organization, encompassing appropriate and effective

risk management, as well as compliance with legal requirements and internal guidelines; the Management Board

established the Group Risk Committee as the central forum for review and decision on material risk and capital-related

topics; the Group Risk Committee is described in more detail below.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Risk governance

Risk management governance structure of the Deutsche Bank Group

The following functional committees are central to the management of risk at Deutsche Bank:

–The Group Risk Committee has various duties and dedicated authority, including approval of new or changed material

risk and capital models and review of the inventory of risks, high-level risk portfolios, risk exposure developments,

internal and regulatory Group-wide stress testing results, and approval of resource limits, endorsed by the Group

Asset & Liability Committee, for Total Capital Demand, Leverage exposure and Economic Capital Demand; in addition,

the Group Risk Committee reviews and recommends items for Management Board approval, such as key risk

management principles, the Group risk appetite statement, the Group recovery plan and the contingency funding

plan, over-arching risk appetite parameters, and recovery and escalation indicators; the Group Risk Committee also

supports the Management Board during Group-wide risk and capital planning processes

–The Group Reputational Risk Committee has the responsibility to review, decide and manage all transactions, client

relationships or other primary reputational risk matters escalated in line with the underlying reputational risk policies

and framework, including from the Regional Reputational Risk Committees

–The Financial Resource Management Council is an ad-hoc governance body, chaired by the Chief Financial Officer

and the Chief Risk Officer, with delegated authority from the Management Board, to oversee financial crisis

management at the bank; the Financial Resource Management Council provides a single forum to oversee execution

of both the contingency funding plan and the Group recovery plan; the council recommends upon mitigating actions

to be taken in a time of anticipated or actual capital or liquidity stress; specifically, the Financial Resource

Management Council is tasked with analyzing the bank’s capital and liquidity position, in anticipation of a stress

scenario recommending proposals for capital and liquidity related matters and overseeing the execution of decisions

–The Group Asset & Liability Committee has been established by the Management Board with the mandate to optimize

the sourcing and deployment of the bank’s balance sheet and financial resources within the overarching risk appetite

set by the Management Board

Deutsche Bank’s Chief Risk Officer, who is a member of the Management Board, has Group-wide, supra-divisional

responsibility for establishing a risk management framework with appropriate identification, measurement, monitoring,

mitigation and reporting of liquidity, credit, market, enterprise, model and operational risks; however, frameworks for

certain risks are established by other functions as per the business allocation plan.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Risk identification and assessment

Risk identification and assessment

Risks to Deutsche Bank’s businesses and infrastructure functions, including under stressed conditions, are regularly

identified. This assessment incorporates input from both first and second line of defense, with the identified risks

assessed for materiality based on their severity and likelihood of materialization. The assessment of risks is

complemented by a view on emerging risks applying a forward-looking perspective. This risk identification and

assessment process results in the risk inventory which captures the material risks for the Group, and where relevant,

across businesses, entities and branches.

Regular updates to the Group risk inventory are reported to the Group Risk Committee and the Management Board. The

inventory informs key risk management processes, including the development of stress scenarios tailored to Deutsche

Bank’s risk profile and informing risk appetite setting and monitoring. Risks in the inventory are also mapped to risks in

the Group risk type taxonomy, where a corresponding materiality assessment is also provided.

Risk appetite and capacity

Risk appetite expresses the aggregate level and types of risk that Deutsche Bank is willing to assume to achieve strategic

objectives, as defined by a set of quantitative metrics and qualitative statements. Risk capacity is defined as the

maximum level of risk that can be assumed given Deutsche Bank’s capital and liquidity base, risk management and

control capabilities, and regulatory constraints.

Risk appetite is an integral element in business planning processes via risk strategy and plan, to promote the appropriate

alignment of risk, capital and performance targets, while at the same time considering risk capacity, risk-return and

appetite constraints from both financial and non-financial risks. Compliance of the plan with risk appetite and capacity is

also tested under stressed market conditions. Top-down risk appetite serves as the limit for risk-taking for the bottom-up

planning from the business functions.

The Management Board reviews and approves risk appetite and capacity on an annual basis, or more frequently in the

event of unexpected changes to the risk environment, with the aim of ensuring that they are consistent with the Group’s

strategy, business and regulatory environment and stakeholders’ requirements.

In order to determine risk appetite and capacity, different group level limits and triggers on a forward-looking basis are

set and the escalation requirements for further action are defined. Deutsche Bank assigns risk metrics that are sensitive

to the material risks to which Deutsche Bank is exposed and which function as indicators of financial health. In addition

to that, the risk and recovery management framework is linked with the risk appetite framework.

Reports relating to risk profile as compared to Deutsche Bank’s risk appetite and strategy and the monitoring thereof are

presented regularly up to the Management Board. In the event that desired risk appetite is breached, a predefined

escalation governance matrix is applied so these breaches are highlighted to the appropriate governance bodies.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Risk measurement and reporting systems

Risk measurement and reporting systems

Overview

Deutsche Bank’s risk measurement systems support regulatory reporting and external disclosures, as well as internal

management reporting across all risk types. The risk infrastructure incorporates the relevant legal entities and business

segments and provides the basis for reporting on risk positions, capital adequacy and limit, threshold, or target utilization

to the relevant functions on a regular and ad-hoc basis. Established units within the CFO and CRO function assume

responsibility for measurement, analysis and reporting of risk while promoting sufficient quality and integrity of risk-

related data and consider, where relevant, the principles for effective risk data aggregation and risk reporting as per the

Basel Committee on Banking Supervision's regulation number 239 (“BCBS 239”). The Group’s risk management systems

are reviewed by Group Audit following a risk-based audit approach.

Deutsche Bank’s reporting is an integral part of Deutsche Bank’s risk management framework and as such aligns with the

organizational setup by delivering consistent information on Group level and for material legal entities as well as

breakdowns by risk types, business segments and material business units.

The following principles guide Deutsche Bank’s “risk measurement and reporting” practices:

–Deutsche Bank monitors risks taken against risk appetite on various levels across the Group, e.g., Group, business

segments, material business units, material legal entities, risk types, material asset classes, portfolio and counterparty

levels

–Risk reporting is required to be accurate, clear, useful and complete and must convey reconciled and validated risk

data to communicate information in a concise manner to ensure, across material financial and operational risks, the

bank’s risk profile is clearly understood

–Senior risk committees, such as the Group Risk Committee, as well as the Management Board who are responsible for

risk and capital management receive regular reporting (as well as ad-hoc reporting as required)

–Dedicated teams within Deutsche Bank proactively manage material financial and non-financial risks and must ensure

that required management information is in place to enable proactive identification and management of risks and

avoid undue concentrations within a specific risk type and across risks (Cross-Risk view)

In applying the previously mentioned principles, Deutsche Bank maintains a common basis for all risk reports and aims to

minimize segregated reporting efforts to allow Deutsche Bank to provide consistent information, which only differs by

granularity and audience focus.

Key risk metrics

The Bank identifies a large number of metrics within its risk measurement systems which support regulatory reporting

and external disclosures, as well as internal management reporting across risks and for material risk types. Deutsche Bank

designates a subset of those as “Key Risk Metrics” that represent the most critical ones for which the Bank places an

appetite, limit, threshold or target at Group level and/or are reported routinely to senior management for discussion or

decision making. The identified Key Risk Metrics include Capital Adequacy and Liquidity metrics; further details can be

found in the section “Key risk metrics” at the beginning of the Risk Report.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Risk measurement and reporting systems

Key risk reports

While a large number of reports are used across the Bank, Deutsche Bank designates a subset of these as “Key Risk

Reports” that are critical to support Deutsche Bank’s Risk Management Framework through the provision of risk

information to senior management and therefore enable the relevant governing bodies to monitor, steer and control the

Bank’s risk taking activities effectively. To ensure that Key Risk Reports meet recipients’ requirements, report producing

functions regularly check whether the Key Risk Reports are clear and useful.

The main reports on risk and capital management that are used to provide Deutsche Bank’s central governance bodies

with information relating to the Group risk profile are the following:

–The monthly Risk and Capital Profile report is a Cross-Risk report, provides a comprehensive view of Deutsche Bank’s

risk profile and is used to inform the Group Risk Committee as well as the Management Board and subsequently the

Risk Committee of the Supervisory Board; the Risk and Capital Profile includes risk type specific and Business-Aligned

overviews and Enterprise-wide risk topics; it also includes updates on Key Group Risk Appetite Metrics and other Key

Portfolio risk type Control Metrics as well as updates on Key Risk Developments, highlighting areas of particular

interest with updates on corresponding risk management strategies

–The Weekly Risk Report is a weekly briefing covering high-level topical issues across key risk areas and is submitted

every Friday to the Members of the Group Risk Committee and the Management Board and subsequently to the

Members of the Risk Committee of the Supervisory Board; the Weekly Risk Report is characterized by the ad-hoc

nature of its commentary as well as coverage of themes and focuses on more volatile risk metrics

–Deutsche Bank runs several Group-wide macroeconomic stress tests. A monthly Risk Appetite scenario serves the

purpose to set and regularly monitor the bank’s stress loss appetite; in addition, there are topical scenarios which are

escalated to the Group Risk Committee if deemed necessary; the stressed key performance indicators are

benchmarked against the Group Risk Appetite thresholds

While the above reports are used at a Group level to monitor and review the risk profile of Deutsche Bank holistically,

there are other, supplementing standard and ad-hoc management reports, including for risk types or Focus Portfolios,

which are used to monitor and control the risk profile.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Strategic and capital plan

Strategic and capital plan

Deutsche Bank conducts annually an integrated strategic planning process which lays out the development of the future

strategic direction for the Group and the individual business areas. The strategic plan aims to create, among other things,

a holistic perspective on capital, funding, and risk under risk-return considerations. This process translates long-term

strategic targets into measurable short- to medium-term financial targets and objectives and enables intra-year

performance monitoring and management. Thereby the Group aims to identify growth options by considering the risks

involved and the allocation of available capital resources to drive sustainable performance. Risk-specific portfolio

strategies complement this framework and allow for an in-depth implementation of the risk strategy on portfolio level,

addressing risk specifics including risk concentrations.

The strategic planning process consists of two phases: a top-down target setting and a bottom-up substantiation.

In a first phase – the top-down target setting – Deutsche Bank’s key targets for profit and loss (including revenues and

costs), RoTE, CIR, capital supply, capital demand as well as leverage, funding and liquidity are defined and discussed for

the group and the key business areas. The global macro-economic outlook and the expected regulatory framework is the

basis for the target setting. Targets and objectives for the Group and the individual business areas are reviewed,

challenged and approved by the Management Board.

In a second phase, the top-down targets are substantiated bottom-up by detailed business unit plans, which consist of a

month-by-month operating plan for year one; years two and three are planned per quarter and years four and five are

annual plans. The bottom-up plans are reviewed and challenged by Finance and Risk and are discussed individually with

the respective business heads. Thereby, the specifics of the business are considered, and concrete targets agreed in line

with the bank’s strategic direction. The bottom-up phase includes the preparation of plans for key legal entities to review

local risk and capitalization levels. Stress tests complement the strategic plan to consider the resilience of the plan

against adverse market conditions.

The resulting Strategic and Capital Plan is presented to the Management Board for discussion and approval. The final

plan is subsequently presented to the Supervisory Board.

The Strategic and Capital Plan is designed to support the Group’s strategy to accelerate value creation by scaling the

Global Hausbank and the bank’s long-term ambition to become the European Champion in banking. The Strategic and

Capital Plan overall aims to ensure:

–Balanced risk adjusted performance across business areas and units

–High risk management standards with focus on risk concentrations

–Compliance with regulatory requirements

–Strong capital and liquidity position

–Stable funding and liquidity strategy allowing for business planning within the liquidity risk appetite and regulatory

requirements

The Strategic and Capital Planning process allows to:

–set earnings and key risk and capital adequacy targets considering the bank’s strategic focus and business plans

–assess the capital adequacy with regard to internal and external requirements (i.e., economic capital and regulatory

capital)

–apply appropriate stress test analyses to assess the impact on capital demand, capital supply and liquidity

All externally communicated financial targets are monitored on an ongoing basis in appropriate management

committees. Any projected shortfall versus targets is discussed together with potential mitigating strategies with the aim

to ensure that the Group remains on track to achieve the targets. Amendments to the Strategic and Capital Plan must be

approved by the Management Board. Achieving the externally communicated solvency targets ensures that the Group

also complies with the solvency ratio related Group Supervisory Review and Evaluation Process (SREP) requirements as

articulated by the home supervisor.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Stress testing

Stress testing

Deutsche Bank has implemented a stress test framework to satisfy internal as well as external stress test requirements

covering worldwide macroeconomic stress assessments as well as more targeted stress tests such as climate and cyber

related stress approaches. The internal stress tests are based on in-house developed methods and inform a variety of risk

management use cases (risk type specific as well as cross-risk). Internal stress tests form an integral part of Deutsche

Bank’s risk management framework complementing traditional risk measures. The cross-risk stress test framework, the

Group Wide Stress Test Framework (GWST), serves a variety of bank management processes, in particular the strategic

planning process, the ICAAP, the risk appetite framework and tangible equity allocation to business units. Capital plan

stress testing is performed to assess the viability of the bank’s capital plan in adverse circumstances and to demonstrate

a clear link between risk appetite, business strategy, capital plan and stress testing. The regulatory stress tests, e.g., the

EBA stress test and the US-based CCAR (Comprehensive Capital Analysis and Review) stress tests, are strictly following

the processes and methodologies as prescribed by the regulatory authorities.

Deutsche Bank’s internal stress tests are performed on a regular basis in order to assess the impact of severe economic

downturns as well as adverse bank-specific events on the bank’s risk profile and financial position. The bank’s stress

testing framework comprises regular sensitivity-based and scenario-based approaches addressing different severities

and regional hotspots. All material risk types are included in the stress testing activities. These activities are

complemented by portfolio- and country-specific downside analysis as well as further regulatory requirements, such as

annual reverse stress tests and additional stress tests requested by regulators on group or legal entity level. The applied

methodologies undergo regular scrutiny from Deutsche Bank’s internal validation team (Model Risk Management) to

ensure they correctly capture the impact of a given stress scenario. In addition, the group-wide stress framework is

subject to regular reviews by Deutsche Bank’s group audit function.

The initial phase of Deutsche Bank’s cross-risk stress test consists of defining a macroeconomic downturn scenario by

Enterprise and Treasury Risk Management (ETRM) Risk Research in cooperation with business specialists through a

formal governance forum, the Stress Working Group. ETRM Risk Strategy maintains a risk radar featuring key risk trends

and emerging risk themes including political and economic developments relevant for the design of potentially harmful

macroeconomic scenarios. Based on quantitative models and expert judgments, economic parameters such as foreign

exchange rates, interest rates, GDP growth or unemployment rates are set accordingly and define the narrative under

which the bank’s solvency position is assessed. The scenario parameters are translated into specific risk drivers by subject

matter experts in the risk units. Based on the bank’s internal model framework for stress testing, the following major

metrics are calculated under stress: risk-weighted assets, impacts on profit and loss and economic capital by risk type.

These results are aggregated at the Group level, and key metrics such as the CET 1 ratio, Total Capital ratio, Economic

Capital Adequacy ratio, MREL ratio and Leverage Ratio under stress are derived. Stress impacts on the Liquidity Coverage

Ratio (LCR) and other Liquidity indicators are also considered. Stress results are also communicated internally at a more

granular business unit level and considered in Deutsche Bank’s risk appetite as well as capital allocation processes. The

time horizon of internal stress tests ranges from one to five years, depending on the use case and scenario assumptions.

The Stress Working Group reviews the final stress results. After comparing these results against the bank’s defined risk

appetite, a specific mitigation strategy may be developed and applied to remediate the stress impacts in case of risk

appetite threshold breaches. The stress results also feed into the recovery planning which is crucial for the recoverability

of the bank in times of crisis. The outcome is presented to senior management up to the Management Board to raise

awareness on the highest level as it provides key insights into specific business vulnerabilities and contributes to the

overall risk profile assessment of the bank.

The Group-wide stress tests performed in 2025 indicated that the bank’s capitalization together with available mitigation

measures as defined in the Group Recovery Plan is adequate to reach the internally set stress exit levels.

The cross-risk reverse stress test leverages the GWST framework and is typically performed annually in order to

challenge Deutsche Bank’s business model by determining scenarios which would cause the bank to become unviable.

Such a reverse stress test is based on a hypothetical macroeconomic scenario enriched by idiosyncratic events based on

the top risks monitored by each risk type. Comparing the non-viability scenario to the current economic environment, the

probability of occurrence of such a hypothetical stress scenario is considered to be extremely low. Given this, it is the

bank’s view that its business continuity is not at risk.

In 2025, the bank has performed multi-year stress tests as part of the annual strategic planning process for 2025 using

two severe adverse scenarios, namely a “Severe EU-led global recession” scenario and a “Severe trade war” scenario. In

addition, further scenarios have been implemented (e.g., “US crisis of confidence”) aligned to the increased geopolitical

uncertainties.

In addition to the GWST that includes all material risk types and major revenue streams, Deutsche Bank has individual

stress test programs in place for all relevant risk metrics in line with regulatory requirements. The relevant stress test

programs are described in the sections about the individual risk management methods.


Deutsche Bank	Risk and capital framework
Annual Report 2025	Recovery and resolution planning

Recovery and resolution planning

In the EU, the Single Resolution Mechanism Regulation (SRM Regulation) and the Bank Recovery and Resolution

Directive (BRRD) aim at reducing the likelihood of another financial crisis, enhance the resilience of institutions under

stress, and eventually support the long-term stability of the financial systems without exposing taxpayers’ money to

losses.

In line with the provisions of the BRRD (which was mainly implemented in Germany by the German Recovery and

Resolution Act (Sanierungs- und Abwicklungsgesetz, SAG)) and the SRM Regulation, Deutsche Bank maintains a recovery

and resolution planning framework designed to identify and manage the impact of adverse events in a timely and

coordinated manner.

The bank maintains a group recovery plan specifying measures to restore the financial position following a significant

deterioration of its financial situation. The group recovery plan is updated at least annually and approved by the

Management Board.

The group resolution plan, on the other hand, is prepared by the resolution authorities, rather than by the bank itself.

Deutsche Bank works closely with the Single Resolution Board (SRB) and the Bundesanstalt für Finanzdienst-

leistungsaufsicht (BaFin) who establish the group resolution plan for Deutsche Bank, which is currently based on a single

point of entry open bank bail-in as the preferred resolution strategy. Under the single point of entry bail-in strategy, the

parent entity Deutsche Bank AG would be recapitalized through a write-down and/or conversion to equity of capital

instruments (Common Equity Tier 1, Additional Tier 1, Tier 2) and other eligible liabilities in order to stabilize the group.

Within one month after the application of the bail-in tool to recapitalize an institution, the BRRD (as implemented in the

SAG) requires such institution to prepare a business reorganization plan, addressing the causes of failure and aiming to

restore the institution's long-term viability. To further support and improve operational continuity of the bank for

resolution planning purposes, Deutsche Bank has completed additional preparations, such as adding termination stay

clauses into client financial agreements governed by non-EU law and including continuity provisions into key service

agreements. Financial contracts and service agreements governed by EU law are already covered by statutory laws

which prevent termination solely due to any resolution measure. Deutsche Bank regularly tests its capabilities and

processes to execute the preferred strategy in dry runs. In addition to the preferred resolution strategy, the bank is

further analyzing in close cooperation with the SRB and BaFin a variant resolution strategy, exploring the applicability of

the sale of business tool, the asset management vehicle, or the bridge bank in combination with the bail-in tool.

In the United States, Deutsche Bank AG is required under Title I of the Dodd-Frank Wall Street Reform and Consumer

Protection Act of 2010 (the Dodd-Frank Act), as amended, to prepare and submit to the Federal Reserve Board and the

Federal Deposit Insurance Corporation (FDIC) either a full or targeted resolution plan (the U.S. Resolution Plan) on a

timeline prescribed by such agencies. The U.S. Resolution Plan must demonstrate that Deutsche Bank AG has the ability

to execute and implement a strategy for the orderly resolution of its designated U.S. material entities and operations. For

foreign-based companies subject to these resolution planning requirements such as Deutsche Bank AG, the U.S.

Resolution Plan relates only to subsidiaries, branches, agencies and businesses that are domiciled in or whose activities

are carried out in whole or in material part in the United States. Deutsche Bank’s U.S. Resolution Plan describes the single

point of entry strategy for Deutsche Bank’s U.S. material entities and operations and prescribes that DB USA Corporation,

one of the bank’s intermediate holding companies, would provide the necessary liquidity and capital support to its U.S.

material entity subsidiaries and ensure their partial sale or solvent wind-down outside of applicable resolution

proceedings. Deutsche Bank submitted its most recent full U.S. Resolution Plan by the October 1, 2025 due date.

Deutsche Bank's next resolution plan submission is a targeted U.S. Resolution Plan that is due by July 1, 2028.


Deutsche Bank	Risk type management
Annual Report 2025	Capital Risk Management

Risk type management

Capital Risk Management

Internal capital adequacy assessment process

Deutsche Bank’s internal capital adequacy assessment process (ICAAP) consists of several components which ensure

that Deutsche Bank maintains sufficient capital to cover the risks to which the bank is exposed on an ongoing basis: s

–Risk identification and assessment: The risk identification process forms the basis of the ICAAP and results in an

inventory of risks for the Group; all risks identified are assessed for their materiality; further details can be found in

section “Risk identification and assessment”

–Capital demand/risk measurement: Risk measurement models are applied to quantify the regulatory and economic

capital demand which is required to cover all material risks except for those which cannot be adequately limited by

capital e.g., liquidity risk; further details can be found in sections “Risk profile” and “Capital, Leverage Ratio, TLAC and

MREL”

–Capital supply: Capital supply quantification refers to the definition of available capital resources to absorb

unexpected losses; further details can be found in sections “Capital, Leverage Ratio, TLAC and MREL” and “Economic

Capital Adequacy”

–Risk appetite: Deutsche Bank has established a set of qualitative statements, quantitative metrics and thresholds

which express the level of risk that Deutsche Bank is willing to assume to achieve strategic objectives; threshold

breaches are subject to a dedicated governance framework triggering management actions aimed to safeguard

capital adequacy; further details can be found in sections “Risk appetite and capacity” and “Capital risk limits”

–Capital planning: The risk appetite limits for capital adequacy metrics constitute boundaries which have to be met in

the capital plan to safeguard capital adequacy on a forward-looking basis; further details can be found in section

“Strategic and capital plan”

–Stress testing: Capital plan figures are also considered under various stress test scenarios to prove resilience and

overall viability of the bank; regulatory and economic capital adequacy metrics are also subject to regular stress tests

throughout the year to constantly evaluate Deutsche Bank’s capital position in hypothetical stress scenarios and to

detect vulnerabilities under stress; further details can be found in section “Stress testing”

–Capital adequacy assessment: Although capital adequacy is constantly monitored throughout the year, the ICAAP

concludes with a dedicated annual capital adequacy statement (CAS); the assessment consists of a Management

Board statement about Deutsche Bank’s capital adequacy, which is linked to specific conclusions and management

actions to be taken to safeguard capital adequacy on a forward-looking basis

As part of its ICAAP, Deutsche Bank distinguishes between a normative perspective and an economic internal

perspective. The normative internal perspective refers to a multi-year assessment of the ability to fulfil all capital-related

legal requirements and supervisory demands. The economic internal perspective refers to an internal process using

internal economic capital demand models and an internal economic capital supply definition. Both perspectives focus on

maintaining the continuity of Deutsche Bank on an ongoing basis under a baseline and an adverse scenario.


Deutsche Bank	Risk type management
Annual Report 2025	Capital Risk Management

Capital risk framework

Capital risk is defined as the risk that Deutsche Bank has an insufficient level or composition of capital supply to support

its current and planned business activities and associated risks during normal and stressed conditions.

The Group’s capital risk framework consists of several elements which aim to ensure that Deutsche Bank maintains on an

ongoing basis an adequate capitalization to cover the risks to which it is exposed. The framework is strongly integrated

with the bank-wide strategic planning process and closely linked to Deutsche Bank’s internal capital adequacy

assessment process. Treasury together with the divisions is the key risk manager of the associated risks and represents

the 1st LoD. Enterprise & Treasury Risk Management acts as the 2nd LoD for capital risk.

Enterprise & Treasury Risk Management sets the ICAAP framework, assesses the capital risk profile and provides

independent challenge to Treasury. This includes setting of risk appetite limits for key capital ratios. Limits also provide

boundaries to the capital plan and are fully integrated into the regular assessment of capital risk under stress scenarios.

Deutsche Bank’s Treasury function manages solvency, capital adequacy, leverage, and bail-in capacity ratios at Group

level and locally in each region, as applicable. Treasury develops Deutsche Bank’s capital plan, which is approved by the

Management Board. Treasury, directly or through the Group Asset and Liability Committee, manages, among other

things, issuance and repurchase of shares and capital instruments, hedging of capital ratios against foreign exchange

swings, the design of shareholders’ equity allocation, and regional capital planning.

Treasury manages the issuance and repurchase of capital instruments, namely Common Equity Tier 1, Additional Tier 1

and Tier 2 capital instruments as well as TLAC/MREL eligible debt instruments. Treasury constantly monitors the market

for liability management trades.

Treasury manages the sensitivity of Deutsche Bank’s CET 1 ratio and capital towards swings in foreign currency exchange

rates against the euro. For this purpose, Treasury develops and executes suitable hedging strategies within the

constraints of a Management Board approved Risk Appetite. Capital invested into Deutsche Bank’s foreign subsidiaries

and branches is either not hedged, partially hedged or fully hedged. Thereby, Treasury aims to balance effects from

foreign exchange rate movements on capital, capital deduction items and risk weighted assets in foreign currency. In

addition, Treasury also accounts for associated hedge cost and implications on market risk weighted assets.

Capital risk limits

Capital risk appetite is operationalized through limits for all relevant capital adequacy metrics. Breaches of limits are

governed by a dedicated escalation up to and including actions under Deutsche Bank’s Recovery Plan.

Limits are defined for the key capital ratios and reviewed at least annually by the Management Board as part of Deutsche

Bank's annual strategic and capital plan, including for CET 1 ratio, Tier 1 ratio, total capital ratio, MREL and ECA ratio. As

a part of Deutsche Bank’s quarterly process, the Group Risk Committee approves divisional limits for total capital

demand, leverage exposure and economic capital demand.

Overall regulatory capital requirements are principally driven by either Deutsche Bank’s CET 1 ratio or leverage ratio

requirements, whichever is the more binding constraint. For the internal capital allocation, the combined contribution of

each segment to the Group’s CET 1 ratio, the Group’s leverage ratio and the Group’s Capital Loss under Stress are

weighted to reflect their relative importance and level of constraint to the Group. Contributions to the CET 1 ratio and

the leverage ratio are measured through RWA and Leverage Ratio Exposure (LRE). The Group’s Capital Loss under Stress

is a measure of the Group’s overall economic risk exposure under a defined stress scenario. Goodwill, other intangible

assets, and business-related regulatory capital deduction items included in total capital demand are directly allocated to

the respective segments, supporting the calculation of the allocated tangible shareholders equity and the respective

rate of return.

Most of Deutsche Bank’s subsidiaries and several of Deutsche Bank’s branches are subject to legal and regulatory capital

requirements. In developing, implementing, and testing Deutsche Bank’s capital and liquidity position, the bank fully

takes such legal and regulatory requirements into account. Any material capital requests of Deutsche Bank’s branches

and subsidiaries across the globe are presented to and approved by the Group Investment Committee prior to execution.


Deutsche Bank	Risk type management
Annual Report 2025	Enterprise Risk Management

Enterprise Risk Management

ETRM provides a holistic view of the Bank’s risk profile across risk types, businesses and geographies. Key responsibilities

include:

–Defining the overarching risk management policy, including setting of risk management standards

–Setting and monitoring the Bank’s overarching risk appetite and cascading to business & entity dimensions

–Delivering insight through emerging risks and trends analysis, forward-looking stress tests, portfolio concentration,

deep-dive analyses and ad-hoc event reporting

–Developing and managing the climate risk management framework

–Providing risk reporting and analytics to key stakeholders, including senior management and regulators

–Acting as risk controlling function for credit risk including frameworks, risk appetite, reporting and portfolio analytics,

as well as model monitoring

Strategic risk

Strategic risk is the risk of a shortfall in planned earnings (excluding other material risks) due to incorrect business plans,

ineffective plan execution, or inability to effectively respond to material plan deviations. Strategic risk arises from the

exposure of the bank to the macroeconomic environment, changes in the competitive landscape, and regulatory and

technological developments. Additionally, it could occur due to errors in strategic positioning, the bank’s failure to

execute its planned strategy and/or a failure to effectively address underperformance versus plan targets.

The strategic plan is developed annually and presented to the Management Board for discussion and approval. The final

plan is presented to the Supervisory Board. The plan is challenged in an iterative process with respect to its assumptions,

credibility and integrity. During the year, execution of business strategies is regularly monitored to assess the

performance against targets. A more comprehensive description of this process is detailed in the section ‘Strategic and

Capital Plan’.

Strategic risk is measured through a dedicated risk model that quantifies potential losses caused by unexpected pre-tax

earnings shortfalls that cannot be offset by cost reductions under extreme but plausible market conditions over a 12-

month period. Strategic risk appetite is also established for the Group via dedicated metrics.

ETRM is the independent risk control function for Strategic Risk. A framework that includes setting risk appetite and

monitoring adherence is in place and aligns to the control standards the ETRM function set.


Deutsche Bank	Risk type management
Annual Report 2025	Enterprise Risk Management

Portfolio concentration risk

Risk concentrations refer to clusters of the same or similar risk drivers within specific risk types (intra-risk concentrations

in credit, market, operational and strategic risks) as well as across different risk types (inter-risk concentrations). They

occur within and across counterparties, businesses, regions/countries, industries and products. The management and

monitoring of risk concentrations is achieved through a quantitative and qualitative approach, as follows:

–Intra-risk concentrations are assessed, monitored and mitigated by the individual risk functions (enterprise, credit,

market, operational and liquidity risk management). This is supported by risk appetite including limit setting on

different levels and/or management according to each risk type

–Inter-risk concentrations are managed through quantitative top-down stress-testing and qualitative bottom-up

reviews, identifying and assessing risk themes independent of any risk type and providing a holistic view across the

bank. The diversification effects between credit, market, operational and strategic risk are measured through an

economic capital model that quantifies the diversification benefit caused by non-perfect correlations between these

risk types. The calculation of the risk type diversification benefit is intended to ensure that the standalone economic

capital figures for the individual risk types are aggregated in an economically meaningful way

The most senior governance body for the oversight of risk concentrations is the Group Risk Committee (GRC).

Environmental, social and governance risk

The impacts of rising global average temperatures, the transition to a net zero economy and the enhanced focus on

climate change from society, regulators and the banking sector have led to the emergence of new and increasing sources

of financial and non-financial risks. These include the physical risks arising from extreme weather events growing in

frequency and severity, as well as transition risks as carbon intensive sectors are expected to face higher taxation,

reduced demand and restricted access to financing. These risks can impact Deutsche Bank across a broad range of

financial and non-financial risk types. Financial institutions are facing increased scrutiny on climate and broader ESG-

related issues from governments, regulators, shareholders and other bodies, leading to reputational risks if the Group is

not seen to support the transition to a lower carbon economy, to protect biodiversity and human rights, among other

themes.

Deutsche Bank’s risk strategy recognizes ESG as a theme that represents a broad range of areas of concern related to

environmental, social, or governance factors that cuts across multiple scenarios and risks. It must be ensured that all

non-financial ESG-related risks are identified and adequately assessed to include potential impacts driven by ESG

factors; the bank must ensure that controls are effective and any potential deficiencies are promptly escalated and

addressed. Deutsche Bank is regularly reviewing and enhancing its ESG-related risk management frameworks in

alignment with regulatory guidance and to ensure that ESG risks are actively managed and greenwashing risk is

mitigated. Limitations in terms of data, methodologies and industry standards for measuring and assessing climate and

other environmental risks continue to lead to a high degree of uncertainty in the bank’s climate-related disclosures. Anti-

ESG measures that were already established in some jurisdictions and have been reinforced and taken further may result

in the loss of existing business and the inability to conduct new business within those jurisdictions, while complying may

lead to reputational risks.

The management of risks stemming from environmental factors relies first and foremost with Deutsche Bank’s net zero-

aligned decarbonization targets for eight sectors: Oil and Gas (upstream), Power Generation, Automotive (light duty

vehicles), Steel, Coal mining, Cement, Shipping and Commercial Aviation. The pathways to achieve these targets are

incorporated into the bank’s risk management framework. Environmental risks are assessed through an annual climate

and environmental materiality assessment and internal stress test, across businesses, portfolios and risk types (Credit,

Market, Liquidity, Reputational and Operational). They are monitored through dedicated reports discussed in senior risk

committees and managed through risk appetite thresholds, policies requirements and exclusions (Environmental and

Social policy framework), and portfolio Early Warning Indicators (EWIs). Climate and environmental risks are incorporated

into the credit approval process for corporate clients via enhanced due diligence requirements. For corporate clients in

carbon-intensive sectors, as well as those in sectors vulnerable to climate-physical and nature (or “other environmental”)

risks, new loan requests above selected tenor and rating-based thresholds to corporate clients in carbon-intensive

sectors require a dedicated risk assessment from the Front Office and review by Credit Risk Management. Overall, these

risks are embedded within the bank’s business model and financial planning through the carbon budgets attributed to

the bank’s businesses derived from its decarbonization targets and through the inclusion of environmental risks within

the Internal Capital Adequacy Assessment Process (ICAAP).

