Deutsche Bank (NYSE: DB) 2025 Form 20-F details capital, dividend plan and rising risk pressures
Filing Impact
Filing Sentiment
Form Type
20-F
Deutsche Bank AG files its 2025 Form 20‑F, combining its IFRS (IASB) financial statements with extensive risk and regulatory disclosures. The filing notes 1,902,873,264 ordinary shares outstanding as of December 31, 2025.
The Management Board intends to propose a €1.00 per-share dividend for 2025, implying payout ratios of 33% basic and 34% diluted earnings per share. A capitalization table shows total debt of €142,336 million and total equity of €82,285 million, for total capitalization of €224,621 million.
The report emphasizes macroeconomic and geopolitical risks, including trade tensions, war-related uncertainty and commercial real estate pressure, and details stringent capital, liquidity and TLAC/MREL requirements. It also highlights ongoing work to strengthen internal controls, technology, and AML/KYC frameworks under close scrutiny from European and U.S. regulators.
Positive
- None.
Negative
- None.
1
–
As filed with the Securities and Exchange Commission on March 12, 2026 |
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
Form 20-F
SECURITIES EXCHANGE ACT OF 1934
or
SECURITIES EXCHANGE ACT OF 1934
FOR THE FISCAL YEAR ENDED December 31 , 2025
or
SECURITIES EXCHANGE ACT OF 1934
or
SECURITIES EXCHANGE ACT OF 1934
Date of event requiring this shell company report
Commission file number 1-15242
(Exact name of Registrant as specified in its charter)
Deutsche Bank Corporation
(Translation of Registrant’s name into English)
Federal Republic of Germany
(Jurisdiction of incorporation or organization)
(Address of principal executive offices)
(Name, Telephone, E-mail and/or Facsimile number and Address of Company Contact Person)
Securities registered or to be registered pursuant to Section 12(b) of the Act
See following page
Securities registered or to be registered pursuant to Section 12(g) of the Act.
NONE
(Title of Class)
Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act.
NONE
(Title of Class)
Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the close of the period
covered by the annual report:
Ordinary Shares, no par value 1,902,873,264
(as of December 31, 2025)
2
–
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.
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).
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.
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 | ||
3
–
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 | ||
4
–
Deutsche Bank | |
Annual Report 2025 on Form 20-F |
Material Contracts | 99 | ||
Exchange Controls | 100 | ||
Taxation | 100 | ||
Dividends and Paying Agents | 104 | ||
Statement by Experts | 104 | ||
Documents on Display | 104 | ||
Subsidiary Information | 104 | ||
Item 11: Quantitative and Qualitative Disclosures about Credit, Market and Other Risk | 105 | ||
Item 12: Description of Securities other than Equity Securities | 105 | ||
PART II | 106 | ||
Item 13: Defaults, Dividend Arrearages and Delinquencies | 106 | ||
Item 14: Material Modifications to the Rights of Security Holders and Use of Proceeds | 106 | ||
Item 15: Controls and Procedures | 106 | ||
Disclosure Controls and Procedures | 106 | ||
Management’s Annual Report on Internal Control over Financial Reporting | 106 | ||
Report of Independent Registered Public Accounting Firm | 107 | ||
Opinion on Internal Control Over Financial Reporting | 107 | ||
Item 16A: Audit Committee Financial Expert | 109 | ||
Item 16B: Code of Ethics | 109 | ||
Item 16C: Principal accountant fees and services | 109 | ||
Item 16D: Exemptions from the Listing Standards for Audit Committees | 109 | ||
Item 16E: Purchases of Equity Securities by the Issuer and Affiliated Purchasers | 110 | ||
Item 16F: Change in Registrant’s Certifying Accountant | 111 | ||
Item 16G: Corporate Governance | 111 | ||
Item 16H: Mine Safety Disclosure | 114 | ||
Item 16I: Disclosure Regarding Foreign Jurisdictions that Prevent Inspections | 114 | ||
Item 16J: Insider Trading Policies | 114 | ||
Item 16K: Cybersecurity | 114 | ||
Disclosures Under Iran Threat Reduction and Syria Human Rights Act of 2012 | 115 | ||
PART III | 117 | ||
Item 17: Financial Statements | 117 | ||
Item 18: Financial Statements | 117 | ||
Item 19: Exhibits | 118 | ||
Signatures | 119 | ||
Annual Report | 120 | ||
Supplemental Financial Information (Unaudited) – S-1 | S-1 | ||
5
–
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.
6
–
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
7
–
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
9
Deutsche Bank | Item 3: Key Information |
Annual Report 2025 on Form 20-F | Capitalization and Indebtedness |
Capitalization and Indebtedness
Consolidated capitalization in accordance with IFRS as issued by the IASB as of December 31, 2025
in € m. | ||
Debt:1 | ||
Long-term debt | 114,754 | |
Trust preferred securities | 283 | |
Long-term debt at fair value through profit or loss | 27,299 | |
Total debt | 142,336 | |
Shareholders’ equity: | ||
Common shares (no par value) | 4,891 | |
Additional paid-in capital | 38,281 | |
Retained earnings | 30,275 | |
Common shares in treasury, at cost | (185) | |
Accumulated other comprehensive income, net of tax | ||
Unrealized net gains (losses) on financial assets at fair value through other comprehensive income, net of tax and other | (819) | |
Unrealized net gains (losses) on derivatives hedging variability of cash flows, net of tax | (36) | |
Unrealized net gains (losses) on assets classified as held for sale, net of tax | ||
Unrealized net gains (losses) attributable to change in own credit risk of financial liabilities designated at fair value through profit and loss, net of tax | (192) | |
Foreign currency translation, net of tax | (3,211) | |
Unrealized net gains (losses) from equity method investments | 10 | |
Total shareholders’ equity | 69,015 | |
Additional equity components | 11,708 | |
Noncontrolling interests | 1,562 | |
Total equity | 82,285 | |
Total capitalization | 224,621 |
1€46,560 million (33%) of Deutsche Bank’s debt was secured as of December 31, 2025.
Reasons for the Offer and Use of Proceeds
Not required because this document is filed as an Annual Report.
10
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.
11
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
12
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.
13
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.
14
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
15
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.
16
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.
17
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.
18
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.
19
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.
20
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.
21
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.
22
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.
23
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.
24
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.
25
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.
26
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.
27
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.
28
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.
29
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.
30
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.
31
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.
32
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.
33
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.
34
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.
35
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.
36
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.
37
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.
38
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.
39
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.
40
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.
41
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.
42
Deutsche Bank | Item 4: Information on the company |
Annual Report 2025 on Form 20-F | Business Strategy |
Financial performance in 2025
In 2025, net revenues were € 31.4 billion in 2025, essentially flat compared to € 31.5 billion in 2024. From 2021 to year
end 2025, revenues grew at a compound annual rate of 5.3%.
On operational efficiency, Deutsche Bank completed its € 2.5 billion operational efficiency program as planned by the
end of 2025. Measures included the optimization of the bank’s platform in Germany and workforce reductions, notably in
non-client-facing roles.
Deutsche Bank’s capital efficiency program delivered further risk-weighted assets (RWA) equivalent benefits in 2025.
These efficiencies contributed to the bank’s year end 2025 CET1 capital ratio of 14.2%, which was up versus 13.8% at the
end of 2024.
During 2025, the bank made capital distributions in respect of 2024 of € 2.3 billion, up by around 50% from 2024. These
included the dividend of € 0.68 per share, or € 1.3 billion in aggregate, and share buybacks of € 1.0 billion. For 2026,
Deutsche Bank plans to propose a dividend in respect of the 2025 financial year of € 1.00 per share, or approximately €
1.9 billion in aggregate, up 50% from € 0.68 per share for 2024, at the bank’s Annual General Meeting in May 2026. The
bank has also secured customary authorizations for up to € 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, to be paid in 2022–2026, thereby
amounting to € 8.5 billion.
43
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.
44
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.
45
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.
46
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.
47
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.
48
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.
49
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%.
50
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.
51
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.
52
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.
53
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.
54
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.
55
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).
56
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.
57
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.
58
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%.
59
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.
60
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.
61
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.
62
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.
63
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.
64
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.
65
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.
66
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.
67
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.
68
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.
69
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.
70
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.
71
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.
72
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.
73
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.
74
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.
75
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.
76
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.
77
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.
78
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.
79
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.
80
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.
81
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.
82
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.
83
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.
84
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.
85
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.
86
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.
87
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.
88
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.
89
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.
90
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.
91
Deutsche Bank | Item 9: The Offer and Listing |
Annual Report 2025 on Form 20-F | Offer and Listing Details and Market |
Item 9: The Offer and Listing
Offer and Listing Details and Markets
Deutsche Bank’s share capital consists of ordinary shares issued in registered form without par value. Under German law,
shares without par value are deemed to have a “nominal” value equal to the total amount of share capital divided by the
number of shares. Deutsche Bank’s shares have a nominal value in this sense of € 2.56 per share.
The principal trading market for Deutsche Bank’s shares is the Frankfurt Stock Exchange, where it trades under the
symbol DBK. Deutsche Bank’s shares are also traded on the six other German stock exchanges (Berlin, Duesseldorf,
Hamburg, Hanover, Munich and Stuttgart, where on each exchange it also trades under the symbol DBK), on the Eurex
and the New York Stock Exchange, where it trades under the symbol DB.
Deutsche Bank maintains a share register in Frankfurt am Main and, for the purposes of trading the bank’s shares on the
New York Stock Exchange, a share register in New York.
All shares on German stock exchanges trade in euros, and all shares on the New York Stock Exchange trade in
U.S. dollars.
You should not rely on Deutsche Bank’s past share performance as a guide to the bank’s future share performance.
Plan of Distribution
Not required because this document is filed as an Annual Report.
Selling Shareholders
Not required because this document is filed as an Annual Report.
Dilution
Not required because this document is filed as an Annual Report.
Expenses of the Issue
Not required because this document is filed as an Annual Report.
92
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.
93
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.
94
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.
95
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.
96
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
Register (Unternehmensregister). An exception applies where the increase of the total number of voting rights is due to
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.
97
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.
98
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.
99
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.
103
Deutsche Bank | Item 10: Additional Information |
Annual Report 2025 on Form 20-F | Exchange Controls |
German Gift and Inheritance Taxes
Under the current estate, inheritance and gift tax treaty between the United States and Germany (the “Estate Tax
Treaty”), a transfer of shares generally will not be subject to German gift or inheritance tax so long as the donor or
decedent, and their donee or other beneficiary, were not domiciled in Germany for purposes of the Estate Tax Treaty at
the time the gift was made, or at the time of the decedent’s death, and the shares were not held in connection with a
permanent establishment or fixed base in Germany.
The Estate Tax Treaty provides a credit against U.S. federal estate and gift tax liability for the amount of inheritance and
gift tax paid in Germany, subject to certain limitations, where shares are subject to German inheritance or gift tax and
United States federal estate or gift tax.
Other German Taxes
There are currently no German net wealth, transfer, stamp or other similar taxes that would apply to a U.S. resident as a
result of the receipt, purchase, ownership or sale of shares.
104
Deutsche Bank | Item 10: Additional Information |
Annual Report 2025 on Form 20-F | Dividends and Paying Agents |
Dividends and Paying Agents
Not required because this document is filed as an Annual Report.
Statement by Experts
Not required because this document is filed as an Annual Report.
Documents on Display
Deutsche Bank is subject to the informational requirements of the Securities Exchange Act of 1934, as amended. In
accordance with these requirements, it files reports and other information with the Securities and Exchange Commission.
The Group’s Securities and Exchange Commission filings are available at the Securities and Exchange Commission’s
website at www.sec.gov under File Number 001-15242.
Subsidiary Information
Not applicable.
105
Deutsche Bank | Item 12: Description of Securities other than Equity Securities |
Annual Report 2025 on Form 20-F |
Item 11: Quantitative and Qualitative Disclosures
about Credit, Market and Other Risk
For quantitative and qualitative disclosures about Credit, Market and Other Risk, please see “Combined Management
Report: Risk Report” in the Annual Report 2025.
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.
Item 12: Description of Securities other than Equity
Securities
Deutsche Bank’s ordinary shares are not represented by American Depositary Receipts and accordingly no information is
required to be provided pursuant to Item 12.D.3 and Item 12.D.4. The remainder of the information required by this Item
12 and by Instruction 2(d) under the Instructions as to Exhibits of Form 20-F is provided as Exhibit 2.2 to this Annual
Report on Form 20-F.
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.
117
Deutsche Bank | Item 18: Financial Statements |
Annual Report 2025 on Form 20-F |
PART III
Item 17: Financial Statements
Not applicable.
Item 18: 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.
The consolidated financial statements have been audited by EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft ,
included in the Annual Report 2025.
118
Deutsche Bank | Item 19: Exhibits |
Annual Report 2025 on Form 20-F |
Item 19: Exhibits
We have filed the following documents as exhibits to this document.
Exhibit number | Description of Exhibit | |
1.1 | English translation of the Articles of Association of Deutsche Bank AG, furnished as Exhibit 99.2 to our Report on Form 6-K, dated January 5, 2026, and incorporated by reference herein. | |
2.1 | The total amount of long-term debt securities of us or our subsidiaries authorized under any instrument does not exceed 10 percent of the total assets of our Group on a consolidated basis. We hereby agree to furnish to the Commission, upon its request, a copy of any instrument defining the rights of holders of long-term debt of us or of our subsidiaries for which consolidated or unconsolidated financial statements are required to be filed. | |
2.2 | Descriptions of securities registered under the Securities Exchange Act of 1934. | |
4.1 | Equity Plan Rules 2021, furnished as Exhibit 4.5 to our 2020 Annual Report on Form 20-F and incorporated by reference herein. | |
4.2 | Equity Plan Rules 2022, furnished as Exhibit 4.6 to our 2021 Annual Report on Form 20-F and incorporated by reference herein. | |
4.3 | Equity Plan Rules 2023, furnished as Exhibit 4.6 to our 2022 Annual Report on Form 20-F and incorporated by reference herein. | |
4.4 | Equity Plan Rules 2024, furnished as Exhibit 4.6 to our 2023 Annual Report on Form 20-F and incorporated by reference herein. | |
4.5 | Equity Plan Rules 2025, furnished as Exhibit 4.6 to our 2024 Annual Report on Form 20-F and incorporated by reference herein. | |
4.6 | Equity Plan Rules 2026. | |
4.7 | Restricted Share Plan Rules 2021, furnished as Exhibit 4.10 to our 2020 Annual Report on Form 20-F and incorporated by reference herein. | |
4.8 | Restricted Share Plan Rules 2022, furnished as Exhibit 4.9 to our 2021 Annual Report on Form 20-F and incorporated by reference herein. | |
4.9 | Restricted Share Plan Rules 2023, furnished as Exhibit 4.10 to our 2022 Annual Report on Form 20-F and incorporated by reference herein. | |
4.10 | Restricted Share Plan Rules 2024, furnished as Exhibit 4.11 to our 2023 Annual Report on Form 20-F and incorporated by reference herein. | |
4.11 | Restricted Share Plan Rules 2025, furnished as Exhibit 4.11 to our 2024 Annual Report on Form 20-F and incorporated by reference herein. | |
4.12 | Restricted Share Plan Rules 2026. | |
8.1 | List of Subsidiaries. | |
11.1 | Personal Account Dealing Policy. | |
11.2 | Excerpts from Code of Conduct, furnished as Exhibit 11.2 to our 2024 Annual Report on Form 20-F and incorporated by reference herein. | |
12.1 | Principal Executive Officer Certifications Required by 17 C.F.R. 240.13a-14(a). | |
12.2 | Principal Financial Officer Certifications Required by 17 C.F.R. 240.13a-14(a). | |
13.1 | Chief Executive Officer Certification Required by 18 U.S.C. Section 1350. | |
13.2 | Chief Financial Officer Certification Required by 18 U.S.C. Section 1350. | |
15.1 | Consent of EY GmbH & Co. KG Wirtschaftsprüfungsgesellschaft. | |
97.1 | Compensation Recovery Policy for Deutsche Bank Management Board Members, furnished as Exhibit 97.1 to our 2023 Annual Report on Form 20-F and incorporated by reference herein. | |
97.2 | Compensation Recovery Policy for Executive Officers, furnished as Exhibit 97.2 to our 2023 Annual Report on Form 20-F and incorporated by reference herein. | |
101.1 | Interactive Data File. |
119
Deutsche Bank | Signatures |
Annual Report 2025 on Form 20-F |
Signatures
The registrant hereby certifies that it meets all of the requirements for filing on Form 20-F and has duly caused and
authorized the undersigned to sign this annual report on its behalf.
Date: March 12, 2026
Deutsche Bank Aktiengesellschaft
/s/ | CHRISTIAN SEWING |
Christian Sewing
Chairman of the Management Board
Chief Executive Officer
/s/ | JAMES VON MOLTKE |
James von Moltke
Member of the Management Board
President and Chief Financial Officer
1
Annual Report
1
[Page intentionally left blank for SEC filing purposes]
2
Deutsche Bank | |
Annual Report 2025 |
Content
4 | 1- Combined Management Report | |
5 | Operating and financial review | |
39 | Outlook | |
40 | Risks and opportunities | |
42 | Risk Report | |
185 | Sustainability Statement | |
186 | Employees | |
192 | Internal control over financial reporting | |
194 | Information pursuant to Section 315a (1) of the German Commercial Code | |
196 | Corporate Governance Statement acc to Sec 289f, 315d of the German Commercial Code | |
198 | Standalone parent company information (HGB) | |
200 | 2- Consolidated Financial Statements | |
201 | Consolidated Statement of Income | |
202 | Consolidated Statement of Comprehensive Income | |
203 | Consolidated Balance Sheet | |
204 | Consolidated Statement of Changes in Equity | |
205 | Consolidated Statement of Cash Flows | |
207 | Notes to the consolidated financial statements | |
246 | Notes to the consolidated income statement | |
253 | Notes to the consolidated balance sheet | |
306 | Additional Notes | |
348 | Report of Independent Registered Public Accounting Firm | |
355 | 3-Compensation Report | |
357 | Compensation of the Management Board | |
385 | Compensation of Supervisory Board members | |
388 | Comparative presentation of compensation and earnings trends | |
391 | Compensation of the employees (unaudited) | |
406 | 4-Corporate Governance Statement according to Sections 289f and 315d of the German Commercial Code | |
407 | Compliance with German Corporate Governance Code | |
410 | Management Board | |
418 | Supervisory Board | |
435 | Related Party Transactions | |
436 | Principal accountant fees and services | |
437 | 5-Supplementary Information (Unaudited) | |
438 | Non-GAAP financial measures | |
446 | Declaration of Backing | |
448 | Group Five-Year Record | |
450 | Imprints | |
3
Deutsche Bank | |
Annual Report 2025 |
[Page intentionally left blank for SEC filing purposes]
4
Deutsche Bank | |
Annual Report 2025 |
1- Combined Management Report
5 | Operating and financial review | |
5 | Executive summary | |
8 | Deutsche Bank Group | |
13 | Results of operations | |
35 | Financial Position | |
38 | Liquidity and capital resources | |
39 | Outlook | |
40 | Risks and opportunities | |
42 | Risk Report | |
44 | Introduction | |
45 | Risk and capital overview | |
50 | Risk and capital framework | |
61 | Risk type management | |
113 | Risk and capital performance | |
185 | Sustainability Statement | |
186 | Employees | |
192 | Internal control over financial reporting | |
194 | Information pursuant to Section 315a (1) of the German Commercial Code | |
196 | Corporate Governance Statement acc to Sec 289f, 315d of the German Commercial Code | |
198 | Standalone parent company information (HGB) | |
5
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
6
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.
7
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.
8
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
9
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.
10
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.
11
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.
12
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.
13
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
14
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.
15
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.
16
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.
17
Deutsche Bank | Operating and financial review |
Annual Report 2025 | Results of operations |
Provision for credit losses
2025
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 bookings, 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. Overall, portfolio quality
remains stable.
2024
Provision for credit losses was € 1.8 billion in 2024, up from € 1.5 billion in 2023 and 38 basis points (bps) of average
loans, in line with the guidance the bank provided after the third quarter. The increase was driven by cyclical events in
the commercial real estate sector, certain larger corporate credit events and temporary effects following the Postbank
integration. The wider portfolios performed broadly in line with expectations despite the challenging macroeconomic
and interest rate environment.
