UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
_________________
FORM 6-K
REPORT OF FOREIGN PRIVATE
 
ISSUER
PURSUANT TO RULE 13a-16 OR 15d-16 UNDER
THE SECURITIES EXCHANGE ACT OF 1934
Date: October 1, 2025
UBS Group AG
(Registrant's Name)
Bahnhofstrasse 45, 8001 Zurich, Switzerland
(Address of principal executive office)
Commission File Number: 1-36764
UBS AG
(Registrant's Name)
Bahnhofstrasse 45, 8001 Zurich, Switzerland
Aeschenvorstadt 1, 4051 Basel, Switzerland
 
(Address of principal executive offices)
Commission File Number: 1-15060
 
Indicate by check mark whether the registrants file or will file annual
 
reports under cover of Form
20-F or Form 40-
F.
Form 20-F
 
 
Form 40-F
 
This Form 6-K consists of the speech and Q&A transcripts of the presentation
 
that took place on
September 30, 2025, that immediately follow this page.
 
 
1
UBS’s response to 6 June 2025
Capital Adequacy Ordinance
(CAO) consultation
30 September 2025
Speeches by
Sergio P.
 
Ermotti
, Group Chief Executive Officer,
 
and
Todd
 
Tuckner
,
Group Chief Financial
 
Officer
Including analyst
 
Q&A session
Transcript.
Presentation and webcast
 
replay is available
 
at www.ubs.com/presentations
Sergio P.
 
Ermotti
Slide 2 – Key messages
Thank you, Sarah and good morning,
 
everyone.
 
Today
 
we
 
would
 
like
 
to
 
briefly
 
highlight
 
key
 
points
 
from
 
our
 
submission
 
to
 
the
 
Capital
 
Adequacy
 
Ordinance
consultation.
 
We
 
want
 
to
 
contribute
 
to
 
an
 
informed
 
discussion
 
based
 
on
 
facts
 
and
 
I
 
remain
 
hopeful
 
for
 
the
 
adoption
 
of
 
a
reasonable solution – one that ultimately benefits all of
 
the stakeholders, including Switzerland.
 
We believe our submission
 
is comprehensive, so
 
we will keep
 
our remarks short
 
as the purpose
 
of this call
 
is to take
questions or provide clarifications on our position.
With respect
 
to the
 
proposal to fully
 
deduct investments
 
in foreign subsidiaries
 
from CET1 capital,
 
we will
 
comment
in more detail at the end of the consultation period
 
which began last week.
 
To
 
re-iterate what we have
 
said several times since
 
the acquisition of Credit
 
Suisse over two years
 
ago, in principle,
we fully
 
support the further
 
strengthening of
 
regulation based on
 
lessons learned from
 
the events leading
 
up to
March 2023, provided the amendments are targeted,
 
proportionate and internationally aligned,
 
and duly consider
the actual root causes of Credit Suisse’s collapse, including
 
the significant regulatory concessions.
 
Unfortunately,
 
the
 
proposals
 
on
 
capital
 
requirements,
 
both
 
at
 
the
 
ordinance
 
and
 
law
 
level,
 
do
 
not
 
meet
 
these
standards.
 
These
 
proposals
 
would
 
unduly
 
penalize
 
UBS,
 
which
 
has
 
operated
 
without regulatory
 
concessions and
 
was
 
in
 
a
position to credibly step
 
in and rescue Credit
 
Suisse, contributing to the stability of
 
the Swiss and global
 
financial
systems in March of 2023.
 
 
 
 
 
2
One critical shortcoming of the proposals is
 
that they don’t differentiate between going-concern capital and loss-
absorbing capacity in recovery
 
and resolution. This
 
disregards the availability of
 
other loss-absorbing instruments,
which in our case amount to 20 billion in
 
AT1 and 100 billion in loss absorbing debt.
Slide 3 – UBS supports in principle enhancing regulation
As you can see, we support or broadly support all the
 
initiatives in principle, except for those related to capital.
 