The Group Sustainability Committee acts as the main governance and decision-making body for sustainability-related

matters across Deutsche Bank. This includes the assessment of material impacts as well as risks and opportunities for the

Bank. The committee also sets the net zero targets for the bank.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Credit Risk Management

Credit risk framework

Credit risk arises from all transactions where actual, contingent or potential claims against any counterparty, borrower,

obligor or issuer (which Deutsche Bank refers to collectively as “counterparties”) exist, including those claims that

Deutsche Bank plans to distribute. It captures the risk of loss because of a deterioration of a counterparty’s

creditworthiness or the failure of a counterparty to meet the terms of any contract with Deutsche Bank or otherwise

perform as agreed.

Based on the Risk Type Taxonomy, credit risk is grouped into four material categories, namely default/migration risk,

transaction/settlement risk (exposure risk), mitigation risk and concentration risk. This is complemented by a regular risk

identification and materiality assessment.

–Default/migration risk as the main element of credit risk, is the risk that a counterparty defaults on its payment

obligations or experiences material credit quality deterioration increasing the likelihood of a default

–Transaction/settlement risk is the risk that arises from any existing, contingent or potential future positive exposure

–Mitigation risk is the risk of higher losses due to risk mitigation measures not performing as anticipated

–Credit concentration risk is the risk of an adverse development in a specific single counterparty, country, industry or

product leading to a disproportionate deterioration in the risk profile of Deutsche Bank’s credit exposures to that

counterparty, country, industry or product

Deutsche Bank manages its credit risk using the following principles:

–Credit Risk is only accepted:

–for adopted clients

–after completed appropriate due diligence led by the respective origination teams as 1st LoD

–New products and changes to existing products having been assessed within Deutsche Bank Group’s Product

Lifecycle Policy

–If a rating has been assigned in line with agreed and approved processes

–If all credit relevant exposures are correctly reflected in the relevant risk systems

–If plans for an orderly termination of the risk positions have been considered

–Credit Risk is assumed within the applicable Risk Appetite

–Profit and Loss responsibility for credit exposures is kept by and remains with the originating Group Division

–Risk taken needs to be adequately compensated

–Risk must be continuously monitored and managed across 1LoD and CRM/“Marktfolge” as well as 2LoD

–Credit standards are applied consistently across all Units in order to maintain a favorable risk profile in line with the

Risk Appetite

–Collateral or other risk mitigating, hedging or rating transfer instruments, which can be an alternative source of

repayment do not substitute for underwriting standards and a thorough assessment of the debt service ability of a

counterparty has to be performed during the credit process

–Deutsche Bank strives to adequately secure, guarantee or hedge outright cash risk and longer tenor-exposures; this

approach does usually not include lower risk short-term transactions and facilities supporting specific trade finance or

other lower risk products where the margin allows for adequate loss coverage

–Deutsche Bank measures and consolidates globally all exposure and facilities to the same Obligor

–Deutsche Bank has established within Credit Risk Management – where appropriate – specialized teams for deriving

internal client ratings, analyzing and approving transactions or covering workout clients; for transaction approval

purposes, structured credit risk management teams are aligned to the respective products or specific risks to

ascertain adequate product expertise

–Where required, Deutsche Bank has established processes to manage credit exposures at a legal entity or regional

level

To meet the requirements of Article 190 CRR, Deutsche Bank has allocated the various control requirements for the

credit processes to units/role holders best suited to perform such controls

Climate and environmental risks are integrated across the different stages of the credit lifecycle including transaction

approval/client onboarding, risk classification and credit ratings, portfolio analysis and monitoring and collateral

valuation.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Measuring credit risk

Credit risk is measured by credit rating, regulatory and internal capital demand and other key components like credit

limits as mentioned below.

The credit rating is an essential part of the bank’s underwriting and credit process and provides – amongst others – a

cornerstone for credit limit determination on an individual counterparty level, credit decision and transaction pricing as

well as the determination of regulatory capital demand for credit risk. Each counterparty must be rated, and each rating

has to be reviewed at least annually supported by ongoing monitoring of counterparties. A credit rating is a prerequisite

for any credit limit established/approved. For each credit rating, the appropriate rating approach has to be applied and

the derived credit rating has to be established in the relevant systems. Specific rating approaches have been established

to best reflect the respective characteristics of exposure classes, including specific product types, central governments

and central banks, institutions, corporates and retail.

Counterparties in the bank’s non-retail portfolios are rated by Deutsche Bank’s independent Credit Risk Management

function partly using automated or semi-automated rating systems. Given the largely homogeneous nature of the retail

portfolio, counterparty creditworthiness and ratings are derived by utilizing an automated decision engine. Country risk-

related ratings are provided by Enterprise and Treasury Risk Management (ETRM) Risk Research.

Deutsche Bank’s rating analysis is based on a combination of qualitative and quantitative factors. When rating a

counterparty, Deutsche Bank applies in-house assessment methodologies, as well as its 21-grade rating scale.

Changes to existing credit models and introduction of new models are approved by the Regulatory Credit Risk Model

Committee (RCRMC) chaired by the Head of Credit Risk Management before the models are used for credit decisions

and capital calculation for the first time or before they are significantly changed. Separately, for all model changes and

for new models an approval by Model Risk Management is required. Proposals with high impact are recommended for

approval to the Group Risk Committee. Furthermore, regulatory approval may also be required. The model validation is

performed independently of model development by Model Risk Management. The results of the regular validation

processes as stipulated by internal policies are brought to the attention of the RCRMC, even if the validation results do

not lead to a change.

Deutsche Bank measures risk-weighted assets to determine the regulatory capital demand for credit risk using

“advanced”, “foundation” and “standard” approaches of which “advanced” and “foundation” approaches are approved by

the bank’s regulator.

The advanced Internal Ratings Based Approach (IRBA) is the most sophisticated approach available under the regulatory

framework for credit risk and allows Deutsche Bank to make use of its internal credit rating models. These models

represent long-used key components of the internal risk measurement and management process supporting the credit

approval process, the economic capital and expected loss calculation and the internal monitoring and reporting of credit

risk. The relevant parameters include the probability of default (PD), the loss given default (LGD) and the maturity (M)

driving the regulatory risk-weight and the credit conversion factor (CCF) as part of the regulatory exposure at default

(EAD) estimation. For the majority of derivative counterparty exposures as well as securities financing transactions (SFT),

Deutsche Bank makes use of the internal model method (IMM) in accordance with CRR to calculate EAD. For most of the

bank’s internal rating systems, more than seven years of historical information is available to assess these parameters.

Deutsche Bank’s internal rating methodologies aim at point-in-time rather than a through-the-cycle rating, but in line

with regulatory solvency requirements, they are calibrated based on long-term averages of observed default rates.

The foundation IRBA is an approach available under the regulatory framework for credit risk allowing institutions to make

use of their internal rating methodologies while using pre-defined regulatory values for all other risk parameters.

Parameters subject to internal estimates include the PD while the LGD and the CCF are defined in the regulatory

framework. Foundation IRBA is applied mandatorily for some exposure classes since introduction of CRR3 and some

exposures stemming from ex-Postbank.

Deutsche Bank applies the standardized approach to a subset of its credit risk exposures. The standardized approach

measures credit risk either pursuant to fixed risk weights, which are predefined by the regulator, or through the

application of external ratings. Deutsche Bank assigns certain credit exposures permanently to the standardized

approach. Exposures to central governments or central banks make up the majority of the exposures carried in the

standardized approach and receive predominantly a risk weight of zero percent. Sovereign exposures that were treated

under IRBA previously have been moved to standardized approach under art. 494d CRR in 2025. For internal purposes,

however, these exposures are subject to an internal credit assessment and fully integrated in the risk management and

economic capital processes.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

In addition to the above-described regulatory capital demand, Deutsche Bank determines the internal capital demand

for credit risk via an economic capital model.

Deutsche Bank calculates economic capital for the default risk, country risk and settlement risk as elements of credit risk.

In line with the bank’s economic capital framework, economic capital for credit risk is set at a level to absorb with a

probability of 99.9% very severe aggregate unexpected losses within one year. Deutsche Bank’s economic capital for

credit risk is derived from the loss distribution of a portfolio via Monte Carlo Simulation of correlated rating migrations.

The loss distribution is modeled in two steps. First, individual credit exposures are specified based on parameters for the

probability of default, exposure at default and loss given default. In a second step, the probability of joint defaults is

modeled through the introduction of economic factors, which correspond to geographic regions and industries. The

simulation of portfolio losses is then performed by an internally developed model, which takes rating migration and

maturity effects into account as well as LGD volatility. Effects due to wrong-way derivatives risk (i.e., the credit exposure

of a derivative in the default case is higher than in non-default scenarios) are modeled by applying the bank’s own alpha

factor when deriving the exposure at default for derivatives and securities financing transactions under the CRR.

Deutsche Bank allocates expected losses and economic capital derived from loss distributions down to transaction level

to enable management on transaction, customer and business level.

Besides the credit rating, as a key component for managing the bank’s credit portfolio, including individual transaction

approval and the setting of risk appetite, Deutsche Bank establishes credit limits for all credit exposures. Credit limits set

forth maximum credit exposures Deutsche Bank is willing to assume over specified periods. In determining the credit

limit for a counterparty, Deutsche Bank considers the counterparty’s credit quality above others by reference to its

internal credit rating. Credit limits and credit exposures are both measured on a gross and net basis where net is derived

by deducting appropriate hedges and certain collateral from respective gross figures. For derivatives, Deutsche Bank

looks at current market values and the potential future exposure over the relevant time horizon, which is based upon the

bank’s legal agreements with the counterparty.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

IFRS 9 Impairment

In the following chapter, the Group provides an overview of the IFRS 9 impairment framework, model updates and

methodology implemented in 2025 as well as key model assumptions and its changes. Further explanations are provided

regarding the development of management overlays applied to the credit loss allowance, how reviews of relevant

assumptions and inputs to the ECL calculation are performed and how potential model imprecisions are assessed. To

provide additional transparency on the impact of reasonable changes to the key assumptions, model sensitivities are

presented in a separate section below which concludes with the key drivers for the IFRS 9 model results.

Description of IFRS 9 model and methodology

The impairment requirements of IFRS 9 apply to all credit exposures that are measured at amortized cost or fair value

through other comprehensive income and to off balance sheet lending commitments, such as loan commitments and

financial guarantees. For purposes of the bank’s impairment approach, the Group refers to these instruments as financial

assets.

The Group determines its allowance for credit losses in accordance with IFRS 9 as follows:

–Stage 1 reflects financial assets where it is assumed that credit risk has not increased significantly after initial

recognition

–Stage 2 contains all financial assets, that are not defaulted, but have experienced a significant increase in credit risk

since initial recognition

–Stage 3 consists of financial assets which are deemed to be in default in accordance with Deutsche Bank’s policies,

which are based on the Capital Requirements Regulation (CRR) Article 178. The Group defines these financial assets

as impaired, non-performing and defaulted

–Significant increase in credit risk is determined using quantitative and qualitative information based on the Group’s

historical experience, credit risk assessment and forward-looking information

–Purchased or Originated Credit-Impaired (POCI) financial assets are assets where at the time of initial recognition,

there is objective evidence of impairment and the Group purchased at a discount

The IFRS 9 impairment approach is an integral part of the Group’s credit risk management procedures. The estimation of

ECL is either performed via the automated, parameter based ECL calculation using the Group’s ECL model or determined

by credit officers. In both cases, the calculation takes place for each financial asset individually. Similarly, the

determination of the need to transfer between stages is made on an individual asset basis. The Group’s ECL model is

used to calculate the allowance for credit losses for all financial assets in Stage 1 and Stage 2, as well as for Stage 3 in

the homogeneous portfolio (i.e., retail and small business loans with similar credit risk characteristics). For financial assets

in the bank’s non-homogeneous portfolio in Stage 3 and for POCI assets, the allowance for credit losses is determined

individually by credit officers.

The Group uses three main components to measure ECL. These are Probability of Default (PD), Loss Given Default (LGD)

and Exposure at Default (EAD). The Group leverages existing parameters used for determination of capital demand under

the Basel Internal Ratings Based Approach (IRBA) and internal risk management practices as much as possible to

calculate ECL. These parameters are adjusted where necessary to comply with IFRS 9 requirements (e.g., use of point in

time ratings and removal of downturn add-ons in the regulatory parameters). Incorporating forecasts of future economic

variables into the measurement of ECL influences the allowance for credit losses. In order to calculate lifetime ECL, the

Group’s calculation derives the corresponding lifetime PDs from migration matrices that reflect economic forecasts.

The Group regularly reviews and validates the ECL model and its components which can result in model updates,

including recalibrations and model changes, of which some may constitute a change in estimate. Any future model

updates may have an impact on ECL and therefore represent a model uncertainty which cannot be reliably quantified.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Stage determination and significant increase in credit risk

At initial recognition, financial assets are reflected in Stage 1, unless the financial assets are POCI. If there is a significant

increase in credit risk, the financial asset is transferred to Stage 2. A significant increase in credit risk is determined by

using rating-related and process-related indicators. The transfer of financial assets to Stage 3 is based on the status of

the borrower being in default. If a borrower is in default, all financial assets of the borrower are transferred to Stage 3.

Rating-related Stage 2 indicators: In the third quarter of 2025 Deutsche Bank introduced a change to the rating-related

Stage 2 indicator approach, in which the Group compares a borrower’s lifetime PD at the reporting date with lifetime PD

expectations at the date of initial recognition to determine if there has been a significant change in the borrower’s PDs

and consequently to any of the borrower’s transaction in the scope of IFRS 9 impairment. Previously the model

determined the lifetime PD distribution based on historically observed migration behavior and a sampling of different

economic scenarios. A quantile of this distribution, which was defined for each counterparty class, was chosen as the

lifetime PD threshold. If the remaining lifetime PD of a transaction according to current expectations exceeded this

threshold, the financial asset was deemed to have incurred a significant increase in credit risk and was transferred to

Stage 2. The new approach compares the annualized lifetime PD at reporting date with the annualized conditional

lifetime PD expectation at origination. A relative and an absolute threshold are used for the comparison, which

represents a key assumption in the model. Different relative thresholds are applied to low-risk assets defined by an

annualized conditional PD at origination of 0.5% or below compared to the remaining high-risk assets. The relative

threshold for high-risk assets is 63% PD increase and for low-risk assets is 131% PD increase, floored by an absolute

threshold of 5.05% PD increase. If one of the newly introduced thresholds is breached, the financial asset is deemed to

have incurred a significant increase in credit risk and is transferred to Stage 2. This change in estimate led to an increase

of the credit loss allowance in the amount of € 15 million at the time of implementation and impacted Stages 1 and 2 in

all portfolios. In addition, the Group applied a threefold annualized lifetime PD increase as additional Stage 2 trigger as a

backstop until the implementation of the new rating related approach. This new approach always identifies assets

subject to the backstop as Stage 2 already.

Process-related Stage 2 indicators are derived via the use of existing risk management indicators, which in the bank’s

view represent situations where the credit risk of financial assets has significantly increased. These include borrowers

being added to the Group’s watchlist, being transferred to workout status, payments being 30 days or more past due or

being in forbearance. As long as the condition for one or more of the process-related or rating-related indicators is

fulfilled and the borrower of the financial asset has not met the definition of default, the asset will remain in Stage 2. If

the Stage 2 indicators are no longer fulfilled and the financial asset has not defaulted, the financial asset transfers back

to Stage 1. In case of performing forborne financial assets, the probation period is two years before the financial asset is

reclassified to Stage 1, which is aligned with regulatory guidance.

If the borrower defaults, all transactions of the borrower are allocated to Stage 3. If, at a later date, the borrower is no

longer in default, the curing criteria according to regulatory guidance is applied (including probation periods), which are

at least three months or one year in case of distressed restructurings. Once the regulatory cure period or criteria has been

met, the borrower will cease to be classified as defaulted and will be transferred back to Stage 2 or Stage 1.

The ECL calculation for Stage 3 distinguishes between transactions in the homogeneous and non-homogeneous

portfolios, as well as POCI financial assets. For transactions that are in Stage 3 and in a homogeneous portfolio, the

Group uses a parameter-based automated approach to determine the credit loss allowance per transaction. For these

transactions, the LGD parameters are to a large extent modelled to be time-dependent, i.e., consider the declining

recovery expectation as time elapses after default. The allowance for credit losses for financial assets in the bank’s non-

homogeneous portfolios in Stage 3, as well as for POCI assets are determined by credit officers and have to be approved

along an established authority grid up to and including the Management Board. This allows credit officers to consider

currently available information and recovery expectations specific to the borrowers and the financial assets at the

reporting date.


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Annual Report 2025	Credit Risk Management

Estimation techniques for key input factors

The first key input factor in the Group ECL calculation is the one-year PD for borrowers which is derived from the bank’s

internal rating systems. The Group assigns a PD to each borrower credit exposure based on a 21-grade master rating

scale for all of the Group’s exposure.

The borrower ratings assigned are derived based on internally developed rating models which specify consistent and

distinct customer-relevant criteria and assign a rating grade based on a specific set of criteria as given for a certain

customer. The set of criteria is generated from information sets relevant for the respective customer segments including

general customer behavior, financial and external data (e.g., credit bureau). The methods in use range from statistical

scoring models to expert-based models taking into account the relevant available quantitative and qualitative

information. Expert-based models are usually applied for borrowers in the exposure classes “Central governments and

central banks”, “Institutions” and “Corporates” with the exception of those “Corporates” for which a sufficient data basis

is available for statistical scoring models. For the latter, as well as for the retail segment, statistical scoring or hybrid

models combining both approaches are commonly used. Quantitative rating methodologies are developed based on

applicable statistical modelling techniques, such as logistic regression.

One-year PDs are extended to multi-year PD curves using through-the-cycle matrices and macroeconomic forecasts.

Based on economic scenarios centered around the macroeconomic baseline forecast, through-the-cycle matrices are

first transformed into point-in-time rating migration matrices, typically for a two-year period. The calculation of the

point-in-time matrices provides the link between macroeconomic variables and the default and rating behavior of

borrowers, which is derived from time series through regression techniques involving macroeconomic variables (MEVs)

and historical rating and default data. In a final step, multi-year PD curves are derived from point-in-time rating migration

matrices for periods where reasonable and supportable forecasts are available and extrapolated based on through-the-

cycle rating migration matrices beyond those periods.

The second key input factor into the ECL calculation is the LGD parameter, which is defined as the likely loss intensity in

case of a borrower’s default. It provides an estimation of the exposure that cannot be recovered in a default event and

therefore captures the severity of a loss. Conceptually, LGD estimates are independent of a borrower’s probability of

default. The LGD models applied in Stages 1 and 2, which are based on regulatory LGD models, but adjusted for IFRS 9

requirements (i.e., removal of downturn-add-on and removal of indirect costs of workout), ensure that the main drivers

for losses (i.e., different levels and quality of collateralization and customer or product types or seniority of facility) are

reflected as risk drivers in LGD estimates. In June 2025, the Group introduced a model update with regard to the Loss

Given Default (LGD) parameter used in the IFRS 9 accounting framework, primarily to align with the corresponding

models implemented in the solvency framework following regulatory guidelines. This change in estimate led to a net

reduction of the credit loss allowance in the amount of € 133 million at the time of implementation and impacted all

stages. The most pronounced reduction of the credit loss allowance was observed in the Private Bank. In the Corporate

Bank and Investment Bank the net impact was primarily in stages 1 and 2 and less pronounced. However, for certain

underlying portfolios such as CRE, a more pronounced increase in credit loss allowance was observed, which was offset

by a reduction of credit loss allowance in other underlying portfolios in these businesses.

In the third quarter of 2025 the Group continued to validate the model performance of relevant feeder and receiver

models. Three probability of default (PD) models and one LGD model were recalibrated on that basis which led to a net

increase in the credit loss allowance in the amount of € 110 million, impacting all stages, mainly in the Investment Bank

and Private Bank.

Forward-looking information (FLI) is also incorporated into LGD projections in terms of FLI LGD scaling factors based on

forecasts for key MEVs. LGD adjustments are quantified relative to long-term historical averages, which represent a

neutral reference point throughout an economic cycle.

The LGD setting for defaulted homogeneous portfolios is partially dependent on time after default and are either

calibrated based on the Group’s multi-decade loss and recovery experience using statistical methods or for less

significant portfolios certain LGD model input parameters (e.g., cure rates) are determined by expert judgement.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

The third key input factor is the exposure at default over the lifetime of a financial asset which is modelled taking into

account expected repayment profiles (e.g., linear amortization, annuities, bullet loan structures). Prepayment options are

modelled for some portfolios. The bank applies specific credit conversion factors (CCFs) in order to calculate an EAD

value. Conceptually, the EAD is defined as the expected amount of the credit exposure to a borrower at the time of its

default. In instances where a transaction involves an unused limit, a percentage share of this unused limit is added to the

outstanding amount in order to appropriately reflect the expected outstanding amount in case of a borrower’s default.

This reflects the assumption that for commitments, the utilization at the time of default might be higher than the current

outstanding balance. In case a transaction involves an additional contingent component (i.e., guarantees) a further

percentage share is applied as part of the CCF model in order to estimate the amount of guarantees drawn in case of

default. The calibrations of such parameters are based on internal historical data and are either based on empirical

analysis or supported by expert judgement and consider borrower and product type specifics. Where supervisory CCF

values need to be applied for regulatory purposes, internal estimates are used for IFRS 9.

Expected lifetime

IFRS 9 requires the determination of lifetime ECL for which the expected lifetime of a financial asset is a key input factor.

Lifetime ECL represent default events over the expected life of a financial asset. The Group measures ECL considering

the risk of default over the maximum contractual period (including any borrower’s extension options) over which the

Group is exposed to credit risk.

Retail overdrafts, credit card facilities and certain corporate revolving facilities typically include both a loan and an

undrawn commitment component. The expected lifetime of such on-demand facilities exceeds their contractual life as

they are typically cancelled only when the Group becomes aware of an increase in credit risk. The expected lifetime is

estimated by taking into consideration historical information and the Group’s credit risk management actions such as

credit limit reductions and facility cancellation. Where such facilities are subject to an individual review by credit risk

management, the lifetime for calculating ECL is 12 months. For facilities not subject to individual review by credit risk

management, the bank applies a lifetime for calculating ECL of 24 months.

Interest rate used in the IFRS 9 model

In the context of the ECL calculation, the Group applies in line with IFRS 9 an approximation of the effective interest rate

(EIR), which is usually the contractual interest rate. The contractual interest rate is deemed to be an appropriate

approximation, as the interest rate is consistently used in the ECL model, interest recognition and for discounting of the

ECL and does not materially differ from the EIR.

Consideration of collateralization in IFRS 9 Expected Credit Loss calculation

The ECL model projects the level of collateralization for each point in time in the life of a financial asset. At the reporting

date, the model uses a collateral distribution process that allocates the value of each eligible collateral to relevant

financial assets. In the ECL calculation, the Group subsequently calculates the collateralization resulting from physical

collateral that enters the LGD model as a risk driver based on the allocated collateral value and the exposure value of the

financial asset.

For personal collateral (e.g., guarantees), the ECL model assumes that the relative level of collateralization remains

stable over time. In the case of an amortizing loan, the outstanding exposure and collateral values decrease together

over time. For physical collateral (e.g., real estate property), the ECL shall assume that the absolute collateral value

remains constant. In case of an amortizing loan, the collateralized part of the exposure increases over time and the loan-

to-value decreases accordingly.

Certain financial guarantee contracts are integral to the financial assets guaranteed. In such cases, the financial

guarantee is considered as collateral for the financial asset and the benefit of the guarantee is used to mitigate the ECL

of the guaranteed financial asset.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Forward looking information

Under IFRS 9, the allowance for credit losses is based on reasonable and supportable forward-looking information

available without undue cost or effort, which takes into consideration past events, current conditions and forecasts of

future economic conditions.

To incorporate forward looking information into the Group’s allowance for credit losses, the bank uses two key elements:

–As its base scenario, the Group uses external survey-based macroeconomic forecasts (e.g., consensus views on GDP

and unemployment rates); in addition, the scenario expansion model, which has been initially developed for stress

testing, is used for forecasting macroeconomic variables that are not covered by external consensus data; all

forecasts are assumed to reflect the most likely development of the respective variables; the Group regularly updates

its forecasts for macro-economic factors during the quarter and reviews aspects of potential model imprecision (e.g.,

MEV parameters outside the historic range used for model calibration, if not already included in the model) as part of

an MEV monitoring framework to assess if an overlay is required

–Statistical techniques are then applied to transform the base scenario projections into a probability distribution of the

macroeconomic variables; these scenarios specify deviations from the baseline forecasts; the scenario distribution is

then used for deriving multi-year PD curves for different rating and counterparty classes, which are applied in the ECL

calculation and in the identification of significant deterioration in credit quality of financial assets as described above

in the rating-related Stage 2 indicators

The Group's Risk and Finance Credit Loss Provision Forum monitors the impact of forward-looking information, including

the latest macroeconomic variables, on a quarterly basis and determines if any additional overlays are required. Although

interest rates and inflation are not separately included in the MEVs, the economic impact of these risks is reflected in

GDP growth rates, unemployment, equities and credit spreads as higher rates and inflation filter through these forecasts.

As of December 31, 2025, the consensus data applied in the ECL model was deemed to have reflected the latest

macroeconomic developments and after considering all relevant uncertainties in the MEVs no additional overlays were

required.

As described earlier, the Group’s approach to reflect forward-looking information into the calculation of ECL is to

incorporate forecasts for the next two to three years into PD and LGD projections. For periods beyond those covered in

terms of reasonable and supportable economic forecasts, reversion to historically observed behavior of defaults, rating

migrations and recoveries is used for ECL measurement.

The tables below contain relevant forward-looking information by macroeconomic variable included in the Group’s IFRS

9 model as of December 31, 2025, and as of December 31, 2024.


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	December 31, 20241 2
	Year 1 (4 quarter avg)	Year 2 (4 quarter avg)
GDP - USA	2.23%	2.04%
GDP - Eurozone	1.04%	1.19%
GDP - Germany	0.38%	1.14%
GDP - Italy	0.74%	1.02%
GDP - Developing Asia	4.53%	4.26%
GDP - Emerging Markets	4.11%	3.81%
Unemployment - USA	4.29%	4.20%
Unemployment - Eurozone	6.46%	6.42%
Unemployment - Germany	3.46%	3.40%
Unemployment - Italy	6.50%	6.76%
Unemployment - Spain	11.12%	10.93%
Unemployment - Japan	2.48%	2.40%
Real Estate Prices - CRE Index USA	312.27	316.81
Real Estate Prices - CRE Index Eurozone	107.75	108.39
Real Estate Prices - House Price Index USA	325.05	333.47
Real Estate Prices - House Price Index Germany	152.78	158.19
Real Estate Prices - House Price Index Spain	1,959.68	2,000.70
Equity - S&P500	6,109	6,436
Equity - Eurostoxx50	4,965	5,162
Equity - DAX40	20,131	20,968
Equity - MSCI EAFE	1,069	1,112
Equity - MSCI Asia	1,602	1,630
Equity - Nikkei	38,972	39,582
Credit - High Yield Index	312.32	358.66
Credit - CDX High Yield	332.33	374.29
Credit - CDX IG	56.50	64.29
Credit - CDX Emerging Markets	177.90	202.59
Credit - ITX Europe 125	62.15	68.66
Commodity - WTI	70.46	65.85
Commodity - Gold	2,588.02	2,612.91

1 MEV as of December 5, 2024, based on Bloomberg Consensus, which barely changed until December 31, 2024

2 Year 1 equals fourth quarter of 2024 to third quarter of 2025, Year 2 equals fourth quarter of 2025 to third quarter of 2026

Model sensitivity

The Group has identified three key model assumptions included in the IFRS 9 model. These include forward looking

macroeconomic variables, the quantitative criteria for determining if a borrower has incurred a significant increase in

credit risk and is transferred to Stage 2, and the LGD setting on homogeneous portfolios in Stage 3. Below the bank

provides sensitivity analysis on the potential impact if these key assumptions applied in the ECL model were to deviate

from the bank’s base case expectations.

Macroeconomic variables

The sensitivity of the ECL model with respect to potential changes in projections for key MEVs is shown in the tables

below, which provides ECL impacts for Stages 1 and 2 from downward and upward shifts applied separately to each

group of MEV as of December 31, 2025, and December 31, 2024. The magnitude of the shifts is selected in the range of

one standard deviation, which is a statistical measure of the dispersion of the values of a random variable. Each of these

groups consists of MEVs from the same category:

–GDP growth rates: includes USA, Eurozone, Germany, Italy, Developing Asia, Emerging Markets

–Unemployment rates: includes USA, Eurozone, Germany, Italy, Japan, Spain

–Equities: S&P500, Eurostoxx50, DAX 40, Nikkei, MSCI Asia, MSCI EAFE

–Credit spreads: ITX Europe 125, High Yield Index, CDX IG, CDX High Yield, CDX Emerging Markets

–Real Estate: CRE Index Eurozone, House Price Index USA, House Price Index Germany, House Price Index Italy, House

Price Index Spain

–Commodities: WTI oil price, Gold price


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Although interest rates and inflation are not included in the above set of MEVs, adverse effects associated with changes

in these risk drivers typically manifest themselves in other economic forecasts incorporated in the ECL model, such as

lower GDP growth, higher unemployment or wider credit spreads.

In addition, the sensitivity analysis only includes the impact of the aggregated MEV group (i.e., potential correlations

between different MEV groups or the impact of management overlays is not taken into consideration). ECL quantification

for Stage 3 does not follow a model-based process for various portfolios and is therefore excluded from the following

tables.

Compared to December 31, 2024, calculation of sensitivities are reflective of ECL model updates that went live in 2025,

including updates to the LGD parameter used in the IFRS9 accounting framework and the Significant Increase in Credit

Risk (SICR) model for staging assessment. The effects of both FLI impacting PDs and FLI impacting LGDs were already

reflected in the 2024 sensitivities. As of December 31, 2025, sensitivities additionally capture the extension of the FLI

LGD model to ex‑Postbank portfolios, resulting in higher sensitivities to real estate prices. Furthermore, the overall

increase in sensitivities observed for GDP, unemployment and real estate prices is also driven by a higher ECL baseline

level compared to last year.

IFRS 9 – Sensitivities of forward-looking information applied on Stage 1 and Stage 2 – Group Level


	December 31, 2025
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(76.3)	(1)pp	87.2
Unemployment rates	(0.5)pp	(49.4)	0.5pp	51.6
Real estate prices1	5%	(35.3)	(5%)	40.1
Equities	10%	(17.1)	(10%)	23.7
Credit spreads	(40%)	(19.5)	40%	21.6
Commodities2	10%	(6.9)	(10%)	7.4


	December 31, 2024
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(66.4)	(1)pp	71.8
Unemployment rates	(0.5)pp	(44.9)	0.5pp	49.0
Real estate prices1	5%	(13.9)	(5%)	16.0
Equities	10%	(14.1)	(10%)	17.8
Credit spreads	(40%)	(20.7)	40%	24.2
Commodities2	10%	(7.7)	(10%)	8.7

1 For a more severe stress test relating to the CRE portfolio that also takes into consideration existing and potential exposure in Stage 3 reference is made to the section on

Commercial Real Estate above

2Here the sign of the shift applies to oil prices changes. Gold price changes have the opposite sign. 1pp (percentage point), e.g., GDP shifts from 3% to 4% // 1%

(percentage change), e.g., Real estate price shifts from 100 to 101

At divisional level, the sensitivity analysis below was performed for the year ended December 31, 2025, and 2024,

respectively, and revealed GDP growth rates, credit spreads and commodities prices to be the dominant factors for the

Investment Bank, whereas the model sensitivity for the Corporate Bank and Private Bank is mainly associated with

changes in GDP growth rates and unemployment rates. The model sensitivity table for the Private Bank shows GDP

growth rates and unemployment rates only, as the key MEVs relevant to the underlying portfolios.


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Annual Report 2025	Credit Risk Management

IFRS 9 – Sensitivities of forward-looking information applied on Stage 1 and Stage 2 - Corporate Bank


	December 31, 2025
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(16.0)	(1)pp	19.2
Unemployment rates	(0.5)pp	(11.0)	0.5pp	12.2
Real estate prices1	5%	(4.3)	(5)%	5.4
Credit spreads	(40)%	(4.1)	40%	4.5
Commodities2	10%	(2.2)	(10)%	2.4


	December 31, 2024
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(18.2)	(1)pp	20.3
Unemployment rates	(0.5)pp	(12.6)	0.5pp	14.2
Real estate prices1	5%	(2.1)	(5)%	2.2
Credit spreads	(40)%	(4.5)	40%	5.0
Commodities2	10%	(2.8)	(10)%	3.1

1 For a more severe stress test relating to the CRE portfolio that also takes into consideration existing and potential exposure in Stage 3 reference is made to the section on

Commercial Real Estate below

2 Here the sign of the shift applies to oil prices changes. Gold price changes have the opposite sign.

IFRS 9 – Sensitivities of forward-looking information applied on Stage 1 and Stage 2 - Investment Bank


	December 31, 2025
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(36.1)	(1)pp	41.5
Unemployment rates	(0.5)pp	(10.7)	0.5pp	11.6
Real estate prices1	5%	(19.4)	(5)%	21.5
Equities	10%	(5.6)	(10)%	9.3
Credit spreads	(40)%	(14.0)	40%	15.7
Commodities2	10%	(4.4)	(10)%	4.7


	December 31, 2024
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(26.4)	(1)pp	28.9
Unemployment rates	(0.5)pp	(11.0)	0.5pp	12.1
Real estate prices1	5%	(8.5)	(5)%	10.2
Equities	10%	(4.7)	(10)%	5.9
Credit spreads	(40)%	(13.5)	40%	16.2
Commodities2	10%	(4.6)	(10)%	5.3

1 For a more severe stress test relating to the CRE portfolio that also takes into consideration existing and potential exposure in Stage 3 reference is made to the section on

Commercial Real Estate below

2 Here the sign of the shift applies to oil prices changes. Gold price changes have the opposite sign.


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IFRS 9 – Sensitivities of forward-looking information applied on Stage 1 and Stage 2 - Private Bank


	December 31, 2025
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(22.6)	(1)pp	24.6
Unemployment rates	(0.5)pp	(26.9)	0.5pp	26.8


	December 31, 2024
	Upward sensitivity		Downward sensitivity
	Upward shift	ECL impact in € m.	Downward shift	ECL impact in € m.
GDP growth rates	1pp	(18.3)	(1)pp	19.3
Unemployment rates	(0.5)pp	(19.5)	0.5pp	20.6

Impact of lifetime expected credit losses for Stage 1 borrowers

As described above, the Group uses a mixture of quantitative and qualitative criteria to determine significant increase in

credit risk which require, for affected borrowers, a move to lifetime ECL (Stage 2). If for all Stage 1 borrowers Deutsche

Bank were to record lifetime expected credit losses, the Group’s allowance for credit losses amounting to € 6.6 billion as

of December 31, 2025 and € 6.2 billion as of December 31, 2024 which would represent an increase of approximately

28% for year end 2025 and 34% for year end 2024, respectively.