The sections “Segment results of operations” and “Risk Report” provide further details on provision for credit losses.
18
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.
19
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.
20
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.
21
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.
22
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
23
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
24
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
25
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
26
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.
27
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
28
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.
29
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
30
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.
31
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
32
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
33
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
34
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.
35
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 |
36
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.
37
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.
38
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”.
39
Deutsche Bank | Outlook |
Annual Report 2025 | |
[Page intentionally left blank for SEC filing purposes
40
Deutsche Bank | Risks and Opportunities |
Annual Report 2025 | |
Risks and
[Page intentionally left blank for SEC filing purposes]
41
Deutsche Bank | Risks and Opportunities |
Annual Report 2025 | |
[Page intentionally left blank for SEC filing purposes]
42
Deutsche Bank | Risk Report |
Annual Report 2025 | |
Risk Report
44 | Introduction | ||
45 | Risk and capital overview | ||
Key risk metrics | 45 | ||
Risk profile | 46 | ||
Key risk themes | 48 | ||
50 | Risk and capital framework | ||
Risk management principles | 50 | ||
Risk governance | 51 | ||
Risk identification and assessment | 54 | ||
Risk appetite and capacity | 54 | ||
Risk measurement and reporting systems | 55 | ||
Strategic and capital plan | 57 | ||
Stress testing | 58 | ||
Recovery and resolution planning | 60 | ||
61 | Risk type management | ||
Capital Risk Management | 62 | ||
Enterprise Risk Management | 63 | ||
Credit Risk Management | 66 | ||
Market Risk Management | 88 | ||
Liquidity risk management | 95 | ||
Model Risk Management | 100 | ||
Operational risk management | 101 | ||
Reputational Risk Management | 107 | ||
Information security | 108 | ||
113 | Risk and capital performance | ||
Capital, Leverage Ratio, TLAC and MREL | 113 | ||
Credit Risk Exposure | 131 | ||
Trading Market Risk Exposures | 167 | ||
Non-trading Market Risk Exposures | 170 | ||
Liquidity Risk Exposure | 172 | ||
Operational Risk exposure | 184 | ||
43
Deutsche Bank | Risk Report |
Annual Report 2025 | |
[Page intentionally left blank for SEC filing purposes]
44
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.
45
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”.
46
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.
47
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.
48
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.
49
Deutsche Bank | Risk and capital overview |
Annual Report 2025 | Key risk themes |
Technology
Loan exposure to the Technology sector accounts for € 15.8 billion (2024: € 11.7 billion), at amortized cost, of which
€ 7.3 billion (2024: € 5.7 billion) is related to Data Centre Financing and a further € 3.2 billion (2024: € 2.7 billion) to
companies focused on software across a diverse range of clients, while the remainder relates mainly to manufacturers
including semi-conductors and hardware. The portfolio is concentrated on large, diversified industry leaders, primarily in the
U.S. Corporate exposures are 60% investment grade rated with limited appetite for smaller, lower rated clients. Almost 100%
of the loans are performing with only 5% in stage 2. Data Centre exposures are predominantly project finance related and
focused on facilities that benefit from long-term leases from investment grade rated global hyperscalers.
Specific risk appetite is set for the overall Technology portfolio as well as for the Data Centre portfolio. Portfolio risk
appetite, and origination standards are regularly reviewed. There is also technology related underwriting exposure, which
is originated to distribute, broadly diversified across issuers and subject to additional restrictions and monitoring as well
as portfolio-based hedging
The bank's Technology exposure is reported under multiple NACE codes reflecting the nature of the underlying risk mainly
shown under Financial and Insurance companies (€ 6.2 billion), Information and Communications (€ 4.5 billion),
Manufacturing (€ 3.0 bn) and Real Estate Activities (€ 0.9 billion).
50
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.
51
Deutsche Bank | Risk and capital framework |
Annual Report 2025 | 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.
52
Deutsche Bank | Risk and capital framework |
Annual Report 2025 | Risk governance |
–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.
53
Deutsche Bank | Risk and capital framework |
Annual Report 2025 | Risk governance |
The Chief Risk Officer has direct management responsibility for the Chief Risk Office function. Risk management and
control duties in the Chief Risk Office function are generally assigned to specialized risk management units focusing on
the management of
–Specific risk types
–Risks within a specific business
–Risks in a specific region.
These specialized risk management units generally handle the following core tasks:
–Foster consistency with the risk appetite set by the Management Board and applied to business segments and their
business units
–Determine and implement risk and capital management policies, procedures and methodologies that are appropriate
to the businesses within each business segment
–Establish and approve risk limits
–Conduct periodic portfolio reviews to keep the portfolio of risks within acceptable parameters
–Develop and implement risk and capital management infrastructures and systems that are appropriate for each
business segment
While operating independently from each other and the business segments, the Finance and Risk functions have the joint
responsibility to quantify and verify the risk that the bank assumes.
54
Deutsche Bank | Risk and capital framework |
Annual Report 2025 | 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.
55
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.
56
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.
57
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.
58
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.
59
Deutsche Bank | Risk and capital framework |
Annual Report 2025 | Stress testing |
In 2025, Deutsche Bank was subject to the biannual EBA Stress Test testing the resilience of European banks. The
outcome of the stress test influences the Pillar 2 Guidance for CET1 and leverage ratio and informs the Pillar 2
requirement. Compared to previous comparable stress tests, Deutsche Bank’s disclosed CET1 ratio depletion was lower
under the adverse scenario in line with improved profitability.
Deutsche Bank’s core U.S. subsidiary, DB USA Corporation, also took part in a major regulatory stress test in 2025 i.e., the
US-based CCAR stress test, as implemented pursuant to the U.S. Dodd-Frank Act. In the CCAR stress test, the Federal
Reserve (FRB) disclosed the stress capital depletion for DB USA Corporation and DWS USA Corporation; the outcome of
which showed that each entity remains very well-capitalized even after withstanding a hypothetical severe stress
environment.
Deutsche Bank performs an annual climate stress test to assess its resilience to climate-related risks. The 2025 stress
test incorporated a range of transition and physical risk scenarios over short, medium and long-term time horizons. The
scope of the exercise included portfolios deemed material for climate risk across different risk types. The results of the
stress test are integrated into relevant processes, including risk appetite, business planning and ICAAP.
60
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.
61
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.
62
Deutsche Bank | Risk type management |
Annual Report 2025 | Capital Risk Management |
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 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.
63
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.
64
Deutsche Bank | Risk type management |
Annual Report 2025 | Enterprise Risk Management |
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).
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.
65
Deutsche Bank | Risk type management |
Annual Report 2025 | Enterprise Risk Management |
The Management Board has delegated sustainability-related decisions to this committee, which is chaired by the Chief
Executive Officer and the Chief Sustainability Officer (Vice Chair). It receives monthly updates on financed emissions and
net zero alignment.
The Group Risk Committee, chaired by the Chief Risk Officer and established by the Management Board has the mandate
to oversee several risk and capital-related matters. This includes the responsibility for developing the bank’s Climate Risk
Framework. The Committee approves the Bank’s climate and environmental risk appetite, including appetite for
deviation from net zero decarbonization pathways. A number of committees are responsible for the development and
management of specific elements of climate and environmental risk.
The Net Zero Forum receives, in addition to the quarterly reports, monthly flash reports on key metrics (i.e., measuring
alignment with decarbonization targets and the consumption of divisional carbon budgets).
66
Deutsche Bank | Risk type management |
Annual Report 2025 | 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
67
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
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.
68
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.
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.
69
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
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.
70
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.
71
Deutsche Bank | Risk type management |
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.
72
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.
73
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.
74
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
December 31, 20251 2 | ||||
Year 1 (4 quarter avg) | Year 2 (4 quarter avg) | |||
GDP - USA | ||||
GDP - Eurozone | ||||
GDP - Germany | ||||
GDP - Italy | ||||
GDP - Developing Asia | ||||
GDP - Emerging Markets | ||||
Unemployment - USA | ||||
Unemployment - Eurozone | ||||
Unemployment - Germany | ||||
Unemployment - Italy | ||||
Unemployment - Spain | ||||
Unemployment - Japan | ||||
Real Estate Prices - CRE Index USA | ||||
Real Estate Prices - CRE Index Eurozone | ||||
Real Estate Prices - House Price Index USA | ||||
Real Estate Prices - House Price Index Germany | ||||
Real Estate Prices - House Price Index Spain | ||||
Equity - S&P500 | ||||
Equity - Eurostoxx50 | ||||
Equity - DAX40 | ||||
Equity - MSCI EAFE | ||||
Equity - MSCI Asia | ||||
Equity - Nikkei | ||||
Credit - High Yield Index | ||||
Credit - CDX High Yield | ||||
Credit - CDX IG | ||||
Credit - CDX Emerging Markets | ||||
Credit - ITX Europe 125 | ||||
Commodity - WTI | ||||
Commodity - Gold | ||||
2 Year 1 equals fourth quarter of 2025 to third quarter of 2026, Year 2 equals fourth quarter of 2026 to third quarter of 2027
75
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
December 31, 20241 2 | ||||
Year 1 (4 quarter avg) | Year 2 (4 quarter avg) | |||
GDP - USA | ||||
GDP - Eurozone | ||||
GDP - Germany | ||||
GDP - Italy | ||||
GDP - Developing Asia | ||||
GDP - Emerging Markets | ||||
Unemployment - USA | ||||
Unemployment - Eurozone | ||||
Unemployment - Germany | ||||
Unemployment - Italy | ||||
Unemployment - Spain | ||||
Unemployment - Japan | ||||
Real Estate Prices - CRE Index USA | ||||
Real Estate Prices - CRE Index Eurozone | ||||
Real Estate Prices - House Price Index USA | ||||
Real Estate Prices - House Price Index Germany | ||||
Real Estate Prices - House Price Index Spain | ||||
Equity - S&P500 | ||||
Equity - Eurostoxx50 | ||||
Equity - DAX40 | ||||
Equity - MSCI EAFE | ||||
Equity - MSCI Asia | ||||
Equity - Nikkei | ||||
Credit - High Yield Index | ||||
Credit - CDX High Yield | ||||
Credit - CDX IG | ||||
Credit - CDX Emerging Markets | ||||
Credit - ITX Europe 125 | ||||
Commodity - WTI | ||||
Commodity - Gold | ||||
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
76
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.
December 31, 2025 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
Real estate prices1 | ( | ( | ||||||
Equities | ( | ( | ||||||
Credit spreads | ( | ( | ||||||
Commodities2 | ( | ( | ||||||
December 31, 2024 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
Real estate prices1 | ( | ( | ||||||
Equities | ( | ( | ||||||
Credit spreads | ( | ( | ||||||
Commodities2 | ( | ( | ||||||
Commercial Real Estate above
(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.
77
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
December 31, 2025 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
Real estate prices1 | ( | ( | ||||||
Credit spreads | ( | ( | ||||||
Commodities2 | ( | ( | ||||||
December 31, 2024 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
Real estate prices1 | ( | ( | ||||||
Credit spreads | ( | ( | ||||||
Commodities2 | ( | ( | ||||||
Commercial Real Estate below
December 31, 2025 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
Real estate prices1 | ( | ( | ||||||
Equities | ( | ( | ||||||
Credit spreads | ( | ( | ||||||
Commodities2 | ( | ( | ||||||
December 31, 2024 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
Real estate prices1 | ( | ( | ||||||
Equities | ( | ( | ||||||
Credit spreads | ( | ( | ||||||
Commodities2 | ( | ( | ||||||
Commercial Real Estate below
78
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
December 31, 2025 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
December 31, 2024 | ||||||||
Upward sensitivity | Downward sensitivity | |||||||
Upward shift | ECL impact in € m. | Downward shift | ECL impact in € m. | |||||
GDP growth rates | ( | ( | ||||||
Unemployment rates | ( | ( | ||||||
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
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.
79
Deutsche Bank | Risk type management |
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.
80
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
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
81
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
82
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.
83
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.
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,
84
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 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”.
85
Deutsche Bank | Risk type management |
Annual Report 2025 | Credit Risk Management |
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.
86
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.
87
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.
88
Deutsche Bank | Risk type management |
Annual Report 2025 | Market Risk Management |
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.
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
89
Deutsche Bank | Risk type management |
Annual Report 2025 | Market Risk Management |
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.
90
Deutsche Bank | Risk type management |
Annual Report 2025 | Market Risk Management |
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 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.
91
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 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.
92
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.
93
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.
94
Deutsche Bank | Risk type management |
Annual Report 2025 | Market Risk Management |
Non-trading market risk economic capital is calculated either by applying the standard trading market risk economic
capital methodology or through the use of non-trading market risk models that are specific to each risk class and which
consider, among other factors, historically observed market moves, the liquidity of each asset class, and changes in
client’s behavior in relation to products with behavioral optionality.
Market risk stress testing
Stress testing is a key risk management technique, which evaluates the potential effects of extreme market events and
movements in individual risk factors. It is one of the core quantitative tools used to assess the market risk of Deutsche
Bank’s positions and complements VaR and Economic Capital. Market Risk Management performs several types of stress
testing to capture the variety of risks (Portfolio Stress Testing, individual specific stress tests at business unit level and
Event Risk Scenarios) and also contributes to Group-wide stress testing. These stress tests cover a wide range of
severities designed to test the earnings stability and capital adequacy of the bank.
95
Deutsche Bank | Risk type management |
Annual Report 2025 | 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.
96
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.
97
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.
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.
98
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.
99
Deutsche Bank | Risk type management |
Annual Report 2025 | Liquidity Risk Management |
Liquidity Risk Mitigation
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.
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.
100
Deutsche Bank | Risk type management |
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
101
Deutsche Bank | Risk type management |
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.
102
Deutsche Bank | Risk type management |
Annual Report 2025 | Operational Risk Management |
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.
103
Deutsche Bank | Risk type management |
Annual Report 2025 | Operational Risk Management |
–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.
104
Deutsche Bank | Risk type management |
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 .
105
Deutsche Bank | Risk type management |
Annual Report 2025 | Operational Risk Management |
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.
106
Deutsche Bank | Risk type management |
Annual Report 2025 | Operational Risk Management |
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.
107
Deutsche Bank | Risk type management |
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.
108
Deutsche Bank | Risk type management |
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.
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.
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,
109
Deutsche Bank | Risk type management |
Annual Report 2025 | Information security |
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.
110
Deutsche Bank | Risk type management |
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.
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.
111
Deutsche Bank | Risk type management |
Annual Report 2025 | Information security |
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.
112
Deutsche Bank | Risk type management |
Annual Report 2025 | Information security |
unauthorized access to confidential company or client information, damaging or interfering with company data, resources, or
business activities, or otherwise exploiting vulnerabilities in its infrastructure, including attacks that occurred along the bank’s
supply chain. The bank, however, did not experience any material effect on its business strategy, results of operation, or financial
Consequently, the bank continued to invest in security risk mitigation. In 2025, Deutsche Bank kept advancing its
security capabilities through a multitude of programs encompassing the breadth of the cyber security domain. A few
specific examples are programs such as enhanced threat detection and prevention, advanced identity management
capabilities, and embedding security as part of infrastructure platform modernization and simplification. The bank also
continues to monitor and evaluate emerging technologies to anticipate and prepare for future risk.
113
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.
114
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.
115
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.
116
Deutsche Bank | Risk and capital performance |
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.
117
Deutsche Bank | Risk and capital performance |
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.
118
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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
119
Deutsche Bank | Risk and capital performance |
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
120
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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.
121
Deutsche Bank | Risk and capital performance |
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.
122
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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.
123
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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 | ||||||
124
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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.
125
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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.
