Initiation of administrative proceeding against PGE Obrót S.A. by the President of the Energy Regulatory Office

The Management Board of PGE Polska Grupa Energetyczna S.A. (”PGE”, the ”Company”) discloses that on February 5, 2026 in the evening PGE Obrót S.A. (“PGE Obrót” – subsidiary of PGE) received:

- notification about initiating ex officio by the President of the Energy Regulatory Office (the „ERO President”) of a proceeding in case of issuance of administrative decision on obligation of PGE Obrót to remit to the account of the Price Difference Payment Fund (the „PDP Fund”), introduced by the Act of October 27, 2022 on extraordinary measures to reduce electricity prices and support certain customers in 2023 (the „Act”), the amounts constituting the difference between the contributions to the PDP Fund calculated by the ERO President and contributions to the PDP Fund paid by PGE Obrót, and

- protocol from audit concerning the verification of the correctness of the contribution to the PDP Fund in the reporting period, i.e. from December 2022 till December 2023, in the scope of calculations of indicated amounts in the appropriate statements of PGE Obrót, as well as the actual amount paid by PGE Obrót to Zarządca Rozliczeń S.A.

The difference between the total contributions paid by PGE Obrót and the one calculated by the ERO President presented in the protocol from audit amounts to approx. PLN 605 m in total.

The audit of the ERO President at PGE Obrót was commenced on November 24, 2025 about which PGE informed in the Quarterly financial report for the period of 3 and 9 months ended September 30, 2025, published on November 25, 2025.

In accordance with the binding procedure, after reviewing the documents submitted by the ERO President, PGE Obrót will file eventual objections to the protocol from audit and explanations in the case within 7 days. Based on the collected materials, the ERO President will make a decision in the given case about what the Company will inform in a separate current report.