Stage 3 LGD setting

The Group’s allowance for credit losses in Stage 3 for the homogeneous portfolios amounts to € 2.4 billion as of

December 31, 2025 and € 2.3 billion as of December 31, 2024. The key driver in determining the ECL provision is the loss

given default estimate, which differs by individual portfolios. Loss given default is influenced by recovery rates, proceeds

from the sale of collateral, and cure rates. Some of the drivers for different portfolios include elements of expert

judgment in particular on expected cure rates. If the LGD for all homogeneous portfolios were to increase by 1%, then

Stage 3 ECL would increase as of December 31, 2025 by approximately € 28 million (thereof € 20 million in Germany,

€ 5 million in Italy and € 2 million in Spain), and by approximately € 26 million as of December 31, 2024 (thereof

€ 17 million in Germany, € 5 million in Italy and € 2 million in Spain).

Management overlays applied to the IFRS 9 model output

The Group regularly reviews the IFRS 9 methodology and processes, key inputs into the ECL calculation and discusses

upcoming model changes, potential model imprecisions or other estimation uncertainties, for example in the

macroeconomic environment to determine if any material overlays are required. Moreover, regular reviews for evolving or

emerging risks are performed, especially in the current geopolitical environment. Measures applied include client surveys

and interviews, along with analysis of portfolios across businesses, regions and sectors. In addition, the Group regularly

reviews and validates key model inputs and assumptions (including those in feeder models) and ensures where expert

judgement is applied, it is in line with the Group’s risk management framework. As of December 31, 2025, the Group had

two existing overlays, one existing overlay reflected a model refinement related to refinancing risk which had not yet

been implemented and a newly created overlay to reflect observations from the bank's portfolio reviews and credit risk

assessments. Apart from these known model weaknesses and overlays, the group did not identify any additional model

weaknesses which would require an overlay.

As of year end 2025, the Group’s IFRS9 management overlays amounted to €156 million, compared to €124 million for

year end 2024 (which resulted in an increase of Allowance for Credit Losses in both periods). Management overlays as of

year end 2025 encompassed two main items, as mentioned above: Expected impacts from a model refinement related to

refinancing risk and observations from the bank’s portfolio reviews and credit risk assessments. The overlay relating to

refinancing risk existed already in 2024 and has been adjusted during 2025. Additionally, at the end of 2024, the Group

recorded an overlay with regard to a PD parameter recalibration, which was released in 2025. The change to

management overlays during the year 2025 was primarily driven by dedicated tariff overlays taken in view of the impacts

from U.S. tariff announcements during the first quarter which were released during the year.


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Annual Report 2025	Credit Risk Management

Overall Assessment of ECL’s

To ensure that Deutsche Bank’s ECL model accounted for the uncertainties in the macroeconomic environment

throughout 2025, the Group continued to review emerging risks, assessed potential baseline and downside impacts and

required actions to manage the bank’s credit strategy and risk appetite. The outcome of these reviews concluded that

the bank adequately provisioned for its expected credit losses as of December 31, 2025, and December 31, 2024.

Results from the above reviews and development of key portfolio indicators are regularly discussed at the Credit Risk

Appetite and Management Forum and Group Risk Committee and as appropriate at the Management Board and the

Audit Committee. Where necessary, actions and measures are taken to mitigate the risks. Client ratings are regularly

reviewed to reflect the latest macroeconomic developments and where potentially significant risks are identified clients

are moved to the watchlist (Stage 2), forbearance measures may be negotiated, and credit limits and collateralization are

reviewed. Overall, the Group believes that based on its day-to-day risk management activities and regular reviews of

emerging risks it has adequately provided for its ECL.

IFRS 9 model results

Provision for credit losses was €1.7 billion in 2025, down from €1.8 billion in 2024 and 35 basis points (bps) of average

loans, in line with the guidance the bank provided after the third quarter. The decrease was primarily driven by lower

Stage 3 provisions, notwithstanding persistently elevated provisions for the commercial real estate sector. This was

partially offset by higher Stage 1 and Stage 2 provisions resulting from model-related effects.

With regard to climate risks, estimates of higher transition and physical risk exposures and their impact on the ECL did not

result in any adjustment of credit loss provisions for the years ended December 31, 2025 as well as December 31, 2024.

For details of the provision for credit losses related to the segments, please refer to section “Segment results of

operations”.

For details on the Group’s accounting policy related to IFRS 9 Impairment, please refer to Note 01 “Material accounting

policies and critical accounting estimates” of the consolidated financial statements.


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Managing and mitigation of credit risk

Managing credit risk on counterparty level

Credit-relevant counterparties are principally allocated to credit officers within credit teams which are organized by type

of counterparty (such as financial institutions, corporates or private individuals), economic area (e.g., emerging markets)

or product and supported by dedicated rating analyst teams where deemed necessary, except for retail clients, which are

managed by the sales unit. The individual credit officers have the relevant expertise and experience to manage the credit

risks associated with these counterparties and their associated credit related transactions. For retail clients, credit

decision making and credit monitoring is highly automated due to standardized products and processes. Credit Risk

Management has oversight of the respective processes and tools used in these highly automated retail credit processes.

It is the responsibility of each credit authority holder or credit officer to undertake ongoing credit monitoring for their

allocated counterparties. Deutsche Bank also has procedures in place intended to identify credit exposures for which

there may be an increased risk of deteriorated risk/loss at an early stage.

In instances where Deutsche Bank has identified counterparties with emerging concern about their credit quality

deteriorating or likely to deteriorate to the point where they present a heightened risk of default/loss, the respective

counterparty is generally placed on the “Watchlist”. Deutsche Bank aims to identify those counterparties at an early

stage to ensure that credit exposures with increased risks are effectively managed, the Bank’s risk management tools are

appropriately applied aiming to minimize potential losses. The objective of this early warning system is to address

potential problems while adequate options for action are still available. This early risk detection is a tenet of Deutsche

Bank’s credit culture and is designed to raise management awareness of these positions.

Credit limits for individual counterparties are established by the Credit Risk Management function (except for retail

clients) applying credit authorities assigned to individual Credit Officers. This also applies to settlement risk that must fall

within limits pre-approved by Credit Risk Management and in a manner that reflects expected settlement patterns for

the subject counterparty. Credit approvals are documented by electronic signature under 4-eye principle by the

respective credit authority holders and are retained for future reference.

Credit authority is generally assigned as a personal credit authority according to the individual’s professional

qualification and experience. All assigned credit authorities are reviewed on a periodic basis to help ensure that they are

commensurate with the individual performance of the authority holder.

Where credit authority is insufficient to establish required credit limits, the transaction is referred to a credit authority

holder with the respective credit authority or if exceeding the highest personal authority to an appropriate credit

committee. Where personal and committee authorities are insufficient to establish appropriate limits, the case is referred

to the Management Board for approval.

Mitigation of credit risk on counterparty level

In addition to determining counterparty credit quality by assigning internal ratings and the alignment of the exposure

with the Bank’s counterparty concentration risk guidelines, Deutsche Bank also uses various credit risk mitigation and

protection techniques to optimize credit exposure and reduce potential credit losses. These techniques are applied in

the following forms:

–Comprehensive and enforceable credit documentation with adequate terms and conditions

–Collateral in its various forms to reduce losses by increasing the recovery of obligations; key principles for collateral

management include legal effectiveness and enforceability, prudent and realistic collateral valuations, risk and

regulatory capital reduction, as well as cost efficiency

–Risk transfers, which shift the risk of default of an obligor to a third-party, including significant risk transfer

instruments are executed by the bank’s Strategic Corporate Lending (SCL) business unit

–Netting and collateral arrangements which reduce the credit exposure from derivatives and securities financing

transactions (e.g., repo transactions)

–Hedging of derivatives counterparty risk including CVA, using primarily CDS contracts via the bank’s Counterparty

Portfolio Management desk


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Collateral

Deutsche Bank regularly agrees on collateral to be received from customers that are subject to credit risk or to be

provided by third parties agreed by legally effective and enforceable contracts as documented by a written and

reasoned legal opinion. Collateral is credit protection in the form of (funded) assigned or pledged assets or (unfunded)

third-party obligations that serves to mitigate the inherent risk of credit loss in an exposure, by either improving

recoveries in the event of a default or substituting the counterparty default risk. Deutsche Bank generally takes all types

of eligible collateral for its respective businesses but may limit accepted collateral types for specific businesses or

regions as customary in the respective market or driven by purpose of efficiency. While collateral can be an alternative

source of repayment, it does not replace the necessity of high-quality underwriting standards and a thorough

assessment of the debt service ability of the counterparty in line with Article 194 (9) CRR.

Deutsche Bank distinguishes the following two types of credit protection approaches:

–Funded Credit Protection like financial and other collateral, which enables Deutsche Bank to recover all or part of the

outstanding exposure by liquidating the collateral/asset provided, in cases where the counterparty is unable or

unwilling to fulfill its primary obligations. Cash collateral, securities (equity, bonds), collateral pledges or assignments

of other claims or inventory, movable assets (i.e., plant, machinery, ships and aircraft) and real estate typically fall into

this category; all financial collateral is regularly, mostly daily, revalued and measured against the respective credit

exposure; the value of other collateral, including real estate, is monitored based upon established processes that

includes regular reviews or revaluations by internal and/or external experts

–Unfunded Credit Protection like Guarantees, which complement the counterparty’s ability to fulfill its obligation

under the legal contract and as such is provided by uncorrelated third parties. Letters of credit, credit insurance,

export credit insurance, guarantees, credit derivatives and (unfunded) risk participations typically fall into this

category. Guarantees and strong letters of comfort provided by correlated group members of customers (generally

the parent company) may also be accepted and considered in approved rating approaches; guarantee collateral with a

non-investment grade rating of the guarantor is limited

Deutsche Bank’s processes seek to ensure that the collateral accepted for risk mitigation purposes is of high quality. This

includes processes to generally ensure legally effective and enforceable documentation for realizable and measurable

collateral or assets which are evaluated within the on-boarding process by dedicated internal appraisers or teams with

the respective qualification, skills and experience or adequate external valuers mandated in regulated processes. The

applied valuations follow generally accepted valuation methods or models and include the identification of material

climate physical and transition risks. Ongoing correctness of values is monitored by collateral type-specific,

appropriately frequent, and event-driven reviews considering relevant risk parameters. Revaluations are applied in cases

of identified probable material deterioration and future monitoring may be adjusted respectively. The assessment of the

suitability of collateral for a specific transaction is part of the credit decision and must be undertaken in a conservative

way. Deutsche Bank strives to avoid “wrong-way” risk characteristics where the counterparty’s risk is positively correlated

with the risk of deterioration in the collateral value. If collateral with material correlation risk is accepted anyhow, a

potential impact on its value is considered conservatively in the valuation. For unfunded credit protection like

guarantees, the process for the analysis of the guarantor’s creditworthiness is aligned to the credit assessment process

for credit-relevant counterparties.

For funded collateral, the value depends on the type and quality of the respective collateral as well as its suitability for

third-party use, its lifespan and other value-influencing factors. Haircuts reflecting risks of liquidation in a default

scenario are implicitly considered in the LGD estimation. Collateral can either move in value over time (dynamic value) or

not (static value). Deutsche Bank uses value deductions to reflect i.a.:

–price fluctuations,

–insufficient third-party usability,

–limitations on liquidation/realization,

–currency mismatch between the secured exposure and the collateral,

–maturity mismatch,

–environmental risks,

–asset specific aspects (age-related discounts, encumbrances and restrictions),

–correlation between the performance of the borrower and the value of the collateral, e.g., in the case of the pledge of

a borrower’s own shares or securities (in this case generally full correlation leads to a 100% value deduction).

These value deductions are either applied within the scope of the assessment and hence directly considered in the

market value or deducted afterwards.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Risk transfers

Risk transfers to third parties form a key part of the bank’s overall risk management process and are executed in various

forms, including outright sales, hedging, and securitizations (significant risk transfers). Risk transfers are conducted by

the respective business units and/or by Strategic Corporate Lending (SCL), in accordance with specifically approved

mandates.

Strategic Corporate Lending manages the credit risk of loans and lending-related commitments of the institutional and

corporate credit portfolio, the leveraged lending portfolio and the medium-sized German companies’ portfolio across the

bank’s Corporate Bank and Investment Bank segments. SCL closely monitors significant risk transfers (SRT) to avoid loan

maturities exceeding the credit protection with replenishment periods allowing to roll hedges and mitigate rollover risk

that might be caused by volatility in the SRT issuance market. In addition, the majority of Deutsche Bank’s SRTs are

structured as fully funded credit linked notes, removing counterparty credit risk.

Acting as a central pricing reference, Strategic Corporate Lending provides the businesses with an observed or derived

capital market rate for loan applications; however, the decision of whether or not the business can enter into the credit

risk remains exclusively with Credit Risk Management.

Strategic Corporate Lending focuses on, managing risk return and single-name credit risk concentrations within the

credit portfolio and by utilizing techniques including loan sales, securitization (significant risk transfer), sub-participations

and credit default swaps.

Netting and collateral arrangements for derivatives and securities financing transactions

Netting (i.e., credit line netting for purposes of the internal capital adequacy assessment process under the Capital

Requirements Directive (Directive 2013/36/EU) and regulatory netting under CRR) is applicable to both exchange traded

derivatives and OTC derivatives (whether cleared or uncleared). Netting is also applied to securities financing

transactions (e.g., repurchase, securities lending and margin lending transactions) as far as documentation, structure and

nature of the risk mitigation allow netting with the underlying credit risk in accordance with applicable law and the

bank’s Financial Contracts Netting and Collateral KOD – Legal ( “Netting Policy”). While cross-product netting between

derivatives and securities financing transactions may be used in certain cases, the bank does not make use of cross-

product netting for regulatory purposes.

All exchange traded derivatives are cleared through Central Counterparties (CCPs), which interpose themselves between

the trading entities by becoming the counterparty to each of the entities. Where legally required or where available and

to the extent agreed with the bank’s counterparties, Deutsche Bank also uses CCP clearing for its OTC derivative

transactions.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

The Dodd-Frank Act and related Commodity Futures Trading Commission (CFTC) rules require CCP clearing in the

United States for certain standardized OTC derivative transactions, including certain interest rate swaps and index credit

default swaps, subject to limited exceptions when facing certain counterparties. The European Regulation (EU) No

648/2012 on OTC Derivatives, CCPs and Trade Repositories (EMIR) and the Commission Delegated Regulations (EU)

2015/2205, (EU) 2015/592 and (EU) 2016/1178 based thereupon introduced mandatory CCP clearing in the EU for

certain standardized OTC derivatives transactions. Mandatory CCP clearing in the EU began for certain interest rate

derivatives on June 21, 2016 and for certain iTraxx-based credit derivatives and additional interest rate derivatives on

February 9, 2017. Article 4 (2) of EMIR authorizes competent authorities to exempt intragroup transactions from

mandatory CCP clearing, provided certain requirements, such as full consolidation of the intragroup transactions and the

application of an appropriate centralized risk evaluation, measurement and control procedure are met. The bank

successfully applied for the clearing exemption for a number of its regulatory-consolidated subsidiaries with intragroup

derivatives, including e.g., Deutsche Bank Securities Inc. and Deutsche Bank Luxembourg S.A. As of December 31, 2025,

the bank is allowed to make use of intragroup exemptions from the EMIR clearing obligation for a number of bilateral

intragroup relationships. The extent of the exemptions differs as not all entities enter into relevant transaction types

subject to the clearing obligation. Of the intragroup relationships, some are relationships where both entities are

established in the European Union (EU) for which a full exemption has been granted, and most are relationships where

one is established in a third country (“Third Country Relationship”). Third Country Relationships required repeat

applications for each new asset class being subject to the clearing obligation; the process took place in the course of

2017. Due to “Brexit”, the status of some group entities has changed from an EU entity to a third country entity, but there

has been no impact for the bank in respect of clearing exemptions. Due to amendments of EMIR entering into force

December 31, 2025, there were some changes to the intragroup exemption requirements, but, as a matter of principle,

Deutsche Bank is able to continue to use pre-existing clearing exemptions.

The rules and regulations of CCPs typically provide for the bilateral set off of all amounts payable on the same day and in

the same currency (“payment netting”) thereby reducing the bank’s settlement risk. Depending on the business model

applied by the CCP, this payment netting applies either to all of the bank’s derivatives cleared by the CCP or at least to

those that form part of the same class of derivatives. Many CCPs’ rules and regulations also provide for the termination,

close-out and netting of all cleared transactions upon the CCP’s default (“close-out netting”), which reduces the bank’s

credit risk. In its risk measurement and risk assessment processes Deutsche Bank applies close-out netting only to the

extent Deutsche Bank believes that the relevant CCP’s close-out netting provisions are legally valid and enforceable and

have been approved in accordance with the bank’s Netting Policy.

In order to reduce the credit risk resulting from OTC derivative transactions, where CCP clearing is not available,

Deutsche Bank regularly seeks the execution of standard master agreements (such as master agreements for derivatives

published by the International Swaps and Derivatives Association, Inc. (ISDA) or the German Master Agreement for

Financial Derivative Transactions with the bank’s counterparties. A master agreement allows for the close-out netting of

rights and obligations arising under derivative transactions that have been entered into under such a master agreement

upon the counterparty’s default, resulting in a single net claim owed by or to the counterparty. Payment netting may be

agreed from time to time with the bank’s counterparties for multiple transactions having the same payment dates (e.g.,

foreign exchange transactions) pursuant to the terms of master agreements which can, reduce the bank’s settlement risk.

In its risk measurement and risk assessment processes Deutsche Bank applies close-out netting only to the extent

Deutsche Bank has concluded that the master agreement is legally valid and enforceable in all relevant jurisdictions and

the recognition of close-out netting has been approved in accordance with the bank’s Netting Policy.

Deutsche Bank also enters into credit support annexes (CSAs) to master agreements in order to further reduce the bank’s

derivatives-related credit risk. These annexes generally provide risk mitigation through periodic, usually daily, margining

of the covered exposure. The CSAs also provide for the right to terminate the related derivative transactions upon the

counterparty’s failure to honor a margin call. As with netting, when Deutsche Bank believes the annex is enforceable,

Deutsche Bank reflects this in its exposure measurement.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Certain CSAs to master agreements provide for rating-dependent triggers, where additional collateral must be pledged if

a party’s rating is downgraded. Deutsche Bank also enters into master agreements that provide for an additional

termination event upon a party’s rating downgrade. These downgrade provisions in CSAs and master agreements usually

apply to both parties but in some agreements may apply to Deutsche Bank only. Deutsche Bank analyzes and monitors

its potential contingent payment obligations resulting from a rating downgrade in its stress testing and liquidity coverage

ratio approach for liquidity risk on an ongoing basis. For an assessment of the quantitative impact of a downgrading of

the bank’s credit rating please refer to table “Stress Testing Results” in the section “Liquidity Risk”.

The Dodd-Frank Act and CFTC rules thereunder, including CFTC rule § 23.504, as well as EMIR and Commission

Delegated Regulation based thereon, namely Commission Delegated Regulation (EU) 2016/2251, introduced the

mandatory use of master agreements and related CSAs, which must be executed prior to or contemporaneously with

entering into an uncleared OTC derivative transaction. Certain documentation is also required by the U.S. margin rules

adopted by U.S. prudential regulators. Under the U.S. prudential regulators’ margin rules, Deutsche Bank is required to

post and collect initial margin for its uncleared derivatives exposures with other derivatives dealers, as well as with the

bank’s counterparties that (i) are “financial end users,” as that term is defined in the U.S. margin rules, and (ii) have an

average daily aggregate notional amount of uncleared swaps, uncleared security-based swaps, foreign exchange

forwards and foreign exchange swaps exceeding U.S.$ 8 billion in June, July and August of the previous calendar year.

The U.S. margin rules additionally requires Deutsche Bank to post and collect variation margin for its derivatives with

other derivatives dealers and certain financial end user counterparties. These margin requirements are subject to a

U.S.$ 50 million threshold for initial margin, but no threshold for variation margin, with a combined U.S.$ 500,000

minimum transfer amount. The U.S. margin requirements have been in effect for large banks since September 2016,

with additional variation margin requirements having come into effect March 1, 2017 and additional initial margin

requirements having been phased in from September 2017 through September 2022.

Under Commission Delegated Regulation (EU) 2016/2251, which implements the EMIR margin requirements, the CSA

must provide for daily valuation and daily variation margining based on a zero threshold and a minimum transfer

amount of not more than € 500,000. For large derivative exposures exceeding € 8 billion, initial margin has to be

posted as well. The variation margin requirements under EMIR apply as of March 1, 2017; the initial margin

requirements originally were subject to a staged phase-in until September 1, 2021. However, legislative changes

published on February 17, 2021 extended deadlines into 2022. Under Article 31 of Commission Delegated Regulation

(EU) 2016/2251, an EU party may decide to not exchange margin with counterparties in certain non-netting

jurisdictions provided certain requirements are met. Pursuant to Article 11 (5) to (10) of EMIR, competent authorities

are authorized to exempt intragroup transactions from the margining obligation, provided certain requirements are

met. While some of those requirements are the same as for the EMIR clearing exemptions (see above), there are

additional requirements such as the absence of any current or foreseen practical or legal impediment to the prompt

transfer of funds or repayment of liabilities between intragroup counterparties. The bank is making use of this

exemption. The bank has successfully applied for the collateral exemption for some of its regulatory-consolidated

subsidiaries with intragroup derivatives, including, e.g., Deutsche Securities Inc. and Deutsche Bank Luxembourg S.A.

As of December 31, 2025, the bank is allowed to use intragroup exemptions from the EMIR collateral obligation for a

number of bilateral intragroup relationships which are published under db.com/legal-resources/european-market-

infrastructure-regulation/intra-group-exemptions-margining. For some bilateral intragroup relationships, the EMIR

margining exemption may be used based on Article 11 (5) of EMIR, i.e., without the need for any application or

publication, because both entities are established in the same EU Member State. For third country subsidiaries, the

intragroup exemption was originally limited until the earlier of June 30, 2025 and four months after the publication of

an equivalence decision by the EU Commission under Article 13(2) EMIR, unless, in the case of an equivalence decision

being applicable, a follow-up exemption application is made and granted. With the EMIR amendments having entered

into force on 24 December 2024 (Regulation (EU) 2024/2987), a so-called “equivalence decision” is no longer a

requirement for a margin exemption. As a matter of principle, Deutsche Bank is able to continue to use pre-existing

margin exemptions.

Concentrations within credit risk mitigation

Concentrations within credit risk mitigations taken may occur if a number of guarantors and credit derivative providers

with similar economic characteristics are engaged in comparable activities with changes in economic or industry

conditions affecting their ability to meet contractual obligations. Concentration risk may also occur in collateral

portfolios (e.g., multiple claims and receivables against third parties) which are considered conservatively within the

valuation process and/or on-site inspections where applicable. Deutsche Bank uses a range of tools and metrics to

monitor its credit risk mitigating activities and potential concentrations.

For more qualitative and quantitative details in relation to the application of credit risk mitigation and potential

concentration effects please refer to the section “Maximum exposure to credit risk”.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Managing credit risk on portfolio level

Enterprise and Treasury Risk Management (ETRM) sets the framework for the management of concentration risks at a

portfolio level. This includes strategically setting, monitoring, reviewing, reporting, and controlling credit risk appetites

across various dimensions such as Deutsche Bank Group, Corporate Division, Business Unit , legal entity, branch, country,

and industry level that need to be considered in the context of credit approvals. ETRM is also responsible for calibrating

and monitoring the single name counterparty concentration grid that provides guidance to credit officers on limit sizing

at counterparty level. In addition, ETRM provides a comprehensive and holistic view of the bank’s risk profile across risk

types.

On a portfolio level, significant concentrations of credit risk could result from having material exposures to a number of

counterparties with similar economic characteristics, or who are engaged in comparable activities, where these

similarities may cause their ability to meet contractual obligations to be affected in the same manner by changes in

economic or industry conditions.

Deutsche Bank’s portfolio management framework supports a comprehensive assessment of concentrations within its

credit risk portfolio in order to keep concentrations within acceptable levels.

Emerging Risks and portfolio developments are discussed at the monthly Credit Risk and Portfolio Management Forum

which includes representation from senior credit risk managers including the Head of Credit Risk Management, as well as

senior managers from ETRM.

Industry risk management

To manage industry risk, Deutsche Bank has grouped its corporate and financial institutions counterparties into various

industry sub-portfolios. Portfolios are regularly reviewed at least on an annual basis. Reviews highlight industry

developments and risks to the bank’s credit portfolio, review cross-risk concentration risks, analyze the risk/reward

profile of the portfolio and incorporate the results of an economic downside stress test. Finally, this analysis is used to

define the credit strategies and risk appetite for respective industries. The setting of industry risk appetite takes into

consideration the group-wide credit risk appetite.

In the bank’s industry risk management framework, thresholds are established by ETRM for aggregate credit limits to

counterparties within each industry sub-portfolio. For risk management purposes, the aggregation of limits across

industry sectors follows an internal risk view that does not have to be congruent with NACE (Nomenclature statistique

des activités économiques dans la Communauté européenne) code-based view applied elsewhere in this report.

Beyond credit risk, the bank’s industry risk framework comprises of thresholds for Traded Credit Positions while key

industry relevant non-financial risks are considered.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Country risk management

Avoiding undue concentrations from a regional and country perspective is also an integral part of the bank’s credit risk

management framework. In order to achieve this, country risk thresholds are set for countries in Non-Japan Asia, Central

Eastern Europe, Middle East & Africa and Latin America as well as selected Developed Markets countries (based on

internal country risk ratings). These thresholds are set for aggregate exposures to all counterparties assigned to specific

‘country of risk’. The counterparty’s ‘country of risk’ reflects its main (macro) economic risk, balance sheet earnings,

jurisdiction, or other financial dependencies. Country of risk is typically aligned with the counterparty’s 'country of

domicile’. As such, for the bank’s country risk management purposes, the aggregation of exposures across countries may

differ from the geographical exposure view applied elsewhere in this report.

Country portfolios are regularly reviewed with the frequency of review dependent on portfolio size and risk profile as well

as risk developments. Larger/riskier portfolios are reviewed at least on an annual basis. These reviews assess amongst

other factors, key macroeconomic and political risk developments and outlook; portfolio composition, quality

developments and risk concentrations under normal and stress conditions. Based on this and taking into account the

Group’s Risk Appetite and strategy, country risk appetite and strategies are set by ETRM.

In addition to country thresholds, thresholds are set to monitor country-on-country wrong-way risk exposure. Beyond

credit risk, the bank’s country risk framework comprises thresholds for trading positions that measure the aggregate

market value of traded credit risk positions. For Emerging Markets, market risk thresholds are also set to measure the

profit and loss impact under specific country stress scenarios on trading positions across the bank’s portfolio.

Furthermore, thresholds are set for capital and intra-group funding exposure of Deutsche Bank entities in above

countries given the transfer risk inherent in these cross-border positions. Key non-financial risks are considered and

factored into financial threshold setting considerations where relevant. To assess country risk, Deutsche Bank utilizes

different measures including country risk ratings that are set and monitored by the research team within ETRM. These

ratings include:

–Sovereign default ratings which measure the probability of the sovereign defaulting on its foreign or local currency

obligations

–Transfer risk ratings which measure the probability of a “transfer risk event”, i.e., the risk that an otherwise solvent

debtor is unable to meet its obligations due to inability to obtain foreign currency or to transfer assets as a result of

direct sovereign intervention

All sovereign and transfer risk ratings are reviewed, at least on an annual basis.

Climate and environmental risk management

The bank established a dedicated framework for the management of climate and environmental risks. The framework

sets out key requirements around governance, risk identification and materiality assessment, risk appetite, risk

monitoring, controls and stress testing.

Concentrations of climate and environmental risks are monitored, via dedicated reports, by key committees of the Bank

(e.g., the Group Risk Committee), and are managed through:

–Risk Appetite thresholds around the bank’s decarbonization targets, established for eight priority sectors (Upstream

Oil and Gas, Power Generation, Automotive - Light Duty, Steel, Coal Mining, Cement and Aviation) and the overall

financed emissions of the Corporate Loan Book

–Early Warning Indicators, established across different portfolios (Corporates, Sovereigns and Financial Institutions) for

climate-transition, climate-physical and nature-related risks

New transactions with a significant impact on the bank’s financed emissions and/or net zero targets are reviewed by the

Group Net Zero Forum consisting of senior representatives from the Business, Risk, and the Chief Sustainability Office.

The review of the forum’s members includes an assessment of client sustainability disclosures, transition strategies,

decarbonization targets and governance. New transactions must fit within Deutsche Bank’s internal sectoral risk appetite

aligned to net zero targets. In 2024 and continuing in 2025, the Group-level sectoral risk appetite metrics were cascaded

to the divisions, to enhance their responsibility and support their business strategies. In this context, dedicated Divisional

Net Zero Fora in the Corporate Bank and the Investment Bank have been established.


Deutsche Bank	Risk type management
Annual Report 2025	Credit Risk Management

Product/Asset class specific risk management

Complementary to the bank’s counterparty, industry and country risk approach, Deutsche Bank has a framework to

manage certain asset class risk concentrations and sets limits or thresholds where required for risk management

purposes. For purposes of DB’s internal portfolio risk management, asset classes are groups of financial exposures that

exhibit similar performance and behaviors in both normal operating conditions and under severe stress. The exposures in

an asset class will typically have a common characteristic or sensitivity to the same economic and/or market factors and

business, legal and regulatory developments. When such characteristic or sensitivity is triggered, transactions in the

asset class may react and perform in a similar manner. These are portfolios which the bank’s Risk division considers as

having the potential for sizable tail risks and require additional monitoring. Group-wide credit risk appetite is considered

in the setting of asset class risk limits or thresholds.

Private Bank and certain Corporate Bank businesses are managed via product-specific strategies setting the bank’s risk

appetite for portfolios with similar credit risk characteristics, such as the retail portfolios of mortgages and consumer

finance products as well as products for business clients. Risk analyses are performed on portfolio level including further

breakdown into business units as well as countries/regions. In Wealth Management, target levels are set for global

concentrations along products as well as based on type and liquidity of collateral.

Underwriting of capital markets transactions

Specific focus is placed on transactions with underwriting risks where Deutsche Bank underwrites commitments with the

intention to sell down or distribute part of the risk to third parties. These commitments include the undertaking to

provide bank loans for syndication into the debt capital market and bridge loans for the issuance of notes. The inherent

risks of being unsuccessful in the distribution of the facilities or the placement of the notes, comprise of a delayed

distribution, funding of the underlying loans as well as a pricing risk as some underwriting commitments are additionally

exposed to market risk in the form of widening credit spreads. Where applicable, Deutsche Bank dynamically hedges this

credit spread risk to be within the approved market risk limit framework.

A major asset class, in which Deutsche Bank is active in underwriting, is leverage lending, which Deutsche Bank mainly

executes through its Leveraged Debt Capital Markets business unit. The business model is a fee-based‚ originate to

distribute approach focused on the distribution of largely unfunded underwriting commitments into the capital market.

The afore-mentioned risks regarding distribution and credit spread movement apply to this business unit, however, are

managed under a range of specific notional as well as market risk limits. The latter require the business to also hedge its

underwriting pipeline against market dislocations. The fee-based model of the bank’s Leveraged Debt Capital Markets

business unit includes a restrictive approach to single-name risk concentrations retained on Deutsche Bank’s balance

sheet, which results in a diversified overall portfolio without any material concentrations. The resulting longer-term on-

balance sheet portfolio is also subject to a comprehensive credit limit and hedging framework.

Deutsche Bank also provides material underwriting activity through its Debt Capital Markets desk which is focused on

supporting Investment Grade and cross-over rated corporate borrowers, usually in connection with M&A transaction

financing. These exposures are typically 12-24 month bridge loans, which are expected to be repaid by syndicated loans

and/or capital markets issuance by the borrower. Deutsche Bank does not bear market placement or pricing risk on these

exposures but faces funding risk and credit risk for the duration of the commitment, which are managed through notional

underwriting limits for the Group and an industry concentration framework.


Deutsche Bank	Risk type management
Annual Report 2025	Market Risk Management

Market Risk Management

Market risk framework

The vast majority of Deutsche Bank’s businesses are subject to market risk, defined as the potential for change in the

market value of the Group’s trading and invested positions. Risk can arise from changes in interest rates, credit spreads,

foreign exchange rates, equity prices, commodity prices and other relevant parameters, such as market volatility and

market implied default probabilities. The market risk can affect accounting, economic and regulatory views of the

exposure.