126
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Capital, Leverage Ratio, TLAC and MREL |
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 |
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
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 | — | — | ||||||||||
Interbank balances (w/o central banks) | — | — | ||||||||||
Central bank funds sold and securities purchased under resale agreements | — | |||||||||||
Securities borrowed | — | |||||||||||
Loans | — | |||||||||||
Other assets subject to credit risk4,5 | ||||||||||||
Total financial assets at amortized cost3 | ||||||||||||
Financial assets at fair value through profit or loss6 | ||||||||||||
Trading assets | — | |||||||||||
Positive market values from derivative financial instruments | ||||||||||||
Non-trading financial assets mandatory at fair value through profit or loss | ||||||||||||
Of which: | ||||||||||||
Securities purchased under resale agreement | — | |||||||||||
Securities borrowed | — | |||||||||||
Loans | ||||||||||||
Financial assets designated at fair value through profit or loss | — | |||||||||||
Total financial assets at fair value through profit or loss | — | |||||||||||
Financial assets at fair value through OCI | ||||||||||||
Of which: | ||||||||||||
Securities purchased under resale agreement | — | |||||||||||
Securities borrowed | — | — | — | |||||||||
Loans | ||||||||||||
Total financial assets at fair value through OCI | — | |||||||||||
Financial guarantees and other credit related contingent liabilities7 | ||||||||||||
Revocable and irrevocable lending commitments and other credit related commitments7 | ||||||||||||
Total off-balance sheet | — | |||||||||||
Maximum exposure to credit risk | ||||||||||||
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 | — | — | − | — | ||||||||
Interbank balances (w/o central banks) | — | — | — | — | ||||||||
Central bank funds sold and securities purchased under resale agreements | — | − | ||||||||||
Securities borrowed | — | − | ||||||||||
Loans | — | |||||||||||
Other assets subject to credit risk4,5 | ||||||||||||
Total financial assets at amortized cost3 | ||||||||||||
Financial assets at fair value through profit or loss6 | ||||||||||||
Trading assets | − | — | ||||||||||
Positive market values from derivative financial instruments | − | |||||||||||
Non-trading financial assets mandatory at fair value through profit or loss | − | |||||||||||
Of which: | ||||||||||||
Securities purchased under resale agreement | − | — | ||||||||||
Securities borrowed | − | — | — | |||||||||
Loans | − | − | ||||||||||
Financial assets designated at fair value through profit or loss | − | — | — | — | ||||||||
Total financial assets at fair value through profit or loss | — | |||||||||||
Financial assets at fair value through OCI | — | |||||||||||
Of which: | — | — | ||||||||||
Securities purchased under resale agreement | — | — | ||||||||||
Securities borrowed | — | — | − | — | — | — | ||||||
Loans | − | |||||||||||
Total financial assets at fair value through OCI | — | |||||||||||
Financial guarantees and other credit related contingent liabilities7 | − | |||||||||||
Revocable and irrevocable lending commitments and other credit related commitments7 | − | |||||||||||
Total off-balance sheet | — | |||||||||||
Maximum exposure to credit risk | ||||||||||||
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 |
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 | ||||||||||||||
Investment Bank | ||||||||||||||
Private Bank | ||||||||||||||
Asset Management | ||||||||||||||
Corporate & Other | ||||||||||||||
Total | ||||||||||||||
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 | ||||||||||||||
Investment Bank | ||||||||||||||
Private Bank | ||||||||||||||
Asset Management | ||||||||||||||
Corporate & Other | ||||||||||||||
Total | ||||||||||||||
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
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
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 | ||||||||||||||
Investment Bank | ||||||||||||||
Private Bank | ||||||||||||||
Asset Management | ||||||||||||||
Corporate & Other | ||||||||||||||
Total | ||||||||||||||
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 | ||||||||||||||
Investment Bank | ||||||||||||||
Private Bank | ||||||||||||||
Asset Management | ||||||||||||||
Corporate & Other | ||||||||||||||
Total | ||||||||||||||
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 | ||||||||||||||
Mining and quarrying | ||||||||||||||
Manufacturing | ||||||||||||||
Electricity, gas, steam and air conditioning supply | ||||||||||||||
Water supply, sewerage, waste management and remediation activities | ||||||||||||||
Construction | ||||||||||||||
Wholesale and retail trade, repair of motor vehicles and motorcycles | ||||||||||||||
Transport and storage | ||||||||||||||
Accommodation and food service activities | ||||||||||||||
Information and communication | ||||||||||||||
Financial and insurance activities⁸ | ||||||||||||||
Real estate activities⁹ | ||||||||||||||
Professional, scientific and technical activities | ||||||||||||||
Administrative and support service activities | ||||||||||||||
Public administration and defense, compulsory social security | ||||||||||||||
Education | ||||||||||||||
Human health services and social work activities | ||||||||||||||
Arts, entertainment and recreation | ||||||||||||||
Other service activities | ||||||||||||||
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use | ||||||||||||||
Activities of extraterritorial organizations and bodies | ||||||||||||||
Total | ||||||||||||||
136
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 | ||||||||
Agriculture, forestry and fishing | — | |||||||||||||
Mining and quarrying | — | |||||||||||||
Manufacturing | — | |||||||||||||
Electricity, gas, steam and air conditioning supply | — | |||||||||||||
Water supply, sewerage, waste management and remediation activities | — | |||||||||||||
Construction | — | |||||||||||||
Wholesale and retail trade, repair of motor vehicles and motorcycles | — | |||||||||||||
Transport and storage | — | |||||||||||||
Accommodation and food service activities | — | |||||||||||||
Information and communication | — | |||||||||||||
Financial and insurance activities⁸ | ||||||||||||||
Real estate activities⁹ | — | |||||||||||||
Professional, scientific and technical activities | — | |||||||||||||
Administrative and support service activities | — | |||||||||||||
Public administration and defense, compulsory social security | — | |||||||||||||
Education | — | |||||||||||||
Human health services and social work activities | — | |||||||||||||
Arts, entertainment and recreation | — | |||||||||||||
Other service activities | — | |||||||||||||
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use | — | |||||||||||||
Activities of extraterritorial organizations and bodies | — | |||||||||||||
Total | ||||||||||||||
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
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 | ||||||||||||||
Mining and quarrying | ||||||||||||||
Manufacturing | ||||||||||||||
Electricity, gas, steam and air conditioning supply | ||||||||||||||
Water supply, sewerage, waste management and remediation activities | ||||||||||||||
Construction | ||||||||||||||
Wholesale and retail trade, repair of motor vehicles and motorcycles | ||||||||||||||
Transport and storage | ||||||||||||||
Accommodation and food service activities | ||||||||||||||
Information and communication | ||||||||||||||
Financial and insurance activities⁸ | ||||||||||||||
Real estate activities⁹ | ||||||||||||||
Professional, scientific and technical activities | ||||||||||||||
Administrative and support service activities | ||||||||||||||
Public administration and defense, compulsory social security | ||||||||||||||
Education | ||||||||||||||
Human health services and social work activities | ||||||||||||||
Arts, entertainment and recreation | ||||||||||||||
Other service activities | ||||||||||||||
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use | ||||||||||||||
Activities of extraterritorial organizations and bodies | ||||||||||||||
Total | ||||||||||||||
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 | — | |||||||||||||
Mining and quarrying | — | |||||||||||||
Manufacturing | — | |||||||||||||
Electricity, gas, steam and air conditioning supply | — | |||||||||||||
Water supply, sewerage, waste management and remediation activities | — | |||||||||||||
Construction | — | |||||||||||||
Wholesale and retail trade, repair of motor vehicles and motorcycles | — | |||||||||||||
Transport and storage | — | |||||||||||||
Accommodation and food service activities | — | |||||||||||||
Information and communication | — | |||||||||||||
Financial and insurance activities⁸ | ||||||||||||||
Real estate activities⁹ | — | |||||||||||||
Professional, scientific and technical activities | — | |||||||||||||
Administrative and support service activities | — | |||||||||||||
Public administration and defense, compulsory social security | — | |||||||||||||
Education | — | |||||||||||||
Human health services and social work activities | — | |||||||||||||
Arts, entertainment and recreation | — | |||||||||||||
Other service activities | — | |||||||||||||
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use | — | |||||||||||||
Activities of extraterritorial organizations and bodies | — | |||||||||||||
Total | ||||||||||||||
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
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 |
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 | ||||||||||||||
Of which: | ||||||||||||||
Germany | ||||||||||||||
United Kingdom | ||||||||||||||
France | ||||||||||||||
Luxembourg | ||||||||||||||
Italy | ||||||||||||||
Netherlands | ||||||||||||||
Spain | ||||||||||||||
Ireland | ||||||||||||||
Switzerland | ||||||||||||||
Poland | ||||||||||||||
Belgium | ||||||||||||||
Russian Federation⁸ | ||||||||||||||
Ukraine⁸ | ||||||||||||||
Other Europe⁸ | ||||||||||||||
North America | ||||||||||||||
Of which: | ||||||||||||||
U.S. | ||||||||||||||
Cayman Islands | ||||||||||||||
Canada | ||||||||||||||
Other North America | ||||||||||||||
Asia/Pacific | ||||||||||||||
Of which: | ||||||||||||||
Japan | ||||||||||||||
Australia | ||||||||||||||
India | ||||||||||||||
China | ||||||||||||||
Singapore | ||||||||||||||
Hong Kong | ||||||||||||||
Other Asia/Pacific | ||||||||||||||
Other geographical areas | ||||||||||||||
Total | ||||||||||||||
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 | ||||||||||||||
Of which: | ||||||||||||||
Germany | ||||||||||||||
United Kingdom | ||||||||||||||
France | ||||||||||||||
Luxembourg | ||||||||||||||
Italy | ||||||||||||||
Netherlands | ||||||||||||||
Spain | ||||||||||||||
Ireland | ||||||||||||||
Switzerland | ||||||||||||||
Poland | ||||||||||||||
Belgium | ||||||||||||||
Russian Federation⁸ | ||||||||||||||
Ukraine⁸ | ||||||||||||||
Other Europe⁸ | ||||||||||||||
North America | ||||||||||||||
Of which: | ||||||||||||||
U.S. | ||||||||||||||
Cayman Islands | ||||||||||||||
Canada | ||||||||||||||
Other North America | ||||||||||||||
Asia/Pacific | ||||||||||||||
Of which: | ||||||||||||||
Japan | ||||||||||||||
Australia | ||||||||||||||
India | ||||||||||||||
China | ||||||||||||||
Singapore | ||||||||||||||
Hong Kong | ||||||||||||||
Other Asia/Pacific | ||||||||||||||
Other geographical areas | ||||||||||||||
Total | ||||||||||||||
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 | ||||||||||||||
Of which: | ||||||||||||||
Germany | ||||||||||||||
United Kingdom | ||||||||||||||
France | ||||||||||||||
Luxembourg | ||||||||||||||
Italy | ||||||||||||||
Netherlands | ||||||||||||||
Spain | ||||||||||||||
Ireland | ||||||||||||||
Switzerland | ||||||||||||||
Poland | ||||||||||||||
Belgium | ||||||||||||||
Russian Federation⁸ | ||||||||||||||
Ukraine⁸ | ||||||||||||||
Other Europe⁸ | ||||||||||||||
North America | ||||||||||||||
Of which: | ||||||||||||||
U.S. | ||||||||||||||
Cayman Islands | ||||||||||||||
Canada | ||||||||||||||
Other North America | ||||||||||||||
Asia/Pacific | ||||||||||||||
Of which: | ||||||||||||||
Japan | ||||||||||||||
Australia | ||||||||||||||
India | ||||||||||||||
China | ||||||||||||||
Singapore | ||||||||||||||
Hong Kong | ||||||||||||||
Other Asia/Pacific | ||||||||||||||
Other geographical areas | ||||||||||||||
Total | ||||||||||||||
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 | ||||||||||||||
Of which: | ||||||||||||||
Germany | ||||||||||||||
United Kingdom | ||||||||||||||
France | ||||||||||||||
Luxembourg | ||||||||||||||
Italy | ||||||||||||||
Netherlands | ||||||||||||||
Spain | ||||||||||||||
Ireland | ||||||||||||||
Switzerland | ||||||||||||||
Poland | ||||||||||||||
Belgium | ||||||||||||||
Russian Federation⁸ | ||||||||||||||
Ukraine⁸ | ||||||||||||||
Other Europe⁸ | ||||||||||||||
North America | ||||||||||||||
Of which: | ||||||||||||||
U.S. | ||||||||||||||
Cayman Islands | ||||||||||||||
Canada | ||||||||||||||
Other North America | ||||||||||||||
Asia/Pacific | ||||||||||||||
Of which: | ||||||||||||||
Japan | ||||||||||||||
Australia | ||||||||||||||
India | ||||||||||||||
China | ||||||||||||||
Singapore | ||||||||||||||
Hong Kong | ||||||||||||||
Other Asia/Pacific | ||||||||||||||
Other geographical areas | ||||||||||||||
Total | ||||||||||||||
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
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 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
The tables above provide an overview of Deutsche Bank’s credit exposure by geographical region, allocated based on the
counterparty’s country of domicile. The domicile view might differ from any internal risk based view applied elsewhere in
this report.
The Group’s largest concentration of credit risk within loans from a regional perspective is in its home market Germany,
with a significant share in households, which includes the majority of the mortgage lending and home loan business.
Within OTC derivatives, tradable assets as well as repo and repo-style transactions, the largest concentrations from a
regional perspective were in Europe and North America.
144
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Credit Exposure Classification
Deutsche Bank also classifies its credit exposure along business divisions, which is in line with the divisionally aligned
chief risk officer mandates. The section below discloses the credit exposure of the Corporate Bank and the Investment
Bank together. The subsequent section provides the credit exposure for the Private Bank.
Corporate Bank and Investment Bank credit exposure
The tables below show the main Corporate Bank and Investment Bank Credit Exposure by product types and internal
rating bands. Please refer to section "Measuring Credit Risk" for more details about the bank’s internal ratings.
Main Corporate Bank and Investment Bank credit exposure categories according to the bank’s internal creditworthiness
categories of the counterparties – gross
Dec 31, 2025 | ||||||||||||||||
in € m. (unless stated otherwise) | Loans | Off-balance sheet | OTC derivatives | |||||||||||||
Rating band | Probability of default in %1 | at amortized cost | trading - at fair value through P&L | Designated/ mandatory at fair value through P&L | at fair value through OCI | Revocable and irrevo-cable lending commitments | Contingent liabilities | at fair value through P&L2 | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 17,345 | 519 | 135 | 239 | 21,928 | 3,933 | 8,234 | ||||||||
iA | > 0.04 ≤ 0.11 | 45,423 | 120 | 248 | 677 | 67,516 | 36,422 | 6,687 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 77,819 | 3,438 | 1,146 | 2,844 | 92,128 | 23,430 | 5,513 | ||||||||
iBB | > 0.5 ≤ 2.27 | 66,044 | 4,840 | 1,587 | 646 | 41,868 | 8,843 | 1,230 | ||||||||
iB | > 2.27 ≤ 10.22 | 18,089 | 1,228 | 93 | 9 | 10,885 | 2,577 | 172 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 10,174 | 2,678 | 160 | 17 | 2,773 | 876 | 335 | ||||||||
Total | 234,895 | 12,823 | 3,370 | 4,432 | 237,097 | 76,082 | 22,170 | |||||||||
Dec 31, 2025 | ||||||||||||||||
in € m. (unless stated otherwise) | Debt Securities | Repo and repo-style transactions | ||||||||||||||
Rating band | Probability of default in %1 | at amortized cost | at fair value through P&L | at fair value through OCI | at amortized cost | at fair value through P&L | at fair value through OCI | Total | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 351 | 71,459 | 1,255 | 16,023 | 36,320 | — | 177,740 | ||||||||
iA | > 0.04 ≤ 0.11 | 3,102 | 20,258 | 902 | 7,033 | 6,821 | — | 195,208 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 747 | 13,616 | 138 | 7,240 | 52,272 | — | 280,333 | ||||||||
iBB | > 0.5 ≤ 2.27 | 957 | 23,358 | 533 | 6,416 | 16,523 | — | 172,844 | ||||||||
iB | > 2.27 ≤ 10.22 | 37 | 594 | 211 | 793 | 452 | — | 35,143 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 25 | 904 | 133 | 9 | 0 | — | 18,083 | ||||||||
Total | 5,220 | 130,188 | 3,173 | 37,514 | 112,388 | — | 879,351 | |||||||||
1Reflects the probability of default for a one year time horizon
2Includes the effect of netting agreements and cash collateral received where applicable
Main Corporate Bank and Investment Bank credit exposure categories according to the bank’s internal creditworthiness
categories of the counterparties – net
Dec 31, 2025¹ | ||||||||||||||||
in € m. (unless stated otherwise) | Loans | OTC derivatives | ||||||||||||||
Rating band | Probability of default in %2 | at amortized cost | trading - at fair value through P&L | Designated/ mandatory at fair value through P&L | at fair value through OCI | Revocable and irrevo- cable lending commitments | Contingent liabilities | at fair value through P&L | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 9,762 | 157 | 135 | 94 | 21,028 | 3,575 | 4,745 | ||||||||
iA | > 0.04 ≤ 0.11 | 33,326 | 120 | 248 | 625 | 65,146 | 32,869 | 3,105 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 36,728 | 2,548 | 697 | 1,974 | 84,025 | 18,315 | 3,588 | ||||||||
iBB | > 0.5 ≤ 2.27 | 29,606 | 4,132 | 1,206 | 463 | 37,687 | 6,398 | 1,157 | ||||||||
iB | > 2.27 ≤ 10.22 | 4,874 | 1,095 | 37 | 4 | 10,084 | 1,386 | 161 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 4,645 | 2,158 | 56 | 9 | 2,625 | 350 | 233 | ||||||||
Total | 118,942 | 10,211 | 2,379 | 3,169 | 220,594 | 62,893 | 12,989 | |||||||||
145
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Dec 31, 2025¹ | ||||||||||||||||
in € m. (unless stated otherwise) | Debt Securities | Repo and repo-style transactions | ||||||||||||||
Rating band | Probability of default in %2 | at amortized cost | at fair value through P&L | at fair value through OCI | at amortized cost | at fair value through P&L | at fair value through OCI | Total | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 351 | 71,391 | 1,255 | — | 351 | — | 112,844 | ||||||||
iA | > 0.04 ≤ 0.11 | 3,102 | 20,258 | 902 | 202 | 25 | — | 159,928 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 266 | 13,351 | 111 | — | 51 | — | 161,652 | ||||||||
iBB | > 0.5 ≤ 2.27 | 484 | 22,828 | 133 | — | 342 | — | 104,437 | ||||||||
iB | > 2.27 ≤ 10.22 | 37 | 508 | 203 | — | — | — | 18,389 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 25 | 730 | 119 | — | — | — | 10,950 | ||||||||
Total | 4,265 | 129,066 | 2,723 | 202 | 768 | — | 568,199 | |||||||||
1Net of eligible collateral, guarantees and hedges based on IFRS requirements
2Reflects the probability of default for a one year time horizon
The tables below show the main Corporate Bank and Investment Bank credit exposure for 2024 by product types and
internal rating bands.
Main Corporate Bank and Investment Bank credit exposure categories according to the bank’s internal creditworthiness
categories of the counterparties – gross
Dec 31, 2024 | ||||||||||||||||
in € m. (unless stated otherwise) | Loans | Off-balance sheet | OTC derivatives | |||||||||||||
Rating band | Probability of default in %1 | at amortized cost | trading - at fair value through P&L | Designated/ mandatory at fair value through P&L | at fair value through OCI | Revocable and irrevo-cable lending commitments | Contingent liabilities | at fair value through P&L2 | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 18,371 | 177 | 84 | 209 | 28,227 | 6,007 | 10,133 | ||||||||
iA | > 0.04 ≤ 0.11 | 47,908 | 60 | 542 | 1,167 | 69,746 | 32,937 | 7,441 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 66,741 | 3,207 | 131 | 2,537 | 88,790 | 22,201 | 4,101 | ||||||||
iBB | > 0.5 ≤ 2.27 | 64,486 | 4,983 | 561 | 1,080 | 34,521 | 6,015 | 2,202 | ||||||||
iB | > 2.27 ≤ 10.22 | 21,094 | 713 | 399 | 10 | 8,865 | 2,244 | 104 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 8,153 | 2,141 | 235 | 65 | 2,210 | 931 | 97 | ||||||||
Total | 226,751 | 11,280 | 1,951 | 5,068 | 232,359 | 70,335 | 24,077 | |||||||||
Dec 31, 2024 | ||||||||||||||||
in € m. (unless stated otherwise) | Debt Securities | Repo and repo-style transactions | ||||||||||||||
Rating band | Probability of default in %1 | at amortized cost | at fair value through P&L | at fair value through OCI | at amortized cost | at fair value through P&L | at fair value through OCI | Total | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 694 | 64,329 | 192 | 17,775 | 39,458 | — | 185,657 | ||||||||
iA | > 0.04 ≤ 0.11 | 2,469 | 14,985 | 46 | 7,374 | 8,817 | — | 193,490 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 1,021 | 19,851 | 149 | 7,506 | 13,055 | — | 229,290 | ||||||||
iBB | > 0.5 ≤ 2.27 | 1,319 | 22,194 | 431 | 7,390 | 41,123 | — | 186,303 | ||||||||
iB | > 2.27 ≤ 10.22 | 90 | 643 | 402 | 686 | 1,795 | — | 37,044 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 42 | 825 | 47 | 115 | — | — | 14,862 | ||||||||
Total | 5,635 | 122,827 | 1,268 | 40,846 | 104,248 | — | 846,646 | |||||||||
1Reflects the probability of default for a one year time horizon
2Includes the effect of netting agreements and cash collateral received where applicable
146
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Main Corporate Bank and Investment Bank credit exposure categories according to the bank’s internal creditworthiness
categories of the counterparties – net
Dec 31, 2024¹ | ||||||||||||||||
in € m. (unless stated otherwise) | Loans | Off-balance sheet | OTC derivatives | |||||||||||||
Rating band | Probability of default in %2 | at amortized cost | trading - at fair value through P&L | Designated/ mandatory at fair value through P&L | at fair value through OCI | Revocable and irrevo- cable lending commitments | Contingent liabilities | at fair value through P&L | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 10,671 | 99 | 84 | 64 | 26,953 | 5,128 | 4,893 | ||||||||
iA | > 0.04 ≤ 0.11 | 36,198 | 60 | 392 | 953 | 67,092 | 29,677 | 4,140 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 30,736 | 2,869 | 56 | 1,836 | 82,049 | 17,106 | 2,948 | ||||||||
iBB | > 0.5 ≤ 2.27 | 27,152 | 4,122 | 480 | 520 | 30,381 | 4,366 | 1,889 | ||||||||
iB | > 2.27 ≤ 10.22 | 6,049 | 503 | 189 | 10 | 8,258 | 1,290 | 103 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 4,285 | 1,570 | 57 | 55 | 2,127 | 348 | 96 | ||||||||
Total | 115,091 | 9,223 | 1,258 | 3,438 | 216,860 | 57,915 | 14,069 | |||||||||
Dec 31, 2024¹ | ||||||||||||||||
in € m. (unless stated otherwise) | Debt Securities | Repo and repo-style transactions | ||||||||||||||
Ratingband | Probability of default in %2 | at amortized cost | at fair value through P&L | at fair value through OCI | at amortized cost | at fair value through P&L | at fair value through OCI | Total | ||||||||
iAAA–iAA | > 0.00 ≤ 0.04 | 694 | 64,254 | 192 | 7 | 261 | — | 113,301 | ||||||||
iA | > 0.04 ≤ 0.11 | 2,469 | 14,985 | 46 | 106 | 13 | — | 156,131 | ||||||||
iBBB | > 0.11 ≤ 0.5 | 562 | 19,756 | 136 | 6 | 35 | — | 158,096 | ||||||||
iBB | > 0.5 ≤ 2.27 | 860 | 21,684 | 334 | — | 1,087 | — | 92,874 | ||||||||
iB | > 2.27 ≤ 10.22 | 20 | 537 | 362 | — | — | — | 17,321 | ||||||||
iCCC and below | > 10.22 ≤ 100 | 42 | 711 | 47 | — | — | — | 9,338 | ||||||||
Total | 4,647 | 121,927 | 1,117 | 119 | 1,396 | — | 547,060 | |||||||||
1Net of eligible collateral, guarantees and hedges based on IFRS requirements
2Reflects the probability of default for a one year time horizon
The above tables show an overall increase in the Corporate Bank and Investment Bank gross exposure in 2025 of
€ 32.7 billion or 4%. Repo and repo-style transactions increased by € 4.8 billion, mainly driven by increased firm trading
activities and client flows. From a regional perspective, the increase was primarily attributable to counterparties
domiciled in the United Kingdom and U.S. Off-balance sheet positions increased by €10.5 billion, mainly driven by new
commitments issued during the period. Loans increased by € 10.5 billion, primarily in the Investment Bank. Debt
Securities increased by € 8.9 billion, mainly due to client flows and desk positioning and decrease in OTC Derivatives of
€ 1.9 billion was primarily due to decrease in foreign exchange derivatives products.