Market Risk Management is part of Deutsche Bank’s independent Risk function and sits within the Market and Valuations

Risk Management group. One of the primary objectives of Market Risk Management is to ensure that the business units’

risk exposure is within the approved risk appetite commensurate with its defined strategy. To achieve this objective,

Market Risk Management works closely together with risk takers (“the business units”) and other control and support

groups.

The Group distinguishes between three substantially different types of market risk:

–Trading market risk arises primarily through the market-making and client facilitation activities of the Investment Bank

segment. This involves taking positions in debt, equity, foreign exchange, other securities and commodities as well as

in equivalent derivatives

–Traded default risk arising from defaults and rating migrations relating to trading instruments

–Non-trading market risk arises from market movements, primarily outside the activities of the trading units, in the

banking book and from off-balance sheet items; this includes interest rate risk, credit spread risk, investment risk and

foreign exchange risk as well as market risk arising from pension schemes, guaranteed funds and equity

compensation; non-trading market risk also includes risk from the modeling of client deposits as well as savings and

loan products

Market Risk Management governance is designed and established to promote oversight of all market risks, effective

decision-making and timely escalation to senior management.

Market Risk Management defines and implements a framework to systematically identify, assess, monitor and report the

Group’s market risk. Market risk managers identify market risks through active portfolio analysis and engagement with the

business units.

Market risk measurement

The Group aims to accurately measure all types of market risks by a comprehensive set of risk metrics embedding

accounting, economic and regulatory considerations.

The market risks are measured by several internally developed key risk metrics and regulatory defined market risk

approaches.

Trading market risk

The Group’s primary mechanism to manage trading market risk is the application of the bank’s risk appetite framework, of

which the limit framework is a key component. The Management Board, supported by Market Risk Management, sets

group-wide value-at-risk, economic capital and portfolio stress testing limits for market risk in the trading book. Market

Risk Management allocates this overall appetite to the business segments and their individual business units based on

established and agreed business plans. Deutsche Bank also has business aligned heads within Market Risk Management

who establish business unit limits, by allocating the limit down to individual portfolios, geographical regions and types of

market risks.

Value-at-risk, economic capital and portfolio stress testing limits are used for managing all types of market risk at an

overall portfolio level. As an additional and important complementary tool for managing certain portfolios or risk types,

Market Risk Management performs risk analysis and business specific stress testing. Limits are also set on sensitivity and

concentration/liquidity, exposure, business-level stress testing and event risk scenarios, taking into consideration

business plans and the risk versus return assessment.

Business units are responsible for adhering to the limits against which exposures are monitored and reported. The market

risk limits set by Market Risk Management are monitored on a daily, weekly and monthly basis, dependent on the risk

management tool being used.


Deutsche Bank	Risk type management
Annual Report 2025	Market Risk Management

Internally developed market risk models

Value-at-Risk (VaR)

VaR is a quantitative measure of the potential loss (in value) of Fair Value positions due to market movements that should

not be exceeded in a defined period of time and with a defined confidence level.

The Group’s value-at-risk for the trading businesses is based on historical simulation model (internal model approach)

predominantly utilizing full revaluation, although some portfolios remain on a sensitivity-based approach. The approach

is used for both Risk Management and capital requirements.

Risk management VaR is calibrated to a 99% confidence level and a one-day holding period. This means we estimate

there is a 1 in 100 chance that a mark-to-market loss from the bank´s trading positions will be at least as large as the

reported VaR. For regulatory capital purposes, the VaR model is calibrated to a 99% confidence interval and a ten-day

holding period.

The calculation employs a historical simulation technique that uses one-year of historical market data as input and

observed correlations between the risk factors during this one-year period.

The VaR model is designed to take into account a comprehensive set of risk factors across all asset classes. Key risk

factors are swap/government curves, index and issuer-specific credit curves, single equity and index prices, foreign

exchange rates, commodity prices as well as their implied volatilities. To help ensure completeness in the risk coverage,

second order risk factors, e.g., money market basis, implied dividends, option-adjusted spreads and precious metals lease

rates are also considered in the VaR calculation. The list of risk factors included in the VaR model is reviewed regularly

and enhanced as part of ongoing model performance reviews.

The model incorporates both linear and, especially for derivatives, nonlinear impacts predominantly through a full

revaluation approach but it also utilizes a sensitivity-based approach for certain portfolios. The full revaluation approach

uses the historical changes to risk factors as input to pricing functions. Whilst this approach is computationally

expensive, it does yield a more accurate view of market risk for nonlinear positions, especially under stressed scenarios.

The sensitivity-based approach uses sensitivities to underlying risk factors in combination with historical changes to

those risk factors.

For each business unit a separate VaR is calculated for each risk type, e.g., interest rate risk, credit spread risk, equity risk,

foreign exchange risk and commodity risk. “Diversification effect” reflects the fact that the total VaR on a given day will

be lower than the sum of the VaR relating to the individual risk types. Simply adding the VaR figures of the individual risk

types to arrive at an aggregate VaR would imply the assumption that the losses in all risk types occur simultaneously.

VaR enables the Group to apply a consistent measure across the fair value exposures. It allows a comparison of risk in

different businesses, and also provides a means of aggregating and netting positions within a portfolio to reflect

correlations and offsets between different asset classes. Furthermore, it facilitates comparisons of the market risk both

over time and against the daily trading results.

When using VaR results a number of considerations should be taken into account. These include:

–The use of historical market data may not be a good indicator of potential future events, particularly those that are

extreme in nature; this “backward-looking” limitation can cause VaR to understate future potential losses (as in

financial credit crisis 2008/09), but can also cause it to be overstated immediately following a period of significant

stress (as in COVID-19 pandemic)

–The one day holding period does not fully capture the market risk arising during periods of illiquidity, when positions

cannot be closed out or hedged within one day

–VaR does not indicate the potential loss beyond the 99th quantile

–Intra-day risk is not reflected in the end of day VaR calculation

–There may be risks in the trading or banking book that are not fully captured in the VaR model (either partially

captured or missing entirely)

The process of systematically capturing and evaluating risks currently not captured in the bank’s VaR model has been

further developed and improved. An assessment is made to determine the level of materiality of these risks and material

risks are prioritized for inclusion in the bank’s internal model. Risks not in VaR are monitored and assessed on a regular

basis through the Risk Not In VaR (RNIV) framework. This framework is consistent with the Historical Simulation approach

which in turn yields a more accurate estimate of the contribution of these missing items and their potential capitalization.

Deutsche Bank is committed to the ongoing development of the internal risk models, and substantial resources are

allocated to review, validate and improve them.


Deutsche Bank	Risk type management
Annual Report 2025	Market Risk Management

Stressed Value-at-Risk

Stressed Value-at-Risk (SVaR) calculates a stressed value-at-risk measure based on a one year period of significant

market stress. The Group calculates a stressed value-at-risk measure using a 99% confidence level. Stressed VaR is

calculated with a holding period of ten days. The SVaR calculation utilizes the same systems, trade information and

processes as those used for the calculation of value-at-risk. The only difference is that historical market data and

observed correlations from a period of significant financial stress (i.e., characterized by high volatilities) are used as an

input for the historical simulation.

The stress period selection process for the stressed value-at-risk calculation is based on the comparison of VaR

calculated using historical time windows compared to the current SVaR. If a historical window produces a VaR which is

higher than the current SVaR, it is further investigated and the SVaR window can subsequently be updated accordingly.

This process runs on a quarterly basis.

During 2025, the stress period selection process for the Group was conducted as outlined above. As a result, the SVaR

window used at various periods in 2025 included the financial credit crisis of 2008/09, the European sovereign crisis of

2011/12 and COVID-19 crisis of 2019/20

Incremental Risk Charge

Incremental Risk Charge captures default and credit rating migration risks for credit-sensitive positions in the trading

book. The Group uses a Monte Carlo Simulation for calculating incremental risk charge as the 99.9% quantile of the

portfolio loss distribution over a one-year capital horizon under a constant position approach and for allocating

contributory incremental risk charge to individual positions.

The model captures the default and migration risk in an accurate and consistent quantitative approach for all portfolios.

Important parameters for the incremental risk charge calculation are exposures, recovery rates, maturities, ratings with

corresponding default and migration probabilities and parameters specifying issuer correlations.

Market risk standardized approach

The Market Risk Standardized Approach (MRSA) is used to determine the regulatory capital charge for the specific

market risk of trading book securitizations, for certain types of investment funds and for longevity risk as set out in CRR/

CRD regulations.

Trading market risk economic capital

Deutsche Bank’s market risk economic capital migrated to historical simulation approach from Monte Carlo in the second

quarter of 2025. This aligns the scenario generation concept in economic capital calculation with the one used for

regulatory capital. The model comprises two core components, the “common risk” component covering risk drivers

across all businesses and the “business-specific risk” component, which enriches the Common Risk via a suite of Business

Specific Stress Tests. Both components are calibrated to historically observed severe market shocks. Common risk is

calculated using a scaled version of the SVaR framework while Business Specific Stress Tests are designed to capture

more product/business-related bespoke risks (e.g., complex basis risks) as well as higher order risks not captured in the

common risk component.


Deutsche Bank	Risk type management
Annual Report 2025	Market Risk Management

Traded default risk economic capital

The Traded Default Risk Economic Capital captures the relevant credit exposures across Deutsche Bank’s trading and

fair value banking books. Trading book exposures are monitored by Market Risk Management via single name

concentration and portfolio thresholds which are set based upon rating, size and liquidity. Single name concentration risk

thresholds are set for two key metrics: Default Exposure, i.e., the P&L impact of an instantaneous default at the current

recovery rate, and bond equivalent Market Value, i.e., default exposure at 0% recovery. In order to capture diversification

and concentration effects, a joint calculation for traded default risk economic capital and credit risk economic capital is

performed. Important parameters for the calculation of traded default risk are exposures, recovery rates and default

probabilities as well as maturities. The probability of joint rating downgrades and defaults is determined by the default

and rating correlations of the portfolio model. These correlations are specified through systematic factors that represent

countries, geographical regions and industries.

Trading market risk reporting

Market Risk Management reporting creates transparency on the risk profile and facilitates the understanding of core

market risk drivers to all levels of the organization. The Management Board and Senior Governance Committees receive

regular reporting, as well as ad hoc reporting as required, on market risk, regulatory capital and stress testing. Senior Risk

Committees receive risk information at a number of frequencies, including weekly or monthly.

Additionally, Market Risk Management produces daily and weekly Market Risk specific reports and daily limit utilization

reports for each business owner.

Regulatory prudent valuation of assets carried at fair value

Pursuant to Article 34 CRR, institutions shall apply the prudent valuation requirements of Article 105 CRR to all assets

measured at fair value and shall deduct from CET 1 capital the amount of any additional value adjustments necessary.

Deutsche Bank determined the amount of the additional value adjustments based on the methodology defined in the

Commission Delegated Regulation (EU) 2016/101.

As of December 31, 2025, the amount of the additional value adjustments was €1.7 billion. The December 31, 2024,

amount was €1.7 billion. No material changes noted year-on-year.

As of December 31, 2025, the reduction of the expected loss from subtracting the additional value adjustments was €80

million, which partly mitigated the negative impact of the additional value adjustments on the bank’s CET 1 capital.

Non-trading market risk

Non-trading market risk arises primarily from activities outside of the trading units, in the banking book, including pension

schemes and guarantees, and embedding considerations of different accounting treatments of transactions. Significant

market risk factors to which the Group is exposed and are overseen by risk management groups in that area are interest

rate risk (including risk from embedded optionality and changes in behavioral patterns for certain product types), credit

spread risk, foreign exchange risk (including structural foreign exchange risk) and equity risk (including equity

compensation related risk and investments in public and private equity as well as real estate, infrastructure and fund

assets).

As for trading market risks the Group’s risk appetite and limit framework is also applied to manage the exposure to non-

trading market risk. At Group level those are captured by limits set by the Management Board for market risk economic

capital capturing exposures to all market risks across asset classes, and for earnings and economic value based metrics

for interest rate risk in the banking book. Those limits are cascaded down by Market Risk Management to the divisional or

portfolio level. The limit framework for non-trading market risk exposure is further complemented by a set of business

specific stress tests, value-at-risk & sensitivity limits monitored on a daily or monthly basis dependent on the risk measure

being used.


Deutsche Bank	Risk type management
Annual Report 2025	Market Risk Management

Interest rate risk in the banking book

Interest rate risk in the banking book (IRRBB) is the current or prospective risk, to both the Group's capital and earnings,

arising from movements in interest rates, which affect the Group's banking book exposures. This includes gap risk, which

arises from the term structure of banking book instruments, basis risk, which describes the impact of relative changes in

interest rates for financial instruments that are priced using different interest rate curves, as well as option risk, which

arises from option derivative positions or from optional elements embedded in financial instruments.

The Group manages its IRRBB exposures using economic value as well as earnings based measures. The Group Treasury

function is mandated to manage the interest rate risk centrally, with Enterprise and Treasury Risk Management acting as

2nd Line of Defense (LoD). The Group Asset & Liability Committee (ALCo) oversees and steers the Group’s structural

interest risk position and the management of the net interest income. The ALCo monitors the sensitivity of financial

resources and associated metrics to key market parameters such as interest rate curves and oversees adherence to

divisional/business financial resource limits.

Economic value based measures analyze the change in economic value of banking book assets, liabilities and off-balance

sheet exposures resulting from interest rate movements, independent of the accounting treatment. Thereby the Group

measures the change in economic value of equity (∆EVE) as the maximum decrease of the banking book economic value

under the six standard scenarios defined by the EBA in addition to internal stress scenarios for risk steering purposes. For

the reporting of internal stress scenarios and risk appetite, the Group applies several modelling assumptions as used in

this disclosure. When aggregating the change in economic value of equity ∆EVE across different currencies, the Group

adds up negative and positive changes without applying weight factors for positive changes. Furthermore, the Group is

using behavioral model assumptions for the interest rate duration of own equity capital as well as non-maturity deposits

from financial institutions.

Earnings-based measures analyze the expected change in net interest income (NII) resulting from interest rate

movements over a defined time horizon, compared to a defined benchmark scenario. Thereby the Group measures the

change in net interest income (∆NII) as the maximum reduction under the six standard scenarios defined by the EBA in

addition to internal stress scenarios for risk steering purposes, compared to a market implied curve scenario, over a

period of 12 months.

The Group employs mitigation techniques to hedge the interest rate risk arising from non-trading positions within given

limits. The interest rate risk arising from non-trading asset and liability positions is managed by the Treasury Markets &

Investments team, part of Group Treasury. Thereby the Group uses derivatives and applies different hedge accounting

techniques such as fair value hedge accounting or cash flow hedge accounting. For fair value hedges, the Group uses

interest rate swaps and options contracts to manage the fair value movements of fixed rate financial instruments due to

changes in benchmark interest rate. For hedges in the context of the cash flow hedge accounting, the Group uses

interest rate swaps to manage the exposure to cash flow variability of the variable rate instruments as a result of changes

in benchmark interest rates.

The Group assesses and measures hedge effectiveness of a hedging relationship based on the change in the fair value or

cash flows of the derivative hedging instrument relative to the change in the fair value or cash flows of the hedged item

attributable to the hedged risk.

The Model Risk Management function performs independent validation of models used for IRRBB measurement, as for all

market risk models, in line with Deutsche Bank’s group-wide risk governance framework.

The calculation of VaR and sensitivities of interest rate risk is performed daily, whereas the measurement and reporting of

economic value interest rate and earnings risk is performed on a monthly basis. The Group generally uses the same

metrics in its internal management systems as it applies for the disclosure in this report.

Deutsche Bank’s key modelling assumptions are applied to the positions in the Private Bank and Corporate Bank

segments. Those positions are subject to risk of changes in clients’ behavior with regard to their deposits as well as loan

products. The Group regularly tests (at least annually) the assumptions and updates them where appropriate following a

defined governance process.

The Group manages the interest rate risk exposure of its non-maturity deposits through a replicating portfolio approach

to determine the average repricing maturity of the portfolio. For the purpose of constructing the replicating portfolio,

the portfolio of non-maturity deposits is clustered by dimensions such as business unit, currency, product and

geographical location. The main dimensions influencing the repricing maturity are elasticity of deposit rates to market

interest rates, volatility of deposit balances and observable client behavior. For the reporting period the average

repricing maturity assigned across all such replicating portfolios is 2.44 years and Deutsche Bank uses 15 years as the

longest repricing maturity.


Deutsche Bank	Risk type management
Annual Report 2025	Market Risk Management

In the loan and some of the term deposit products Deutsche Bank considers early prepayment/withdrawal behavior of its

customers. The parameters are based on historical observations, statistical analyses and expert assessments.

Furthermore, the Group generally calculates IRRBB related metrics in contractual currencies and aggregates the

resulting metrics for reporting purposes. When calculating economic value based metrics the commercial margin is

excluded for material parts of the balance sheet.

Credit spread risk in the banking book

Deutsche Bank is exposed to credit spread risk in the Banking Book (CSRBB) mainly from bonds held by Treasury for

liquidity reserve and asset liability interest rate risk management activities. The credit spread risk in the banking book is

managed by Treasury and the businesses, with Enterprise and Treasury Risk Management acting as an independent

oversight function ensuring that the exposure is within the approved risk appetite. The perimeter for the measurement

and monitoring of CSRBB exposure extends beyond fair value assets and liabilities and also includes positions accounted

for at amortized cost whose pricing is linked to an observable market benchmark. The calculation of credit spread

sensitivities and value-at-risk for material credit spread exposure is in general performed on a daily basis. The

measurement and reporting of economic capital and specific CSRBB stress tests are performed on a monthly basis.

Foreign exchange risk

Foreign exchange risk arises from non-trading asset and liability positions that are denominated in currencies other than

the functional currency of the respective entity. The majority of this foreign exchange risk is transferred through internal

hedges to trading books within the Investment Bank and is therefore reflected and managed via the value-at-risk figures

in the trading books. The remaining foreign exchange risks that have not been transferred are mitigated through match

funding the investment in the same currency, so that only residual risk remains in the portfolios. Small exceptions to

above approach follow the general Market Risk Management monitoring and reporting process, as outlined for the

trading portfolio.

The bulk of non-trading open foreign exchange risk arises from the foreign exchange translation of local capital into the

reporting currency of the Group and related capital hedge positions. Thereby structural open long positions are taken for

a selected number of relevant currencies to immunize the sensitivity of the capital ratio of the Group against changes in

the exchange rates.

Equity and investment risk

Non-trading equity risk is arising predominantly from non-consolidated investment holdings in the banking book and

from equity compensation plans.

Deutsche Bank’s non-consolidated equity investment holdings in the banking book are categorized into strategic and

alternative investment assets. Strategic investments typically relate to acquisitions made to support the bank’s business

franchise and are undertaken with a medium to long-term investment horizon. Alternative assets are comprised of

principal investments and other non-strategic investment assets. Principal investments are direct investments in private

equity, real estate, venture capital, hedge or mutual funds whereas assets recovered in the workout of distressed

positions or other legacy investment assets in private equity and real estate are of a non-strategic nature.

The equity investment holdings are included in regular group-wide stress tests and the monthly market risk economic

capital calculations.

Pension risk

The Group is exposed to market risks from defined benefit pension schemes for past and current employees. Market risks

in pension plans materialize due to a potential decline in the market value of plan assets or an increase in the present

value of the pension liability of each of the pension plans. Market Risk Management is responsible for a regular

measurement, monitoring, reporting and control of market risks of the asset and liability side of the defined benefit

pension plans. Thereby, market risks in pension plans include but are not restricted to interest rate risk, inflation risk,

credit spread risk, equity risk, and longevity risk. For further details on the Group’s defined benefit pension obligations

and their management, please refer to Note 33 “Employee Benefits” in the “Notes to the Consolidated Financial

Statements” section.

Other risks in the banking book

Market risks in the Asset Management business primarily result from principal guaranteed funds or accounts, but also

from co-investments in the bank’s funds.


Deutsche Bank	Risk type management
Annual Report 2025	Liquidity Risk Management

Liquidity Risk Management

Liquidity risk arises from Deutsche Bank Groups potential inability to meet payment obligations when they come due or

without incurring excessive costs. The Group’s risk taxonomy differentiates between two aspects of liquidity risk: Short-

term liquidity risk and structural funding risk, both embedded in an overarching liquidity and funding risk management

framework. The framework’s objective is to ensure that robust governance and controls are established within the Group

to fulfill its payment obligations (including intraday) at all times, including periods of stress, and to manage its liquidity

and funding risks within the Management Board’s approved risk appetite, when executing the strategic plan. The

framework considers all relevant and significant drivers of liquidity risk, whether on-balance sheet or off-balance sheet.

Liquidity and funding risk framework

Liquidity and funding key risk metrics are embedded in the bank’s risk appetite framework and reviewed as well as

approved by the Management Board at least on an annual basis. The risk appetite is applied at the Group level and to

internally defined Key Liquidity Entities, e.g., Deutsche Bank AG, to monitor and control liquidity risk as well as the

Group’s long-term funding and issuance plan.

The Group Asset and Liability Committee is the Group’s decision making governing body mandated by the Management

Board to optimize the sourcing and deployment of the Group’s balance sheet and financial resources in line with the

Management Board’s risk appetite and strategy. From the second line of defense perspective, the Group Risk Committee

is mandated by the Management Board with decision-making authority regarding material risk-related topics. Detailed

roles and responsibilities of the Group Asset and Liability committee as well as the Group Risk Committee are defined in

the “Risk Governance” section of this report.

The Liquidity and Funding Risk Management Framework defines the organization of the liquidity managing functions in

alignment with the three lines of defense structure, which is described in the “Risk Management principles” section of

this report, including the respective responsibilities of those functions comprising of the three lines of defense. In the

context of the Liquidity and Funding Risk Management Framework, these functions include the following:

–First Line of Defense: Corporate divisions and Treasury

–Second Line of Defense: CRO - Enterprise and Treasury Risk Management (ETRM)

–Third Line of Defense: Group Audit

The Group’s liquidity risk management principles are documented in a policy document and the framework is described

in the framework document. Both the policy and framework documents adhere to and articulate how the eight key risk

management practices are applied to liquidity risk, with such key practices including 1) risk governance, 2) risk

organization (3 lines of defense), 3) risk culture, 4) risk appetite and -strategy, 5) risk identification and -assessment,

6) risk mitigation and controls, 7) risk measurement and reporting as well as 8) stress planning and execution. The

individual roles and responsibilities relevant to each of these practices are laid out and documented in the Global

Responsibility Matrix for liquidity risk, which provides further clarity and transparency on the roles and responsibilities

across all involved stakeholders. All additional procedures and supporting documents (both global and local) issued by

the liquidity risk management functions further define the requirements specific to liquidity risk practices.

In accordance with the European Central Bank’s Supervisory Review and Evaluation Process (and revised Internal

Liquidity Adequacy Assessment Process requirement issued in November 2018), the Group has implemented an Internal

Liquidity Adequacy Assessment Process which is carried out, assessed, documented, and reviewed at least annually and

approved by the Management Board.

Risk appetite and control setting

The Group’s liquidity risk appetite, which is defined through qualitative principles and supporting quantitative metrics, is

laid out in the Risk Appetite Statement and is subject to the standards defined in the Risk Appetite Policy. This Group

Risk Appetite Statement (RAS) covers regulatory (Pillar 1) as well as internal (Pillar 2) metrics, and is further underpinned

by the liquidity risk controls framework consisting of Risk Appetite limits, as well as a suite of additional limits, thresholds

and early warning indicators.

Treasury manages liquidity and funding, in accordance with the risk appetite across all relevant metrics and implements

tools, including business level risk limits, further cascading aspects of risk appetite to divisional level, ensuring ease of

compliance at Group level. As such, Treasury works closely with Enterprise and Treasury Risk Management under its

delegated authority and the business divisions to identify, analyze and monitor underlying liquidity risk characteristics

within business portfolios. These parties are engaged in regular dialogue regarding changes in the Group’s liquidity

position arising from business activities and market events.


Deutsche Bank	Risk type management
Annual Report 2025	Liquidity Risk Management

Furthermore, the Group ensures at the level of each Liquidity Relevant Entity that all local liquidity metrics are managed

in compliance with the defined risk appetite. Local liquidity surpluses are pooled in Deutsche Bank AG hubs and local

liquidity shortfalls can be met through support from these hubs. Transfers of liquidity capacity between entities are

subject to the Intercompany Funding approval framework involving the Group’s liquidity steering function as well as the

local liquidity managers considering the compliance with Pillar 1 metrics, including Liquidity Coverage Ratio (LCR) and

Net Stable Funding Ratio (NSFR), as well as Pillar 2 metrics, including the stressed Net Liquidity Position (sNLP) and

Funding Matrix. Any available surplus that resides in entities with restrictions on transferring liquidity to other Group

entities, for example due to regulatory lending requirements, is treated as trapped and as such not considered in the

calculation of the consolidated Group liquidity surplus.

The Management Board is informed about the Group’s performance against the key liquidity metrics, including the risk

appetite and internal and market indicators, via a weekly liquidity dashboard.

Funding Risk Management and Funding Diversification

In line with regulatory guidelines, Deutsche Bank has developed a set of internal indicators to measure its inherent

funding risks. These are considered for risk management and steering purposes in addition to the Pillar 1 requirements.

The Group relies on a diverse range of funding sources including deposits, unsecured wholesale funding, Capital Markets

Issuances and secured funding. These funding sources protect the Group’s liquidity position in two ways. First, since

stress events may impact funding markets differently, maintaining a well-diversified funding portfolio will lower the

average impact of these events. Second, when experiencing a liquidity stress, having access to a wide range of funding

sources significantly improves the Group’s ability to tap different funding markets. The diversification across products is

complemented by Risk indicators which have been set to monitor tenor concentration and counterparty concentration.

The stability of Deutsche Bank Group’s funding position can be negatively impacted by various forms of industry risks

which often manifests medium to long term structural trends with a potentially significant long-term impact on the

economy and banks’ balance sheets. Deutsche Bank performs ad-hoc analyses on such emerging risks to assess the

impact of such trends on its funding position to ensure that mitigating measures are taken on a timely basis when

deemed necessary. In addition, Treasury evaluates current market access information in its significant funding markets

on a monthly basis with results compiled and presented to the Group Asset and Liability Committee.

Deutsche Bank’s tool for monitoring and managing the Group’s long-term funding profile for more than ten years is the

Funding Matrix. To produce the Funding Matrix, all assets and liabilities are mapped into time buckets corresponding to

their baseline contractual or modelled maturities. This allows the Group to identify expected excesses and shortfalls in

term liabilities over assets in each time bucket, facilitating the management of potential liquidity exposures over time.

The liquidity profile is based on contractual cash flow information. If the contractual maturity profile of a product does

not adequately reflect the liquidity profile or in case of non-maturing products, the maturity is replaced by baseline

modelling assumptions.

Capital Markets Issuance

The main objective of debt issuance is to raise long term funding in the most cost optimal manner. Debt issuance,

encompassing senior unsecured bonds, covered bonds, and capital securities, is a key source of term funding for the

Group and is managed directly by Treasury. At least once a year, following endorsement by the Asset and Liability

Committee, Treasury submits an annual long-term funding plan to the Group Risk Committee for recommendation and

then to the Management Board for approval. This plan is driven by global and local funding and liquidity requirements

based on expected business development. The Group’s capital markets issuance portfolio is dynamically managed

through annual issuance plans to avoid excessive maturity concentrations.

Deutsche Bank holds a license to issue mortgage Pfandbriefe and maintains a program to issue structured covered

bonds. In 2025, the Pfandbrief platform was enriched to support callable Pfandbriefe which further broadens the

bandwidth offered to investors. The Spanish covered bond program (Cedulas) is currently winding down, although there

are plans to restart the program in 2026. Since 2020, the Group has maintained its Green Bond framework which offers

green note issuances to both, institutional and retail investors. Furthermore, multiple green structured notes, green

deposits and repurchase agreements (repos) have been executed. In 2024, the sustainability framework was enriched to

also support social assets. Deutsche Bank also expanded its platform to issue Panda bonds in China. Since 2023, bonds

with a total notional value of CNY 8 billion were issued into the Chinese market.


Deutsche Bank	Risk type management
Annual Report 2025	Liquidity Risk Management

Liquidity risk monitoring and management

The Finance teams Liquidity and Treasury Reporting & Analysis (LTRA) and Liquidity Data Measurement and Reporting

(LDMR) together own the overall accountability for the accurate and timely production of both external regulatory

liquidity reporting (Pillar 1) as well as internal management reporting (Pillar 2) for the liquidity risk of the Group. In

addition, LTRA is responsible for the development of management information systems and the related analysis to

support the liquidity risk framework and its governance for Enterprise and Treasury Risk Management.

Liquidity Coverage Ratio (LCR)

The Liquidity Coverage Ratio (LCR) is a regulatory metric designed to ensure that the Group maintains adequate liquidity

resources in the form of High Quality Liquid Assets (HQLA) to offset short-term liquidity stress described in Net Cash

Outflows (NCO) over a 30-day horizon on a consolidated currency basis.

By maintaining a ratio in excess of the minimum regulatory requirements, the LCR seeks to ensure that the Group holds

adequate liquidity resources to mitigate a short-term liquidity stress.

Stressed Net Liquidity Position (sNLP)

Stressed Net Liquidity Position (sNLP) is an internal metric used to measure liquidity risk and evaluate Deutsche Bank’s

short-term liquidity position through stress testing and scenario analysis across various time horizons. Key differences

between the internal liquidity stress test metric (sNLP) and the LCR include the risk appetite time horizon (3 months

versus 30 days, respectively), the classification and haircut differences between debt securities within the sNLP and the

HQLA contributing to the LCR, outflow rates for various categories of funding, as well as inflow assumption for various

assets (e.g., loan repayments). The Group’s internal liquidity stress test also includes outflows related to intraday liquidity

assumptions, which are not systematically reflected in the LCR.

Net Stable Funding Ratio (NSFR)

The Net Stable Funding Ratio (NSFR) is a regulatory metric which assesses Deutsche Bank’s structural funding profile by

comparing Available Stable Funding (ASF), including Capital and stable liabilities, to Required Stable Funding (RSF) for

on-balance sheet assets, thereby mitigating medium to long-term funding risks.

Liquidity stress testing and scenario analysis

Global internal liquidity stress testing and scenario analysis is used for measuring liquidity risk and evaluating the Group’s

short-term liquidity position within the liquidity framework. This complements the daily operational cash management

process. The long-term liquidity strategy based on baseline contractual or modelled maturities is represented by a long-

term metric known as the Funding Matrix (additional information can be found in the section “Funding risk management

and funding diversification” in this report).

The global liquidity stress testing exposure is managed by Treasury in compliance with the respective risk appetite.

Treasury is responsible for the design of the overall stress test methodology, the choice of liquidity risk drivers and the

determination of appropriate assumptions (parameters) to translate input data into stress testing output. Enterprise and

Treasury Risk Management is responsible for the definition of the stress scenarios. Laid out by the Model Risk

Management Policy and Procedure, Enterprise and Treasury Risk Management and Model Risk Management perform the

independent validation of liquidity risk models. The Finance teams Liquidity and Treasury Reporting & Analysis (LTRA)

and Liquidity Data Measurement and Reporting (LDMR) are responsible for implementing these methodologies and

performing the stress test calculation in conjunction with Treasury, Liquidity Risk Management, Group Strategic Analytics

and Information Technology.

Stress testing and scenario analysis are used to describe and evaluate the impact of sudden and severe stress events on

the Group’s liquidity position. Deutsche Bank has selected four scenarios to calculate the Group’s stressed Net Liquidity

Position. These scenarios are designed to capture potential outcomes which may be experienced by the Group. The most

severe scenario assesses the potential consequences of a combined market-wide and severe idiosyncratic stress event,

including multi-notch downgrades of the Bank’s credit ratings. Under each of the scenarios, the impact of a liquidity

stress event over different time horizons and across multiple liquidity risk drivers, covering all business lines and product

areas and with that all portfolios and balance sheet, is considered. The output from this scenario analysis also feeds the

Group Wide Stress Test run by Enterprise Risk Management, which analyzes liquidity risk in conjunction with the other

defined risk types and evaluates their impact and interplay to both Capital and Liquidity positions.


Deutsche Bank	Risk type management
Annual Report 2025	Liquidity Risk Management

In addition, potential funding requirements from contingent liquidity risks which can arise under stress, including

drawdowns on lending facilities, increased collateral requirements under derivative agreements, and outflows from

deposits with a contractual rating linked trigger are included in the analysis. Subsequently, countermeasures, which are

the actions the Group would take to counterbalance the outflows incurred during a stress event, are also taken into

consideration. These countermeasures include the usage of the Group’s liquidity reserves and generating liquidity from

other unencumbered, marketable assets without causing any material impact on the Group’s business model.

Stress testing is conducted at a group level and for defined entities relevant for liquidity risk management. The stress

analysis covers a range of time periods out to 1 year depending on the scenario. The most acute stress uses a time period

of three months which is considered to be the critical time period during a liquidity crisis requiring that liquidity is

actively assessed and steered on a Group level. In addition to the consolidated currency stress test, further stress tests

are performed for material currencies, namely euro and U.S. dollar. At the global level as well as for the U.S. entities,

liquidity stress tests also cover a twelve-months period for which a risk appetite limit has been set. Ad hoc analysis may

be conducted to reflect the impact of potential downside events that could affect the Group, such as climate/ESG-

related events. Relevant stress assumptions are applied to reflect liquidity flows from risk drivers and on-balance sheet

and off-balance sheet products. The suite of stress testing scenarios and assumptions are reviewed on a regular basis

and are updated when enhancements are made to stress testing methodologies.


Deutsche Bank	Risk type management
Annual Report 2025	Liquidity Risk Management

Liquidity Risk Mitigation

High Quality Liquid Assets

High-quality Liquid Assets (HQLA) is a Pillar 1 calculation which feeds into LCR and is a key limit per the risk appetite.

HQLA comprise available cash and cash equivalents and unencumbered high quality liquid securities (including

government and government guaranteed bonds), representing the most readily available and most important

countermeasure in a stress event.

The vast majority of the Group’s HQLA are held centrally across major currencies at the central bank accounts of the

parent entity and foreign branches in the key locations in which the Bank is active, and in a dedicated Treasury-owned

Strategic Liquidity Reserves portfolio, set up exclusively to serve as a mitigant during periods of stress.

Asset Encumbrance

Encumbered assets primarily comprise those on- and off-balance sheet assets that are pledged as collateral against

secured funding, collateral swaps, and other collateralized obligations. Generally, loans are encumbered to support long-

term capital markets secured issuance such as covered bonds or other self-securitization structures, while financing debt

and equity inventory on a secured basis is a regular activity for the Investment Bank business. Additionally, in line with

the European Banking Authority technical standards on regulatory asset encumbrance reporting, assets pledged with

settlement systems (including default funds and initial margins) as well as other assets pledged which cannot be freely

withdrawn such as mandatory minimum reserves at central banks are considered encumbered assets. Derivative margin

receivable assets as encumbered under these European Banking Authority guidelines are also included.

Funds Transfer Pricing (FTP)

FTP is a cost allocation and business steering tool to manage costs and benefits (remuneration) associated with funding

and contingent liquidity risk, aligned to the firm’s risk appetite. FTP applies to all business segments and entities with

balance sheet items requiring active management and funding from the Group and promotes pricing of (i) assets in

accordance with their underlying liquidity risk, (ii) liabilities in accordance with their liquidity value and (iii) contingent

liquidity exposures in accordance with the cost of providing for appropriate High Quality Liquid Assets.

Within this framework, funding and liquidity risk costs and benefits are allocated to the Group’s business units based on

rates which reflect the economic costs of liquidity for the Bank. Treasury might set further financial incentives in line with

the Group’s liquidity risk guidelines.

Additional details are included in Note 04 “Business segments and related information“ of the consolidated financial

statements.

Contingency Funding Planning

The Group Contingency Funding Plan outlines how Deutsche Bank would respond to an actual or anticipated liquidity

stress event. It specifies the provisions, procedures and action plans for responding to potential disruptions to the Bank’s

ability to fund itself. It covers actions that can be taken to raise cash and/or recover the Bank’s liquidity metrics in breach.

The Contingency Funding Plan outlines governance arrangements for its activation and presents the framework of

liquidity indicators enabling the bank to identify deteriorating market circumstances in a timely manner and that

determine quickly what actions need to be taken, including communication and coordination during a liquidity stress

event. Deutsche Bank has established the Financial Resource Management Council, which is responsible for oversight of

capital and liquidity across contingency, recovery, and resolution scenarios in a defined crisis situation.

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Annual Report 2025	Model Risk Management

Model Risk Management

Model risk is the potential for adverse consequences from decisions based on incorrect models or their misused outputs.

Model risk can lead to financial loss, poor business or strategic decision making, or damage to its reputation. Deutsche

Bank recognizes the use of models can affect other risk-types, and that model risk is a distinct risk that can increase or

decrease aggregate risk across other risk-types.

Deutsche Bank uses models for a broad range of decision-making activities, such as: underwriting credits; valuing

exposures, instruments, and positions; measuring risk; managing and safeguarding client assets and determining capital

and reserve adequacy. The term ‘model’ is a quantitative or qualitative method, system, or approach that applies expert

judgement, statistical, economic, financial, or mathematical theories, techniques, and assumptions to process input data

into quantitative estimates. Models are simplified representations of real-world relationships and are based on

assumptions and judgment. Accordingly, the bank is exposed to model risk, which must be identified, measured, and

controlled appropriately.

Model risk management oversight is provided by all levels of management, including the Management Board.

Management of model risk is underpinned by a framework designed and monitored by a 2nd Line of Defense control

function independent from developer, owner, and user of models.

Model Risk Management Framework and Governance

Model risk is overseen by the Chief Risk Officer through the setting of a quantitative and qualitative risk appetite

statement, and managed via:

–The Model Risk Policy and Procedure, and supporting documents aligned to risk appetite, regulatory requirements,

and industry best practice, with clear roles and responsibilities for stakeholders

–Inventorization of all models, supporting ongoing model risk framework components, including risk assessments and

attestations

–Key controls for models from development through to decommissioning, including validation, approval, deployment

and monitoring

–Models are assessed for their materiality, complexity, uncertainty and reliance and in aggregate assigned a risk Tier,

which is used to identify those which present the higher risk to Deutsche Bank

–A risk based approach to managing the models by Tier is applied

–Independent validations, and subsequent independent approvals, verify that models have been appropriately

designed and implemented for their intended scope and purpose, and that respective controls are in place to assure

that they continue to perform as expected during their use

–The controls identify models’ limitations and weaknesses, resulting in findings and compensating controls, these may

be conditions for use, such as adjustments or overlays

–Model risk governance, including senior forums for monitoring and escalation of model risk related topics, as well as

monthly updates to the Management Board on the model risk appetite metrics, and periodic model risk updates to the

Supervisory Board

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Annual Report 2025	Operational Risk Management

Operational Risk Management

Operational Risk Management Overview

Deutsche Bank applies the European Banking Authority’s Single Rulebook definition of operational risk: “Operational risk

means the risk of losses stemming from inadequate or failed internal processes, people and systems or from external

events. Operational risk includes legal risks but excludes business and reputational risk and is embedded in all banking

products and activities.”

Deutsche Bank’s operational risk appetite defines the amount of operational risk it is willing to accept as a consequence

of conducting its business. The bank takes on operational risks consciously, both strategically and in day-to-day business.

While the bank has no appetite for certain types of operational risk events (such as violations of laws or regulations or

misconduct), other types of operational risk must be accepted for the bank is to achieve its business objectives. Where

residual risk is assessed to be outside risk appetite, risk-reducing actions must be undertaken, including risk remediation,

risk transfer through insurance, or ceasing business activity.

The Operational Risk Management Framework comprises a set of interrelated tools and processes used to identify,

assess, mitigate and monitor the bank’s operational risks. Its components are designed to work together to provide a

comprehensive, risk-based approach to managing the bank’s most material operational risks. The Framework includes the

Group’s approach to setting and adhering to operational risk appetite, the operational risk type and control taxonomies,

the policies and procedures governing operational risk management processes and tools, and the bank’s operational risk

capital calculation.

Organizational and governance structure

Operational risk is managed according to the principle that day‑to‑day responsibility lies with the divisions and

infrastructure functions where these risks originate. Operational Risk Management (“ORM”) provides independent

oversight of the Group’s operational risk profile, identifies and reports risk concentrations, and ensures consistent

application of the Operational Risk Management Framework across the bank. ORM forms part of the Group’s risk function

within the Chief Risk Office, led by the Chief Risk Officer. The Chief Risk Officer appoints the Head of ORM, who is

responsible for designing, overseeing, and maintaining an effective, efficient, and regulatory‑compliant Operational Risk

Management Framework, including the methodology for operational risk capital calculation. The Head of ORM monitors

and challenges the Framework’s Group‑wide implementation and tracks the overall operational risk levels against the

bank’s defined operational risk appetite.

Operational risk governance is aligned with the bank’s Three Lines of Defence (“3LoD”) model. The Operational Risk

Management Framework defines governance standards and outlines the core responsibilities of the 1st and 2nd LoD to

ensure effective risk management and appropriate independent challenge. The Operational Risk Committee governs and

coordinates the management of operational risk across the Group. Its mandate includes decision‑making and policy

responsibilities, as well as reviewing, advising on, and addressing operational risk matters that may influence the risk

profile of business divisions or infrastructure functions. A number of sub‑fora, with participants from both the First Line of

Defence (1st LoD) and Second Line of Defence (2nd LoD), support the Committee in fulfilling its responsibilities. In

addition to the Group‑level Committee, business divisions maintain 1st LoD operational risk fora to oversee and manage

operational risks at various organisational levels.

Risk owners within the 1st LoD have full accountability for the operational risks arising from their activities and are

responsible for managing these risks within the established risk appetite. As leaders of business divisions or infrastructure

functions, risk owners must determine the appropriate organisational structure to identify their operational risk profile,

actively manage operational risks, make decisions on mitigating or accepting risks to remain within appetite, and

establish and maintain effective 1st LoD controls.

Risk Type Heads serve as 2nd LoD control functions for all sub‑risk types within the overarching operational risk category.

They define the framework and Group‑level risk appetite for the risk type they oversee, establish minimum risk

management requirements and control objectives, and independently monitor and challenge the 1st LoD’s

implementation of these requirements. They provide independent oversight of the risk type and monitor adherence to

the defined risk appetite. As subject matter experts, they define the risk taxonomy, support implementation of the

Framework in the 1st LoD, and maintain independence by being located solely within infrastructure functions.

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As the 2nd LoD risk control function for operational risk, ORM establishes and maintains the overarching Operational Risk

Management Framework.

–ORM defines the bank’s approach to operational risk appetite, monitors adherence, evaluates consequences of

breaches, and oversees remediation plans to return the operational risk profile to within appetite where needed. ORM

also regularly reports the Group’s operational risk profile, including any risks that fall outside the defined appetite.

–ORM provides independent assessments to support proactive operational risk management, engages with risk owners

in the 1st LoD, and facilitates consistent implementation of risk management requirements across the bank.

–ORM is responsible for designing, implementing, and maintaining the methodology to determine the appropriate

capital for operational risk, for recommendation to the Management Board. This includes calculating and allocating

operational risk capital demand and expected loss.

Operational Risk Management Framework

The Operational Risk Management Framework (ORMF) enables the bank to determine its operational risk profile relative

to its defined risk appetite, identify systemic themes and concentrations, and establish mitigation measures and

priorities.

In 2025, the bank further enhanced the Framework by introducing cross‑risk types within the Operational Risk Type

Taxonomy to better reflect the bank’s operational risk profile. Additional improvements included operationalizing control

assessment, testing and certification within the new strategic tool for the operational risk controls inventory and

transitioning the Risk & Control Self‑Assessment to a more data‑driven approach.

Key sub-components include:

–Loss Data Collection: Internal operational risk events with a P&L impact of € 10,000 or more are recorded and

validated, and external events are assessed for their relevance to the group and business divisions. Material events

trigger a formal lessons‑learned and read‑across process conducted by the 1st Line of Defense in close collaboration

with business partners, risk control functions, and other infrastructure areas. Lessons‑learned reviews assess root

causes of significant events and document remediation actions to reduce recurrence. Read‑across analyses evaluate

whether similar weaknesses may exist elsewhere in the bank, even if they have not yet resulted in losses, thereby

facilitating preventative action. In 2025, the internal event database was enhanced particularly the mapping of

controls to events and automated read‑across triggers, and the external events review process was refined to assess

susceptibility of similar risks within the bank.

–Risk Appetite: Operational risk appetite defines the level of operational risk the bank is willing to accept to pursue its

strategy. The operational risk appetite framework provides a consistent approach to setting appetite levels across the

bank and monitoring exposures against these levels. The bank regularly monitors its operational risk profile against

defined appetite to alert the organization on impending problems in a timely fashion. In 2025, the bank implemented

previously introduced concepts of residual risk zones and operating conditions, including monitoring processes, and

further refined the granularity of risk appetite setting.

–Risk & Control Self‑Assessment: The Risk & Control Self‑Assessment (RCSA) comprises bottom‑up evaluations of risks

generated within business divisions and infrastructure functions, the effectiveness of associated controls, and

required remediation actions to ensure risks remain within appetite. Conducted at the global business level, the RCSA

covers all jurisdictions and is designed to assist Senior Management to determine whether operational risks are

managed and controlled adequately via a dynamic assessment approach covering all applicable Risk Types from the

Group’s Operational Risk Type Taxonomy (ORTT). The Risk & Control Self-Assessment puts a greater emphasis on

assessing and mitigating risks that are outside of appetite and risks that drive unethical and inappropriate market

conduct within the bank. In 2025, RCSA granularity was increased to provide more precise risk insights and ensure a

more accurate risk profile for comparison against defined appetite.

–Emerging risk: Emerging risk themes are derived from internal and external indicators. Operational risk outputs are

combined with external event data to identify emerging trends and concentrations. This analysis complements

insights from divisional emerging risk themes, dynamic RCSA results, findings, scenario analysis, internal and external

events, and industry developments, enabling Risk Owners to draw informed conclusions.

–Scenario Analysis: The operational risk profile is further substantiated through exploratory scenario analysis, which

supplements day‑to‑day risk management. Scenario analysis supports the identification of potential exposures,

highlights gaps in the current risk profile, and informs forward‑looking risk mitigation. Scenario development

incorporates themes from internal losses, emerging risk assessments, top risks, concentrations, findings, and external

peer loss events. Insights from actual and potential events are used to identify thematic vulnerabilities and drive

actions such as deep‑dive reviews or enhancements to risk profiles. In 2025, the capture and governance of scenario

analysis was migrated to the Event Management Application to improve data quality and oversight.

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–Transformation Risk Assessment: A Transformation Risk Assessment (TRA) process is in place to appropriately identify

and manage risks arising from material change initiatives to assess the impact of transformation on the bank’s risk

profile. The TRA applies to all key deliverables including regulatory initiatives, technology migrations, risk mitigation

projects, strategy changes, organizational restructuring, real estate moves within the bank, as well as joint ventures

and strategic investments.

–Findings and Issue Management: The findings and issue management process supports the mitigation of risks arising

from known control weaknesses and deficiencies. It enables management to make risk-based decisions over the need

for further remediation or risk acceptance. Outputs from the findings management process must be able to

demonstrate to internal and external stakeholders that the bank is actively identifying its control weaknesses and

taking steps to manage associated risks within acceptable levels of risk appetite. In 2025, the process was

strengthened through more robust requirements for identifying correct findings owners, enhancing management

reporting, and the timely remediation of Action Plans.

Framework Adherence: As owner of the Operational Risk Management Framework, ORM performs regular independent

monitoring and testing to assess adherence by both the 1st and 2nd LoD:

–Annually, assess 1LoD and 2LoD Risk Type Head (RTH) implementation and adherence to the requirements of the

ORMF

–Adverse outcomes of adherence result in consequences being applied

–Adherence results also aim to proactively identify both design and implementation improvements (Framework,

Tooling, etc.)

In 2025, annual Framework Adherence results were incorporated in the ORM Composite KPI and made mandatory for all

divisions, creating a direct variable compensation impact via the Balanced Scorecard (BSC). Quarterly U.S. RCSA

Adherence reviews were also introduced.

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Annual Report 2025	Operational Risk Management

Operational Risk Type Oversight

The Framework applies to operational sub‑risk types at a more granular level and enables the bank to aggregate, oversee,

and monitor its overall operational risk profile. These operational sub‑risk types are managed by various infrastructure

functions and include the following:

–ORM includes the Risk Type Head role for several operational risk types. Its mandate includes second line oversight of

controls related to transaction processing activities and infrastructure risks, to prevent technology or process

disruptions, maintain the confidentiality, integrity, and availability of data and records, ensure robust information

security, and confirm that business divisions and infrastructure functions have effective plans in place to recover

critical processes and functions in the event of disruption, including technical or building outages, cyber‑attacks,

natural disasters, or physical security and safety risk. ORM Risk Type Heads also manages risks arising from the bank’s

internal and external vendor engagements through the implementation of a comprehensive third‑party risk management

framework.

–The Compliance department performs an independent 2nd line control function that protects the bank’s license to

operate by promoting and enforcing compliance with the law and driving a culture of compliance and ethical conduct

in the bank. The Compliance department assists, reviews and challenges the business divisions and works with other

infrastructure functions and regulators to establish and maintain a risk-based approach to the management of the

bank’s compliance risks in accordance with the bank’s risk appetite and to help the bank detect, mitigate and prevent

breaches of laws, rules and regulations as well as internal policies. The Compliance department performs the

following principal activities: engaging with and managing regulatory matters in collaboration with the Regulatory and

Exam Management Group; identifying and assessing new and amended laws, rules, and regulations; acting as advisor

to the management board and performing independent review and challenge; performing second line controls; as

well as identifying, assessing, mitigating, monitoring, and reporting on compliance risk. The results of these

assessments and controls are regularly reported to both the Management Board and the Supervisory Board.

–Financial crime risks are managed by the Anti-Financial Crime (AFC), an independent Infrastructure second line

function. AFC maintains a dedicated program which is based on regulatory and supervisory requirements with defined

roles and responsibilities for the identification and management of financial crime risks resulting from money

laundering, terrorism financing, compliance with sanctions and embargoes, the facilitation of tax evasion as well as

other criminal activities including fraud, bribery and corruption and other crimes. AFC updates its strategy for financial

crime prevention via regular development of internal policies processes and controls, institution-specific risk

assessment and staff training.

–Group Governance defines, implements, and monitors the governance framework for Deutsche Bank globally in

support of the bank’s overall strategy, ensuring that governance structures are lean, transparent, and sustainable. The

unit develops and safeguards efficient corporate governance structures suitable to support effective individual and

joint decision-making that avoids and manages (structural and organizational) conflicts. It also establishes, maintains

and controls an appropriate and transparent policy taxonomy, landscape and tooling. The independency of Group

Governance is ensured through direct reporting line into the Management Board and not into any business division,

and through a ring-fenced incentive system and compensation system where performance evaluation is tied

principally to risk management and not to business revenues.

–Legal is a fully independent infrastructure function, mandated to provide legal advice both to the Management Board

as well as to the business divisions and infrastructure functions and to manage the Bank’s litigation and contentious

regulatory matters. Legal has a monopoly for giving legal advice, retaining and controlling outside counsel. Legal’s

independence is supported by its reporting line to the Management Board and a compensation framework that

focuses on risk management.

–Deutsche Bank’s New Product Approval and Systematic Product Review processes form a control framework

designed to manage the risks associated with new products and services and their lifecycle management. These

processes are overseen by the New Business Office and Product & Structured Transaction Lifecycle teams within the

Operational Risk Management function. Existing products and services are reviewed on one‑ to three‑year cycles to

assess whether they remain fit for purpose and aligned with the characteristics and objectives of their respective

target markets. Each product or service must be sponsored by a business Managing Director, who retains ultimate

accountability for it. Breaches of the New Product Approval requirements fall within the scope of the bank’s Red Flag

consequence management process .

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Measuring Operational Risks

Deutsche Bank measures risk-weighted assets to determine the regulatory capital demand for operational risk using the

“Standardized Measurement Approach” laid out in the European Capital Requirements Regulation (CRR3) introduced in

2025.

In addition to regulatory capital demand, Deutsche Bank continues to determine its internal economic capital demand

for operational risk using the Advanced Measurement Approach (AMA) methodology. The AMA capital calculation is

based on a loss distribution approach. Gross losses from historical internal and external loss data (Operational Risk data

eXchange Association consortium data) are used to estimate the risk profile (i.e., a loss frequency and a loss severity

distribution). The loss distribution approach model includes conservatism by recognizing losses on events that arise over

multiple years as single events in the historical loss profile.

Within the AMA model, the frequency and severity distributions are combined in a Monte Carlo simulation to generate

potential losses over a one-year time horizon. Correlation and diversification benefits are applied to the net losses to

arrive at a net loss distribution at Group level, covering expected and unexpected losses. The resulting economic capital

demand is then allocated to each of the business divisions considering qualitative adjustments after deducting expected

loss.

The economic capital requirements for operational risk is derived from the 99.9% percentile and calculated for a time

horizon of one year.

The economic capital demand calculation is performed on a quarterly basis.

ORM establishes and maintains the approach for capital demand quantification and ensures that appropriate

development, validation and change governance processes are in place, whereby the validation is performed by an

independent validation function and in line with the Group’s model risk management process.

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Drivers for operational risk economic capital development

By design of the AMA capital calculation, Deutsche Bank’s operational risk economic capital demand is predominantly

driven by historical internal loss events.

In view of the relevance of legal risks within the bank’s operational risk profile, specific attention is dedicated to the

management and measurement of open civil litigation and regulatory enforcement matters where the bank relies both

on information from internal as well as external data sources to consider developments in legal matters that affect the

bank specifically but also the banking industry as a whole. Reflecting the multi-year nature of legal proceedings the

measurement of these risks furthermore takes into account changing levels of certainty by capturing the risks at various

stages throughout the lifecycle of a legal matter.

Conceptually, the bank measures operational risk including legal risk by determining the annual operational risk loss that

will not be exceeded with a given probability. This loss amount is driven by a component that due to the IFRS criteria is

reflected in the bank’s financial statements and a component beyond the amount reflected as provisions within the

bank’s financial statements.

The legal losses which the bank expects with a likelihood of more than 50% are already reflected in the IFRS group

financial statements. These losses include net changes in provisions for existing and new cases in a specific period where

the loss is deemed probable and is reliably measurable in accordance with IAS 37.

Uncertain legal losses which are not reflected in the bank’s financial statements as provisions because they do not meet

the recognition criteria under IAS 37 are considered within the “economic capital demand”.

To quantify the litigation losses in the AMA model, the bank takes into account historical losses, provisions, contingent

liabilities and legal forecasts. Legal forecasts generally comprise ranges of potential losses covering risks of outflows

greater than the provision and adjustments which are deemed remote or relate to yet unknown matters. Such forecasts

may result from ongoing and new legal matters which are reviewed at least quarterly by the attorneys handling the legal

matters.

The legal forecasts are included in the loss data input into the AMA model. The projection range of the legal forecasts is

not restricted to the one year capital time horizon but goes beyond and conservatively assumes early settlement of the

underlying losses in the reporting period - thus considering the multi-year nature of legal matters.

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Annual Report 2025	Reputational Risk Management

Reputational Risk Management

Within the group’s risk management process, reputational risk is defined as the risk of possible damage to Deutsche

Bank’s brand and reputation, and the associated risk to earnings, capital or liquidity arising from any association, action or

inaction which could be perceived by stakeholders to be inappropriate, unethical or inconsistent with Deutsche Bank’s

Code of Conduct.

Deutsche Bank has limited appetite for transactions or relationships with material reputational risk or in areas which

inherently pose a higher reputational risk such as the defense, gaming, or adult entertainment sectors, or where there are

certain environmental concerns. Decisions about specific transactions or relationships are made based on a risk based,

individualized and objective assessment. Reputational risk cannot be precluded as it can be driven by unforeseeable

changes in perception of its practices by its various stakeholders (e.g. public, clients, shareholders and regulators).

The Reputational Risk Framework (the Framework) is in place to manage the process through which active decisions are

taken on matters which may pose a reputational risk, before the event, and in doing so to prevent damage to Deutsche

Bank’s reputation wherever possible. The Framework provides consistent standards for the identification, assessment

and management of reputational risk issues.

Reputational Risk could arise from multiple sources including, but not limited to, Deutsche Bank’s employees, business

strategies and activities, clients, and counterparties. Such events could contribute to among other consequences,

financial losses, litigation, regulatory enforcement actions, or monetary fines, as well as other reputational harm.

The modelling and quantitative measurement of reputational risk internal capital is implicitly covered in the bank’s

economic capital framework primarily within strategic risk.

Governance and Organizational Structure

Deutsche Bank manages reputational risk through a framework. Under this framework, Deutsche Bank has established a

risk appetite statement and policies and controls embedded throughout our business and risk management processes,

with variances available when necessary to comply with applicable country laws, regulations and expectations. . Matters

specific to DWS are reviewed by the DWS Reputational Risk Committee and, if necessary, escalated to the DWS

Executive Board. Decisions are subject to the DWS and Deutsche Bank internal Corporate Governance policies.

Whilst every employee has a responsibility to protect the bank’s reputation, the primary responsibility for the

identification, assessment, management, monitoring and, if necessary, referring or reporting of reputational risk matters

lies with Deutsche Bank’s business divisions as the primary risk owners. Each business division has an established process

through which matters, which are deemed to be a moderate or greater reputational risk are assessed, the Unit

Reputational Risk Assessment Process.

The Unit Reputational Risk Assessment Process is required to refer any material reputational risk matters to the

respective Regional Reputational Risk Committee. The Framework also sets out a number of matters which are

considered inherently higher risk from a reputational risk perspective and are therefore mandatory referrals to the

Regional Reputational Risk Committees. The Regional Reputational Risk Committees are 2nd LoD Committees and meet

on an ad hoc basis as required. The Group Reputational Risk Committee (GRRC) reviews cases with a group-wide impact

and in exceptional circumstances, those that could not be resolved at a regional level.

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Annual Report 2025	Information security

Information security

Deutsche Bank operates in an environment with increasing levels of digitization and a constantly evolving threat

landscape related to information security. Amid these ongoing developments, threats and challenges, Deutsche Bank

has the responsibility to preserve the confidentiality, integrity, and availability of clients’ data, business partners’ data,

and the bank’s own information assets, including the bank’s employees’ information. Doing so consistently and

effectively is essential for retaining the trust of the various stakeholders and preserving their interests.

Due to the dynamic and complex nature of the environment, the bank continuously monitors the security threat

landscape; vigilantly observes technological developments, the geopolitical landscape, and economic impacts driving

security risks; and assesses their relevance for potential impacts on the bank and the wider financial ecosystem.

Deutsche Bank adjusts its security capabilities accordingly to safeguard its ability to provide products and services to

clients and protect the continuous operations of the bank’s businesses.

This section provides a comprehensive overview of Deutsche Bank’s approach to information security, detailing its

continuous efforts to robustly protect data and services, including its security governance structure, security strategy,

and security risk management.

Governance

Responsibility for security matters at Deutsche Bank sits within the Chief Security Office. The Group Chief Security

Officer (CSO) has delegated authority from the Management Board, including approval of the security policies and the

security strategy for the Deutsche Bank Group. The Group CSO reports directly to the Chief Technology, Data, and

Innovation Officer, a member of the Management Board. The Management Board is accountable for overseeing the

implementation of the information security framework, with oversight from the Supervisory Board. There are multiple

mechanisms in place for the Group CSO to escalate security issues directly to the Management Board if required.

Deutsche Bank’s Group CSO has served in various information security roles for more than 20 years. These include

positions as global Chief Information Security Officer (CISO)/CSO for three different large European financial institutions

and a partner position at a global strategy and consulting firm, leading security work for financial service clients.

The Group Chief Security Officer is supported by information security experts at various seniority levels across the bank

to ensure that security requirements are met from regional, divisional, and technical perspectives. All information

security activities are overseen by two dedicated governance forums established and chaired by the Group CSO: the

Group IT Security Council (interfacing with the bank’s IT units) and the Group Information Security Council (interfacing

with the bank’s business and infrastructure divisions). The independent operational risk management function for

information security is represented in both forums. Both forums provide advice on the security strategy and oversee the

progress and performance of key information security deliverables, the remediation status of information security-

related audit findings, information security incidents, and the information security posture of Deutsche Bank Group

against defined targets. In the event of critical issues, members are assigned with specific actions by the Group CSO

according to their responsibility. In addition to the Group CSO-led governance forums, the Technology & Information

Security Risk Committee (TISRC) oversees technology and information security risks, ensuring alignment with the bank's

strategic objectives. The committee is chaired by the Chief Technology, Data and Innovation Officer, and vice chaired by

the Group CSO and the Head of Group Technology Infrastructure, with a mandatory attendance requirement for the

Chief Information Officers and veto power for the risk function represented by both the Global Head of Operational Risk

Management and the Global Head of IT Risk and Information Security Risk.

Security indicators and reporting provided to the bank’s relevant governance forums support appropriate security risk

awareness and decision-making. The comprehensive metrics framework maintained by the Chief Security Office is

underpinned by an extensive data set, allowing for various dedicated views. The Management Board and the Supervisory

Board receive a quarterly information security risk posture report, as well as ad-hoc information if required. Furthermore,

the Group CSO provides regular updates on material topics relating to security to the Supervisory Board’s committee

responsible for Technology, Data and Innovation.,

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Strategy

The Chief Security Office develops the bank’s group-wide security strategy and oversees its global implementation and

operationalization via the organizational setup, governance, and implemented security policies. The security strategy,

which is reviewed on a regular basis, incorporates developments in the threat landscape, technology, the regulatory

environment, the bank’s corporate and IT strategy, and other internal and external parameters. The approach provides

comprehensive and layered security controls. The Chief Security Office works closely with the bank´s divisions to enable

alignment with the security-by-design approach throughout bank-wide programs and initiatives. Security investments

are prioritized and adjusted from a threat-driven perspective, leveraging the regular review and assessment of the

maturity of the bank’s security implementation.

A key element of the bank’s security strategy is to foster responsibility and active awareness among Deutsche Bank staff.

By embedding these principles into daily practices, Deutsche Bank aims to bring about long-term behavioral changes

that help mitigate risks and enhance overall security posture. The bank’s security culture and awareness campaign,

Mission Security, continuously updated to reflect emerging threats and best practices and communicated to all

employees worldwide, reinforces these efforts. Another way the bank strengthens security culture is by periodically

conducting simulations and testing exercises, including phishing simulation and mandatory training.

Impact, risk, and opportunity management

Impacts, risks, and opportunities

Clients expect secure access to their bank’s services anytime, anywhere, and through a variety of channels. As part

of doing business with the bank, clients entrust Deutsche Bank with sensitive data. Deutsche Bank has the

responsibility to preserve the confidentiality, integrity, and availability of clients and business partner data, as well

as its own information assets, including employee information. Doing so consistently and effectively is essential for

retaining the trust of these stakeholders and preserving their interests. Consequently, the bank continues to invest

in security risk mitigation. Based on a comprehensive policy framework for security and stringent risk management

processes, Deutsche Bank adjusts its security capabilities to safeguard its ability to provide products and services

to clients and to protect the continued operations of the bank’s businesses. Stable and resilient services support

stakeholder trust, protecting brand value while enabling business growth and the realization of revenue

opportunities.

Technological advancements are steadily increasing the demands for data privacy and security, while the growing

frequency and sophistication of cyberattacks have significantly elevated the risk profile of organizations

worldwide, including Deutsche Bank and other organizations along its supply chain. Third-party software and

technology providers remain prime targets for threat actors, who exploit supply chain vulnerabilities to

compromise or disrupt large numbers of downstream customers and assets, amplifying the impact of their attacks.

In 2025, geopolitical unrest remained a key driver of cyber threat activity. Financially motivated and highly

sophisticated cyberattacks have become persistent across industries and are expected to intensify. The rapid

adoption and advancement of artificial intelligence (AI) continues to reshape the threat landscape, accelerating

hybrid warfare tactics, misinformation campaigns, and social engineering attacks leveraging deepfakes. Common

attack vectors such as ransomware, denial-of-service attacks, and exploits of unnoticed vulnerabilities (so called

zero-day exploits) are increasing in scale and complexity. Quantum computing, while still emerging, remains a

strategic focus area for long-term risk management.

Failure to embed and ensure oversight of security requirements within the bank’s framework to best address

associated risks and subsequent appropriate implementation can lead to breaches of confidentiality and integrity

of information, and unavailability of information and/or services. Additionally, Deutsche Bank may face operational

risks arising from failures in the control environment, including errors in the performance of processes or security

controls, as well as data loss, which may disrupt business and lead to material losses.

Security breaches can occur due to unauthorized access to networks or resources, unauthorized access or loss/

destruction of confidential information, unintended exposure of vulnerabilities in the bank's infrastructure, or the

introduction of computer viruses or malware, technology failures, or other forms of cybersecurity attacks or

incidents, including breaches of the security of third-party computer systems.

In case of a successful attack, there might be an impact on Deutsche Bank’s stakeholders and the wider financial

ecosystem due to compromised data, unintentional spread of malware, unavailability of services, and the

inaccessibility of systems and/or data. This encompasses internal and third-party information technology systems.

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Annual Report 2025	Information security

A successful cyberattack could have a significant negative direct or indirect impact on the bank that may result in

the disclosure or misuse of client information and the bank’s proprietary information, damage to or inability to

access information technology systems, statutory or regulatory non-compliance and financial losses. Potential

consequences range from reputational damage and client dissatisfaction, contractual non-compliance (e.g., if

services are not provided as agreed), remediation costs (such as for investigation and reestablishing services),

increased cybersecurity costs (such as for additional personnel, technology, or third-party vendors), potential

penalties and fines, to personal data breach notification obligations, and litigation exposure.

Deutsche Bank maintains insurance as an additional risk mitigant for cyber risk. The bank´s insurance coverage is

designed to include the mitigation of the financial impact of security incidents; however, it may not fully cover all

potential losses, including reputational damage or indirect costs associated with a cyber event. Notwithstanding

the bank’s security measures, there can be no assurance that its policies, controls, or cyber insurance coverage will

be sufficient to prevent or fully mitigate the impact of future cyber incidents, and it could have a material adverse

effect on its financial condition.

Policies and risk management

The bank’s policies and controls support risk reduction and mitigation for potential negative impacts. Information security risk is

managed as an operational risk under the bank’s Operational Risk Management Framework. The Chief Security Office is

responsible for and executes security matters against the Operational Risk Management Framework and leverages the results of

its various instruments, such as risk appetite, while Operational Risk Management provides oversight, review, and challenge.

Measures for the further reduction of material residual risks may include policy changes or policy amendments at divisional or

group level, as well as prioritized investment and accelerated implementation of risk-mitigating activities.

Security risks are assessed on a continual basis through analysis of internal and external cyber events, including events at peer

institutions, monitoring of the threat environment, and discussion in various forums.