The Group uses risk mitigation techniques as described above to optimize Corporate Bank and Investment Bank credit
exposures and reduce potential credit losses. The tables for “net” exposure disclose the development of the bank’s
Corporate Bank and Investment Bank credit exposures net of collateral, guarantees and hedges.
Risk Mitigation for Credit Exposure
Strategic Corporate Lending (“SCL”) unit helps to mitigate the risk of the bank’s corporate credit exposures. The notional
amount of SCL’s risk reduction activities increased from € 43.2 billion as of December 31, 2024, to € 54.4 billion as of
December 31, 2025. As of year-end 2025, SCL mitigated the credit risk of € 49.9 billion of loans and lending-related
commitments, through significant risk transfer. This position totalled € 38.4 billion as of December 31, 2024.
SCL also managed credit derivatives with an underlying notional amount of € 4.5 billion as of December 31, 2025. The
position totalled € 4.7 billion as of December 31, 2024. The credit derivatives used for the bank’s portfolio management
activities are accounted for at fair value.
The bank makes use of hedging also in other businesses to reduce single name concentration risks and utilizes private risk
insurance and export credit agency cover to manage noncollateralized exposures.
147
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Private Bank credit exposure
Private Bank credit exposure, credit exposure in stage 3 and net credit costs
Total exposure in € m. | of which loan book in € m. | Credit exposure stage 3 in € m. | Net credit costs as a % of total exposure¹ | |||||||||||||
Dec 31, 2025 | Dec 31, 2024 | Dec 31, 2025 | Dec 31, 2024 | Dec 31, 2025 | Dec 31, 2024 | Dec 31, 2025 | Dec 31, 2024 | |||||||||
Consumer Finance | 39,413 | 40,098 | 25,414 | 25,571 | 1,994 | 1,689 | 0.93% | 1.26% | ||||||||
Mortgages | 155,424 | 162,057 | 153,275 | 159,510 | 2,026 | 2,212 | 0.02% | 0.09% | ||||||||
Business Finance | 15,192 | 15,878 | 11,585 | 12,420 | 1,112 | 1,058 | 0.61% | 0.63% | ||||||||
Wealth Management | 76,916 | 79,592 | 56,283 | 59,894 | 2,197 | 3,134 | 0.11% | 0.13% | ||||||||
Other | 430 | 583 | 36 | 81 | — | 24 | 0.55% | (0.01)% | ||||||||
Total | 287,375 | 298,209 | 246,594 | 257,476 | 7,328 | 8,118 | 0.23% | 0.29% | ||||||||
1Net credit costs for the twelve months period ended at the respective balance sheet date divided by the total exposure at that balance sheet date
Consumer Finance is divided into personal installment loans, credit lines and credit cards. Consumer Finance business is
uncollateralized, loan risk depends on client quality. Various lending requirements are stipulated, including (but not
limited to) client rating, maximum loan amounts and maximum tenors, and are adapted to individual circumstances of
the borrower (i.e., for consumer loans maximum loan amount and maximum tenor taking into account amongst others
customer net income). Given the largely homogeneous nature of this portfolio, counterparty credit-worthiness and
ratings are derived by utilizing an automated decision engine.
Mortgage business is financing of real estates with focus on residential properties (primarily owner-occupied) sold by
various business channels in Europe, primarily in Germany but also in Spain and Italy. The level of credit risk of the
mortgage loan portfolio is determined by assessing the quality of the client and the underlying collateral. The loan
amounts are generally larger than Consumer Finance loans and they are extended for longer time horizons. Based on the
bank’s underwriting criteria and processes and the diversified portfolio (customers/properties) with respective
collateralization, the mortgage portfolio is categorized as lower risk, while consumer finance is categorized as high risk.
Business Finance represents credit products for small businesses, SME up to large corporates. Products range from
current accounts and credit lines to investment loans or revolving facilities, factoring, leasing and derivatives. Clients are
located primarily in Italy and Spain, but credit can also be extended to subsidiaries abroad, mostly in Europe.
Wealth Management offers globally customized wealth management solutions and private banking services including
discretionary portfolio management and traditional and alternative investment solutions, complemented by structured
risk management, wealth planning, lending and family office services for wealth, high-net-worth (HNW) and ultra-high-
net-worth (UHNW) individuals and family offices. Wealth Management’s total exposure is divided into Lombard Lending
(against readily marketable liquid collateral/securities) and Structured Lending (against less liquid collateral). While the
level of credit risk for the Lombard portfolio is determined by assessing the quality of the underlying collateral, the level
of credit risk for the structured portfolio is determined by assessing both the quality of the client and the collateral.
Products range from secured Lombard and mortgage loans to current accounts (Europe only), credit lines and other
loans; to a lesser extent derivatives and contingencies.
Private Bank mortgage loan-to-value1
Dec 31, 2025 | Dec 31, 2024 | |||
≤ 50% | 66% | 65% | ||
> 50 ≤ 70% | 16% | 16% | ||
> 70 ≤ 90% | 10% | 10% | ||
> 90 ≤ 100% | 3% | 3% | ||
> 100 ≤ 110% | 2% | 2% | ||
> 110 ≤ 130% | 1% | 2% | ||
> 130% | 1% | 1% |
1When assigning the exposure to the corresponding LTV buckets, the exposure amounts are distributed according to their relative share of the underlying assessed real
estate value
The LTV expresses the amount of exposure as a percentage of the underlying real estate value.
The Group’s LTV ratios are calculated using the total exposure divided by the current determined value of the respective
properties. These values are monitored and updated if necessary, on a regular basis. The exposure of transactions that
are additionally backed by liquid collateral is reduced by the respective collateral values, whereas any prior charges
increase the corresponding total exposure. The LTV calculation includes exposure which is secured by real estate
collateral. Any mortgage lending exposure that is collateralized exclusively by any other type of collateral is not included
in the LTV calculation.
148
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
The creditor’s creditworthiness, the LTV and the quality of collateral is an integral part of the Group’s risk management
when originating loans and when monitoring and steering the Group’s credit risks. In general, the Group is willing to
accept higher LTV’s, the better the creditor’s creditworthiness is. Nevertheless, restrictions of LTV apply e.g., for
countries with negative economic outlook or expected declines of real estate values.
As of December 31, 2025, 66% of the Group’s exposure related to the mortgage lending portfolio had an LTV ratio below
or equal to 50% compared to 65% as of December 31, 2024.
As mentioned in the Key risk themes section, Deutsche Bank has identified commercial real estate and climate risk as
focus areas of the Group in 2025.
Commercial Real Estate
Commercial Real Estate (CRE) markets continue to face headwinds due to the impacts of higher interest rates, reduced
market liquidity attached to tightened lending conditions, and structural changes in the office sector. The market stress
has been more pronounced in the U.S. where property price indices show a more substantial decline of CRE asset values
from recent peaks, compared to Europe and APAC. Especially within the office segment, the market weakness is most
evident in the U.S., reflected in subdued leasing activity and higher vacancy rates compared to Europe. Recent market
data indicate stabilization in some markets.
In the current environment, the main risk for the portfolio is related to refinancing and extension of maturing loans which
is negatively affected by the impact of higher interest rates on collateral values and debt service. CRE loans often have a
significant portion of principal payable at maturity. Under current market conditions, borrowers may have difficulty
obtaining a new loan to repay the maturing debt or to meet conditions that allow extension of loans. This risk is further
amplified for loans in the office segment due to increased uncertainty about letting prospects for office properties.
Deutsche Bank is closely monitoring the CRE portfolio for development of such risks.
The Group continues to proactively work with borrowers to address upcoming maturities to establish terms for loan
amendments and extensions, which in many cases, are classified as forbearance triggering Stage 2 classification under
IFRS 9 but are not always deemed modifications under IFRS (please see modification of financial assets and financial
liabilities section). However, in certain cases, no agreement can be reached on loan extensions or loan amendments and
the borrower’s inability to restructure or refinance leads to a default. This has resulted in higher Stage 3 ECL’s in 2024
and 2025. Overall, uncertainty remains with respect to future defaults and the timing of a full recovery in the CRE
markets.
The CRE portfolio consists of lending arrangements originated across various parts of the bank and client segments. The
CRE portfolio under the Group’s CRE definition includes exposures reported under the Main Credit Exposure Categories
by Industry Sectors for Real Estate Activities NACE and exposures reported under other NACE classifications including
Financial and Insurance Activities.
Within the CRE portfolio, the Group differentiates between recourse and non-recourse financing. Recourse CRE
financings typically have a lower inherent risk profile based on recourse to creditworthy entities or individuals, in addition
to mortgage collateral. Recourse CRE exposures range from secured recourse lending for business or commercial
properties to property companies, Wealth Management clients, as well as other private and corporate clients.
Non-recourse financings rely on sources of repayment that are typically limited to the cash flows generated by the
financed property and the ability to refinance such loans may be constrained by the underlying property value and
income stream generated by such property at the time of refinancing.
The entire CRE loan portfolio is subject to periodic stress testing under Deutsche Bank’s Group Wide Stress Test
Framework. In addition, Deutsche Bank uses bespoke portfolio stress testing for certain sub-segments of the CRE loan
portfolio to obtain a more comprehensive view of potential downside risks. For the year ending December 31, 2025Group
performed a bespoke portfolio stress test on a subset of the non-recourse financing portfolio deemed higher risk based
on its heightened sensitivity to current CRE market stress factors, including higher interest rates, declining collateral
values and elevated refinancing risk due to loan structures with a high proportion of their outstanding principal balance
payable at maturity.
149
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
As of December 31, 2025, the non-recourse portfolio subject to bespoke portfolio stress testing, also referred to as the
higher risk CRE portfolio or the stress-tested CRE portfolio, amounted to € 24.3 billion of the € 30.6 billion non-recourse
CRE portfolio, excluding sub-portfolios with less impacted risk drivers, which benefit from strong underlying demand
fundamentals. The reduction in the non-recourse CRE portfolio and stress-tested CRE portfolio since December 31,
2024 was € 5.9 billion and € 5.0 billion, respectively, mainly driven by loan repayments , loan sales and FX impact partially
offset by new loan originations. Allowance for credit losses as per December 31, 2025 amounted to € 1.1 billion for the
non-recourse and € 903 million for the stress-tested CRE portfolios (December 31, 2024 € 795 million and € 653 million
respectively).
The following table shows the stress-tested CRE portfolio by IFRS 9 stages, region, property type and average weighted loan to
value (LTV) as well as provision for credit losses recorded for the year ended December 31, 2025, and December 31, 2024,
respectively.
Dec 31, 2025 | Dec 31, 2024 | |||
in € m. | Gross Carrying Amount1 | Gross Carrying Amount1 | ||
Exposure by stages | ||||
Stage 1 | ||||
Stage 2 | ||||
Stage 3 | ||||
Total | ||||
thereof: | ||||
Forborne exposure | ||||
thereof: | ||||
North America | ||||
Western Europe (including Germany) | ||||
Asia/Pacific | ||||
thereof: offices | ||||
North America | ||||
Western Europe (including Germany) | ||||
Asia/Pacific | ||||
thereof: residential | ||||
thereof: hospitality | ||||
thereof: retail | ||||
Weighted average LTV, in % | ||||
Investment Bank | ||||
Corporate Bank | ||||
Other Business | ||||
2025 | 2024 | |||
Allowance for Credit Losses4 | ||||
Provision for Credit Losses4 | ||||
thereof: North America | ||||
1 Loans at amortized cost
2 Germany accounts for approximately 9 % of the total stress-tested CRE portfolio
3 Office loans in Germany account for 14 % of total office loans in the stress-tested CRE portfolio
4Allowance for Credit Losses and Provision for Credit Losses do not include country risk provisions
The average LTV in the U.S. office loan segment increased from 81 % as of December 31, 2024 to 88 % as of December 31,
2025, in part due to repayments of some larger exposures. LTV calculations are based on latest externally appraised
values which are additionally subject to regular interim internal adjustments. While the Group is updating CRE collateral
values where applicable, such values and their underlying assumptions are subject to a higher degree of fluctuation and
uncertainty in the current environment of heightened market volatility and reduced market liquidity.
150
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Stage classification and provisioning levels are primarily based on the Group’s assessment of a borrower’s ability to
generate recurring cash flows, its ability to obtain refinancing at the loan’s maturity, and an assessment of the financed
property’s collateral value. Deutsche Bank actively monitors these factors for potential signs of deterioration to ensure
timely adjustment of the borrower’s loan classifications. When a loan is deemed to be impaired, the Group calculates
required credit loss provisions using multiple potential scenarios for loan resolution, weighted by their expected
probabilities and taking into account information available at that point. Such assessments are inherently subjective with
respect to scenario weightings and subject to various assumptions, including future cash flows generated by a property
and potential property liquidation proceeds. These assumptions are subject to uncertainties which are exacerbated in the
current volatile market environment such that deviating developments to initial assumptions could have a material
future impact on calculated provisions. Additional uncertainty exists within the office sector due to the uncertain long-
term impact of remote working arrangements on demand for office space. The Group remains highly selective around
new business, focusing on more attractive property types such as multi-family in particular sub-markets.
While central banks have started to cut short-term interest rates, the Group expects current CRE market conditions to
continue, in the near-term particularly in the office sector which could result in further deterioration of asset quality and
elevated credit loss provisions.
Since the onset of the CRE market deterioration, the Group aims to assess the downside risk of additional credit losses in
its higher risk non-recourse portfolio through a temporary bespoke stress testing focused on examining property values
movements as basis of to identify potential losses on a portfolio basis. Stressed values are derived by applying an
observed peak-to-trough market index decline (a commercial property value market index) to the appraised values
reduced by an additional haircut, differentiated by property type and region. Implying a liquidation scenario, the stress
analysis assumes a loss to occur on a loan when the stressed property value is less than the outstanding loan balance, i.e.,
the stress LTV beyond 100 %.
Based on the stress test assumptions, utilizing the stress-tested CRE portfolio and most current risk data as of
December 31, 2025, as a starting point, macro-economic stress could result in a severe stress scenario of
approximately € 1.2 billion of credit losses, over multiple years based on the respective maturity profile. The allowance
recorded against the stress tested portfolio was € 0.9 billion as of December 31, 2025.
The bespoke stress test has numerous limitations, including but not restricted to lack of differentiation based on
individual asset performance, specific location or asset desirability, all of which could have a material impact on potential
stress losses. Furthermore, calculated stress losses are sensitive to potential further deterioration of peak-to-trough
index values and assumptions about incremental haircuts and incremental stress loss can therefore change in future.
Changes in underlying assumptions could lead to a wider range of stress results and hence the Group's bespoke stress
approach should be viewed as one of multiple possible scenarios. While the stress test aims to assess potential losses in
an adverse scenario, Deutsche Bank believes that based on currently available information, the ECL estimate related to
the Group’s CRE portfolio is within a reasonable range and thus represents the bank’s best estimate, considering the
advanced stage of the current down cycle which is pointing towards stabilization as real estate values have adjusted to
the shocks from higher interest rates and remote working trends.
Climate Risk
Background and definitions
Climate transition and physical risks present growing risks to the bank’s sectoral and regional portfolios.
Transition risks, defined as the risks arising from the policy, technology and behavioral changes needed to decarbonize
the global economy, are expected to lead to a progressive shift away from fossil fuel-based technologies in favor of
renewable energy sources. This will generate increased risks for companies with carbon intensive business models who
are unable to execute on credible transition plans. Deutsche Bank is exposed to transition risks via its lending to, and
other business activities with, carbon intensive clients and physical assets.
Physical risks, defined as the potential for physical damage and associated financial and non-financial losses due to rising
temperatures, are increasing in frequency and intensity. Deutsche Bank is exposed to physical risks via its lending to, and
other business activities with, clients and physical assets in regions which are vulnerable to acute events (e.g., wildfires,
hurricanes) and chronic events (e.g., rising sea levels).
151
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Risk identification, assessment and management.
A comprehensive climate materiality assessment is performed on an annual basis which assesses potential impacts
across a range of scenarios and timeframes. The assessment utilizes a range of quantitative estimation approaches
including emissions and emission intensity estimates, physical risk loss estimates across a range of different temperature
scenarios and client transition and physical risk scorecards. The materiality assessment is based on internal ratings
migration for corporate lending exposures and the impact on collateral value for real estate exposures. The quantitative
assessment is supplemented by qualitative views from internal subject matter experts. The bank also conducts annual
stress testing of climate and physical risks across a range of scenarios and timeframes.
The results of these assessments are utilized to quantify potential downside risks and to identify clients in higher risk
portfolios which are subject to enhanced due diligence as part of the bank’s credit approval process. Risk assessments
are integrated into the internal credit rating process and are considered as potential triggers for inclusion in the
Watchlist. Dedicated requirements for insurance arrangements are in place for real estate lending. To manage climate
transition risks, net zero targets have been established for key carbon intensive sectors with dedicated governance in
place to review transactions with a significant impact on target metrics. A detailed presentation and discussion of the
bank’s net zero targets is provided in the Bank’s updated Transition Plan published in August 2025.
Forward-looking impact analysis
Based on the 2025 materiality assessment and climate stress test results the Group concludes that potential credit risk
impacts are well-contained in both the short (1-2yr) and medium term (3-5yr) under current policy assumptions, and also
in a scenario where all stated pledges by governments are enforced. The former scenario is considered most likely to
occur in the short-to-medium term, that latter scenario is considered less likely to materialize in the current geopolitical
environment.
The 2025 materiality assessment concludes that long-term risks are potentially material across all scenarios but with a
high degree of uncertainty over the results reflecting the very long time frame, up to 25 years, and based on several
conservative assumptions including a static balance sheet.
Risks to the portfolio would be significantly higher in a disorderly net zero scenario where following a prolonged period of
inaction governments introduced punitive climate taxes and other policies with a very short implementation period.
Deutsche Bank considers this scenario to be extremely unlikely to materialize in the short to medium term and thus the
risk is reflected in Deutsche Bank´s Economic Capital calculation rather than ECL.
Both the materiality assessment and bespoke climate stress test have several limitations including but not limited to high
levels of uncertainty on policy developments over the medium-to-long term, difficulty with precisely forecasting the
location and severity of physical risk events and assumptions around the adaptive capabilities of the bank´s clients.
Utilization of multiple scenarios is designed to mitigate these uncertainties.
Based on these estimates Deutsche Bank believes that ECL estimates for higher transition and physical risk exposures are
within reasonable ranges and require no additional corrective measure.
A sensitivity analysis has been undertaken as part of the climate stress test that is based on reasonable ranges of
potential variation for carbon prices and energy prices. The stressed ECL impacts at a one-year horizon were found to be
from a single digit number for a current policies scenario to a low 2-digit figure for a Delayed Transition scenario. These
estimations are aligned with the outputs of the materiality assessment.
Conclusion
To ensure that Deutsche Bank’s expected credit losses (ECL) model was taking into account the uncertainties in the
macroeconomic environment throughout 2025, the Group reviewed emerging risks to assess its potential downside and
to manage the bank’s credit strategy and risk appetite on an ongoing basis. Overall, Deutsche Bank believes the actions
taken as a result of these reviews were designated to ensure the bank was adequately provisioned for its expected credit
losses as of December 31, 2025.
152
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Asset Quality
This section describes the quality of debt instruments subject to impairment, which under IFRS 9 consist of debt
instruments measured at amortized cost, financial instruments at fair value through other comprehensive income
(FVOCI) as well as off balance sheet lending commitments such as loan commitments and financial guarantees (hereafter
collectively referred to as “Financial Assets”).
The following tables provide an overview of the exposure amount and allowance for credit losses by financial asset class
broken down into stages as per IFRS 9 requirements.