The annual risk and control assessment process evaluates diverse risk scenarios, encompassing service disruption, system

misuse, data distortion, asset/data destruction, data disclosure, financial theft, and non-adherence to regulatory policies and

laws. This comprehensive analysis incorporates potentially affected stakeholders, including clients and suppliers, and assesses

the external threat landscape by leveraging industry-standard frameworks, such as MITRE ATT&CK (standardized framework to

assess cyberattacks). When evaluating control suites and residual risk positions, the process considers contextual data and

controls, such as major events, threat assessments, findings, scenario analysis, control metrics, lessons learned, events at peer

institutions, read-across, regulatory expectations, and remediation activities. Additional risk reviews are conducted for emerging

developments, with results evaluated against the bank's control capabilities.

As an integral part of this assessment, internal security subject matter experts provide risk evaluations, supported by areas like

Legal, Compliance, or Group Data Privacy, as needed. These evaluations are subsequently reviewed and challenged by risk

subject matter experts to determine the final risk position. Concurrently, senior information security experts from all divisions

and functions assess the group’s exposure within their respective domains. These divisional and functional assessments are also

subjected to review and challenge by risk subject matter experts, establishing the final risk positions across the organization.

Deutsche Bank maintains an ISO 27001-compliant information security management system (ISMS) to protect

information assets. The system facilitates the comprehensive identification, assessment, and mitigation of risks through

the holistic integration of security controls across the entire workforce, operational processes, and technological

infrastructure. It defines the foundational objectives and principles of the bank's security architecture and strategy,

consistent with its overarching governance framework for policies and operational risk management directives.

The ISMS is comprehensively supported by a structured suite of policies, procedures, and controls that clearly define

responsibilities for all employees, designated security roles, and third parties. It also sets forth objectives and processes

for security functions, including access management, threat intelligence, and incident response.

Continuous monitoring and iterative improvement are integral to the ISMS, ensuring adaptability to evolving threats and

vulnerabilities. The framework undergoes an annual strategic review, with all updates approved by the Group CSO. Its

established processes are centrally governed and applied throughout the bank. Unit-specific guidelines further detail

operational implementation, demonstrating a strong commitment to established security standards.

The bank’s ISMS has been certified by an accredited certification body according to ISO 27001 for all information

security domains defined within that standard since 2012. To maintain its ISO 27001 certification, the bank performs a

full recertification process every three years, with the latest taking place in 2024, and included the upgrade of its ISMS to

the 2022 version of ISO 27001. Furthermore, the bank performs an annual surveillance audit designed to ensure

compliance between certification intervals with the most recent surveillance audit conducted in 2025.

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Deutsche Bank	Risk type management
Annual Report 2025	Information security

Actions and resources

To address the evolving threat landscape, Deutsche Bank employs a variety of prevention methods and controls. These include,

for example, network security, identity and access management, endpoint and data security (including data classification and

leakage prevention), threat intelligence, cyber hygiene, and encryption solutions. These preventive controls are backed by a

threat-driven detection setup and a robust incident response process.

Deutsche Bank has established a holistic information security program with appropriate staffing, tooling, and processes. The

bank continually reviews and enhances its information security controls through multiple layers of technology, including

databases, infrastructure, devices, and applications. This is complemented by organizational controls and security training and

awareness. The purpose of this layered approach is to strengthen end-to-end protection by utilizing multiple opportunities to

prevent, detect, respond to, and recover from cyber threats.

Deutsche Bank leverages various mechanisms to self-identify areas for improvements and control enhancements. These

encompass comprehensive security testing including red teaming and threat-led penetration testing, security problem

management, and lessons learned. Deutsche Bank´s Group Audit provides independent, risk-based assurance by periodically

assessing the design and operating effectiveness of key information security controls within the ISMS. The bank’s overall

information security program is evaluated on a regular basis by third-party organizations which include external auditors,

regulators and security testing organizations.

The bank actively shares security best practices and threat information with national and international security organizations,

government authorities, and peer organizations. These relationships help ensure that the bank’s security technology and

procedures reflect current financial industry best practices and keep pace with the evolving threat environment.

As digitalization advances, the need to enhance societal literacy on information security topics grows. Deutsche Bank addresses

this need by educating and informing through informational materials, publicly provided via its dedicated client-facing security

website covering security-related topics and highlighting information security threats (including those related to emerging

technologies like AI, deepfakes and phishing via quick response (QR) codes), best practices for secure behavior, and links to

relevant resources. To strengthen trust, additionally, an overview of the bank's protective measures is provided. Client

interaction also encompasses presentation of security topics at client events and responses to client inquiries on security topics

by its client relationship managers.

Deutsche Bank requires yearly mandatory information security baseline training for all employees and eligible contractor staff.

This training encompasses the content of the information security policy, the process to report security incidents or any other

security-related concerns, as well as important and current security threats. To ensure relevance and to comply with internal

standards, the training is updated at least on a yearly basis. For Deutsche Bank employees, failure to complete this training and

late completion can result in disciplinary consequences. In 2025, a learning completion rate of 99,66% was achieved for the e-

learning-based mandatory information security training, compared to 99,65% in 2024.

Deutsche Bank’s security incident management provides ongoing coverage for security events that may affect the bank, its

clients and business partners, or employees. The bank’s Cyber Threat Operations Centers located in Asia Pacific, Europe and

USA support global and group-wide detection of threats and response to incidents 24/7. The related management and

reporting processes performed with involvement of subject matter experts, such as divisional CISOs, Compliance, Legal, Group

Communications and Group Data Privacy, are designed to enable a quick and effective response to cyberattacks and

information security threats. The objective is to minimize the risk of impacts on Deutsche Bank and to use insights gained from

incident handling to continuously improve the bank’s processes.

Information security risks of third parties are managed by Deutsche Bank through a combination of capabilities, implementing a

comprehensive approach to mitigate these risks. Key components include the bank’s global third-party risk management

program, which is designed to identify, monitor, and mitigate risks associated with third-party engagements. In combination,

the bank requires adherence to an information security policy with specific security controls for third parties, which

include incident notification requirements.

Third parties are also re-assessed periodically based on their criticality (annually or bi-annually) to seek continued

assurance that control requirements are being met. Additionally, third parties are also engaged in response to specific

threats and incidents to assess any impact on the bank.

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Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Risk and capital performance

Capital, Leverage Ratio, TLAC and MREL

Own Funds

The calculation of Deutsche Bank’s own funds incorporates the capital requirements following the “Regulation (EU)

No 575/2013 on prudential requirements for credit institutions” (CRR) and the “Directive 2013/36/EU on access to the

activity of credit institutions and the prudential supervision of credit institutions” (CRD), which have been further

amended with subsequent Regulations and Directives. The CRD has been implemented into German law. The

information in this section as well as in the section “Development of risk-weighted assets” is based on the regulatory

principles of consolidation.

This section refers to the capital adequacy of the group of entities consolidated for banking regulatory purposes

pursuant to the CRR and the German Banking Act (“Kreditwesengesetz” or “KWG”), which does not include insurance

companies and companies outside the finance sector.

The total own funds pursuant to the effective regulations as of year-end 2025 comprises Tier 1 and Tier 2 capital. Tier 1

capital is subdivided into Common Equity Tier 1 capital and Additional Tier 1 capital.

CET 1 capital consists primarily of common share capital (net of own holdings) including related share premium

accounts, retained earnings (including losses for the financial year, if any) and accumulated other comprehensive income,

subject to prudential filters and regulatory adjustments as well as minority interests qualifying for inclusion in

consolidated CET 1 capital. Prudential filters for CET 1 capital, according to Articles 32 to 35 CRR, include securitization

gains on sale, cash flow hedges and changes in the value of own liabilities, and additional value adjustments. CET 1

capital regulatory adjustments for instance includes intangible assets (exceeding their prudential value), temporary

treatment of unrealized gains and losses measured at fair value through OCI in accordance with Article 468 CRR which

was discontinued in the fourth quarter of 2025, deferred tax assets that rely on future profitability, negative amounts

resulting from the calculation of expected loss amounts, net defined benefit pension fund assets, reciprocal cross

holdings in the capital of financial sector entities and, significant and non-significant investments in the capital (CET 1,

AT1, Tier 2) of financial sector entities above certain thresholds. All items which are not deducted (i.e., amounts below

the threshold) are subject to risk-weighting.

Additional Tier 1 capital consists of AT1 capital instruments and related share premium accounts as well as

noncontrolling interests qualifying for inclusion in consolidated AT1 capital. To qualify as AT1 capital under CRR/CRD,

instruments must have principal loss absorption through a conversion to common shares or a write-down mechanism

allocating losses at a trigger point and must also meet further requirements such as perpetual with no incentive to

redeem and institution must have full dividend/coupon discretion at all times.

Tier 2 capital comprises eligible capital instruments, the related share premium accounts and subordinated long-term

debt, certain loan loss provisions and noncontrolling interests that qualify for inclusion in consolidated Tier 2 capital. To

qualify as Tier 2 capital, capital instruments or subordinated debt must have an original maturity of at least five years.

Moreover, eligible capital instruments may inter alia not contain an incentive to redeem, a right of investors to accelerate

repayment, or a credit sensitive dividend feature.

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Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Capital instruments

The Management Board was authorized by the 2024 Annual General Meeting to buy, on or before April 30, 2029, shares

of up to 10% of the share capital at the time this resolution was taken or, if lower, of the share capital at the respective

time the authorization was exercised. As at the 2024 Annual General Meeting, this corresponded to a volume of up to

199.5 million shares. Thereof, a volume of up to 5% of the total share capital or 99.7 million shares can be purchased by

using derivatives, including derivatives with a volume of up to 2% of the total share capital with a maturity exceeding 18

months. During the period from the 2024 Annual General Meeting until the 2025 Annual General Meeting, 34.6 million

shares were purchased for equity compensation purposes in the same period or upcoming periods. Thereof, 21.3 million

shares were purchased by exercising call options. In addition, 22.7 million new call options were purchased for equity

compensation purposes in upcoming periods. Furthermore, 27.9 million shares were purchased for cancellation with the

purpose of distributing capital to shareholders in the same period. Thereof, 20.9 million shares were acquired as part of

the share buyback program of € 675 million in 2024 and were cancelled at the beginning of the year 2025; and

7.0 million shares were acquired as part of the share buyback program of € 750 million in 2025. The number of shares

held in Treasury amounted to 12.9 million as of the 2025 Annual General Meeting. Thereof, 7.0 million shares relate to

shares bought back for cancellation as part of the € 750 million share buyback program in 2025. The remaining volume of

5.9 million shares relates to shares to be used for equity compensation purposes in upcoming periods.

The Annual General Meeting on May 22, 2025 granted the Management Board the approval to buy, on or before April 30,

2030, shares of up to 10% of the share capital at the time of this resolution was taken or, if lower, of the share capital at

the respective time the authorization was exercised. As at the 2025 Annual General Meeting, this corresponded to

194.8 million shares. Thereof, a volume of up to 5% of the total share capital or 97.4 million shares can be purchased by

using derivatives, including derivatives with a volume of up to 2% of the total share capital with a maturity exceeding 18

months. These authorizations replaced the authorizations of the previous year. During the period from the 2025 Annual

General Meeting until December 31, 2025, 4.6 million shares were purchased for equity compensation purposes in

upcoming periods and 30.6 million shares were purchased for cancellation with the purpose of distributing capital to

shareholders. Thereof, 22.3 million shares were purchased as part of the € 750 million share buyback program and

8.4 million shares were acquired as part of the € 250 million share buyback program. In December 2025, a total number

of 37.7 million shares were cancelled. The number of shares held in Treasury amounted to 7.7 million shares as of

December 31, 2025. The shares will be used for equity compensation purposes in upcoming periods.

Since the 2017 Annual General Meeting, renewed at the 2021 Annual General Meeting and valid until the 2025 Annual

General Meeting, authorized capital available to the Management Board was € 2,560 million (1,000 million shares). At the

2025 Annual General Meeting this authorized capital was replaced by a new authorized capital of € 2,493 million

(973.8 million shares). As of December 31, 2025 this authorization has not been utilized and authorized capital remains at

€ 2,493 million.

Since the 2022 Annual General Meeting and until the 2025 Annual General Meeting, the Management Board was

authorized to issue participatory notes and other hybrid debt securities that fulfill the regulatory requirements to qualify

as Additional Tier 1 capital with an equivalent value of € 9 billion. In this period Deutsche Bank issued € 5.75 billion new

AT1 notes, thereof € 1.5 billion in March 2025. Since the 2025 Annual General Meeting the Management Board is

authorized to issue participatory notes and other hybrid debt securities that fulfill the regulatory requirements to qualify

as Additional Tier 1 capital with an equivalent value of € 12 billion on or before April 30, 2030. Under this authorization as

of December 31, 2025 Deutsche Bank issued € 1.0 billion new AT1 notes.

Based on the current CRR, the amount recognized as regulatory AT1 capital amounted to € 11.5 billion. The

corresponding nominal amount of outstanding AT1 instruments was € 11.7 billion as of December 31, 2025. In 2025, AT1

instruments with a nominal value of € 2.4 billion were called. The bank issued new AT1 notes with a nominal amount of

€ 2.5 billion in 2025.

As of December 31, 2025, the amount recognized as regulatory Tier 2 amounted capital to € 7.1 billion. The

corresponding nominal amount of outstanding Tier 2 instruments was € 8.3 billion as of December 31, 2025. In 2025,

Tier 2 instruments with a nominal value of € 2.8 billion matured and € 0.1 billion became ineligible. There were no new

issuances of Tier 2 instruments in 2025.

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Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Prudential requirements and additional buffers

The Pillar 1 CET 1 minimum capital requirement applicable to the Group is 4.50% of RWA. The Pillar 1 total capital

requirement of 8.00% demands further resources that may be met with up to 1.50% Additional Tier 1 capital and up to

2.00% Tier 2 capital.

Failure to meet minimum capital requirements can result in supervisory measures such as restrictions of profit

distributions or limitations on certain businesses such as lending. Deutsche Bank complied with the minimum regulatory

capital adequacy requirements in 2025.

In addition to these minimum capital requirements, the following combined capital buffer requirements were fully

effective beginning 2025 onwards. These buffer requirements must be met in addition to the Pillar 1 minimum capital

requirements but can be drawn down in times of economic stress.

The capital conservation buffer is implemented in Section 10c German Banking Act, based on Article 129 CRD and

equals a requirement of 2.50% CET 1 capital of RWA.

The countercyclical capital buffer is deployed in a jurisdiction when excess credit growth is associated with an increase in

system-wide risk. It may vary between 0% and 2.50% CET 1 capital of RWA. In exceptional cases, it could also be higher

than 2.50%. The institution-specific countercyclical buffer that applies to Deutsche Bank is the weighted average of the

countercyclical capital buffers that apply in the jurisdictions where relevant credit exposures are located. As per

December 31, 2025, the institution-specific countercyclical capital buffer was at 0.50%.

In addition to the aforementioned buffers, national authorities, such as the BaFin, may require a systemic risk buffer to

prevent and mitigate long-term non-cyclical systemic or macro-prudential risks that are not covered by the CRR. They

can require an additional buffer of up to 5.00% CET 1 capital of RWA. As of the year end 2025, the systemic risk buffer

applied to Deutsche Bank is 0.14%.

Deutsche Bank continues to be designated as a global systemically important institution (G-SII) by the BaFin resulting in

a G-SII buffer requirement of 1.50% CET 1 capital of RWA in 2025. 2025 BaFin has announced that the G-SII buffer

requirement for Deutsche Bank will be reduced to 1.00% for the year 2026.

Additionally, Deutsche Bank has been classified by BaFin as an “other systemically important institution” (O-SII) with an

additional capital buffer requirement of 2.00% in 2025 that has to be met on a consolidated level and remains

unchanged for 2026. The higher of the buffers for systemically important institutions (G-SII buffer or O-SII buffer) must

be applied.

Pursuant to the Pillar 2 SREP, the ECB may impose capital requirements on individual banks which are more stringent

than statutory requirements (so-called Pillar 2 requirement).

In December 2024, the ECB informed Deutsche Bank of its decision effective January 1, 2025, that the bank’s Pillar 2

requirement changed compared to 2024. This resulted in ECB’s Pillar 2 requirement amounting to 2.90% of RWA. As of

December 31, 2025, Deutsche Bank needs to maintain on a consolidated basis a CET 1 ratio of at least 11.26%, a Tier 1

ratio of at least 13.31% and a Total Capital ratio of at least 16.03%. The CET 1 requirement comprises the Pillar 1

minimum capital requirement of 4.50%, the Pillar 2 requirement (SREP add-on) of 1.63%, the capital conservation buffer

of 2.50%, the countercyclical buffer of 0.50% and the systemic risk buffer of 0.14% (both subject to changes throughout

the year) as well as the higher of the bank´s G-SII/O-SII buffer of 2.00%. Correspondingly, the Tier 1 capital requirement

includes additionally a Tier 1 minimum capital requirement of 1.50% plus a Pillar 2 requirement of 0.54%, and the Total

Capital requirement includes further a Tier 2 minimum capital requirement of 2.00% and a Pillar 2 requirement of

0.72%.In addition, ECB communicated to Deutsche Bank an individual expectation to maintain a further Pillar 2 CET 1

capital add-on commonly referred to as the Pillar 2 guidance. This capital add-on is separate from and in addition to the

Pillar 2 requirement. The ECB expects banks to meet the Pillar 2 guidance although it is not legally binding, and failure to

meet the Pillar 2 guidance does not lead to automatic restrictions of capital distributions.

On October 28, 2025, Deutsche Bank was informed by the ECB of its decision regarding prudential minimum capital

requirements for 2026 that applies from January 1, 2026, onwards, following the results of the 2025 SREP. The decision

set ECB’s Pillar 2 requirement to 2.85% of RWA, effective as of January 1, 2026, of which at least 1.60% must be covered

by CET 1 capital and 2.14% by Tier 1 capital.

The following table gives an overview of the different Pillar 1 and Pillar 2 minimum capital buffer requirements (but

excluding the Pillar 2 guidance) as applicable to Deutsche Bank for the years 2025 and 2026.

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Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Overview prudential requirements and additional buffers


	2025	2026
Pillar 1
Minimum CET 1 requirement	4.50%	4.50%
Combined buffer requirement	5.13%	5.15%
Capital Conservation Buffer	2.50%	2.50%
Countercyclical Buffer¹	0.50%	0.52%
Systemic Risk Buffer²	0.14%	0.14%
Maximum of:	2.00%	2.00%
G-SII Buffer	1.50%	1.00%
O-SII Buffer	2.00%	2.00%
Pillar 2
Pillar 2 SREP Add-on of Total capital (excluding the "Pillar 2" guidance)	2.90%	2.85%
of which covered by CET 1 capital	1.63%	1.60%
of which covered by Tier 1 capital	2.18%	2.14%
of which covered by Tier 2 capital	0.72%	0.71%
Total CET 1 requirement from Pillar 1 and 2³	11.26%	11.25%
Total Tier 1 requirement from Pillar 1 and 2	13.31%	13.29%
Total capital requirement from Pillar 1 and 2	16.03%	16.00%

Pillar 1 Leverage Ratio minimum requirement	3.00%	3.00%
Pillar 2 Leverage Ratio requirement	0.10%	0.10%
G-SII Leverage Ratio Buffer	0.75%	0.50%
Total Leverage Ratio requirement	3.85%	3.60%

1Deutsche Bank’s countercyclical buffer requirement is subject to country-specific buffer rates decreed by EBA and the Basel Committee of Banking Supervision (BCBS)

as well as Deutsche Bank’s relevant credit exposures as per respective reporting date; the countercyclical buffer rate for 2026 has been calculated to be 0.52% based on

known countercyclical buffer changes in 2026; the countercyclical buffer is subject to Deutsche Bank portfolio changes and further changes of countercyclical buffer

rates throughout the year

2The Systemic risk buffer rate for 2026 has been calculated to be 0.14% based on known systemic risk buffer changes in 2026; the systemic risk buffer is subject to

Deutsche Bank portfolio changes and further changes in systemic risk buffer rates throughout the year

3The total Pillar 1 and Pillar 2 CET 1 requirement (excluding the “Pillar 2” guidance) is calculated as the sum of the SREP requirement, the systemic risk buffer requirement,

the capital conservation buffer requirement and countercyclical buffer requirement as well as the higher of the G-SII/O-SII requirement

The Group’s Pillar 1 Tier 1 capital requirement applicable is 3.00% of leverage exposure. An additional leverage ratio

buffer requirement, equivalent to 50% of the applicable G-SII buffer rate, also applies. For Deutsche Bank, this additional

requirement equals 0.75% for 2025 and 0.50% for 2026. Furthermore, the ECB has set a Pillar 2 requirement for the

leverage ratio of 0.10%. This adds up to a total leverage ratio requirement of 3.85% for 2025. In addition, ECB

communicated to Deutsche Bank an individual expectation to maintain a further Pillar 2 Tier 1 capital add-on in relation

to leverage ratio, commonly referred to as the Pillar 2 guidance. This capital add-on is separate from and in addition to

the Pillar 2 requirement. The ECB expects banks to meet the Pillar 2 guidance although it is not legally binding, and

failure to meet the Pillar 2 guidance does not lead to automatic restrictions of capital distributions.

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Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Development of Own Funds

Deutsche Bank’s CET 1 capital as of December 31, 2025, amounted to € 49.3 billion, a decrease of € 0.2 billion compared

to € 49.5 billion at the end of 2024. AT1 capital was € 11.5 billion as of December 31, 2025, an increase of € 0.1 billion

compared to € 11.4 billion at the end of 2024. Tier 1 capital was € 60.8 billion as of December 31, 2025, broadly stable

compared to the end of 2024. Tier 2 capital amounted to € 7.1 billion as of December 31, 2025, a decrease of

€ 0.6 billion compared to € 7.7 billion at the end of 2024. Total capital amounted to € 67.8 billion as of December 31,

2025, a decrease of € 0.7 billion compared to € 68.5 billion at the end of 2024.

As of December 31, 2025, Deutsche Bank's CET1 ratio was 14.2%, an increase of 40 basis points compared to December 31,

2024. This development was primarily driven by lower RWA as outlined in “Development of risk-weighted assets” section,

partly offset by a decrease in CET1 capital as outlined below. The initial effect of the implementation of CRR3 amounted

to 1 basis point, comprising a CET1 capital reduction of € 0.4 billion and an overall decrease of € 3.4 billion in RWA.

CET 1 capital decreased by € 0.2 billion during 2025. This development included a net profit of € 6.9 billion for the year

2025 reduced by regulatory deductions for future shareholder distribution and AT1 coupon payments of € 3.6 billion

which is in line with the ECB Decision (EU) (2015/656) on the recognition of interim or year-end profits in CET 1 capital in

accordance with the Article 26(2) of Regulation (EU) No 575/2013 (ECB/2015/4). In addition, the decrease in CET 1

capital was driven by accumulated other comprehensive income which includes currency translation adjustments of

€ 3.2 billion, discontinuation of the temporary treatment of unrealized gains and losses measured at fair value through

OCI in accordance with Article 468 CRR by € 1.0 billion, higher deduction for non-performing exposures of € 0.4 billion,

effects from the completion of the second share buyback program of € 0.3 billion and collective investment

undertakings not included in RWA of € 0.2 billion. These reductions were partially offset by lower deductions from

deferred tax assets of € 0.9 billion, expected loss shortfall of € 0.5 billion as well as goodwill and other intangibles of

€ 0.2 billion.

The AT1 capital increase of € 0.1 billion was mainly due to the issuance of two new AT1 capital instruments during the

year amounting to €2.5 billion, reduced by the exercised call options on two instruments with a total principal amount of

€ 2.4 billion (U.S.$2.75 billion equivalent).

The Tier 2 capital decrease of € 0.6 billion was mainly due to foreign exchange effects of € 0.6 billion and € 0.3 billion

due to amortization. This was partly offset by an increase of € 0.3 billion in carrying amount change arising from accrued

interest and fair value hedge.

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Own Funds Template (including RWA and capital ratios)



in € m.	Dec 31, 2025	Dec 31, 2024
Common Equity Tier 1 (CET 1) capital: instruments and reserves
Capital instruments, related share premium accounts and other reserves	42,983	44,130
Retained earnings	21,149	19,978
Accumulated other comprehensive income (loss), net of tax	(4,159)	(1,229)
Independently reviewed interim profits net of any foreseeable charge or dividend1	3,347	801
Other	917	1,020
Common Equity Tier 1 (CET 1) capital before regulatory adjustments	64,237	64,700

Common Equity Tier 1 (CET 1) capital: regulatory adjustments
Additional value adjustments (negative amount)	(1,667)	(1,680)
Other prudential filters (other than additional value adjustments)	296	95
Goodwill and other intangible assets (net of related tax liabilities) (negative amount)	(5,045)	(5,277)
Deferred tax assets that rely on future profitability excluding those arising from temporary differences (net of related tax liabilities where the conditions in Art. 38 (3) CRR are met) (negative amount)	(2,533)	(3,463)
Negative amounts resulting from the calculation of expected loss amounts	(2,579)	(3,037)
Defined benefit pension fund assets (net of related tax liabilities) (negative amount)	(1,135)	(1,173)
Direct, indirect and synthetic holdings by an institution of own CET 1 instruments (negative amount)	—	—
Direct, indirect and synthetic holdings by the institution of the CET 1 instruments of financial sector entities where the institution has a significant investment in those entities (amount above the 10%/15% thresholds and net of eligible short positions) (negative amount)	—	—
Deferred tax assets arising from temporary differences (net of related tax liabilities where the conditions in Art. 38 (3) CRR are met) (amount above the 10%/15% thresholds) (negative amount)	—	—
Regulatory adjustments relating to unrealized gains and losses pursuant to Art. 468 CRR	—	1,012
Other regulatory adjustments2	(2,309)	(1,721)
Total regulatory adjustments to Common Equity Tier 1 (CET 1) capital	(14,971)	(15,244)
Common Equity Tier 1 (CET 1) capital	49,266	49,457

Additional Tier 1 (AT1) capital: instruments
Capital instruments and the related share premium accounts	11,648	11,508
Amount of qualifying items referred to in Art. 484 (4) CRR and the related share premium accounts subject to phase out from AT1	—	—
Additional Tier 1 (AT1) capital before regulatory adjustments	11,648	11,508

Additional Tier 1 (AT1) capital: regulatory adjustments
Direct, indirect and synthetic holdings by an institution of own AT1 instruments (negative amount)	(130)	(130)
Residual amounts deducted from AT1 capital with regard to deduction from CET 1 capital during the transitional period pursuant to Art. 472 CRR	—	—
Other regulatory adjustments	—	—
Total regulatory adjustments to Additional Tier 1 (AT1) capital	(130)	(130)
Additional Tier 1 (AT1) capital	11,518	11,378
Tier 1 capital (T1 = CET 1 + AT1)	60,784	60,835

Tier 2 (T2) capital	7,050	7,676
Total capital (TC = T1 + T2)	67,834	68,511
Total risk-weighted assets	347,133	357,427
Capital ratios
Common Equity Tier 1 capital ratio (as a percentage of risk-weighted assets)	14.2	13.8
Tier 1 capital ratio (as a percentage of risk-weighted assets)	17.5	17.0
Total capital ratio (as a percentage of risk-weighted assets)	19.5	19.2

1Full year profit is recognized as per ECB Decision (EU) 2015/656 in accordance with the Article 26(2) of Regulation (EU) No 575/2013 (ECB/2015/4); current year profits

of € 6.9 billion reduced by deductions for future shareholder distribution of € 3.1 billion and AT1 coupons of € 0.5 billion

2Includes capital deductions of € 1.4 billion (December 2024: € 1.4 billion) based on ECB guidance on irrevocable payment commitments related to the Single Resolution

Fund and the Deposit Guarantee Scheme, € 0.7 billion (December 2024: € 0.3 billion) based on ECB's supervisory recommendation for a prudential provisioning of non-

performing exposures

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Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Reconciliation of shareholders’ equity to Own Funds


	CRR/CRD
in € m.	Dec 31, 2025	Dec 31, 2024
Total shareholders’ equity per accounting balance sheet (IASB IFRS)	69,015	68,709
Difference between equity per IASB IFRS/EU IFRS³	(2,082)	(2,433)
Total shareholders’ equity per accounting balance sheet (EU IFRS)	66,933	66,276
Deconsolidation/Consolidation of entities	(24)	(24)
Of which:
Additional paid-in capital	—	—
Retained earnings	(16)	(24)
Accumulated other comprehensive income (loss), net of tax	(9)	—
Total shareholders' equity per regulatory balance sheet	66,909	66,252
Minority Interests (amount allowed in consolidated CET 1)	917	1,020
AT1 coupon and shareholder distribution deduction1	(3,585)	(2,565)
Capital instruments not eligible under CET 1 as per CRR 28(1)	(4)	(7)
Common Equity Tier 1 (CET 1) capital before regulatory adjustments	64,237	64,700
Prudential filters	(1,371)	(1,585)
Of which:
Additional value adjustments	(1,667)	(1,680)
Any increase in equity that results from securitized assets	—	—
Fair value reserves related to gains or losses on cash flow hedges and gains or losses on liabilities designated at fair value resulting from changes in own credit standing	296	95
Regulatory adjustments	(13,600)	(13,659)
Of which:
Goodwill and other intangible assets (net of related tax liabilities) (negative amount)	(5,045)	(5,277)
Deferred tax assets that rely on future profitability	(2,533)	(3,463)
Negative amounts resulting from the calculation of expected loss amounts	(2,579)	(3,037)
Defined benefit pension fund assets (net of related tax liabilities) (negative amount)	(1,135)	(1,173)
Direct, indirect and synthetic holdings by the institution of the CET 1 instruments of financial sector entities where the institution has a significant investment in those entities	—	—
Securitization positions not included in risk-weighted assets	—	—
Collective Investment Undertakings (CIU) not included in risk-weighted assets	(214)	—
Regulatory adjustments relating to unrealized gains and losses pursuant to Art. 468 CRR	—	1,012
Others2	(2,094)	(1,721)
Common Equity Tier 1 capital	49,266	49,457

1 Full year profit is recognized as per ECB Decision (EU) 2015/656 in accordance with the Article 26(2) of Regulation (EU) No 575/2013 (ECB/2015/4); current year

deductions include deductions for future shareholder distribution of € 3.1 billion and AT1 coupons of € 0.5 billion

2 Includes capital deductions of € 1.4 billion (December 31, 2024: € 1.4 billion) based on ECB guidance on irrevocable payment commitments related to the Single

Resolution Fund and the Deposit Guarantee Scheme, € 0.7 billion (December 31, 2024: € 0.3 billion) based on ECB’s supervisory recommendation for a prudential

provisioning of non-performing exposures

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Development of Own Funds


	CRR/CRD
in € m.	twelve months ended Dec 31, 2025	twelve months ended Dec 31, 2024
Common Equity Tier 1 (CET 1) capital - opening amount	49,457	48,066
Common shares, net effect	(215)	(115)
Additional paid-in capital	(1,460)	(430)
Retained earnings	7,301	3,341
Common shares in treasury, net effect/(+) sales (–) purchase	528	(232)
Movements in accumulated other comprehensive income	(2,929)	530
AT1 coupon and shareholder distribution deduction¹	(3,585)	(2,565)
Additional value adjustments	13	47
Goodwill and other intangible assets (net of related tax liabilities) (negative amount)	232	(263)
Deferred tax assets that rely on future profitability (excluding those arising from temporary differences)	930	744
Negative amounts resulting from the calculation of expected loss amounts	458	(651)
Defined benefit pension fund assets (net of related tax liabilities) (negative amount)	37	(253)
Direct, indirect and synthetic holdings by the institution of the CET 1 instruments of financial sector entities where the institution has a significant investment in those entities	—	—
Deferred tax assets arising from temporary differences (amount above 10% and 15% threshold, net of related tax liabilities where the conditions in Art. 38 (3) CRR are met)	—	—
Other, including regulatory adjustments	(1,501)	1,238
Common Equity Tier 1 (CET 1) capital - closing amount	49,266	49,457
Additional Tier 1 (AT1) Capital – opening amount	11,378	8,328
New Additional Tier 1 eligible capital issues	2,500	2,950
Matured and called instruments	(2,360)	—
Other, including regulatory adjustments	—	100
Additional Tier 1 (AT1) Capital – closing amount	11,518	11,378
Tier 1 capital	60,784	60,835
Tier 2 (T2) capital – closing amount	7,050	7,676
Total regulatory capital	67,834	68,511

1Full year profit is recognized as per ECB Decision (EU) 2015/656 in accordance with the Article 26(2) of Regulation (EU) No 575/2013 (ECB/2015/4); current year

deductions include deductions for future shareholder distribution of € 3.1 billion and AT1 coupons of € 0.5 billion

Minimum loss coverage for Non Performing Exposure (NPE)

In April 2019, the EU published requirements Regulation (EU) 2019/630 amending the CRR (Regulation (EU) No 575/2013) for a

prudential backstop reserve for non-performing exposure (NPE). This regulation results in a Pillar 1 deduction from CET 1 capital

when a minimum loss coverage requirement is not met. It is applied to exposures originated and defaulted after April 25, 2019.

In addition, in March 2018, the ECB published its “Addendum to the ECB Guidance to banks on non-performing loans:

supervisory expectations for prudential provisioning of non-performing exposures” and in August 2019, its “Communication on

supervisory coverage expectations for NPEs”.

The ECB guidance issued is applicable to all newly defaulted loans after April 1, 2018 (ECB - new NPE’s after April 1, 2018) and,

similar to the EU rules, it requires banks to take measures in case a minimum impairment coverage requirement is not met.

Within the annual SREP discussions ECB may impose Pillar 2 measures on banks in case ECB is not confident with measure

taken by the individual bank.