Dec 31, 2025 | Dec 31, 2024 | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Amortized cost¹ | ||||||||||||||||||||
Gross carrying amount | ||||||||||||||||||||
Allowance for credit losses² | ||||||||||||||||||||
of which Loans | ||||||||||||||||||||
Gross carrying amount | ||||||||||||||||||||
Allowance for credit losses² | ||||||||||||||||||||
Fair value through OCI | ||||||||||||||||||||
Fair value | ||||||||||||||||||||
Allowance for credit losses | ||||||||||||||||||||
Off-balance sheet | ||||||||||||||||||||
Notional amount | ||||||||||||||||||||
Allowance for credit losses³ | ||||||||||||||||||||
1 Financial assets at amortized cost consist of: loans at amortized cost, cash and central bank balances, interbank balances (w/o central banks), central bank funds sold and
securities purchased under resale agreements, securities borrowed and certain subcategories of other assets
2 Allowance for credit losses do not include allowance for country risk amounting to € 7 million as of December 31, 2025 and € 14 million as of December 31, 2024
3 Allowance for credit losses do not include allowance for country risk amounting to € 12 million as of December 31, 2025 and € 2 million as of December 31, 2024
153
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Financial assets at amortized cost
The following tables provide an overview of development of financial assets at amortized cost and related allowance for
credit losses in each of the relevant reporting periods broken down into stages as per IFRS 9 requirements.
Dec 31, 2025 | ||||||||||
Gross carrying amount | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | |||||
Balance, beginning of year | ||||||||||
Movements in financial assets including new business and credit extensions | ||||||||||
Transfers due to changes in creditworthiness | ( | — | ||||||||
Changes due to modifications that did not result in derecognition | ( | ( | ||||||||
Changes in models | N/M | N/M | N/M | N/M | N/M | |||||
Financial assets that have been derecognized during the period | ( | ( | ( | ( | ( | |||||
Recovery of written off amounts | ||||||||||
Foreign exchange and other changes | ( | ( | ( | ( | ||||||
Balance, end of reporting period | ||||||||||
N/M – Not meaningful
Financial assets at amortized cost subject to impairment increased primarily in Stage 1 in 2025:
Stage 1 exposures increased by € 46 billion or 7 %, primarily due to an increase in cash and central bank balances and
securities purchased as a part of Bank’s asset purchase program initiative to expand portfolio of European government
bonds.
Stage 2 exposures went down by € 10 billion or 16 % mainly due to stage upgrade from Stage 2 to stage 1 for a single
large client in Asia Pacific and a decrease in Private Bank.
Stage 3 exposures decreased by € 0.3 billion or 2 % in 2025, primarily due to decrease in Private Bank. This decrease has
been partially offset by an increase in CRE Portfolio within Investment Bank.
Dec 31, 2024 | ||||||||||
Gross carrying amount | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | |||||
Balance, beginning of year | ||||||||||
Movements in financial assets including new business and credit extensions | ( | |||||||||
Transfers due to changes in creditworthiness | ( | N/M | ||||||||
Changes due to modifications that did not result in derecognition | ( | ( | ||||||||
Changes in models | N/M | N/M | N/M | N/M | N/M | |||||
Financial assets that have been derecognized during the period | ( | ( | ( | ( | ( | |||||
Recovery of written off amounts | ||||||||||
Foreign exchange and other changes | ||||||||||
Balance, end of reporting period | ||||||||||
N/M – Not meaningful
Financial assets at amortized cost subject to impairment slightly decreased by € 1 billion in 2024, driven by stage 1:Stage
1 exposures decreased by € 11 billion or 2 %, primarily due to a reduction in cash and central bank balances partly offset
by an increase in securities purchased under resale agreements.
Stage 2 exposures went up by € 8 billion or 15 % mainly due to a large single client in Corporate & Other and an increase
in Private Bank mainly driven by residual temporary impacts following the Postbank integration.
Stage 3 exposures increased by € 2 billion or 16 % in 2024, mainly driven by new defaults in Private Bank and Corporate &
Other. The latter were related to the CRE portfolio.
154
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Dec 31, 2025 | ||||||||||
Allowance for Credit Losses² | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI⁴ | Total | |||||
Balance, beginning of year | ||||||||||
Movements in financial assets including new business and credit extensions | ( | |||||||||
Transfers due to changes in creditworthiness | ( | ( | N/M | |||||||
Changes due to modifications that did not result in derecognition | N/M | N/M | N/M | N/M | N/M | |||||
Changes in models5 | ( | ( | ( | |||||||
Financial assets that have been derecognized during the period³ | ( | ( | ||||||||
Recovery of written off amounts | ||||||||||
Foreign exchange and other changes | ( | ( | ( | |||||||
Balance, end of reporting period | ||||||||||
Provision for Credit Losses excluding country risk¹ | ( | |||||||||
N/M – Not meaningful
1 Movements in financial assets including new business, transfers due to changes in creditworthiness and changes in models add up to Provision for Credit Losses excluding country risk
2 Allowance for credit losses does not include allowance for country risk amounting to € 7 million as of December 31, 2025
3 This position represents charge offs of allowance for credit losses
4 The total amount of undiscounted expected credit losses at initial recognition on financial assets that are purchased or originated credit-impaired initially recognized
during the reporting period was € 74 million in 2025 and € — million in 2024
5 Changes in models primarily reflect LGD model update and changes to the SICR model
Allowance for credit losses for financial assets at amortized cost subject to impairment went up by € 358 million or 6 % in
2025, largely driven by Stage 3:
Stage 1 allowances decreased by € 16 million or 4 % mainly driven by Private Bank due to exposure reduction which has
been partially offset by increases in Corporate Bank and Investment Bank.
Stage 2 allowances increased by € 152 million or 21 % largely due to Private Bank and Investment Bank.
Stage 3 allowances went up by € 222 million or 5 % in 2025, driven by additional charges in the CRE portfolio within
Investment Bank and an increase in Personal Banking within Private Bank.
The Group’s Stage 3 coverage ratio (defined as allowance for credit losses in Stage 3 (excluding POCI) as a percentage of
financial assets at amortized cost in Stage 3 (excluding POCI)) amounted to 31 % in the current fiscal year, compared to
Dec 31, 2024 | ||||||||||
Allowance for Credit Losses² | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI⁴ | Total | |||||
Balance, beginning of year | ||||||||||
Movements in financial assets including new business and credit extensions | ( | |||||||||
Transfers due to changes in creditworthiness | ( | N/M | ||||||||
Changes due to modifications that did not result in derecognition | N/M | N/M | N/M | N/M | N/M | |||||
Changes in models | ( | ( | ( | |||||||
Financial assets that have been derecognized during the period³ | ( | ( | ||||||||
Recovery of written off amounts | ||||||||||
Foreign exchange and other changes | ( | ( | ( | |||||||
Balance, end of reporting period | ||||||||||
Provision for Credit Losses excluding country risk¹ | ( | |||||||||
N/M – Not meaningful
1 Movements in financial assets including new business, transfers due to changes in creditworthiness and changes in models add up to Provision for Credit Losses excluding
country risk
2 Allowance for credit losses does not include allowance for country risk amounting to € 14 million as of December 31, 2024
3 This position represents charge offs of allowance for credit losses
4 The total amount of undiscounted expected credit losses at initial recognition on financial assets that are purchased or originated credit-impaired initially recognized
during the reporting period was € — million in 2024 and € — million in 2023
155
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Allowance for credit losses for financial assets at amortized cost subject to impairment went up by € 513 million or 10 %
in 2024, driven by stage 3:
Stage 1 allowances decreased by € 9 million or 2 % mainly driven by Private Bank due to exposure reduction and almost
offset by increases in Corporate Bank and Investment Bank.
Stage 2 allowances increased by € 56 million or 8 % largely due to Private Bank and Corporate Bank.
Stage 3 allowances went up by € 466 million or 11 % in 2024, driven by additional charges in the CRE portfolio and in
Corporate Bank as well as new defaults in Private Bank. The latter were offset to a large extent by non-performing loans
sales.
The Group’s stage 3 coverage ratio (defined as allowance for credit losses in stage 3 (excluding POCI) as a percentage of
financial assets at amortized cost in stage 3 (excluding POCI)) amounted to 29 % in the current fiscal year, compared to
Dec 31, 2025 | ||||||||||||||||||||
Gross Carrying Amount¹ | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Corporate Bank | ( | |||||||||||||||||||
Investment Bank | ||||||||||||||||||||
Private Bank | ||||||||||||||||||||
Asset Management | ||||||||||||||||||||
Corporate & Other | ||||||||||||||||||||
Total | ||||||||||||||||||||
1 Gross Carrying Amount numbers per business division are reported after a reallocation of cash balances from business divisions to Corporate & Other
Dec 31, 2024 | ||||||||||||||||||||
Gross Carrying Amount¹ | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Corporate Bank | ||||||||||||||||||||
Investment Bank | ||||||||||||||||||||
Private Bank | ||||||||||||||||||||
Asset Management | ||||||||||||||||||||
Corporate & Other | ||||||||||||||||||||
Total | ||||||||||||||||||||
1 Gross Carrying Amount numbers per business division are reported after a reallocation of cash balances from business divisions to Corporate & Other
156
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
The below table provides an overview of the Group’s asset quality by industry and is based on the NACE code of the
counterparty. NACE (Nomenclature des Activités Économiques dans la Communauté Européenne) is a standard
European industry classification system.
Dec 31, 2025 | ||||||||||||||||||||
Gross Carrying Amount | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Agriculture, forestry and fishing | ||||||||||||||||||||
Mining and quarrying | ||||||||||||||||||||
Manufacturing | ||||||||||||||||||||
Electricity, gas, steam and air conditioning supply | ||||||||||||||||||||
Water supply, sewerage, waste management and remediation activities | ||||||||||||||||||||
Construction | ||||||||||||||||||||
Wholesale and retail trade, repair of motor vehicles and motorcycles | ||||||||||||||||||||
Transport and storage | ||||||||||||||||||||
Accommodation and food service activities | ||||||||||||||||||||
Information and communication | ||||||||||||||||||||
Financial and insurance activities | ||||||||||||||||||||
Real estate activities | ||||||||||||||||||||
Professional, scientific and technical activities | ||||||||||||||||||||
Administrative and support service activities | ||||||||||||||||||||
Public administration and defense, compulsory social security | ||||||||||||||||||||
Education | ||||||||||||||||||||
Human health services and social work activities | ||||||||||||||||||||
Arts, entertainment and recreation | ||||||||||||||||||||
Other service activities | ||||||||||||||||||||
Activities of households as employers, undifferentiated goods- and services-producing activities of households for own use | ||||||||||||||||||||
Activities of extraterritorial organizations and bodies | ||||||||||||||||||||
Total | ||||||||||||||||||||
157
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Dec 31, 2024 | ||||||||||||||||||||
Gross Carrying Amount | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Agriculture, forestry and fishing | ||||||||||||||||||||
Mining and quarrying | ||||||||||||||||||||
Manufacturing | ||||||||||||||||||||
Electricity, gas, steam and air conditioning supply | ||||||||||||||||||||
Water supply, sewerage, waste management and remediation activities | ||||||||||||||||||||
Construction | ||||||||||||||||||||
Wholesale and retail trade, repair of motor vehicles and motorcycles | ||||||||||||||||||||
Transport and storage | ||||||||||||||||||||
Accommodation and food service activities | ||||||||||||||||||||
Information and communication | ||||||||||||||||||||
Financial and insurance activities | ||||||||||||||||||||
Real estate activities | ||||||||||||||||||||
Professional, scientific and technical activities | ||||||||||||||||||||
Administrative and support service activities | ||||||||||||||||||||
Public administration and defense, compulsory social security | ||||||||||||||||||||
Education | ||||||||||||||||||||
Human health services and social work activities | ||||||||||||||||||||
Arts, entertainment and recreation | ||||||||||||||||||||
Other service activities | ||||||||||||||||||||
Activities of households as employers, undifferentiated goods- and services- producing activities of households for own use | ||||||||||||||||||||
Activities of extraterritorial organizations and bodies | ||||||||||||||||||||
Total | ||||||||||||||||||||
158
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Dec 31, 2025 | ||||||||||||||||||||
Gross Carrying Amount | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Germany | ( | |||||||||||||||||||
Western Europe (excluding Germany) | ||||||||||||||||||||
Eastern Europe | ||||||||||||||||||||
North America | ||||||||||||||||||||
Central and South America | ||||||||||||||||||||
Asia/Pacific | ||||||||||||||||||||
Africa | ||||||||||||||||||||
Other | ||||||||||||||||||||
Total | ||||||||||||||||||||
Dec 31, 2024 | ||||||||||||||||||||
Gross Carrying Amount | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Germany | ( | |||||||||||||||||||
Western Europe (excluding Germany) | ||||||||||||||||||||
Eastern Europe | ||||||||||||||||||||
North America | ||||||||||||||||||||
Central and South America | ||||||||||||||||||||
Asia/Pacific | ( | |||||||||||||||||||
Africa | ||||||||||||||||||||
Other | ||||||||||||||||||||
Total | ||||||||||||||||||||
Dec 31, 2025 | ||||||||||||||||||||
Gross Carrying Amount | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
iAAA–iAA | ||||||||||||||||||||
iA | ||||||||||||||||||||
iBBB | ||||||||||||||||||||
iBB | ||||||||||||||||||||
iB | ||||||||||||||||||||
iCCC and below | ||||||||||||||||||||
Total | ||||||||||||||||||||
Dec 31, 2024 | ||||||||||||||||||||
Gross Carrying Amount | Allowance for Credit Losses | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
iAAA–iAA | ||||||||||||||||||||
iA | ||||||||||||||||||||
iBBB | ||||||||||||||||||||
iBB | ||||||||||||||||||||
iB | ||||||||||||||||||||
iCCC and below | ||||||||||||||||||||
Total | ||||||||||||||||||||
159
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
The Group’s existing commitments to lend additional funds to debtors with stage 3 financial assets at amortized cost
amounted to € 903 million as of December 31, 2025 and € 710 million as of December 31, 2024.
Dec 31, 2025 | Dec 31, 2024 | |||||||||||
in € m. | Gross Carrying Amount | Collateral | Guarantees | Gross Carrying Amount | Collateral | Guarantees | ||||||
Financial Assets at Amortized Cost (Stage 3)1 | ||||||||||||
1 Stage 3 excluding POCI assets
In 2025, collateral and guarantees held against financial assets at amortized cost in Stage 3 decreased by € 0.3 billion, or
Due to full collateralization the Group did not recognize an allowance for credit losses against financial assets at
amortized cost in Stage 3 for € 1.8 billion in 2025 and € 1.6 billion in 2024.
Modified assets at amortized cost
A financial asset is considered modified when its contractual cash flows are renegotiated or otherwise modified.
Renegotiation or modification may or may not lead to derecognition of the old and recognition of the new financial
instrument. This section covers modified financial assets that have not been derecognized.
Under IFRS 9, when the terms of a financial asset are renegotiated or modified and the modification does not result in
derecognition, a gain or loss is recognized in the income statement as the difference between the original contractual
cash flows and the modified cash flows discounted at the original effective interest rate (EIR). For modified financial
assets the determination of whether the asset’s credit risk has increased significantly reflects the comparison of:
–The remaining lifetime probability of default (PD) at the reporting date based on the modified terms; with
–The remaining lifetime PD estimated based on data at initial recognition and based on the original contractual terms.
The following table provides the overview of modified financial assets at amortized cost broken down into IFRS 9 stages.
Dec 31, 2025 | Dec 31, 2024 | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | ||||||||||
Amortized cost carrying amount prior to modification | ||||||||||||||||||||
Net modification gain/losses recognized | ( | ( | ( | ( | ||||||||||||||||
In 2025, the bank has observed a decrease of € 291 million in modified assets at amortized cost due to client related
modifications, driven by Investment Bank and Private Bank.
In 2025, the Group has not observed any amounts of modified assets that have been upgraded to Stage 1. The bank has
not observed any subsequent re-deterioration of those assets into Stages 2 and 3.
In 2024, the Group has not observed any amounts of modified assets that have been upgraded to Stage 1. The bank has
not observed any subsequent re-deterioration of those assets into Stages 2 and 3.
Financial assets at fair value through other comprehensive income
The fair value of financial assets at fair value through other comprehensive income (FVOCI) subject to impairment under
IFRS 9 was € 44 billion at December 31, 2025, compared to € 42 billion at December 31, 2024. Allowance for credit
losses against these assets remained at very low levels (€ 48 million as of December 31, 2025 and € 38 million as of
December 31, 2024). Due to immateriality no further breakdown is provided for financial assets at FVOCI.
160
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Off-balance sheet lending commitments and guarantee business
The following tables provide an overview of the nominal amount and credit loss allowance for the Group’s off-balance
sheet financial asset class broken down into stages as per IFRS 9 requirements.
Dec 31, 2025 | ||||||||||
Nominal Amount | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | |||||
Balance, beginning of year | ||||||||||
Movements including new business | ||||||||||
Transfers due to changes in creditworthiness | ( | N/M | ||||||||
Changes in models | N/M | N/M | N/M | N/M | — | |||||
Foreign exchange and other changes | ( | ( | ( | ( | ||||||
Balance, end of reporting period | ||||||||||
of which: Financial guarantees | ||||||||||
N/M – Not meaningful
Development of nominal amount in the previous reporting period
Dec 31, 2024 | ||||||||||
Nominal Amount | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | |||||
Balance, beginning of year | ||||||||||
Movements including new business | ( | ( | ||||||||
Transfers due to changes in creditworthiness | ( | ( | N/M | |||||||
Changes in models | N/M | N/M | N/M | N/M | N/M | |||||
Foreign exchange and other changes | ||||||||||
Balance, end of reporting period | ||||||||||
of which: Financial guarantees | ||||||||||
N/M – Not meaningful
Dec 31, 2025 | ||||||||||
Allowance for Credit Losses2 | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | |||||
Balance, beginning of year | ||||||||||
Movements including new business | ( | |||||||||
Transfers due to changes in creditworthiness | ( | ( | N/M | |||||||
Changes in models | ||||||||||
Foreign exchange and other changes | ( | ( | ( | |||||||
Balance, end of reporting period | ||||||||||
of which: Financial guarantees | ||||||||||
Provision for Credit Losses excluding country risk1 | ( | |||||||||
N/M – Not meaningful
1 The above table breaks down the impact on provision for credit losses from movements in financial assets including new business, transfers due to changes in
creditworthiness and changes in models
2 Allowance for credit losses does not include allowance for country risk amounting to € 12 million as of December 31, 2025
161
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Development of allowance for credit losses in the previous reporting period
Dec 31, 2024 | ||||||||||
Allowance for Credit Losses2 | ||||||||||
in € m. | Stage 1 | Stage 2 | Stage 3 | Stage 3 POCI | Total | |||||
Balance, beginning of year | ||||||||||
Movements including new business | ( | ( | ( | |||||||
Transfers due to changes in creditworthiness | ( | N/M | ||||||||
Changes in models | ||||||||||
Foreign exchange and other changes | ( | |||||||||
Balance, end of reporting period | ||||||||||
of which: Financial guarantees | ||||||||||
Provision for Credit Losses excluding country risk1 | ( | ( | ( | ( | ||||||
N/M – Not meaningful
1 The above table breaks down the impact on provision for credit losses from movements in financial assets including new business, transfers due to changes in
creditworthiness and changes in models
2 Allowance for credit losses does not include allowance for country risk amounting to € 2 million as of December 31, 2024
Legal claims
Assets subject to enforcement activity consist of assets, which have been fully or partially written off and the Group still
continues to pursue recovery of the asset. Such enforcement activity comprises for example cases where the bank
continues to devote resources (e.g., Legal Department/CRM workout unit) towards recovery, either via legal channels or
third party recovery agents. Enforcement activity also applies to cases where the Bank maintains outstanding and
unsettled legal claims. This is irrespective of whether amounts are expected to be recovered and the recovery timeframe.
It may be common practice in certain jurisdictions for recovery cases to span several years.
Amounts outstanding on financial assets that were written off during the reporting period and are still subject to
enforcement activity amounted to € 277 million and € 222 million in 2025 and 2024 respectively, mainly in Investment
For economic or legal reasons the bank might enter into a forbearance agreement with a borrower who faces or will face
financial difficulties in order to ease the contractual obligation for a limited period of time. A case-by-case approach is
applied for corporate clients considering each transaction and client-specific facts and circumstances. For consumer
loans the bank offers forbearances for a limited period of time, in which the total or partial outstanding or future
installments are deferred to a later point of time. However, the amount not paid including accrued interest during this
period must be re-compensated at a later point of time. Repayment options include distribution over residual tenor, a
one-off payment or a tenor extension. Forbearances are restricted and depending on the economic situation of the
client, the Group’s risk management strategies and the local legislation. In case a forbearance agreement is entered into,
an impairment measurement is conducted as described below, an impairment charge is taken if necessary and the loan is
subsequently recorded as impaired.
In the Group’s management and reporting of forborne assets at amortized costs, the bank follows the EBA definition for
forbearances and non-performing loans (Implementing Technical Standards (ITS) on Supervisory reporting on
forbearance and non-performing exposures under article 99(4) of Regulation (EU) No 575/2013). Once the conditions
mentioned in the ITS are met, the Group reports the loan as being forborne; removes the asset from the bank’s
forbearance reporting, once the discontinuance criteria in the ITS are met (i.e., the contract is considered as performing, a
minimum two year probation period has passed, regular payments of more than an insignificant aggregate amount of
principal or interest have been made during at least half of the probation period, and none of the exposures to the debtor
is more than 30 days past-due at the end of the probation period).
162
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Dec 31, 2025 | Dec 31, 2024 | |||||||||||||||||||||||
Performing | Non-performing | Total | Performing | Non-performing | Total | |||||||||||||||||||
in € m. | Stage 1 | Stage 2 | Stage 1 | Stage 2 | Stage 3 | Stage 1 | Stage 2 | Stage 1 | Stage 2 | Stage 3 | ||||||||||||||
German | ||||||||||||||||||||||||
Non- German | ||||||||||||||||||||||||
Total | ||||||||||||||||||||||||
in € m. | Dec 31, 2025 | Dec 31, 2024 | ||
Balance beginning of period | ||||
Classified as forborne during the year | ||||
Transferred to non-forborne during the year (including repayments) | ( | ( | ||
Charge-offs | ( | ( | ||
Exchange rate and other movements | ( | |||
Balance end of period |
Forborne assets at amortized cost decreased by € 1.2 billion, or 8 % in 2025, largely driven by decrease in real estate
exposures within Investment Bank and Wealth Management and Personal Banking within Private Bank.
Forborne assets at amortized cost increased by € 2.9 billion, or 23 % in 2024. largely driven by real estate exposures
across various divisions.
The Group obtains collateral on the balance sheet only in certain cases by either taking possession of collateral held as
security or by calling upon other credit enhancements. Collateral obtained is made available for sale in an orderly fashion
or through public auctions, with the proceeds used to repay or reduce outstanding indebtedness. Generally, the bank
does not occupy obtained properties for its business use.
in € m. | 2025 | 2024 | ||
Commercial real estate | ||||
Residential real estate1 | ||||
Other | ||||
Total collateral obtained during the reporting period |
1 Carrying amount of foreclosed residential real estate properties amounted to € 19 million as of December 31, 2025 and €17 million as of December 31, 2024
Total collateral obtained of € 49 million during 2025 as well as € 254 million during 2024 primarily relate to a small
number of foreclosed commercial real estate properties in the US.
The collateral obtained, as shown in the table above, excludes collateral recorded as a result of consolidating
securitization trusts under IFRS 10. In 2025, the Group obtained € 47
Derivatives – Credit Valuation Adjustment
The bank establishes counterparty Credit Valuation Adjustment (CVA) for OTC derivative transactions to cover expected
credit losses. The adjustment amount is determined by assessing the potential credit exposure to a given counterparty
and taking into account any collateral held, the effect of any relevant netting arrangements, expected loss given default
and the credit risk, based on available market information, including CDS spreads.
Treatment of default situations under derivatives
Unlike standard loan assets, the bank generally has more options to manage the credit risk in its derivatives transactions
when movement in the current replacement costs or the behavior of its counterparty indicate that there is the risk that
upcoming payment obligations under the transactions might not be honored. In these situations, the bank is frequently
able under the relevant derivatives agreements to obtain additional collateral or to terminate and close-out the
derivative transactions at short notice.
163
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
The master agreements and associated collateralization agreements for OTC derivative transactions executed with its
clients typically result in the majority of its credit exposure being secured by collateral. It also provides for a broad set of
standard or bespoke termination rights, which allows the bank to respond swiftly to a counterparty’s default or to other
circumstances which indicate a high probability of failure.
The banks contractual termination rights are supported by internal policies and procedures with defined roles and
responsibilities which ensure that potential counterparty defaults are identified and addressed in a timely fashion. These
procedures include necessary settlement and trading restrictions. When its decision to terminate derivative transactions
results in a residual net obligation owed by the counterparty, the bank restructures the obligation into a non-derivative
claim and manage it through its regular work-out process. As a consequence, for accounting purposes the bank typically
does not show any nonperforming derivatives.
Wrong-way risk occurs when exposure to a counterparty is adversely correlated with the credit quality of that
counterparty. In compliance with Article 291(2) and (4) CRR the bank has a monthly process to monitor several layers of
wrong-way risk (specific wrong-way risk, general explicit wrong-way risk at country/industry/region levels and general
implicit wrong-way risk, whereby relevant exposures arising from transactions subject to wrong-way risk are
automatically selected and presented for comment to the responsible credit officer). A wrong-way risk report is then sent
to Credit Risk senior management on a monthly basis. In addition, the bank utilized its established process for calibrating
its own alpha factor (as defined in Article 284 (9) CRR) to estimate the overall wrong-way risk in its derivatives and
securities financing transactions portfolio. The Private Bank Germany’s derivative counterparty risk is immaterial to the
Group and collateral held is typically in the form of cash.
Credit Exposure from Derivatives
All exchange traded derivatives are cleared through central counterparties (“CCPs”), the rules and regulations of which
provide for daily margining of all current and future credit risk positions emerging out of such transactions. To the extent
possible, the bank also uses CCP services for OTC derivative transactions (“OTC clearing”); thereby the bank benefits
from the credit risk mitigation achieved through the CCP’s settlement system.
The Dodd-Frank Act provides for an extensive framework for the regulation of OTC derivatives, including mandatory
clearing, platform 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 Dodd-Frank Act and related
CFTC rules require OTC clearing in the United States for certain standardized OTC derivative transactions, including
certain interest rate swaps and index credit default swaps. Margin requirements for non-cleared derivative transactions in
the U.S. started in September 2016. The European Regulation (EU) No 648/2012 on OTC Derivatives, Central
Counterparties and Trade Repositories (“EMIR”) introduced a number of risk mitigation techniques for non-centrally
cleared OTC derivatives in 2013 and the reporting of OTC and exchange traded derivatives in 2014. Mandatory clearing
of certain standardized OTC derivatives transactions in the EU began in June 2016, and margin requirements for un-
cleared OTC derivative transactions in the EU started in February 2017. Deutsche Bank implemented the exchange of
both initial and variation margin in the EU from February 2017 for the first category of counterparties subject to the EMIR
margin for uncleared derivatives requirements.
The CFTC has adopted rules implementing the most significant provisions of the Dodd-Frank Act. More recently, in
September 2020, the CFTC issued a final rule on the cross-border application of U.S. swap rules, which builds on, and in
some cases supersedes the CFTC’s cross-border guidance from 2013 and related no-action relief letters. In October
2020, also pursuant to the Dodd-Frank Act, the CFTC finalized regulations to impose position limits on certain
commodities and economically equivalent swaps, futures and options.
The SEC has also finalized rules regarding registration, trade reporting, capital, margin, risk mitigation techniques,
business conduct standards, trade acknowledgement and verification, recordkeeping and financial reporting, and cross-
border requirements for security-based swap dealers and major security-based swap participants. Compliance with these
requirements was generally required as of November 2021.
Finally, U.S. prudential regulators (the Federal Reserve, the FDIC, the Office of the Comptroller of the Currency, the Farm
Credit Administration and the Federal Housing Finance Agency) have adopted final rules establishing margin
requirements for non-cleared swaps and security-based swaps that are applicable to swap dealers and security-based
swap dealers that are subject to U.S. prudential regulations (such as Deutsche Bank) in lieu of the CFTC’s and the SEC’s
margin rules. Deutsche Bank implemented the exchange of both initial and variation margin for uncleared derivatives in
the U.S. from September 2016, for the first category of counterparties subject to the U.S. prudential regulators’ margin
requirements. Additional initial margin requirements for smaller counterparties have been phased in from September
2017 through September 2022, with the relevant compliance dates depending in each case on the transactional volume
of the parties and their affiliates.
164
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
The following table shows a breakdown of notional amounts and gross market values for assets and liabilities of
exchange traded and OTC derivative transactions on the basis of clearing channel.
Notional amounts of derivatives on basis of clearing channel and type of derivative
Dec 31, 2025 | ||||||||||||||
Notional amount maturity distribution | ||||||||||||||
in € m. | Within 1 year | > 1 and ≤ 5 years | After 5 years | Total | Positive market value | Negative market value | Net market value | |||||||
Interest rate related: | ||||||||||||||
OTC | 17,041,938 | 13,931,032 | 9,541,283 | 40,514,253 | 118,098 | 105,415 | 12,683 | |||||||
Bilateral (Amt) | 3,753,247 | 2,319,020 | 1,543,911 | 7,616,178 | 94,373 | 82,403 | 11,971 | |||||||
CCP (Amt) | 13,288,691 | 11,612,012 | 7,997,372 | 32,898,075 | 23,724 | 23,012 | 712 | |||||||
Exchange-traded | 2,911,731 | 493,685 | 87 | 3,405,503 | 99 | 125 | (26) | |||||||
Total Interest rate related | 19,953,668 | 14,424,718 | 9,541,370 | 43,919,755 | 118,196 | 105,540 | 12,656 | |||||||
Currency related: | ||||||||||||||
OTC | 7,061,584 | 1,257,976 | 526,624 | 8,846,185 | 96,211 | 90,949 | 5,262 | |||||||
Bilateral (Amt) | 6,850,895 | 1,238,176 | 525,924 | 8,614,995 | 95,056 | 89,730 | 5,326 | |||||||
CCP (Amt) | 210,690 | 19,800 | 700 | 231,190 | 1,156 | 1,219 | (63) | |||||||
Exchange-traded | 83,825 | 301 | — | 84,126 | 280 | 310 | (30) | |||||||
Total Currency related | 7,145,409 | 1,258,277 | 526,624 | 8,930,311 | 96,491 | 91,259 | 5,232 | |||||||
Equity/index related: | ||||||||||||||
OTC | 26,058 | 19,183 | 10,493 | 55,735 | 1,794 | 2,620 | (826) | |||||||
Bilateral (Amt) | 26,058 | 19,183 | 10,493 | 55,735 | 1,794 | 2,620 | (826) | |||||||
CCP (Amt) | — | — | — | — | — | — | ||||||||
Exchange-traded | 182,299 | 32,150 | 2,352 | 216,800 | 2,220 | 2,353 | (134) | |||||||
Total Equity/index related | 208,357 | 51,333 | 12,845 | 272,534 | 4,013 | 4,973 | (960) | |||||||
Credit derivatives related | ||||||||||||||
OTC | 214,471 | 1,007,267 | 67,448 | 1,289,186 | 16,705 | 16,926 | (220) | |||||||
Bilateral (Amt) | 86,663 | 105,904 | 27,916 | 220,483 | 3,456 | 3,754 | (298) | |||||||
CCP (Amt) | 127,808 | 901,363 | 39,532 | 1,068,704 | 13,250 | 13,172 | 78 | |||||||
Exchange-traded | — | — | — | — | — | — | ||||||||
Total Credit derivatives related | 214,471 | 1,007,267 | 67,448 | 1,289,186 | 16,705 | 16,926 | (220) | |||||||
Commodity related: | ||||||||||||||
OTC | 55,943 | 809 | 5,027 | 61,779 | 128 | 362 | (234) | |||||||
Bilateral (Amt) | 55,943 | 809 | 5,027 | 61,779 | 128 | 362 | (234) | |||||||
CCP (Amt) | — | — | — | — | — | — | — | |||||||
Exchange-traded | 28,252 | 2,417 | — | 30,669 | 151 | 144 | 8 | |||||||
Total Commodity related | 84,195 | 3,226 | 5,027 | 92,449 | 279 | 505 | (226) | |||||||
Other: | ||||||||||||||
OTC | 166,974 | 11,055 | 76 | 178,105 | 6,548 | 6,598 | (49) | |||||||
Bilateral (Amt) | 166,892 | 11,055 | 76 | 178,023 | 6,525 | 6,539 | (14) | |||||||
CCP (Amt) | 82 | — | — | 82 | 23 | 58 | (35) | |||||||
Exchange-traded | 39,452 | 1 | — | 39,452 | 215 | 198 | 17 | |||||||
Total Other | 206,425 | 11,056 | 76 | 217,557 | 6,763 | 6,796 | (32) | |||||||
Total OTC business | 24,566,968 | 16,227,322 | 10,150,951 | 50,945,242 | 239,485 | 222,869 | 16,616 | |||||||
Total bilateral business | 10,939,698 | 3,694,147 | 2,113,347 | 16,747,192 | 201,332 | 185,407 | 15,924 | |||||||
Total CCP business | 13,627,270 | 12,533,176 | 8,037,604 | 34,198,050 | 38,153 | 37,462 | 691 | |||||||
Total exchange-traded business | 3,245,558 | 528,554 | 2,438 | 3,776,550 | 2,965 | 3,130 | (165) | |||||||
Total | 27,812,526 | 16,755,876 | 10,153,389 | 54,721,792 | 242,449 | 225,998 | 16,451 | |||||||
Positive market values after netting and cash collateral received | — | — | — | — | 25,299 | — | — | |||||||
165
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Dec 31, 2024 | ||||||||||||||
Notional amount maturity distribution | ||||||||||||||
in € m. | Within 1 year | > 1 and ≤ 5 years | After 5 years | Total | Positive market value | Negative market value | Net market value | |||||||
Interest rate related: | ||||||||||||||
OTC | 15,951,107 | 14,364,208 | 9,997,538 | 40,312,853 | 122,114 | 111,053 | 11,061 | |||||||
Bilateral (Amt) | 2,396,075 | 2,537,847 | 1,557,885 | 6,491,807 | 98,528 | 88,114 | 10,414 | |||||||
CCP (Amt) | 13,555,032 | 11,826,361 | 8,439,653 | 33,821,046 | 23,586 | 22,939 | 647 | |||||||
Exchange-traded | 3,292,886 | 498,496 | 590 | 3,791,972 | 239 | 268 | (29) | |||||||
Total Interest rate related | 19,243,992 | 14,862,704 | 9,998,128 | 44,104,825 | 122,353 | 111,321 | 11,032 | |||||||
Currency related: | ||||||||||||||
OTC | 7,718,689 | 1,225,352 | 508,959 | 9,453,000 | 147,876 | 144,688 | 3,188 | |||||||
Bilateral (Amt) | 7,496,403 | 1,209,689 | 508,809 | 9,214,900 | 144,648 | 141,847 | 2,800 | |||||||
CCP (Amt) | 222,287 | 15,664 | 150 | 238,100 | 3,228 | 2,841 | 388 | |||||||
Exchange-traded | 78,320 | — | — | 78,320 | 384 | 477 | (93) | |||||||
Total Currency related | 7,797,010 | 1,225,352 | 508,959 | 9,531,321 | 148,260 | 145,165 | 3,095 | |||||||
Equity/index related: | ||||||||||||||
OTC | 22,675 | 9,048 | 15,544 | 47,268 | 1,332 | 2,741 | (1,409) | |||||||
Bilateral (Amt) | 22,675 | 9,048 | 15,544 | 47,268 | 1,332 | 2,741 | (1,409) | |||||||
CCP (Amt) | — | — | — | — | — | — | — | |||||||
Exchange-traded | 174,707 | 28,489 | 2,348 | 205,544 | 1,818 | 1,827 | (9) | |||||||
Total Equity/index related | 197,382 | 37,537 | 17,892 | 252,812 | 3,150 | 4,568 | (1,418) | |||||||
Credit derivatives related | ||||||||||||||
OTC | 278,974 | 896,712 | 73,668 | 1,249,354 | 15,609 | 14,322 | 1,288 | |||||||
Bilateral (Amt) | 87,962 | 96,506 | 28,063 | 212,531 | 3,366 | 2,186 | 1,180 | |||||||
CCP (Amt) | 191,012 | 800,206 | 45,605 | 1,036,823 | 12,243 | 12,136 | 107 | |||||||
Exchange-traded | — | — | — | — | — | — | — | |||||||
Total Credit derivatives related | 278,974 | 896,712 | 73,668 | 1,249,354 | 15,609 | 14,322 | 1,288 | |||||||
Commodity related: | ||||||||||||||
OTC | 11,316 | 34,566 | 1,448 | 47,330 | 226 | 160 | 66 | |||||||
Bilateral (Amt) | 11,316 | 34,566 | 1,448 | 47,330 | 226 | 160 | 66 | |||||||
CCP (Amt) | — | — | — | — | — | — | — | |||||||
Exchange-traded | 34,816 | 2,645 | — | 37,461 | 168 | 169 | (1) | |||||||
Total Commodity related | 46,132 | 37,211 | 1,448 | 84,791 | 394 | 329 | 65 | |||||||
Other: | ||||||||||||||
OTC | 155,359 | 7,012 | 151 | 162,521 | 2,339 | 2,355 | (16) | |||||||
Bilateral (Amt) | 155,313 | 7,012 | 151 | 162,476 | 2,336 | 2,313 | 23 | |||||||
CCP (Amt) | 45 | — | — | 45 | 3 | 42 | (39) | |||||||
Exchange-traded | 18,687 | — | — | 18,687 | 31 | 24 | 7 | |||||||
Total Other | 174,045 | 7,012 | 151 | 181,208 | 2,370 | 2,379 | (9) | |||||||
Total OTC business | 24,138,119 | 16,536,899 | 10,597,308 | 51,272,326 | 289,497 | 275,319 | 14,177 | |||||||
Total bilateral business | 10,169,744 | 3,894,668 | 2,111,900 | 16,176,312 | 250,436 | 237,362 | 13,075 | |||||||
Total CCP business | 13,968,376 | 12,642,231 | 8,485,408 | 35,096,014 | 39,060 | 37,958 | 1,103 | |||||||
Total exchange-traded business | 3,599,416 | 529,630 | 2,938 | 4,131,984 | 2,640 | 2,766 | (126) | |||||||
Total | 27,737,535 | 17,066,528 | 10,600,247 | 55,404,310 | 292,137 | 278,085 | 14,052 | |||||||
Positive market values after netting and cash collateral received | — | — | — | — | 27,392 | — | — | |||||||
166
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Credit Risk Exposure |
Equity Exposure
The table below presents the carrying values of equity investments split by trading and non-trading for the respective
reporting dates. Deutsche Bank manages its respective positions within market risk and other appropriate risk
frameworks.
Composition of Equity Exposure
in € m. | Dec 31, 2025 | Dec 31, 2024 | ||
Trading Equities | 1,852 | 2,753 | ||
Non-trading Equities¹ | 2,044 | 2,052 | ||
Total Equity Exposure | 3,896 | 4,806 |
1Includes equity investment funds amounting to € 49 million as of December 31, 2025 and € 70 million as of December 31, 2024
As of December 31, 2025, the group’s trading equities exposure in Investment Bank was € 1.6 billion compared to
€ 2.4 billion on December 31, 2024
167
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Trading Market Risk Exposures |
Trading Market Risk Exposures
Value-at-Risk Metrics of Trading Units of Deutsche Bank Group
The tables and graph below present the Historic Simulation value-at-risk metrics calculated with a 99% confidence level
and a one-day holding period for the Group’s trading units.