For the year end 2020, the bank introduced a framework to determine the prudential provisioning of non-performing exposure

as a Pillar 2 measure as requested in the before mentioned ECB’s guidance and SREP recommendation.

For the minimum loss coverage expectation for NPE´s arising from clients defaulted before April 1, 2018 (ECB – NPE Stock) a

phase-in path to 100% coverage expectation was envisaged with an annual increase of 10%. In a first step, banks were allocated

to three comparable groups on the basis of the bank’s net NPL ratios as of end-2017 and in a second step an assessment of

capacity regarding the potential impact was carried out for each individual bank with a horizon of end-2026. Deutsche Bank has

been assigned to Group 1 which requires a full applicability of 100% minimum loss coverage by year end 2024 for secured loans

respectively by year end2023 for unsecured loans.

The shortfall between the minimum loss coverage requirements for non-performing exposure and the risk reserves recorded in

line with the IFRS 9 for defaulted (Stage 3) assets amounted to € 657 million as of December 31, 2025 and was deducted from

CET 1. This additional CET 1 charge can be considered as additional regulatory loss reserve and leads to a € 2.6 billion RWA

relief.

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Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Non-performing exposure loss coverage


	Dec 31, 2025
in € m. (unless stated otherwise)	Exposure value1	Total minimum coverage requirement	Available coverage	Applicable amount of insufficient coverage
Corporate Bank	2,954	838	1,520	163
Investment Bank	10,931	2,709	4,700	362
Private Bank	7,276	1,735	4,090	61
Asset Management	—	—	—	—
Corporate & Other	791	106	254	70
Total	21,952	5,388	10,563	657

1Exposure value in accordance with Article 47c CRR


	Dec 31, 2024
in € m. (unless stated otherwise)	Exposure value1	Total minimum coverage requirement	Available coverage	Applicable amount of insufficient coverage
Corporate Bank	4,107	696	1,818	48
Investment Bank	9,602	3,355	4,986	171
Private Bank	8,139	1,224	3,674	53
Asset Management	—	—	—	—
Corporate & Other	969	58	177	29
Total	22,817	5,334	10,654	302

1Exposure value in accordance with Article 47c CRR

Development of risk-weighted assets

The table below provides an overview of RWA broken down by risk type and segment. It includes the aggregated effects

of the segmental reallocation of infrastructure related positions, if applicable, as well as reallocations between the

segments. As of December 31, 2025, the output floor for RWA according to CRR3 had no impact on Deutsche Bank´s

RWA based on the currently applicable regulation.

Risk-weighted assets by risk type and segment


	Dec 31, 2025
in € m.	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total
Credit Risk	60,942	97,311	77,192	10,192	14,537	260,174
Settlement Risk	—	91	—	—	44	135
Credit Valuation Adjustment (CVA)	—	2,328	58	3	201	2,591
Market Risk	201	18,809	20	7	2,012	21,050
Operational Risk	10,844	17,873	14,726	5,318	14,422	63,183
Total	71,988	136,412	91,996	15,520	31,216	347,133


	Dec 31, 2024
in € m.	Corporate Bank	Investment Bank	Private Bank	Asset Management	Corporate & Other	Total
Credit Risk	67,115	95,869	82,655	13,683	17,633	276,955
Settlement Risk	—	4	—	—	11	15
Credit Valuation Adjustment (CVA)	29	2,907	161	—	334	3,431
Market Risk	248	16,270	27	31	2,390	18,965
Operational Risk	10,784	14,775	14,438	4,700	13,363	58,061
Total	78,176	129,825	97,281	18,414	33,732	357,427

RWA of Deutsche Bank were € 347.1 billion as of December 31, 2025, compared to € 357.4 billion at the end of 2024.

The decrease of € 10.3 billion, thereof € 3.4 billion from the introduction of CRR3, was driven by credit risk RWA and

credit valuation adjustment RWA, partially offset by operational risk RWA and market risk RWA.

Credit risk RWA decreased by € 16.8 billion, including an impact of € 5.0 billion from the introduction of CRR3, as

detailed further below, as well as foreign exchange movements and capital efficiency measures. This was partially offset

by credit risk RWA increases from Deutsche Bank´s business growth in 2025.

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Credit valuation adjustment RWA decreased by € 0.8 billion, primarily driven by reduced exposures, as well as hedging

activities offsetting the initial impact from the introduction of the new Basic Approach under CRR3.

Deutsche Bank´s operational risk RWA increased by € 5.1 billion, driven by the move from the advanced measurement

approach to the new standardized measurement approach for operational risks under CRR3.

Market risk RWA increased by € 2.1 billion, primarily driven by Stressed-Value-at-Risk (SVaR) due to changes in sovereign

bond exposure under Fixed Income and Currencies Trading business.

The tables below provide an analysis of the key drivers for risk-weighted asset movements observed for credit risk, credit

valuation adjustments as well as market risk in the reporting period. They also show the corresponding movements in

minimum capital requirements, which are 8% of RWA.

Development of risk-weighted assets for Credit Risk including Counterparty Credit Risk


	Dec 31, 2025		Dec 31, 2024
in € m.	Credit risk RWA	Capital requirements	Credit risk RWA	Capital requirements
Credit risk RWA balance, beginning of year	276,955	22,156	265,789	21,263
Book size	3,645	292	4,944	396
Book quality	(1,371)	(110)	(7,793)	(623)
Model updates	4,110	329	3,668	293
Methodology and policy	(10,901)	(872)	3,443	275
Acquisition and disposals	—	—	—	—
Foreign exchange movements	(13,506)	(1,080)	5,410	433
Other	1,242	99	1,494	119
Credit risk RWA balance, end of year	260,174	20,814	276,955	22,156

Of which: Development of risk-weighted assets for Counterparty Credit Risk


	Dec 31, 2025		Dec 31, 2024
in € m.	Counterparty credit risk RWA	Capital requirements	Counterparty credit risk RWA	Capital requirements
Counterparty credit risk RWA balance, beginning of year	19,470	1,558	19,868	1,589
Book size	1,588	127	(1,194)	(96)
Book quality	(42)	(3)	(47)	(4)
Model updates	(895)	(72)	186	15
Methodology and policy	(169)	(14)	—	—
Acquisition and disposals	—	—	—	—
Foreign exchange movements	(1,361)	(109)	657	53
Other	—	—	—	—
Counterparty credit risk RWA balance, end of year	18,590	1,487	19,470	1,558

Organic changes in the Group´s portfolio size and composition are considered in the category “book size”. The category

“book quality” mainly represents the effects from portfolio rating migrations, loss given default, model parameter

recalibrations as well as collateral and netting coverage activities. “Model updates” include model refinements and

advanced model roll out. RWA movements resulting from externally, regulatory-driven changes, e.g., applying new

regulations, are considered in the “methodology and policy” section. “Acquisition and disposals” shows significant

exposure movements which can be clearly assigned to new businesses or disposal-related activities. Changes that

cannot be attributed to the above categories are reflected in the category “other”.

RWA for credit risk decreased by € 16.8 billion, or 6.1%, since December 31, 2024, which was mainly driven by the

categories “foreign exchange movements”, “methodology and policy” as well as “book quality” and was partly offset by

categories “model updates”, “book size” and “other”.

The decrease in category “methodology and policy” reflects impacts from the introduction of CRR3. In this regard, the

two major drivers were the adoption of the rule to deduct exposures for collective investment undertakings that are

assigned to a risk weight of 1,250% and reduced risk weights for exchange traded equity exposures. Additionally, this

category includes impacts from the remediation of regulatory obligations as well as a refinement on the application of

the scaling factor on collaterals, which were partly offset by impacts from the introduction of new margin of

conservatisms on key model inputs.

The decrease in category “book quality” is mainly driven by RWA reductions from capital efficiency measures, partly

offset by counterparty rating deteriorations.

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The aforementioned decreases were partly offset by increases in category “model updates”, primarily due to refinements

of Deutsche Bank´s IRBA model including the recalibration of margin of conservatisms applied on key model inputs.

The increase in category “book size” is reflecting Deutsche Bank´s business growth in 2025, especially within the

Investment Bank and the Corporate Bank, as well as market movements along with higher equity shares in guaranteed

funds, partly offset by capital efficiency measures in the form of synthetic securitizations.

Additionally, the increase in category “other” reflects higher RWA for deferred tax assets, including the effects from the

discontinuation of the temporary treatment of unrealized gains and losses measured at fair value through OCI in

accordance with Article 468 CRR, and investments in financial sector entities.

RWA for counterparty credit risk decreased by € 0.9 billion, or 4.5%, since December 31, 2024, mainly driven by the

decrease in categories “foreign exchange”, “model updates” and “methodology and policy”, partly offset by category

“book size”. The decrease in category “model updates” mainly reflects refinements of internal models. Additionally, the

reduction in category “methodology and policy” is mainly driven by impacts from the introduction of CRR3. The

aforementioned decreases were partly offset by an increase in category “book size”, reflecting a higher trading inventory.

Based on the CRR/CRD regulatory framework, Deutsche Bank is required to calculate RWA using the CVA which takes

into account the credit quality of the bank´s counterparties. RWA for CVA covers the risk of mark-to-market losses on the

expected counterparty risk in connection with OTC derivative exposures and fair-valued securities financing transactions.

Under CRR3, Deutsche Bank applies the Basic Approach for CVA (BA‑CVA) to determine the regulatory capital charges.

Development of risk-weighted assets for Credit Valuation Adjustment


	Dec 31, 2025		Dec 31, 2024
in € m.	CVA RWA	Capital requirements	CVA RWA	Capital requirements
CVA RWA balance, beginning of year	3,431	274	5,276	422
Movement in risk levels	(1,709)	(137)	(1,205)	(96)
Market data changes and recalibrations	—	—	(640)	(51)
Model updates	—	—	—	—
Methodology and policy	868	69	—	—
Acquisitions and disposals	—	—	—	—
Foreign exchange movements	—	—	—	—
CVA RWA balance, end of year	2,591	207	3,431	274

The development of CVA RWA is broken down into a number of categories: “Movement in risk levels”, which includes

changes to the portfolio size and composition; “Market data changes and calibrations”, which includes changes in market

data levels and volatilities as well as recalibrations; “Model updates”, which refers to changes to the IMM credit exposure

model that are used for CVA RWA; “Methodology and policy”, which relates to changes to the regulation. Any significant

business acquisitions or disposals would be presented in the category “Acquisitions and disposals”.

As of December 31, 2025, the RWA for CVA amounted to € 2.6 billion, representing a decrease of € 0.8 billion, 24%

compared to December 31, 2024. This includes € 1.7 billion decrease in movement in risk levels (primarily driven by

reduced exposure as well as hedging activities) and € 0.9 billion increase in methodology and policy update (the

introduction of the new basic approach under CRR3).

Development of risk-weighted assets for Market Risk


	Dec 31, 2025
in € m.	VaR	SVaR	IRC	Other	Total RWA	Total capital requirements
Market risk RWA balance, beginning of year	2,705	6,204	6,268	3,787	18,965	1,517
Movement in risk levels	(1,610)	797	(449)	312	(950)	(76)
Market data changes and recalibrations	1,572	1,933	—	58	3,563	285
Model updates/changes	49	(27)	(168)	—	(147)	(12)
Methodology and policy	—	—	—	(120)	(120)	(10)
Acquisitions and disposals	—	—	—	—	—	—
Foreign exchange movements	—	—	—	(261)	(261)	(21)
Other	—	—	—	—	—	—
Market risk RWA balance, end of year	2,716	8,907	5,651	3,776	21,050	1,684

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	Dec 31, 2024
in € m.	VaR	SVaR	IRC	Other	Total RWA	Total capital requirements
Market risk RWA balance, beginning of year	3,750	7,090	7,129	3,542	21,510	1,721
Movement in risk levels	(307)	(513)	(860)	(194)	(1,874)	(150)
Market data changes and recalibrations	(767)	(336)	—	330	(773)	(62)
Model updates/changes	29	(37)	—	—	(8)	(1)
Methodology and policy	—	—	—	—	—	—
Acquisitions and disposals	—	—	—	—	—	—
Foreign exchange movements	—	—	—	109	109	9
Other	—	—	—	—	—	—
Market risk RWA balance, end of year	2,705	6,204	6,268	3,787	18,965	1,517

The analysis for market risk covers movements in the bank’s internal models for value-at-risk (VaR), stressed value-at-risk,

incremental risk charge (IRC) as well as results from the market risk standardized approach (MRSA), which is captured in

the category “Other”. MRSA is used to determine the regulatory capital charge for the specific market risk of trading

book securitizations, for certain types of investment funds and for longevity risk as set out in CRR/CRD regulations.

Market risk RWA movements due to changes in market data levels, volatilities, correlations, liquidity and ratings are

included under the “Market data changes and recalibrations” category. Changes to market risk RWA internal models,

such as methodology enhancements or risk scope extensions, are included in the category “Model updates”. In the

“Methodology and policy” category regulatory driven changes to market risk RWA models and calculations are reported.

Significant new businesses and disposals would be assigned to the line item “Acquisition and disposals”. The impacts of

“Foreign exchange movements” are only calculated for the CRM and Standardized approach methods.

As of December 31, 2025 the RWA for market risk was € 21.0 billion, an increase of € 2.1 billion, or 11% since December 31,

2024. The increase was driven by higher stressed value-at-risk RWA due to changes in sovereign bond exposure under Fixed

Income and Currencies Trading business.

Development of risk-weighted assets for operational risk

The overall increase of RWA for operational risk by € 5.1 billion during 2025 was driven by the transition to the

standardized measurement approach as laid out in the CRR3 as well as the bank’s revenue development as its primary

driver. As this approach does not distinguish operational risk loss event type categories, the related granular reporting of

operational risk exposures is discontinued.

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Economic Capital Adequacy

Deutsche Bank’s internal capital adequacy assessment process (ICAAP) aims at maintaining the continuity of the bank on

an ongoing basis. Internal capital adequacy is assessed from an economic perspective as the ratio of economic capital

supply divided by economic capital demand as shown in the table below.

Economic capital supply and demand


in € m. (unless stated otherwise)	Dec 31, 2025	Dec 31, 2024
Components of economic capital supply
Shareholders' equity1	66,933	66,276
Noncontrolling interests2	922	957
AT1 coupon and shareholder distribution deduction1	(3,585)	(2,565)
Gain on sale of securitizations, cash flow hedges	49	(36)
Fair value gains on own debt and debt valuation adjustments, subject to own credit risk	247	131
Additional valuation adjustments	(1,667)	(1,680)
Intangible assets	(3,513)	(3,847)
IFRS deferred tax assets excl. temporary differences	(3,006)	(4,073)
Expected loss shortfall	(2,579)	(3,037)
Defined benefit pension fund assets	(1,137)	(1,174)
Other adjustments1	(2,192)	(2,833)
Economic capital supply	50,474	48,119

Components of economic capital demand
Credit risk	13,395	12,507
Market risk	9,970	8,667
Operational risk	4,960	4,645
Strategic risk	1,980	1,936
Diversification benefit	(4,234)	(3,530)
Total economic capital demand	26,071	24,225

Economic capital adequacy ratio	194%	199%

1Prior year’s comparatives aligned to presentation in the current year

2Includes noncontrolling interest up to the economic capital requirement for each subsidiary

The economic capital adequacy ratio was 194% as of December 31, 2025, compared with 199% as of December 31,

2024. The overall decline was due to an increase in economic capital demand for market risk, credit risk and operational

risk which is explained in the section “Risk Profile”. This was partly offset by an increase in economic capital supply.

The increase in economic capital supply by € 2.4 billion compared to year-end 2024 was mainly driven by a positive net

income of € 6.9 billion, lower capital deductions from deferred tax assets of € 1.1 billion, from valuation differences

between carrying and fair values for debt securities held to collect of € 0.7 billion, from expected loss shortfall of

€ 0.5 billion and from intangible assets of € 0.3 billion as well as unrealized gains and losses of € 0.3 billion. These increases

were partly offset by € 3.6 billion from deductions for future shareholder distributions relating to the Group’s 50% payout

ratio policy in respect of financial year 2025 and accrued AT1 coupon payments, € 3.2 billion from foreign currency

translation adjustments, € 0.3 billion of executed share buyback program, € 0.1 billion from equity compensation and

€ 0.1 billion from actuarial gains and losses.

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Leverage Ratio

Leverage Ratio according to CRR/CRD framework

The non-risk-based leverage ratio is intended to act as a supplementary measure to the risk-based capital requirements.

Its objectives are to constrain the build-up of leverage in the banking sector, helping avoid destabilizing deleveraging

processes which can damage the broader financial system and the economy, and to reinforce the risk-based

requirements with a simple, non-risk based “backstop” measure.

Deutsche Bank calculates its leverage ratio exposure in accordance with Articles 429 to 429g of the CRR.

The Group’s total leverage ratio exposure includes derivatives, securities financing transactions (SFTs), off-balance sheet

exposure and other on-balance sheet exposure (excluding derivatives and SFTs).

The leverage exposure for derivatives is calculated by using a modified version of the standardized approach for

counterparty credit risk (SA-CCR), comprising the current replacement cost plus a regulatory defined add-on for the

potential future exposure. The effective notional amount of written credit derivatives, i.e., the notional reduced by any

negative fair value changes that have been incorporated in Tier 1 capital is included in the leverage ratio exposure

measure; the resulting exposure measure is further reduced by the effective notional amount of purchased credit

derivative protection on the same reference name provided certain conditions are met.

The SFT component includes the gross receivables for SFTs, which are netted with SFT payables if specific conditions are

met. In addition to the gross exposure a regulatory add-on for the counterparty credit risk is included.

The off-balance sheet exposure component follows the standardized approach for credit risk with credit risk conversion

factors (CCF) based on five different buckets (100% for bucket 1, 50% for bucket 2, 40% for bucket 3, 20% for bucket 4

and 10% for bucket 5).

The on-balance sheet exposures (excluding derivatives and SFTs) component reflects the accounting values of the assets

(excluding derivatives, SFTs and regular-way purchases and sales awaiting settlement). The exposure value of regular-

way purchases and sales awaiting settlement is determined as offset between those cash receivables and cash payables

where the related regular-way sales and purchases are both settled on a delivery-versus payment basis.

Assets can be excluded from the leverage ratio exposure measure if they have been deducted in the determination of

Tier 1 capital. The corresponding regulatory adjustments are reflected in the asset amounts deducted in determining

Tier 1 capital component.

The following tables show the leverage ratio exposure and the leverage ratio. For further details on Tier 1 capital please

also refer to the section “Development of Own Funds”.

Summary reconciliation of accounting assets and leverage ratio exposures


in € bn.	Dec 31, 2025	Dec 31, 2024
Total assets as per published financial statements	1,435	1,387
Adjustment for entities which are consolidated for accounting purposes but are outside the scope of regulatory consolidation	(2)	2
Adjustments for derivative financial instruments	(113)	(156)
Adjustment for securities financing transactions (SFTs)	8	4
Adjustment for off-balance sheet items (i.e., conversion to credit equivalent amounts of off-balance sheet exposures)	128	158
Other adjustments	(128)	(79)
Leverage ratio total exposure measure	1,327	1,316

127


Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Leverage ratio common disclosure


in € bn. (unless stated otherwise)	Dec 31, 2025	Dec 31, 2024
Tier 1 capital	60.8	60.8

Derivative exposures	130	137
Securities financing transaction exposures	159	152
Off-balance sheet exposures	128	158
On-balance sheet exposures (excluding derivatives and SFTs)	924	883
Asset amounts deducted in determining Tier 1 capital	(13)	(13)
Leverage ratio total exposure measure	1,327	1,316

Leverage ratio (in %)	4.6	4.6

Factors impacting the leverage ratio

As of December 31, 2025, Tier 1 capital was € 60.8 billion, essentially flat compared to the prior year. For main drivers of

the Tier 1 capital development please refer to section “Development of Own Funds”.

During the year 2025 the leverage exposure increased by € 11.5 billion to € 1,327.4 billion, largely driven by on-balance

sheet exposures (excluding derivatives and SFTs), which increased by € 41.5 billion, and the leverage exposure for

securities financing transactions (SFTs), which increased by € 7.1 billion, both largely in line with the development on the

balance sheet. For additional information on the development of the balance sheet please refer to the section

“Movements in assets and liabilities” in this report. These increases were partly offset by off-balance sheet leverage

exposures, which declined by € 30.4 billion, of which € 15.7 billion related to a changed treatment of chargeback risk in a

specific payments business and € 11.3 billion impact from changed credit conversion factors under CRR3. Furthermore,

the leverage exposure related to derivatives decreased by € 6.9 billion, driven by replacement costs under the

standardized approach for Counterparty Credit Risk (SA-CCR) and effective notional amounts of written credit

derivatives, partly offset by potential future exposure add-ons under SA-CCR.

The development of the leverage exposure in 2025 included a negative foreign exchange impact of € 70.6 billion, mainly

due to the weakening of the U.S. dollar versus the euro. The effects from foreign exchange rate movements are

embedded in the movement of the leverage exposure items discussed in this section.

As of December 31, 2025, the leverage ratio was 4.6%, essentially flat compared to December 31, 2024. This takes into

account a Tier 1 capital of € 60.8 billion over an applicable exposure measure of € 1,327.4 billion as of December 31,

2025 (€ 60.8 billion and € 1,315.9 billion as of December 31, 2024, respectively).

The initial effect of the implementation of CRR3 amounted to 6 basis points, comprising a Tier 1 capital reduction of

€ 0.4 billion and a decrease of € 27.0 billion in leverage exposure.

128


Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Minimum Requirement of Own Funds and Eligible Liabilities and Total Loss

Absorbing Capacity

MREL Requirements

The minimum requirement for own funds and eligible liabilities (MREL) was introduced by the European Union’s

regulation establishing uniform rules and a uniform procedure for the resolution of credit institutions (Single Resolution

Mechanism Regulation or SRMR) and the European Union’s Directive establishing a framework for the recovery and

resolution of credit institutions (Bank Recovery and Resolution Directive or BRRD) as implemented into German law by

the German Recovery and Resolution Act.

The currently required level of MREL is determined by the competent resolution authorities for each supervised bank

individually, depending on the respective preferred resolution strategy. In the case of Deutsche Bank AG, MREL is

determined by the Single Resolution Board. While there is no statutory minimum level of MREL, the SRMR, BRRD and a

delegated regulation set out criteria which the resolution authority must consider when determining the relevant

required level of MREL. Guidance is provided through an MREL policy published annually by the SRB. Any binding MREL

ratio determined by the SRB is communicated to Deutsche Bank via the German Federal Financial Supervisory Authority

(BaFin).

As a result of its regular annual review the SRB has updated Deutsche Bank AG’s binding MREL ratio requirements in the

second quarter of 2025 applicable immediately. The MREL ratio requirement on a consolidated basis is now 25.98% of

RWA and 7.03% of LRE, of which 19.81% of RWA and 7.03% of Leverage Ratio Exposure must be met with own funds and

subordinated instruments.

The combined buffer requirements of 5.13% as of December 31, 2025 must be met in addition to the RWA based MREL

and subordinated MREL requirements.

TLAC Requirements

Since June 27, 2019, Deutsche Bank, as a global systemically important bank, has also become subject to global

minimum standards for its Total Loss-Absorbing Capacity (TLAC). The TLAC requirement was implemented via

amendments to the Capital Requirements Regulation and the Capital Requirements Directive provided in June 2019 with

the publication of Regulation (EU) 2019/876 and Directive (EU) 2019/878.

This TLAC requirement is based on both risk-based and non-risk-based denominators and set at the higher-of 18% of

RWA plus the combined buffer requirements and 6.75% of LRE since January 1, 2022.

MREL ratio development

As of December 31, 2025, available MREL were €131.0 billion, corresponding to a ratio of 37.74% of RWA and 9.87% of

LRE. This means that Deutsche Bank has a MREL surplus of € 23.0 billion above Deutsche Bank’s MREL requirement of

€ 108.0 billion (i.e., 31.11% of RWA including combined buffer requirement). Compared to December 31, 2024 the

surplus remained almost unchanged as a higher MREL requirement and lower MREL capacity were offset by lower RWA.

€ 114.9 billion of Deutsche Bank’s available MREL were own funds and subordinated liabilities, corresponding to a MREL

subordination ratio of 33.11% of RWA and 8.7% of LRE, a buffer of € 21.6 billion over Deutsche Bank’s subordination

requirement of € 93.3 billion (i.e., 7.03% of LRE). Compared to December 31, 2024 , the surplus has decreased due to a

higher subordinated MREL requirement, higher LRE and lower own funds and subordinated liabilities.

TLAC ratio development

As of December 31, 2025, TLAC was € 114.9 billion and the corresponding TLAC ratios were 33.11% of RWA and 8.7% of

LRE. This means that Deutsche Bank has a TLAC surplus of € 25.3 billion over its TLAC requirement of € 89.6 billion

(6.75% of LRE). Compared to December 31, 2024 the surplus has decreased due to higher LRE and lower TLAC.

129


Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

MREL and TLAC disclosure


in € m. (unless stated otherwise)	Dec 31, 2025	Dec 31, 2024
Regulatory capital elements of TLAC/MREL
Common Equity Tier 1 capital (CET 1)	49,266	49,457
Additional Tier 1 (AT1) capital instruments eligible under TLAC/MREL	11,518	11,378
Tier 2 (T2) capital instruments eligible under TLAC/MREL
Tier 2 (T2) capital instruments before TLAC/MREL adjustments	7,050	7,676
Tier 2 (T2) capital instruments adjustments for TLAC/MREL	30	628
Tier 2 (T2) capital instruments eligible under TLAC/MREL	7,080	8,304
Total regulatory capital elements of TLAC/MREL	67,864	69,139

Other elements of TLAC/MREL
Senior non-preferred plain vanilla	47,071	49,352
Holdings of eligible liabilities instruments of other G-SIIs (TLAC only)	—	—
Total Loss Absorbing Capacity (TLAC)	114,936	118,491
Add back of holdings of eligible liabilities instruments of other G-SIIs (TLAC only)	—	—
Available Own Funds and subordinated Eligible Liabilities (subordinated MREL)	114,936	118,491
Senior preferred plain vanilla	7,706	8,939
Senior preferred structured	8,381	6,441
Available Minimum Own Funds and Eligible Liabilities (MREL)	131,023	133,871

Risk Weighted Assets (RWA)	347,133	357,427
Leverage Ratio Exposure (LRE)	1,327,441	1,315,906

TLAC ratio
TLAC ratio (as percentage of RWA)	33.11	33
TLAC requirement (as percentage of RWA)	23.13	23
TLAC ratio (as percentage of Leverage Exposure)	9	9
TLAC requirement (as percentage of Leverage Exposure)	6.75	7
TLAC surplus over RWA requirement	34,641	35,538
TLAC surplus over LRE requirement	25,334	29,667

MREL subordination
MREL subordination ratio (as percentage of RWA)	33	33
MREL subordination requirement (as percentage of RWA)	25	25
MREL subordination ratio (as percentage of LRE)	9	9
MREL subordination requirement (as percentage of LRE)	7	7
MREL subordination surplus over RWA requirement	28,358	30,570
MREL subordination surplus over LRE requirement	21,617	27,036

MREL ratio
MREL ratio (as percentage of RWA)	38	37
MREL requirement (as percentage of RWA)	31	31
MREL ratio (as percentage of LRE)	10	10
MREL requirement (as percentage of LRE)	7	7
MREL surplus over RWA requirement	23,026	23,146
MREL surplus over LRE requirement	37,704	42,415

130


Deutsche Bank	Risk and capital performance
Annual Report 2025	Capital, Leverage Ratio, TLAC and MREL

Own Funds and Eligible Liabilities

To meet the MREL and TLAC requirement, Deutsche Bank needs to ensure that enough eligible liabilities instruments are

maintained. Instruments eligible for MREL and TLAC are regulatory capital instruments (own funds) and liabilities that

meet certain criteria, which are referred to as eligible liabilities.

Own funds used for MREL and TLAC include the full amount of Tier 2 capital instruments with a remaining maturity of

greater than 1 year and less than 5 years which are reflected in regulatory capital on a pro-rata basis only.

Eligible liabilities are liabilities issued out of the resolution entity Deutsche Bank AG that meet eligibility criteria which

are supposed to ensure that they are structurally suited as loss-absorbing capital. As a result, eligible liabilities exclude

deposits which are covered by an insurance deposit protection scheme or which are preferred under German insolvency

law (e.g., deposits from private individuals as well as small and medium-sized enterprises). Among other things, secured

liabilities and derivatives liabilities are generally excluded as well. Debt instruments with embedded derivative features

can be included under certain conditions (e.g., a known and fixed or increasing principal). In addition, eligible liabilities

must have a remaining time to maturity of at least one year and must either be issued under the law of a Member State of

the European Union or must include a bail-in clause in their contractual terms to make write-down or conversion

effective.

In addition, eligible liabilities need to be subordinated to be counted against the TLAC and MREL subordination

requirements. Effective January 1, 2017, the German Banking Act provided for a new class of statutorily subordinated

debt securities that rank as senior non-preferred below the bank’s other senior liabilities (but in priority to the bank’s

contractually subordinated liabilities, such as those qualifying as Tier 2 instruments). Following a harmonization effort by

the European Union implemented in Germany effective July 21, 2018, banks are permitted to now decide if a specific

issuance of eligible senior debt will be in the non-preferred or in the preferred category. Any such senior non-preferred

debt instruments issued by Deutsche Bank AG under such rules rank on parity with its outstanding debt instruments that

were classified as senior non-preferred under the prior rules. All these senior non-preferred issuances meet the TLAC and

MREL subordination criteria.

131


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

Credit Risk Exposure

Deutsche Bank defines its credit exposure by taking into account all transactions where losses might occur due to the

fact that counterparties may not fulfill their contractual payment obligations as defined under ‘Credit Risk Framework’.

Maximum Exposure to Credit Risk

The maximum exposure to credit risk table shows the direct exposure before consideration of associated collateral held

and other credit enhancements (netting and hedges) that do not qualify for offset in the financial statements for the

periods specified. The netting credit enhancement component includes the effects of legally enforceable netting

agreements as well as the offset of negative mark-to-markets from derivatives against pledged cash collateral. The

collateral credit enhancement component mainly includes real estate, collateral in the form of cash as well as securities-

related collateral. In relation to collateral, the Group applies internally determined haircuts and additionally cap all

collateral values at the level of the respective collateralized exposure

Maximum Exposure to Credit Risk


	Dec 31, 2025
			Credit Enhancements
in € m.	Maximum exposure to credit risk1	Subject to impairment	Netting	Collateral	Guarantees and Credit derivatives2	Total credit enhancements
Financial assets at amortized cost3
Cash and central bank balances	164,664	164,664	—			—
Interbank balances (w/o central banks)	6,963	6,963	—			—
Central bank funds sold and securities purchased under resale agreements	37,509	37,509	—	37,376		37,376
Securities borrowed	6	6	—	6		6
Loans	484,270	484,270	—	256,542	49,168	305,710
Other assets subject to credit risk4,5	109,015	103,271	25,790	1,107	258	27,154
Total financial assets at amortized cost3	802,426	796,683	25,790	295,031	49,426	370,247
Financial assets at fair value through profit or loss6
Trading assets	142,273		—	1,525	895	2,419
Positive market values from derivative financial instruments	241,654		180,780	45,704	10	226,494
Non-trading financial assets mandatory at fair value through profit or loss	123,517		1,774	111,207	495	113,476
Of which:
Securities purchased under resale agreement	95,802		1,774	94,028	—	95,802
Securities borrowed	16,513		—	16,271		16,271
Loans	3,370			840	495	1,335
Financial assets designated at fair value through profit or loss	—		—			—
Total financial assets at fair value through profit or loss	507,444	—	182,554	158,436	1,399	342,389
Financial assets at fair value through OCI	43,644	43,644		1,342	1,232	2,574
Of which:
Securities purchased under resale agreement	1,128	1,128	—	90		90
Securities borrowed	—	—				—
Loans	4,432	4,432		20	1,232	1,252
Total financial assets at fair value through OCI	43,644	43,644	—	1,342	1,232	2,574
Financial guarantees and other credit related contingent liabilities7	79,092	79,092		4,619	9,928	14,547
Revocable and irrevocable lending commitments and other credit related commitments7	274,305	272,072		24,219	7,348	31,567
Total off-balance sheet	353,397	351,164	—	28,838	17,276	46,114

Maximum exposure to credit risk	1,706,911	1,191,490	208,344	483,647	69,333	761,323

1 Does not include credit derivative notional sold (€ 620 billion ) and credit derivative notional bought protection

2 Bought Credit protection is reflected with the notional of the underlying

3 All amounts at gross value before deductions of allowance for credit losses

132


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

4 All amounts at amortized cost (gross) except for qualifying hedge derivatives, which are reflected at Fair value through P&L

5 Includes Asset Held for Sale regardless of accounting classification

6 Excludes equities, other equity interests and commodities

7 Figures are reflected at notional amounts


	Dec 31, 2024
			Credit Enhancements
in € m.	Maximum exposure to credit risk1	Subject to impairment	Netting	Collateral	Guarantees and Credit derivatives2	Total credit enhancements
Financial assets at amortized cost3
Cash and central bank balances	147,511	147,511	—	—	−	—
Interbank balances (w/o central banks)	6,169	6,169	—	—	—	—
Central bank funds sold and securities purchased under resale agreements	40,802	40,802	—	40,580	−	40,580
Securities borrowed	44	44	—	32	−	32
Loans	489,579	489,579	—	264,252	44,211	308,463
Other assets subject to credit risk4,5	81,985	76,702	24,750	1,668	270	26,687
Total financial assets at amortized cost3	766,091	760,807	24,750	306,532	44,481	375,763
Financial assets at fair value through profit or loss6
Trading assets	134,118	−	—	1,207	612	1,819
Positive market values from derivative financial instruments	291,800	−	229,605	45,613	115	275,333
Non-trading financial assets mandatory at fair value through profit or loss	113,433	−	1,638	103,339	292	105,269
Of which:
Securities purchased under resale agreement	88,736	−	1,638	87,091	—	88,729
Securities borrowed	15,913	−	—	15,671	—	15,671
Loans	1,954	−	−	485	272	757
Financial assets designated at fair value through profit or loss	—	−	—	—	—	—
Total financial assets at fair value through profit or loss	539,350	—	231,243	150,159	1,019	382,421
Financial assets at fair value through OCI	42,090	42,090	—	4,077	1,168	5,244
Of which:					—	—
Securities purchased under resale agreement	2,786	2,786	—	2,455	—	2,455
Securities borrowed	—	—	−	—	—	—
Loans	5,068	5,068	−	454	1,168	1,621
Total financial assets at fair value through OCI	42,090	42,090	—	4,077	1,168	5,244
Financial guarantees and other credit related contingent liabilities7	73,468	73,467	−	4,410	9,227	13,637
Revocable and irrevocable lending commitments and other credit related commitments7	269,699	268,373	−	21,737	8,227	29,964
Total off-balance sheet	343,167	341,840	—	26,147	17,455	43,602

Maximum exposure to credit risk	1,690,698	1,144,738	255,993	486,915	64,122	807,029

1 Does not include credit derivative notional sold (€ 597.9 billion ) and credit derivative notional bought protection

2 Bought Credit protection is reflected with the notional of the underlying

3 All amounts at gross value before deductions of allowance for credit losses

4 All amounts at amortized cost (gross) except for qualifying hedge derivatives, which are reflected at Fair value through P&L

5 Includes Asset Held for Sale regardless of accounting classification

6 Excludes equities, other equity interests and commodities

7 Figures are reflected at notional amounts

133


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

The overall increase in maximum exposure to credit risk for December 31, 2025 was €16.2 billion mainly driven by

increases of € 27.0 billion in other assets subject to credit risk, € 17.2 billion in cash and central bank balances,

€ 10.2 billion in off-balance sheet exposure, € 8.2 billion in trading assets, and€ 7.1 billion in securities purchased under

resale agreement at fair value through profit or loss. These increases were partly offset by a decrease in positive market

values from derivative financial instruments by € 50.1 billion.