Total | Diversification effect | Interest rate risk | Credit spread risk | Equity price risk | Foreign exchange risk² | Commodity price risk | ||||||||||||||||||||||
in € m. | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | ||||||||||||||
Average | 28.3 | 31.4 | (33.5) | (41.2) | 16.0 | 26.9 | 24.5 | 22.9 | 10.2 | 10.2 | 9.7 | 11.6 | 1.4 | 1.0 | ||||||||||||||
Maximum | 45.5 | 60.6 | (10.5) | (27.2) | 34.0 | 55.1 | 31.9 | 35.5 | 17.0 | 15.6 | 21.3 | 19.0 | 2.8 | 1.8 | ||||||||||||||
Minimum | 20.0 | 19.0 | (50.1) | (56.2) | 8.3 | 13.4 | 18.9 | 17.6 | 4.7 | 6.2 | 5.2 | 6.3 | 0.8 | 0.3 | ||||||||||||||
Period-end | ( | ( | ||||||||||||||||||||||||||
Development of historic simulation value-at-risk by risk types in 2025
The average one-day trading value-at-risk over 2025 was € 28 million, which decreased by € 3.1 million compared to the
average for 2024.
the spot value at the reporting dates, and their preceding 12-week average calculation.
horizon)1,2
Total | Credit Trading | Global Rates | Emerging Markets | Other | ||||||||||||||||
in € m. | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | 2025 | 2024 | ||||||||||
Average | 549.28 | 604.89 | 128.76 | 191.83 | 212.62 | 210.10 | 288.11 | 205.90 | (80.22) | (2.94) | ||||||||||
Maximum | 842.52 | 755.51 | 201.19 | 247.31 | 374.53 | 375.68 | 630.50 | 350.06 | (25.17) | 49.49 | ||||||||||
Minimum | 414.86 | 501.46 | 44.87 | 95.30 | 128.59 | 125.39 | 196.64 | 142.91 | (174.20) | (54.16) | ||||||||||
Period-end | ( | ( | ||||||||||||||||||
The incremental risk charge as at the end of 2025 was € 452 million, which has reduced by € 49 million 10% compared to
year-end 2024. The change was driven by risk reduction under Global Rates and Emerging Markets business.
168
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Trading Market Risk Exposures |
Results of Regulatory Backtesting of Trading Market Risk
In 2025, the Group observed two outliers where the Group’s loss on a buy-and-hold basis exceeded the value-at-risk of
the Trading books. The outliers in early April 2025 were driven by increased market volatility stemming from trade tariffs
announcements from the U.S. administration. There were no actual profit and loss negative outliers in the current 1 year
period.
The following graph shows the trading units daily buy-and-hold and Actual income in comparison to the value-at-risk as
of the close of the previous business day for the trading days of the reporting period. The value-at-risk is presented in
negative amounts to visually compare the estimated potential loss of the trading positions with the buy and hold income
given buy-and-hold is the relevant portion of daily profit and loss for comparison against the previous day's value at risk
which excludes new trades, reserves, and any carry profit and loss ordinarily part of actual income. Figures are shown
in millions of euro. The chart shows that the trading units achieved a positive buy and hold income for 55% of the trading
days in 2025 as well as displays the group outliers experienced in 2025.
EU MR4 – Comparison of VAR estimates with gains/losses
169
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Trading Market Risk Exposures |
Daily Income of Deutsche Bank Group Trading Units
The following histogram shows the distribution of daily income of Group trading units. Daily income is defined as total
income which consists of new trades, fees & commissions, buy & hold income, reserves, carry and other income. It
displays the number of trading days on which the Group reached each level of trading income shown on the horizontal
axis in millions of euro.
Distribution of daily income of Group’s trading units in 2025
The trading units achieved a positive income for 95% of the trading days in 2025 compared with 95% in the full year
2024.
170
Deutsche Bank | Risk and capital performance |
Annual Report 2025 |
The following table shows the Non-trading Market Risk economic capital usage by risk type:
Economic capital usage | ||||
in € m. | Dec 31, 2025 | Dec 31, 2024 | ||
Interest rate risk | ||||
Credit spread risk | ||||
Equity and Investment risk | ||||
Foreign exchange risk | ||||
Pension risk | ||||
Guaranteed funds risk | ||||
Total non-trading market risk portfolios | ||||
The economic capital figures take into account diversification benefits between the different risk types.
Economic capital usage for Non-trading Market Risk totaled € 8.2 billion as of December 31, 2025, which is € 1.4 billion
above the economic capital usage at year-end 2024. The increase is mainly driven by the model changes described in
section “Market Risk Management”. In particular, Economic Capital usage for FX risk increased due to the adoption of a
more conservative liquidity horizon scaling in the revised modeling approach. This was partly offset by lower Economic
Capital usage for interest rate risk, following the move from a Monte Carlo to historical simulation based methodology in
the core market risk Economic Capital model.
–Interest rate risk: economic capital usage for interest rate risk in the banking book, including gap risk, basis risk and
option risk, such as the risk of a change in client behavior embedded in modelled non-maturity deposits or
prepayment risk; in total the economic capital usage for December 31, 2025 was € 1.3 billion, compared to
€ 2.8 billion for December 31, 2024
–Credit spread risk: economic capital usage for portfolios in the banking book subject to credit spread risk; economic
capital usage was € 772 million as of December 31, 2025, versus € 184 million as of December 31, 2024
–Equity and Investment risk: economic capital usage for equity risk from a structural short position in the bank’s own
share price arising from the Group’s equity compensation plans, and from the non-consolidated investment holdings,
such as strategic investments and alternative assets the economic capital usage was € 1.3 billion as of December 31,
2025, compared to € 1.2 billion as of December 31, 2024
–Foreign exchange risk: foreign exchange risk predominantly arises from the Group’s structural position taken to
protect the sensitivity of the bank’s capital ratio against changes in the exchange rates. The economic capital usage
was € 4.5 billion as of December 31, 2025, versus € 1.7 billion as of December 31, 2024
–Pension risk: this risk arises from the Group’s defined benefit obligations, including interest rate risk and inflation risk,
credit spread risk, equity risk and longevity risk. The economic capital usage was € 0.3 billion as of December 31, 2025,
compared to € 0.9 billion as of December 31, 2024
–Guaranteed funds risk: risk arising from guaranteed fund products offered by the asset management division providing
a partial or full guarantee on the clients’ investment. The risk materializes if the value of the underlying investment
fund on guarantee date is lower than the guaranteed amount. The economic capital usage was € 103 million as of
December 31, 2025, versus € 100 million as of December 31, 2024.
171
Deutsche Bank | Risk and capital performance |
Annual Report 2025 |
Interest Rate Risk in the Banking Book
The following table shows the impact on the Group’s economic value of equity and net interest income in the banking
book from interest rate changes under the six standard scenarios defined by the EBA:
Economic value and net interest income interest rate risk in the banking book by EBA scenario
Delta EVE | Delta NII1 | |||||||
in € bn. | Dec 31, 2025 | Dec 31, 2024 | Dec 31, 2025 | Dec 31, 2024 | ||||
Parallel up | (6.7) | (5.8) | — | 0.2 | ||||
Parallel down | 1.4 | 1.3 | (0.6) | (0.7) | ||||
Steepener | (0.7) | (0.8) | — | (0.1) | ||||
Flattener | (0.8) | (0.7) | (0.1) | — | ||||
Short rates up | (2.5) | (2.1) | (0.1) | — | ||||
Short rates down | 0.8 | 0.6 | (0.4) | (0.6) | ||||
Maximum | (6.7) | (5.8) | (0.6) | (0.7) | ||||
in € bn. | Dec 31, 2025 | Dec 31, 2024 | ||||||
Tier 1 Capital | 60.8 | 60.8 | ||||||
1Delta Net Interest Income (NII) reflects the difference between projected NII in the respective scenario with shifted rates vs. market implied rates. Sensitivities are based
on a static balance sheet at constant exchange rates, excluding trading positions and DWS. Figures do not include Mark-to-Market (MtM)/Other Comprehensive Income
(OCI) effects on centrally managed positions not eligible for hedge accounting
The maximum economic value of equity (EVE) loss was € (6.7) billion as of December 31, 2025, compared to € (5.8) billion
as of December 31, 2024. As per December 31, 2025 the maximum EVE loss represents 11.0% of Tier 1 Capital.
The maximum economic value of equity (EVE) loss due to a +200 basis points parallel shift of the yield curve across all
currencies as defined by the BaFin was € (6.6) billion as of December 31, 2025, representing 9.8% of Total Capital.
The increase in the maximum economic value of equity (EVE) loss for the “Parallel up” interest rate scenario was a result
of change in the risk management positions held within Group Treasury’s portfolio managing earnings risks arising from
Deutsche Bank’s equity as well as Private Bank and Corporate Bank portfolios. Applied hedge strategies are aligned with
Deutsche Bank’s objective to stabilize net interest income (NII) and with the IRRBB governance framework.
The maximum one-year loss in net interest income for the “Parallel down” interest rate scenario was € (0.6) billion as of
December 31, 2025, compared to € (0.7) billion as of December 31, 2024.
The maximum net interest income loss in the “Parallel down” scenario was almost unchanged compared to 2024, in line
with the strategy to stabilize net interest income (NII).
The following table shows the variation of the economic value for Deutsche Bank’s banking book positions resulting from
downward and upward interest rate shocks by currency:
Economic value interest rate risk in the banking book by currency
Dec 31, 2025 | Dec 31, 2024 | |||||||
in € bn. | Parallel up | Parallel down | Parallel up | Parallel down | ||||
EUR | (5.8) | 1.2 | (5.1) | 1.2 | ||||
USD | (0.8) | 0.4 | (0.7) | 0.4 | ||||
Other | (0.1) | (0.2) | — | (0.3) | ||||
Total | (6.7) | 1.4 | (5.8) | 1.3 | ||||
172
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Funding Markets and Capital Markets Issuance
Multiple macro topics emerged during 2025 and weighed on markets, including U.S. tariff announcement in April,
political instability in France, continued inflationary pressures and geopolitical tensions in the Middle East. Despite
creating a dent, those events were not material enough to outweigh risk-on mood. Against this backdrop, the Bank
navigated well through the markets and successfully concluded its issuance activity at € 18.7 billion, including € 3 billion
pre-funding for 2026 requirements in line with the bank´s 2025 target range of 15 – 20 billion euros.
In contrast to market fears, credit markets showed a constructive performance despite the multiple disruptions with
broader indices trading tighter vs. year end 2024. Deutsche Bank continued its strong idiosyncratic performance in 2025.
On average, in 2025, the bank’s senior debt traded 8 bps,wider, and its capital securities traded 14 bps wider, than peers
(Societe Generale, Barclays, BNP, UBS), versus 10 bps wider and 17 bps narrower, respectively, in 2024.
The total issuance volume of € 18.7 billion is split as follows: € 2.5 billion in capital issuances, € 11.0 billion of senior non-
preferred funding, The total issuance volume of € 18.7 billion is split as follows: € 2.5 billion in capital issuances, € 11.0
billion of senior non-preferred funding, € 4.8 billion in senior preferred and € 0.4 billion in covered bonds. From a
currency perspective, the total issuance volume is divided as follows: euros (€ 9.8 billion), U.S. dollars (€ 7.1 billion),
Japanese Yen (€ 0.5 billion), Pound Sterling (€ 0.6 billion) and other currencies aggregated (€ 0.7 billion). The Group’s
investor base for 2025 issuances was as follows: asset managers and pension funds (63.3 %), banks (10.6 %), retail
customers (3.2 %), insurance companies (5.2 %), other institutional investors (11.3 %), Governments and agencies (4.4 %) and
Other (1.7 %). The geographical distribution was split between Germany (15.0 %), rest of Europe (44.0 %), U.S. (29.0 %), Asia/
Pacific (8.0 %) and Other (4.0 %). The average spread of issuance over 3-months-Euribor/RFR (Risk Free Rate) was 95 bp for
the full year. The average tenor was 4.8 years. The Group issued the following volumes over each quarter: first quarter: €
Deutsche Bank’s issuance plan for 2026 is € 10 -15 billion. Focus will be on senior non-preferred bonds. Senior preferred
issuances will be primarily in non-benchmark format. The Group also plans to raise a portion of this funding in U.S. dollar
and may enter into cross currency swaps to manage any residual requirements. The Bank has total capital markets
maturities, excluding legally exercisable calls, of approximately € 14.0 billion. Furthermore, the Bank issued structured
notes with a volume of around € 7.7 billion euros net in 2025 and plans to issue ~€ 7.3 billion in 2026. This activity is
conducted by the FIC division and not part of the Treasury issuance plan.
In 2025, total external funding increased by € 56.3 billion from € 1,024.8 billion at December 31, 2024, to
€ 1,081.1 billion at December 31, 2025. Funding has increased by € 16.8 billion in the Corporate Bank and by € 8.9 billion
in the Private Bank. Within both segments, growth was most pronounced in sight deposits. The unsecured Wholesale
Funding portfolio increased by € 4.6 billion, supported by newly issued Commercial Paper. Secured funding and shorts
have increased by € 16.1 billion, driven by growth in repurchase operations. The Capital Markets and Equity position
slightly increased by € 0.3 billion. While Equity increased by € 0.3 billion, Capital Markets increased by € 0.1 billion.
Underlying growth in structured notes issued by FIC was offset by a reduction in Treasury issued debt. Additional growth
in the Other Customers bucket of € 9.4 billion was mainly driven by an increase in long-term debt due to growth from
ETF structures.
173
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Composition of External Funding Sources
* Other Customers includes fiduciary deposits, X-markets notes and margin/Prime Brokerage cash balances (shown on a net basis)
Reference: Reconciliation to total balance sheet of € 1,435.1 billion (€1,391.0 billion): Derivatives & settlement balances € 277.7 billion (€ 288.8 billion), add-back for
netting effect for margin/Prime Brokerage cash balances (shown on a net basis) € 46.6 billion (€ 42.2 billion), other non-funding liabilities € 34.5 billion (€ 35.3 billion for
December 31, 2025, and December 31, 2024, respectively
Maturity of unsecured wholesale funding, ABCP and capital markets issuance1
Dec 31, 2025 | ||||||||||||||||
in € m. | Not more than 1 month | Over 1 month but not more than 3 months | Over 3 months but not more than 6 months | Over 6 months but not more than 1 year | Sub-total less than 1 year | Over 1 year but not more than 2 years | Over 2 years | Total | ||||||||
Deposits from banks | 1,027 | 476 | 77 | 450 | 2,029 | 102 | — | 2,132 | ||||||||
Deposits from other wholesale customers | 12,662 | 2,954 | 2,406 | 4,695 | 22,717 | 1,041 | 73 | 23,831 | ||||||||
CDs and CP | 4,929 | 2,524 | 2,491 | 5,290 | 15,234 | 1,793 | 1,408 | 18,436 | ||||||||
ABCP | — | — | — | — | — | — | — | — | ||||||||
Senior non-preferred plain vanilla | 1,239 | 1,967 | 1,335 | 7,730 | 12,270 | 11,734 | 31,268 | 55,272 | ||||||||
Senior preferred plain vanilla | 1,758 | 1,113 | 866 | 611 | 4,348 | 2,287 | 8,353 | 14,988 | ||||||||
Senior structured | 151 | 675 | 899 | 1,143 | 2,867 | 2,592 | 25,663 | 31,122 | ||||||||
Covered bonds/ABS | 505 | 126 | 1,334 | 1,317 | 3,282 | 1,927 | 8,389 | 13,598 | ||||||||
Subordinated liabilities | — | 1,262 | 1,989 | 1,279 | 4,530 | 4,897 | 10,886 | 20,313 | ||||||||
Other | 53 | — | — | — | 53 | — | — | 53 | ||||||||
Total | 22,323 | 11,096 | 11,397 | 22,515 | 67,331 | 26,372 | 86,040 | 179,743 | ||||||||
Of which: | ||||||||||||||||
Secured | 21,818 | 10,971 | 10,063 | 21,197 | 64,049 | 24,445 | 77,651 | 166,145 | ||||||||
Unsecured | 21,812 | 10,964 | 10,057 | 21,170 | 64,002 | 23,224 | 77,530 | 164,756 | ||||||||
1Includes additional Tier 1 notes reported as additional equity components in the financial statements. Liabilities with call features are shown at earliest legally exercisable
call date. No assumption is made as to whether such calls would be exercised
Capital market issuances volume reported post own debt elimination
The total volume of unsecured wholesale liabilities, asset-backed commercial paper (ABCP) and capital markets issuance
maturing within one year amount to € 67 billion as of December 31, 2025, and should be viewed in the context of total
High Quality Liquid Assets (HQLA) of € 260 billion.
174
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Dec 31, 2024 | ||||||||||||||||
in € m. | Not more than 1 month | Over 1 month but not more than 3 months | Over 3 months but not more than 6 months | Over 6 months but not more than 1 year | Sub-total less than 1 year | Over 1 year but not more than 2 years | Over 2 years | Total | ||||||||
Deposits from banks | 829 | 697 | 1,294 | 1,277 | 4,098 | 56 | — | 4,153 | ||||||||
Deposits from other wholesale customers | 3,106 | 7,919 | 4,698 | 5,396 | 21,119 | 2,231 | 1,013 | 24,363 | ||||||||
CDs and CP | 1,107 | 3,623 | 2,647 | 3,688 | 11,064 | 10 | 117 | 11,190 | ||||||||
ABCP | — | — | — | — | — | — | — | — | ||||||||
Senior non-preferred plain vanilla | 239 | 1,467 | 1,788 | 5,190 | 8,685 | 12,054 | 33,279 | 54,018 | ||||||||
Senior preferred plain vanilla | 171 | 360 | 1,681 | 1,712 | 3,923 | 4,442 | 7,930 | 16,294 | ||||||||
Senior structured | 239 | 793 | 1,029 | 1,381 | 3,442 | 2,187 | 20,094 | 25,723 | ||||||||
Covered bonds/ABS | 765 | 343 | 225 | 757 | 2,091 | 3,301 | 10,163 | 15,554 | ||||||||
Subordinated liabilities | — | 1,264 | 3,945 | 1,190 | 6,399 | 4,239 | 12,991 | 23,630 | ||||||||
Other | 49 | — | — | — | 49 | — | 7 | 57 | ||||||||
Total | 6,505 | 16,468 | 17,307 | 20,591 | 60,870 | 28,519 | 85,593 | 174,982 | ||||||||
Of which: | ||||||||||||||||
Secured | 765 | 343 | 225 | 757 | 2,091 | 3,301 | 10,163 | 15,554 | ||||||||
Unsecured | 5,740 | 16,124 | 17,081 | 19,834 | 58,779 | 25,218 | 75,430 | 159,428 | ||||||||
The following table shows the currency breakdown of short-term unsecured wholesale funding, of ABCP funding and of
capital markets issuance.
Unsecured wholesale funding, ABCP and capital markets issuance (currency breakdown)
Dec 31, 2025 | Dec 31, 2024 | |||||||||||||||||||
in € m. | in EUR | in USD | in GBP | in other CCYs | Total | in EUR | in USD | in GBP | in other CCYs | Total | ||||||||||
Deposits from banks | 320 | 1,341 | 48 | — | 1,709 | 629 | 2,583 | 40 | 902 | 4,153 | ||||||||||
Deposits from other whole- sale customers | 8,291 | 12,923 | 147 | — | 21,361 | 7,722 | 13,836 | 264 | 2,542 | 24,363 | ||||||||||
CDs and CP | 8,031 | 10,145 | — | — | 18,176 | 3,695 | 7,230 | — | 266 | 11,190 | ||||||||||
ABCP | — | — | — | — | — | — | — | — | — | — | ||||||||||
Senior non-preferred plain vanilla | 26,352 | 23,502 | 1,904 | 3,513 | 55,272 | 23,485 | 24,503 | 2,167 | 3,862 | 54,018 | ||||||||||
Senior preferred plain vanilla | 7,712 | 5,071 | 17 | 2,188 | 14,988 | 8,919 | 5,390 | 15 | 1,970 | 16,294 | ||||||||||
Senior structured | 13,574 | 14,784 | 44 | 2,720 | 31,122 | 10,704 | 12,250 | 50 | 2,719 | 25,723 | ||||||||||
Covered bonds/ ABS | 12,953 | 645 | — | — | 13,598 | 14,822 | 732 | — | — | 15,554 | ||||||||||
Subordinated liabilities | 13,958 | 5,439 | 917 | — | 20,313 | 12,553 | 9,938 | 952 | 187 | 23,630 | ||||||||||
Other | 6 | — | — | — | 6 | 8 | — | — | 49 | 57 | ||||||||||
Total | 91,197 | 73,850 | 3,077 | 8,422 | 176,545 | 82,536 | 76,461 | 3,489 | 12,495 | 174,982 | ||||||||||
Of which: | ||||||||||||||||||||
Secured | 78,244 | 73,205 | 3,077 | 8,422 | 162,947 | 14,822 | 732 | — | — | 15,554 | ||||||||||
Unsecured | 76,806 | 73,124 | 3,073 | 11,753 | 164,756 | 67,714 | 75,729 | 3,489 | 12,495 | 159,428 | ||||||||||
175
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
High quality liquid assets
Composition of Group’s HQLA by parent company (including branches) and subsidiaries
Dec 31, 2025 | Dec 31, 2024 | |||||||
in € bn. | Market Value | Value according to Article 9 CRR | Market Value | Value according to Article 9 CRR | ||||
Available-Cash and Central Bank Reserves | 144 | 144 | 124 | 124 | ||||
Parent (incl. foreign branches) | 116 | 116 | 97 | 97 | ||||
Subsidiaries | 28 | 28 | 26 | 26 | ||||
High Quality liquid securities (includes government, government guaranteed and agency securities | 120 | 116 | 106 | 102 | ||||
Parent (incl. foreign branches) | 117 | 113 | 98 | 94 | ||||
Subsidiaries | 3 | 3 | 8 | 8 | ||||
Total HQLA | 264 | 260 | 230 | 226 | ||||
Parent (incl. foreign branches) | 233 | 229 | 195 | 191 | ||||
Subsidiaries | 31 | 31 | 34 | 34 | ||||
As of December 31, 2025, the Group’s HQLA increased to € 260 billion compared to December 31, 2024 at € 226 billion.