Trading assets as of December 31, 2025, included traded bonds of € 126.6 billion (€ 120.0 billion as of December 31,

2024) of which over 82% were investment-grade (over 82% as of December 31, 2024).

Credit Enhancements are split into three categories: netting, collateral and guarantees/credit derivatives. Haircuts,

parameter setting for regular margin calls as well as expert judgments for collateral valuation are employed to prevent

market developments from leading to a build-up of uncollateralized exposures. All categories are monitored and

reviewed regularly. Overall credit enhancements received are diversified and of adequate quality being largely cash,

highly rated government bonds and third-party guarantees mostly from well rated banks and insurance companies.

These financial institutions are domiciled mainly in European countries and the United States. Furthermore, the bank has

collateral pools of highly liquid assets and mortgages (principally consisting of residential properties mainly in Germany)

for the homogeneous retail portfolio.

Main Credit Exposure Categories

The tables in this section show details about several of Deutsche Bank’s main credit exposure categories, namely Loans,

Revocable and Irrevocable Lending Commitments, Contingent Liabilities, Over-The-Counter (“OTC”) Derivatives, Debt

Securities and Repo and repo-style transactions:

–“Loans” are gross loans as reported on the bank´s balance sheet at amortized cost, loans at fair value through profit

and loss and loans at fair value through other comprehensive income before deduction of allowance for credit losses;

this includes “Traded loans” that are bought and held for the purpose of selling them in the near term, or the material

risks of which have all been hedged or sold; from a regulatory perspective the latter category principally covers

trading book positions

–“Revocable and irrevocable lending commitments” consist of the undrawn portion of revocable and irrevocable

lending-related commitments

–“Contingent liabilities” consist of financial and performance guarantees, standby letters of credit and other similar

arrangements (mainly indemnity agreements)

–“OTC derivatives” are the bank’s credit exposures from over-the-counter derivative transactions that the Group has

entered into, after netting and cash collateral received; on the bank’s balance sheet, these are included in financial

assets at fair value through profit or loss or, for derivatives qualifying for hedge accounting, in other assets, in either

case only applying cash collateral received and netting eligible under IFRS

–“Debt securities” include debentures, bonds, deposits, notes or commercial paper, which are issued for a fixed term

and redeemable by the issuer, as reported on the bank´s balance sheet within accounting categories at amortized cost

and at fair value through other comprehensive income before deduction of allowance for credit losses, it also includes

category at fair value through profit and loss; this includes “Traded bonds”, which are bonds, deposits, notes or

commercial paper that are bought and held for the purpose of selling them in the near term; from a regulatory

perspective the latter category principally covers trading book positions

–“Repo and repo-style transactions” consist of reverse repurchase transactions, as well as securities or commodities

borrowing transactions, only applying collateral received and netting eligible under IFRS.

Although considered in the monitoring of maximum credit exposures, the following are not included in the details of the

Group’s main credit exposure: brokerage and securities related receivables, cash and central bank balances, interbank

balances (without central banks), assets held for sale, accrued interest receivables, traditional securitization positions.

Unless stated otherwise, the tables below reflect credit exposure before the consideration of collateral and risk

mitigation or structural enhancements, except for OTC derivatives wherein they are post credit enhancements.

134


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

Main Credit Exposure Categories by Business Divisions


	Dec 31, 2025
	Loans				Off-balance sheet		OTC derivatives
in € m.	at amortized cost1	trading - at fair value through P&L	Designated / mandatory at fair value through P&L	at fair value through OCI2	Revocable and irrevocable lending commitments3	Contingent liabilities	at fair value through P&L4
Corporate Bank	119,570	21	685	4,116	169,251	73,258	29
Investment Bank	115,325	12,803	2,685	316	67,846	2,824	22,141
Private Bank	246,594	6	—	—	36,961	2,945	497
Asset Management	3	—	—	—	124	10	—
Corporate & Other	2,778	13	—	—	123	56	1,669
Total	484,270	12,842	3,370	4,432	274,305	79,092	24,336


	Dec 31, 2025
	Debt Securities			Repo and repo-style transactions7			Total
in € m.	at amortized cost5	at fair value through P&L	at fair value through OCI6	at amortized cost	at fair value through P&L	at fair value through OCI
Corporate Bank	50	11	—	10,078	—	—	377,069
Investment Bank	5,170	130,177	3,173	27,436	112,314	—	502,208
Private Bank	373	—	—	—	—	—	287,376
Asset Management	—	5,050	62	—	—	—	5,249
Corporate & Other	34,692	336	34,849	—	—	1,128	75,645
Total	40,285	135,575	38,084	37,514	112,315	1,128	1,247,548

1 Includes stage 3 and stage 3 POCI loans at amortized cost amounting to € 15.3 billion as of December 31, 2025

2 Includes stage 3 and stage 3 POCI loans at fair value through OCI amounting to € 16.9 million as of December 31, 2025

3 Includes stage 3 and stage 3 POCI off-balance sheet exposure amounting to € 2.7 billion as of December 31, 2025

4 Includes the effect of netting agreements and cash collateral received where applicable. Excludes derivatives qualifying for hedge accounting

5 Includes stage 3 and stage 3 POCI debt securities at amortized cost amounting to € 25.3 million as of December 31, 2025

6 Includes stage 3 and stage 3 POCI debt securities at fair value through OCI amounting to € 130.2 million as of December 31, 2025

7 Before reflection of collateral and limited to securities purchased under resale agreements and securities borrowed


	Dec 31, 2024
	Loans				Off-balance sheet		OTC derivatives
in € m.	at amortized cost1	trading - at fair value through P&L	Designated / mandatory at fair value through P&L	at fair value through OCI2	Revocable and irrevocable lending commitments3	Contingent liabilities	at fair value through P&L4
Corporate Bank	116,674	212	508	4,110	170,667	67,067	47
Investment Bank	110,077	11,068	1,443	958	61,692	3,268	24,031
Private Bank	257,476	6	—	—	37,110	2,815	391
Asset Management	1	—	—	—	130	9	—
Corporate & Other	5,352	93	3	—	100	309	2,431
Total	489,579	11,380	1,954	5,068	269,699	73,468	26,900


	Dec 31, 2024
	Debt Securities			Repo and repo-style transactions7			Total
in € m.	at amortized cost5	at fair value through P&L	at fair value through OCI6	at amortized cost	at fair value through P&L	at fair value through OCI
Corporate Bank	266	14	—	9,033	—	—	368,598
Investment Bank	5,369	122,813	1,268	31,813	104,248	—	478,047
Private Bank	409	1	1	—	—	—	298,209
Asset Management	—	4,526	82	—	—	—	4,748
Corporate & Other	15,612	390	32,885	—	401	2,786	60,362
Total	21,655	127,744	34,236	40,846	104,649	2,786	1,209,964

1 Includes stage 3 and stage 3 POCI loans at amortized cost amounting to € 15.6 billion as of December 31, 2024

2 Includes stage 3 and stage 3 POCI loans at fair value through OCI amounting to € 60.7 million as of December 31, 2024

3 Includes stage 3 and stage 3 POCI off-balance sheet exposure amounting to € 2.2 billion as of December 31, 2024

4 Includes the effect of netting agreements and cash collateral received where applicable. Excludes derivatives qualifying for hedge accounting

5 Includes stage 3 and stage 3 POCI debt securities at amortized cost amounting to € 41.6 million as of December 31, 2024

6 Includes stage 3 and stage 3 POCI debt securities at fair value through OCI amounting to € 25.6 million as of December 31, 2024

7 Before reflection of collateral and limited to securities purchased under resale agreements and securities borrowed

135


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

Deutsche Bank’s total main credit exposure increased by € 37.0 billion year-on-year with € 24.2 billion in Investment

Bank mainly driven by debt securities and higher repo and repo style holding due to increased firm trading activities and

client flows, as well as growth in loans and € 8.5 billion in the Corporate Bank mainly driven by growth in off balance

sheet exposure due to new and refinanced deals. Exposure increases have been observed across all the products

included in main credit exposures by business divisions, except for Private Bank, where a decrease of €10.8 billion was

observed.

Main Credit Exposure Categories by Industry Sectors

The below tables give an overview of the bank’s credit exposure by industry based on the NACE code of the

counterparty. NACE (Nomenclature des Activités Économiques dans la Communauté Européenne) is a standard

European industry classification system and does not have to be congruent with an internal risk based view applied

elsewhere in this report.


	Dec 31, 2025
	Loans				Off-balance sheet		OTC derivatives
in € m.	at amortized cost1	trading - at fair value through P&L	Designated / mandatory at fair value through P&L	at fair value through OCI2	Revocable and irrevocable lending commitments3	Contingent liabilities	at fair value through P&L4
Agriculture, forestry and fishing	346	2	—	—	262	13	—
Mining and quarrying	1,964	1,629	41	—	4,533	1,410	853
Manufacturing	26,496	747	195	814	53,985	13,742	789
Electricity, gas, steam and air conditioning supply	4,787	256	5	82	8,956	4,009	207
Water supply, sewerage, waste management and remediation activities	675	39	—	4	1,042	405	141
Construction	4,628	451	179	55	4,764	3,732	74
Wholesale and retail trade, repair of motor vehicles and motorcycles	21,094	375	178	699	17,358	6,106	239
Transport and storage	4,580	36	2	98	5,784	1,524	184
Accommodation and food service activities	3,560	81	33	—	1,393	150	4
Information and communication	8,920	1,172	22	396	13,486	2,863	351
Financial and insurance activities⁸	129,848	5,441	1,354	1,845	97,880	38,349	19,636
Real estate activities⁹	45,505	1,445	147	56	7,566	321	185
Professional, scientific and technical activities	9,873	269	118	238	12,733	4,125	42
Administrative and support service activities	6,820	128	161	62	5,163	907	226
Public administration and defense, compulsory social security	7,758	384	10	—	8,755	148	358
Education	249	76	—	—	153	14	33
Human health services and social work activities	3,808	91	—	8	1,784	93	17
Arts, entertainment and recreation	851	17	—	13	1,255	96	18
Other service activities	8,731	191	923	62	3,043	833	713
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use	193,777	—	—	—	24,412	249	265
Activities of extraterritorial organizations and bodies	4	12	—	—	1	4	1
Total	484,270	12,842	3,370	4,432	274,305	79,092	24,336

136


Deutsche Bank	Risk and capital performance
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	Dec 31, 2025
	Debt Securities			Repo and repo-style transactions7			Total
in € m.	at amortized cost5	at fair value through P&L	at fair value through OCI6	at amortized cost	at fair value through P&L	at fair value through OCI
Agriculture, forestry and fishing	—	16	—	—	—	—	640
Mining and quarrying	—	595	—	—	—	—	11,025
Manufacturing	—	1,362	57	52	37	—	98,274
Electricity, gas, steam and air conditioning supply	49	766	94	—	—	—	19,210
Water supply, sewerage, waste management and remediation activities	—	71	11	—	—	—	2,386
Construction	360	377	260	—	—	—	14,881
Wholesale and retail trade, repair of motor vehicles and motorcycles	118	446	6	—	—	—	46,620
Transport and storage	243	408	25	—	—	—	12,883
Accommodation and food service activities	—	88	2	—	—	—	5,311
Information and communication	7	1,930	—	—	3	—	29,151
Financial and insurance activities⁸	6,916	35,177	3,810	37,362	111,332	1,128	490,078
Real estate activities⁹	81	1,314	215	101	2	—	56,939
Professional, scientific and technical activities	—	556	119	—	7	—	28,079
Administrative and support service activities	—	422	8	—	23	—	13,920
Public administration and defense, compulsory social security	24,233	82,712	32,171	—	631	—	157,158
Education	—	207	82	—	—	—	814
Human health services and social work activities	108	206	86	—	—	—	6,201
Arts, entertainment and recreation	—	46	10	—	—	—	2,305
Other service activities	153	4,106	16	—	279	—	19,050
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use	—	—	—	—	—	—	218,703
Activities of extraterritorial organizations and bodies	8,017	4,770	1,112	—	—	—	13,920
Total	40,285	135,575	38,084	37,514	112,315	1,128	1,247,548

1 Includes stage 3 and stage 3 POCI loans at amortized cost amounting to € 15.3 billion as of December 31, 2025

2 Includes stage 3 and stage 3 POCI loans at fair value through OCI amounting to € 16.9 million as of December 31, 2025

3 Includes stage 3 and stage 3 POCI off-balance sheet exposure amounting to € 2.7 billion as of December 31, 2025

4 Includes the effect of netting agreements and cash collateral received where applicable. Excludes derivatives qualifying for hedge accounting

5 Includes stage 3 and stage 3 POCI debt securities at amortized cost amounting to € 25.3 million as of December 31, 2025

6 Includes stage 3 and stage 3 POCI debt securities at fair value through OCI amounting to € 130.2 million as of December 31, 2025

7 Before reflection of collateral and limited to securities purchased under resale agreements and securities borrowed

8 Includes exposure to Corporates including Holding Companies of € 108 billion, Asset-Backed Securities of € 47 billion, Banks of € 91 billion, Insurance of € 21 billion,

Financial Intermediaries of € 13 billion and Public Sector of € 16 billion , all based on internal client classification

9 Non-recourse Commercial Real Estate portfolio based on Deutsche Bank’s definition is € 31 billion

137


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure


	Dec 31, 2024
	Loans				Off-balance sheet		OTC derivatives
in € m.	at amortized cost1	trading - at fair value through P&L	Designated / mandatory at fair value through P&L	at fair value through OCI2	Revocable and irrevocable lending commitments3	Contingent liabilities	at fair value through P&L4
Agriculture, forestry and fishing	336	—	—	—	239	24	1
Mining and quarrying	1,885	2,392	66	—	5,934	1,275	145
Manufacturing	26,634	525	5	1,195	56,933	14,331	1,205
Electricity, gas, steam and air conditioning supply	4,346	632	—	38	8,870	4,489	150
Water supply, sewerage, waste management and remediation activities	595	—	—	3	1,013	264	50
Construction	4,330	244	—	30	3,039	3,244	13
Wholesale and retail trade, repair of motor vehicles and motorcycles	21,405	165	103	809	18,290	6,339	180
Transport and storage	4,766	416	63	103	5,373	1,201	164
Accommodation and food service activities	2,665	64	—	19	1,314	150	2
Information and communication	8,930	757	16	237	16,501	3,014	384
Financial and insurance activities⁸	126,640	3,944	1,177	1,589	95,492	34,889	22,093
Real estate activities⁹	49,859	1,005	136	535	7,868	399	326
Professional, scientific and technical activities	6,276	133	—	214	5,754	2,129	161
Administrative and support service activities	8,921	319	95	161	5,025	493	138
Public administration and defense, compulsory social security	5,740	458	14	24	7,438	120	286
Education	295	17	—	—	99	55	55
Human health services and social work activities	4,130	29	—	12	1,850	91	46
Arts, entertainment and recreation	820	4	—	15	1,166	83	17
Other service activities	6,719	260	280	81	7,013	628	1,305
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use	204,282	—	—	—	20,488	246	174
Activities of extraterritorial organizations and bodies	5	17	—	—	1	3	4
Total	489,579	11,380	1,954	5,068	269,699	73,468	26,900

138


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure


	Dec 31, 2024
	Debt Securities			Repo and repo-style transactions7			Total
in € m.	at amortized cost5	at fair value through P&L	at fair value through OCI6	at amortized cost	at fair value through P&L	at fair value through OCI
Agriculture, forestry and fishing	—	2	—	—	—	—	602
Mining and quarrying	41	553	2	—	—	—	12,293
Manufacturing	23	1,389	50	43	42	—	102,375
Electricity, gas, steam and air conditioning supply	71	915	28	—	—	—	19,541
Water supply, sewerage, waste management and remediation activities	—	143	1	—	—	—	2,070
Construction	264	344	285	—	—	—	11,793
Wholesale and retail trade, repair of motor vehicles and motorcycles	—	612	3	—	—	—	47,904
Transport and storage	159	461	3	—	—	—	12,710
Accommodation and food service activities	5	90	1	—	—	—	4,311
Information and communication	31	1,048	—	—	—	—	30,918
Financial and insurance activities⁸	5,379	29,863	5,671	40,437	104,150	2,786	474,109
Real estate activities⁹	198	1,277	181	324	7	—	62,114
Professional, scientific and technical activities	48	256	105	—	—	—	15,075
Administrative and support service activities	19	471	4	—	16	—	15,661
Public administration and defense, compulsory social security	14,160	83,873	27,354	—	110	—	139,577
Education	—	262	14	—	—	—	797
Human health services and social work activities	103	289	—	—	1	—	6,550
Arts, entertainment and recreation	—	19	—	—	—	—	2,124
Other service activities	450	3,514	13	42	207	—	20,514
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use	—	—	—	—	—	—	225,190
Activities of extraterritorial organizations and bodies	704	2,362	522	—	117	—	3,735
Total	21,655	127,744	34,236	40,846	104,649	2,786	1,209,964

1 Includes stage 3 and stage 3 POCI loans at amortized cost amounting to € 15.6 billion as of December 31, 2024

2 Includes stage 3 and stage 3 POCI loans at fair value through OCI amounting to €60.7 million as of December 31, 2024

3 Includes stage 3 and stage 3 POCI off-balance sheet exposure amounting to € 2.2 billion as of December 31, 2024

4 Includes the effect of netting agreements and cash collateral received where applicable. Excludes derivatives qualifying for hedge accounting

5 Includes stage 3 and stage 3 POCI debt securities at amortized cost amounting to € 41.6 million as of December 31, 2024

6 Includes stage 3 and stage 3 POCI debt securities at fair value through OCI amounting to € 25.6 million as of December 31, 2024

7 Before reflection of collateral and limited to securities purchased under resale agreements and securities borrowed

8 Includes exposure to Corporates including Holding Companies of € 108 billion, Asset-Backed Securities of € 49 billion, Banks of € 66 billion, Insurance of € 9 billion,

Financial Intermediaries of € 15 billion and Public Sector of € 17 billion, all based on internal client classification

9 Non-recourse Commercial Real Estate portfolio based on Deutsche Bank’s definition is € 36 billion

139


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

All credit exposures are subject to the same credit underwriting requirements stipulated in the bank’s “Principles for

Managing Credit Risk”, including various controls according to single name, country, industry and product/asset class-

specific concentration.

Material transactions, such as loans underwritten with the intention to sell down or distribute part of the risk to third

parties, are subject to review and approval by senior credit risk management professionals and (depending upon size) an

underwriting committee and/or the Management Board. High emphasis is placed on structuring and pricing such

transactions so that de-risking can be achieved in a timely manner and – where Deutsche Bank takes market price risk –

to mitigate such market risk.

The Group’s credit exposure to the ten largest counterparties accounted for 11% of the bank’s aggregated total credit

exposure in these categories as of December 31, 2025, compared with 11% as of December 31, 2024. The top ten

counterparty exposures were well-rated counterparties or otherwise related to structured trades which show high levels

of risk mitigation.

The Group’s amortized cost loan exposure within above categories is mostly with borrowers of good credit quality.

Moreover, with the focus on the Corporate Bank and Investment Bank, loan exposure is subject to further risk mitigation

through the bank’s e.g., Strategic Corporate Lending unit.

Deutsche Bank’s household loan exposure is principally associated with Private Bank portfolios.

The bank’s amortized cost loan exposure of € 45.5 billion to Real Estate activities as reported above is based on NACE

code classification and comprises of recourse and non-recourse financing, across various parts of the group and client

segment. This includes € 18.8 billion of loans which is based on Deutsche Bank’s definition of non-recourse CRE loans.

For more information on non-recourse CRE loans, see section “Focus areas”.

The Group’s commercial real estate loans, primarily originated in the U.S. and Europe, are generally secured by first

mortgages on the underlying real estate property. Deutsche Bank originates fixed and floating rate loans and selectively

acquires (generally at substantial discount) sub-/non-performing loans sold by financial institutions. The underwriting

process is stringent and the exposure is managed under separate portfolio limits. Credit underwriting policy guidelines

provide that LTV ratios of generally less than 80% are adhered to loan origination. Additionally, given the significance of

the underlying collateral, independent external appraisals are commissioned for all secured loans by a valuation team

(part of the independent Credit Risk Management function) which is also responsible for reviewing and challenging the

reported real estate values regularly. Deutsche Bank originates loans for distribution in the banking market or via

securitization. In this context Deutsche Bank frequently retains a portion of the syndicated loans while securitized

positions may be entirely sold (except where regulation requires retention of economic risk). Mezzanine or other junior

tranches of debt are retained only in exceptional cases. The bank also participates in conservatively underwritten

unsecured lines of credit to well-capitalized real estate investment trusts and other real estate operating companies.

Commercial real estate property valuations and rental incomes can be significantly impacted by macro-economic

conditions and idiosyncratic events affecting the underlying properties. Accordingly, the portfolio is categorized as

higher risk and hence subject to the aforementioned tight restrictions on concentration.

Deutsche Bank’s exposure to Financial and Insurance Activities is € 490.1 billion as of December 31, 2025 which also

includes exposures to Asset Backed Securities, Banks, Insurance, Financial intermediaries, Public Sector as well as to

Corporates including Holding Companies. Exposures are managed using bespoke risk management frameworks, trade-

by-trade approvals and relevant risk appetite metrics. Total loans across all applicable measurement categories

amounted to € 138.5 billion, total repo and repo style transactions across all applicable measurement categories

amounted to € 149.8 billion and off-balance sheet activities amounted to € 136.2 billion as of December 31, 2025 and

were principally associated with Investment Bank and Corporate Bank portfolios, which were majorly held in North

America and Europe.

140


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure

Main credit exposure categories by geographical region


	Dec 31, 2025
	Loans				Off-balance sheet		OTC derivatives
in € m.	at amortized cost1	trading - at fair value through P&L	Designated / mandatory at fair value through P&L	at fair value through OCI2	Revocable and irrevo- cable lending commitments3	Contingent liabilities	at fair value through P&L4
Europe	328,619	4,376	2,100	1,861	148,112	42,864	14,026
Of which:
Germany	213,628	460	935	538	73,322	16,477	3,631
United Kingdom	13,579	954	331	146	11,164	4,861	4,274
France	4,476	253	99	30	8,402	2,398	688
Luxembourg	18,397	839	316	163	9,740	466	2,033
Italy	23,710	124	34	172	4,263	5,299	148
Netherlands	8,969	262	25	394	8,150	2,458	1,093
Spain	15,592	56	47	109	3,827	4,788	151
Ireland	6,447	448	308	31	5,704	335	525
Switzerland	5,858	38		103	8,896	3,018	104
Poland	3,082			11	1,987	227	29
Belgium	1,914	81		61	1,584	519	148
Russian Federation⁸	12				—
Ukraine⁸	206	1339			363	8
Other Europe⁸	12,749	727	5	102	10,710	2,009	1,202
North America	105,390	4,474	910	1,507	105,259	18,588	4,730
Of which:
U.S.	91,357	4,252	547	1,357	97,229	16,755	3,158
Cayman Islands	6,155	128	322	77	2,762	1,025	1,032
Canada	2,478	94		53	3,378	195	138
Other North America	5,400	—	41	21	1,889	613	402
Asia/Pacific	39,770	1,669	344	963	17,504	16,093	4,511
Of which:
Japan	1,719	102	27	544	524	688	469
Australia	3,543	264	2	46	3,177	1,691	408
India	9,473	98		8	1,525	3,584	142
China	3,495	3	1	21	757	1,699	231
Singapore	4,142	88	3	98	2,086	1,260	287
Hong Kong	2,338	17	59	34	3,158	723	309
Other Asia/Pacific	15,059	1,097	251	211	6,278	6,449	2,665
Other geographical areas	10,491	2,322	16	101	3,430	1,548	1,068
Total	484,270	12,842	3,370	4,432	274,305	79,092	24,336

141


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure


	Dec 31, 2025
	Debt Securities			Repo and repo-style transactions7			Total
in € m.	at amortized cost5	at fair value through P&L	at fair value through OCI6	at amortized cost	at fair value through P&L	at fair value through OCI
Europe	28,302	65,420	18,907	21,965	30,276	—	706,827
Of which:
Germany	426	7,002	4,075	1,470	286	—	322,250
United Kingdom	1,824	13,446	2,729	11,736	14,924	—	79,968
France	7,857	10,793	4,063	3,592	4,069	—	46,720
Luxembourg	149	3,076	15		4,013	—	39,207
Italy	6,030	8,845	961	3,380	805	—	53,771
Netherlands	50	2,220	41	169	32	—	23,863
Spain	1,490	3,763	588	1,123	27	—	31,561
Ireland	922	1,930	21	7	987	—	17,666
Switzerland		1,319	4		247	—	19,586
Poland		555	3,511		191	—	9,594
Belgium	5,572	5,208	2,022	—		—	17,109
Russian Federation⁸		—	1			—	13
Ukraine⁸		172	17			—	899
Other Europe⁸	3,983	7,090	861	487	4,696	—	44,621
North America	6,103	35,201	12,318	11,001	68,842	—	374,324
Of which:
U.S.	5,730	32,907	12,132	7,554	49,668	—	322,645
Cayman Islands	373	185		3,200	15,011	—	30,269
Canada	—	1,977	187	86	4,161	—	12,747
Other North America		132		161	1	—	8,662
Asia/Pacific	4,792	27,901	6,380	3,653	12,717	—	136,297
Of which:
Japan	5	2,666	2,028	157	7,179		16,108
Australia	3,145	2,507	294		1,315		16,393
India	569	6,750	55		16		22,220
China	118	2,289	249	90	240		9,192
Singapore	9	1,041	528	—	979		10,519
Hong Kong	13	410	567	—	662		8,289
Other Asia/Pacific	933	12,238	2,660	3,407	2,327		53,576
Other geographical areas	1,089	7,053	478	896	480	1,128	30,099
Total	40,285	135,575	38,084	37,514	112,315	1,128	1,247,548

1 Includes stage 3 and stage 3 POCI loans at amortized cost amounting to € 15.3 billion as of December 31, 2025

2 Includes stage 3 and stage 3 POCI loans at fair value through OCI amounting to € 16.9 million as of December 31, 2025

3 Includes stage 3 and stage 3 POCI off-balance sheet exposure amounting to € 2.7 billion as of December 31, 2025

4 Includes the effect of netting agreements and cash collateral received where applicable. Excludes derivatives qualifying for hedge accounting

5 Includes stage 3 and stage 3 POCI debt securities at amortized cost amounting to € 25.3 million as of December 31, 2025

6 Includes stage 3 and stage 3 POCI debt securities at fair value through OCI amounting to € 130.2 million as of December 31, 2025

7 Before reflection of collateral and limited to securities purchased under resale agreements and securities borrowed

8 Thematic addition on back of the ongoing border conflict between the Russian Federation and Ukraine

9 Ukraine trading loan exposure driven by financing, materially guaranteed by supranational development bank. Net exposure considering broader risk mitigation structure

is de minimis

142


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure


	Dec 31, 2024
	Loans				Off-balance sheet		OTC derivatives
in € m.	at amortized cost1	trading - at fair value through P&L	Designated / mandatory at fair value through P&L	at fair value through OCI2	Revocable and irrevo- cable lending commitments3	Contingent liabilities	at fair value through P&L4
Europe	331,232	3,420	702	1,843	146,860	42,033	15,611
Of which:
Germany	220,959	304	353	512	72,341	15,761	4,393
United Kingdom	11,044	365	23	163	12,589	4,418	3,594
France	4,319	69	39	33	6,967	2,111	746
Luxembourg	17,119	944	14	131	8,737	546	1,780
Italy	23,190	229	24	69	4,424	5,302	266
Netherlands	9,593	265	4	332	9,452	2,964	1,460
Spain	15,580	109	40	123	3,833	4,633	169
Ireland	6,483	271	195	61	5,057	295	568
Switzerland	6,050	19	—	196	8,562	2,548	434
Poland	2,890	—	—	15	2,358	181	5
Belgium	1,991	33	—	80	1,685	1,582	181
Russian Federation⁸	102	—	—	12	1	21	—
Ukraine⁸	98	1729	—	—	—	5	—
Other Europe⁸	11,813	639	10	116	10,855	1,665	2,016
North America	108,465	3,262	931	2,324	110,332	14,856	5,890
Of which:
U.S.	95,186	2,986	507	2,095	102,989	13,462	4,923
Cayman Islands	5,969	151	319	87	2,770	660	515
Canada	1,491	121	33	118	2,584	223	202
Other North America	5,819	4	72	24	1,989	511	250
Asia/Pacific	40,066	1,433	309	611	9,941	15,232	5,156
Of which:
Japan	1,744	151	42	77	532	645	598
Australia	3,404	238	—	9	2,918	1,371	512
India	9,001	24	25	—	1,405	3,789	104
China	4,245	4	95	24	443	1,852	755
Singapore	5,146	95	17	129	1,136	2,128	291
Hong Kong	3,062	90	—	87	723	366	229
Other Asia/Pacific	13,466	831	130	285	2,783	5,082	2,666
Other geographical areas	9,816	3,265	11	289	2,567	1,348	244
Total	489,579	11,380	1,954	5,068	269,699	73,468	26,900

143


Deutsche Bank	Risk and capital performance
Annual Report 2025	Credit Risk Exposure


	Dec 31, 2024
	Debt Securities			Repo and repo-style transactions7			Total
in € m.	at amortized cost5	at fair value through P&L	at fair value through OCI6	at amortized cost	at fair value through P&L	at fair value through OCI
Europe	10,425	57,024	15,388	27,957	34,516	283	687,293
Of which:
Germany	321	7,899	1,887	2,033	855	—	327,619
United Kingdom	503	12,141	1,983	12,407	14,163	—	73,393
France	1,511	7,855	3,888	4,077	8,058	—	39,672
Luxembourg	—	2,699	472	127	3,615	—	36,184
Italy	4,914	8,038	985	4,144	1,425	—	53,011
Netherlands	87	2,014	33	—	71	—	26,276
Spain	1,489	4,096	359	1,388	33	—	31,853
Ireland	1,326	1,695	8	29	1,065	—	17,053
Switzerland	—	1,657	1	2,658	280	—	22,404
Poland	—	262	3,554	—	84	—	9,349
Belgium	—	4,197	1,572	—	5	—	11,325
Russian Federation⁸	—	3	—	—	—	—	138
Ukraine⁸	—	165	13	—	—	—	454
Other Europe⁸	273	4,304	634	1,094	4,861	283	38,562
North America	7,227	34,972	12,695	8,205	52,388	—	361,546
Of which:
U.S.	6,854	33,637	12,499	4,991	39,389	—	319,517
Cayman Islands	373	370	—	3,032	9,388	—	23,634
Canada	—	872	195	—	3,575	—	9,415
Other North America	—	93	—	182	36	—	8,979
Asia/Pacific	3,844	28,246	5,995	3,839	17,524	1,006	133,202
Of which:
Japan	6	2,985	964	178	8,815	—	16,736
Australia	2,526	2,374	311	212	2,720	—	16,596
India	658	6,630	75	—	—	681	22,391
China	—	4,400	274	—	952	—	13,042
Singapore	61	946	738	—	711	—	11,397
Hong Kong	9	559	553	—	329	—	6,007
Other Asia/Pacific	584	10,353	3,081	3,449	3,997	326	47,032
Other geographical areas	160	7,501	158	845	222	1,497	27,923
Total	21,655	127,744	34,236	40,846	104,649	2,786	1,209,964