This is primarily due to increased deposits and issuance of long-term debt largely offset by TLTRO repayment and
increased business held assets.
Liquidity Coverage Ratio
The Liquidity Coverage Ratio was 144% at the end of 2025, a surplus to regulatory requirements of € 80 billion as
compared to 131% as at the end of 2024, a surplus to regulatory requirements of € 53 billion. The increase in surplus was
predominantly driven by increased Private Bank and Corporate Bank deposits through H2 2025.
The Group’s twelve month weighted average LCR was 137%. This has been calculated in accordance with the
Commission Delegated Regulation (EU) 2015/61 and the EBA Guidelines on LCR disclosure to complement the
disclosure of liquidity risk management under Article 435 CRR.
LCR components
Dec 31, 2025 | Dec 31, 2024 | |||
in € bn. (unless stated otherwise) | Total adjusted weighted value (average) | Total adjusted weighted value (average) | ||
Number of data points used in the calculation of averages | 12 | 12 | ||
High Quality Liquid Assets | 238 | 224 | ||
Total net cash outflows | 174 | 167 | ||
Liquidity Coverage Ratio (LCR) in % | 137% | 134% |
Funding Risk Management
Structural Funding
All funding matrices (the aggregate currency, the USD and the GBP funding matrix) were in line with the targets as at
year ends 2025 and 2024.
176
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Stress Testing and Scenario Analysis
At the end of 2025, the Group’s stressed Net Liquidity Position stood at € 94 billion compared to € 56 billion as at the
end of 2024 with the change in scenario of minimum surplus liquidity reflecting the introduction of a 12-month risk
appetite horizon under the Systemic Market Risk scenario.
Dec 31, 2025 | Dec 31, 2024 | |||||||||||
in € bn. | Funding Gap1 | Gap Closure2 | Net Liquidity Position | Funding Gap1 | Gap Closure2 | Net Liquidity Position | ||||||
Systemic market risk | 187 | 306 | 119 | 208 | 265 | 56 | ||||||
1 notch downgrade (DB specific) | 39 | 215 | 176 | 34 | 174 | 140 | ||||||
Severe downgrade (DB specific) | 107 | 235 | 128 | 142 | 241 | 99 | ||||||
Combined³ | ||||||||||||
Global Euro Daily Stress Testing Results
Dec 31, 2025 | Dec 31, 2024 | |||||||||||
in € bn. | Funding Gap1 | Gap Closure2 | Net Liquidity Position | Funding Gap1 | Gap Closure2 | Net Liquidity Position | ||||||
Combined³ | 81 | 143 | 62 | 91 | 104 | 13 | ||||||
1Funding gap caused by impaired rollover of liabilities and other projected outflows
2Based on liquidity generation through Liquidity Reserves and other business mitigants
3Combined impact of systemic market risk and severe downgrade
Global U.S. dollar Daily Stress Testing Results
Dec 31, 2025 | Dec 31, 2024 | |||||||||||
in € bn. | Funding Gap1 | Gap Closure | Net Liquidity Position | Funding Gap1 | Gap Closure2 | Net Liquidity Position | ||||||
Combined³ | 80 | 94 | 14 | 80 | 102 | 22 | ||||||
1Funding gap caused by impaired rollover of liabilities and other projected outflows
2Based on liquidity generation through Liquidity Reserves and other business mitigants
3Combined impact of systemic market risk and severe downgrade
Global British pound Daily Stress Testing Results
Dec 31, 2025 | Dec 31, 2024 | |||||||||||
in € bn. | Funding Gap1 | Gap Closure2 | Net Liquidity Position | Funding Gap1 | Gap Closure2 | Net Liquidity Position | ||||||
Combined³ | 4 | 8 | 3 | 5 | 10 | 5 | ||||||
1Funding gap caused by impaired rollover of liabilities and other projected outflows
2Based on liquidity generation through Liquidity Reserves and other business mitigants
3Combined impact of systemic market risk and severe downgrade
The following table presents the amount needed to meet collateral requirements from contractual obligations in the
event of a one- or two-notch downgrade by rating agencies for all currencies.
Contractual Obligations
Dec 31, 2025 | Dec 31, 2024 | |||||||
in € m. | One-notch downgrade | Two-notch downgrade | One-notch downgrade | Two-notch downgrade | ||||
Contractual derivatives funding or margin requirements | 161 | 212 | 182 | 309 | ||||
Other contractual funding or margin requirements | — | — | — | — | ||||
177
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Net stable funding ratio
The Net Stable Funding Ratio was 119% as at year end 2025, a surplus to regulatory requirements of € 104 billion as
compared to 121% as at the end of 2024, a surplus to regulatory requirements of € 110 billion.
Net stable funding ratio
Dec 31, 2025 | Dec 31, 2024 | |||
in € bn. (unless stated otherwise) | Total adjusted weighted value | Total adjusted weighted value (average) | ||
Available stable funding (ASF) | 649 | 625 | ||
Required stable funding (RSF) | 545 | 515 | ||
Net Stable Funding Ratio (NSFR) in % | 119% | 121% |
Asset Encumbrance
This section refers to asset encumbrance in the Group of institutions consolidated for banking regulatory purposes
pursuant to the German Banking Act. Therefore, this excludes insurance companies or companies outside the finance
sector. Assets pledged by insurance subsidiaries are included in Note 20 “Assets Pledged and Received as Collateral” of
the consolidated financial statements, and restricted assets held to satisfy obligations to insurance companies’ policy
holders are included within Note 37 “Information on Subsidiaries” of the consolidated financial statements.
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. Additionally, in line with EBA technical standards
on regulatory asset encumbrance reporting, assets placed 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. The balances presented also include derivative margin receivable assets as
encumbered under relevant EBA guidelines.
Readily available assets are those on- and off-balance sheet assets that are not otherwise encumbered, and which are in
freely transferrable form. Unencumbered financial assets at fair value, other than securities borrowed or purchased under
resale agreements and positive market value from derivatives, and available for sale investments are all assumed to be
readily available.
The readily available value represents the on- and off-balance sheet carrying amount or fair value rather than any form of
stressed liquidity value (see the “High Quality Liquid Assets” for an analysis of unencumbered liquid assets available
under a liquidity stress scenario). Other unencumbered on- and off-balance sheet assets are those assets that have not
been pledged as collateral against secured funding or other collateralized obligations or are otherwise not considered to
be readily available. Included in this category are securities borrowed or purchased under resale agreements and positive
market value from derivatives. Similarly, for loans and other advances to customers, these would only be viewed as
readily available to the extent they are already in a pre-packaged transferrable format and have not already been used to
generate funding. This represents the most conservative view given that an element of such loans currently shown in
other assets could be packaged into a format that would be suitable for use to generate funding.
178
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Encumbered and unencumbered assets
Dec 31, 2025 | ||||||||
Carrying value | ||||||||
Unencumbered assets | ||||||||
in € m. (unless stated otherwise) | Assets | Encumbered assets | Readily available | Other | ||||
Debt securities | 209 | 106 | 103 | — | ||||
Equity instruments | 4 | — | 4 | — | ||||
Other assets: | ||||||||
Cash and due from banks & Interest earning deposits with Banks | 172 | 13 | 158 | — | ||||
Securities borrowed or purchased under resale agreements¹ | 38 | — | — | 38 | ||||
Financial assets at fair value through profit and loss² | ||||||||
Trading assets | 13 | — | 13 | — | ||||
Positive market value from derivative financial instruments | 241 | — | — | 241 | ||||
Securities borrowed or purchased under resale agreements¹ | 113 | — | — | 113 | ||||
Other financial assets at fair value through profit or loss | 4 | — | 4 | — | ||||
Financial assets at fair value through other comprehensive income² | 6 | — | 4 | 1 | ||||
Loans | 550 | 43 | 76 | 430 | ||||
Other assets | 85 | 43 | — | 41 | ||||
Total | 1,433 | 206 | 363 | 864 | ||||
1Securities borrowed and securities purchased under resale agreements are all shown as other unencumbered. The use of the underlying collateral is separately captured
in the off-balance sheet table below
2Excludes Debt securities and Equity instruments (separately disclosed above)
Dec 31, 2025 | ||||||||
Fair value of collateral received | ||||||||
Unencumbered assets | ||||||||
in € m. (unless stated otherwise) | Assets | Encumbered assets | Readily available | Other | ||||
Collateral received: | 557,837 | 431,792 | 125,943 | 101 | ||||
Debt securities | 556,142 | 430,204 | 125,938 | — | ||||
Equity instruments | 690 | 685 | 5 | — | ||||
Other collateral received | 1,005 | 903 | — | 101 | ||||
Dec 31, 2024 | ||||||||
Carrying value | ||||||||
Unencumbered assets | ||||||||
in € m. (unless stated otherwise) | Assets | Encumbered assets | Readily available | Other | ||||
Debt securities | 179 | 80 | 99 | — | ||||
Equity instruments | 4 | — | 4 | — | ||||
Other assets: | ||||||||
Cash and due from banks & Interest earning deposits with Banks | 154 | 14 | 139 | — | ||||
Securities borrowed or purchased under resale agreements¹ | 41 | — | — | 41 | ||||
Financial assets at fair value through profit and loss² | ||||||||
Trading assets | 12 | — | 12 | — | ||||
Positive market value from derivative financial instruments | 292 | — | — | 292 | ||||
Securities borrowed or purchased under resale agreements¹ | 105 | — | — | 105 | ||||
Other financial assets at fair value through profit or loss | 3 | — | 3 | — | ||||
Financial assets at fair value through other comprehensive income² | 8 | — | 5 | 3 | ||||
Loans | 517 | 48 | 41 | 427 | ||||
Other assets | 75 | 40 | — | 35 | ||||
Total | 1,389 | 183 | 303 | 903 | ||||
1Securities borrowed and securities purchased under resale agreements are all shown as other unencumbered. The use of the underlying collateral is separately captured
in the off-balance sheet table below
2Excludes Debt securities and Equity instruments (separately disclosed above)
Dec 31, 2024 | ||||||||
Fair value of collateral received | ||||||||
Unencumbered assets | ||||||||
in € m. (unless stated otherwise) | Assets | Encumbered assets | Readily available | Other | ||||
Collateral received: | 479 | 366 | 110 | 3 | ||||
Debt securities | 473 | 363 | 110 | — | ||||
Equity instruments | 1 | 1 | — | — | ||||
Other collateral received | 6 | 2 | — | 3 | ||||
179
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Maturity Analysis of Assets and Financial Liabilities
Treasury manages the maturity analysis of assets and liabilities. Modeling of assets and liabilities is necessary in cases
where the contractual maturity does not adequately reflect the liquidity risk position. The most significant example in
this context would be immediately repayable deposits from retail and transaction banking customers which have
consistently displayed high stability throughout even the most severe financial crises.
The modeling profiles are part of the overall liquidity risk management framework (see section “Liquidity Stress Testing
and Scenario Analysis” for short-term liquidity positions ≤ 1 year and section “Structural Funding” for long-term liquidity
positions > 1 year) which is defined and approved by the Management Board.
The following tables present a maturity analysis of total assets based on carrying value and upon earliest legally
exercisable maturity as of December 31, 2025 and 2024 , respectively.
Analysis of the earliest contractual maturity of assets
Dec 31, 2025 | ||||||||||||||||||||
in € m. | On demand (incl. Overnight and one day notice) | Up to one month | Over 1 month to no more than 3 months | Over 3 months but no more than 6 months | Over 6 months but no more than 9 months | Over 9 months but no more than 1 year | Over 1 year but no more than 2 years | Over 2 years but no more than 5 years | Over 5 years | Total | ||||||||||
Cash and central bank balances¹ | 151,073 | 10,354 | 2,828 | 371 | 19 | 14 | — | — | — | 164,659 | ||||||||||
Interbank balances (w/o central banks)¹ | 5,310 | 1,442 | 80 | 39 | 2 | 83 | — | — | 6 | 6,962 | ||||||||||
Central bank funds sold | — | — | — | — | — | — | — | — | — | — | ||||||||||
Securities purchased under resale agreements | 570 | 4,568 | 8,073 | 8,530 | 4,407 | 1,751 | 4,848 | 4,761 | — | 37,509 | ||||||||||
With banks | 304 | 1,904 | 2,378 | 1,080 | 1,958 | 1,048 | 2,019 | 2,166 | — | 12,857 | ||||||||||
With customers | 266 | 2,664 | 5,696 | 7,450 | 2,448 | 703 | 2,829 | 2,595 | — | 24,652 | ||||||||||
Securities borrowed | — | 6 | — | — | — | — | — | — | — | 6 | ||||||||||
With banks | — | — | — | — | — | — | — | — | — | — | ||||||||||
With customers | — | 6 | — | — | — | — | — | — | — | 6 | ||||||||||
Financial assets at fair value through profit or loss | 411,247 | 83,355 | 8,297 | 5,011 | 914 | 3,199 | 1,628 | 2,047 | 4,261 | 519,960 | ||||||||||
Trading assets | 151,725 | — | — | — | — | 1,928 | 38 | — | 120 | 153,811 | ||||||||||
Fixed-income securities and loans | 139,484 | — | — | — | — | — | — | — | — | 139,484 | ||||||||||
Equities and other variable-income securities | 1,852 | — | — | — | — | 1,928 | 38 | — | 120 | 3,939 | ||||||||||
Other trading assets | 10,388 | — | — | — | — | — | — | — | — | 10,388 | ||||||||||
Positive market values from derivative financial instruments | 241,328 | — | 61 | 30 | 32 | 8 | 13 | 114 | 68 | 241,654 | ||||||||||
Non-trading financial assets mandatory at fair value through profit or loss | 18,194 | 83,355 | 8,236 | 4,981 | 882 | 1,263 | 1,577 | 1,933 | 4,073 | 124,495 | ||||||||||
Securities purchased under resale agreements | 5,954 | 78,582 | 6,251 | 3,703 | 223 | 114 | 710 | 184 | 81 | 95,802 | ||||||||||
Securities borrowed | 12,154 | 2,759 | 1,117 | 472 | — | — | 11 | — | — | 16,513 | ||||||||||
Fixed-income securities and loans | 21 | 616 | 829 | 806 | 638 | 540 | 821 | 1,741 | 2,955 | 8,967 | ||||||||||
Other non-trading financial assets mandatory at fair value through profit or loss | 65 | 1,397 | 40 | — | 21 | 609 | 35 | 9 | 1,037 | 3,213 | ||||||||||
Financial assets designated at fair value through profit or loss | — | — | — | — | — | — | — | — | — | — | ||||||||||
Positive market values from derivative financial instruments qualifying for hedge accounting | — | 183 | 318 | 179 | 34 | 19 | 21 | 23 | 18 | 795 | ||||||||||
180
Deutsche Bank | Risk and capital performance |
Annual Report 2025 | Liquidity Risk Exposure |
Dec 31, 2025 | ||||||||||||||||||||
in € m. | On demand (incl. Overnight and one day notice) | Up to one month | Over 1 month to no more than 3 months | Over 3 months but no more than 6 months | Over 6 months but no more than 9 months | Over 9 months but no more than 1 year | Over 1 year but no more than 2 years | Over 2 years but no more than 5 years | Over 5 years | Total | ||||||||||
Financial assets at fair value through other comprehensive income | 1 | 3,611 | 1,635 | 3,512 | 1,607 | 911 | 3,283 | 7,058 | 22,027 | 43,644 | ||||||||||
Securities purchased under resale agreements | — | ⚠️ Filing Content TruncatedThis filing was too large to display in its entirety (original size: 32.07 MB). The content has been truncated to fit within database limits. To view the complete filing, please visit the original source: View Complete Filing on SEC Website
Filing: 20-F - DEUTSCHE BANK AKTIENGESELLSCHAFT (DB,DGP,DGZ,DZZ,ADZCF,DEENF,OLOXF) | ||||||||||||||||||
FAQ
What dividend does Deutsche Bank (DB) plan for the 2025 financial year?
Deutsche Bank’s Management Board intends to propose a €1.00 per-share dividend for 2025. This corresponds to payout ratios of 33% based on basic earnings per share and 34% on diluted earnings per share, before German withholding tax.
How is Deutsche Bank’s capitalization structured in the 2025 Form 20-F?
Deutsche Bank reports total debt of €142,336 million and total equity of €82,285 million as of December 31, 2025. This results in total capitalization of €224,621 million, combining long‑term debt, additional equity components and noncontrolling interests.
How many Deutsche Bank shares were outstanding at the end of 2025?
Deutsche Bank reports 1,902,873,264 ordinary shares outstanding as of December 31, 2025. These no‑par-value ordinary shares represent the company’s primary equity capital and are the basis for earnings-per-share and dividend calculations described in the 2025 Form 20‑F.
What are the main macroeconomic and geopolitical risks highlighted by Deutsche Bank (DB)?
Deutsche Bank cites risks from global trade tensions, Russia’s war in Ukraine, policy divergence, elevated inflation and weak European growth. It also notes vulnerabilities from commercial real estate, private credit stress and potential simultaneous shocks that could pressure portfolio quality, credit losses, capital and liquidity.
What capital targets does Deutsche Bank set in its 2025 annual report?
Deutsche Bank aims to operate with a CET1 ratio range of 13.5–14.0%, maintaining at least 200 basis points above its Maximum Distributable Amount threshold. Meeting these targets depends on business performance, risk‑weighted asset evolution, regulatory changes and execution of strategic and cost initiatives.
How do regulatory and resolution rules affect Deutsche Bank’s strategy?
The bank explains that Basel III, CRR3/CRD6, TLAC and MREL rules raise required capital and bail‑inable debt, potentially constraining growth or requiring balance‑sheet adjustments. Failure to meet minimums could trigger restrictions on dividends, buybacks or coupons and, in extreme cases, resolution tools including bail‑in.
What internal control and AML challenges does Deutsche Bank (DB) disclose?
Deutsche Bank describes ongoing remediation of legacy IT, data fragmentation and manual processes, plus enhancements to AML and KYC controls. German and U.S. authorities have issued orders and a 2023 consent order, with potential for escalated actions if required improvements are not completed and sustained over time.
Deutsche Bk
NYSE:DB
DB Rankings
DB Latest News
Jan 30, 2026
Deutsche Bank appointed as Successor Depositary Bank for the American Depositary Receipt Program of Swisscom AG
Jan 27, 2026
Deutsche Bank Appointed as Successor Depositary Bank for the American Depositary Receipt Program of CSL Limited
Dec 19, 2025
Deutsche Bank Appointed as Depositary Bank for the Sponsored American Depositary Receipt Program of Metaplanet Inc.
Dec 10, 2025
Deutsche Bank Decreases Prime Lending Rate to 6.75%
Oct 29, 2025
Deutsche Bank Decreases Prime Lending Rate to 7.00%