Our sustainable
 
and diversified
 
business model,
 
and strong
 
capital and
 
liquidity positions,
 
contribute
 
to the
 
resilience
of
 
the
 
Swiss
 
financial
 
center,
 
and
 
are
 
complemented
 
by
 
a
 
credible
 
recovery
 
and
 
resolution
 
plan
 
that
 
we
 
have
developed over many years.
We
 
continue to
 
support efforts
 
to
 
further
 
enhance our
 
resolvability,
 
although some
 
important clarifications
 
are
needed.
Slide 4 – Sum of the proposed capital measures is by far
 
the strictest regime among peers
This
 
chart
 
illustrates
 
why
 
we
 
believe
 
the
 
proposed
 
capital
 
measures
 
go
 
well
 
beyond
 
the
 
global
 
norms,
 
despite
intentions to align with international
 
standards.
 
It also shows that while some regimes are more demanding than others on
 
certain elements, they compensate for
that in other areas, resulting in a more balanced capital regime.
That is why it is critical to look at the full regulatory picture
 
and not just isolated components.
Slide 5
 
– Proposed
 
capital measures
 
are extreme
 
and would
 
make UBS
 
a pronounced
 
outlier, while also
 
understating
its CET1 ratio
This
 
chart
 
illustrates
 
how
 
the
 
proposed
 
changes
 
would
 
significantly
 
undermine
 
our
 
competitive
 
position
 
when
comparing minimum requirements.
 
The Swiss regime, particularly after the full
 
implementation of Basel 3, is one of
 
the strictest globally.
 
Due to this,
our current regulatory requirements are already much higher than peers on a like-for-like basis.
 
So our current true
 
minimum on a
 
comparative basis is
 
therefore actually closer to
 
16%, which is
 
well above peers,
many of which have a much higher risk profile.
 
No matter how
 
CET1 capital ratios
 
are presented, the
 
legislative proposals still
 
result in an
 
increase of around
 
24
billion in CET1 capital.
 
And equity is the most expensive form of financing.
 
Considering that UBS’s cost of equity, as determined by the market, has remained stable at around
 
10% over the
last ten years, this level of capital overshooting
 
is not something we can accept.
 
With that, I hand over to Todd who will take you through our position in more detail.
 
 
 
 
3
Todd
 
Tuckner
Slide 6 – CAO proposals would unduly eliminate ~11bn
 
of CET1 capital at Group level
 
Thanks Sergio. Let me dive a bit deeper into the
 
ordinance proposals and how we framed our response.
 
It is
 
important to
 
re-iterate that,
 
in addition
 
to being
 
excessive and
 
misaligned with
 
international standards,
 
the
proposals fail to address the key lessons learned at Credit
 
Suisse’s parent bank, which was the stated intention of
the Swiss Federal Council’s proposals from the beginning.
 
If adopted as
 
proposed, the ordinance changes,
 
which I’ll cover
 
momentarily, would eliminate around 11
 
billion, or
12%, of Group equity as eligible capital.
 
By contrast, at the parent company
 
level, the ordinance proposals would
erode 3 billion , or 3%, of UBS AG’s standalone equity
 
as eligible capital.
Slide 7 – Full deduction of capitalized software lacks regulatory
 
and economic justification
Turning to slide 7 and starting with capitalized software.
 
The use and development of software is fundamental to how banks operate and compete. Software supports the
running
 
of
 
daily
 
operations,
 
augments
 
a
 
bank’s
 
risk
 
control
 
environment,
 
enhances
 
the
 
client
 
experience
 
and
enables strategic transformation.
 
Generally
 
speaking,
 
software,
 
whether
 
purchased
 
or
 
internally developed,
 
is
 
commonly
 
capitalized on
 
a
 
bank’s
balance sheet to reflect future economic benefits and
 
is amortized over its expected life.
 
The proposals would entirely
 
remove capitalized software from
 
regulatory capital, thereby ignoring
 
the importance
of software as a strategic competitive differentiator for a
 
financial institution like UBS.
 
Even during periods
 
of severe stress,
 
software assets maintain
 
their utility and
 
remain essential for
 
serving clients
and preserving the value of the franchise.
 
In this light,
 
Credit Suisse’s capitalized
 
software assets retained
 
their economic and
 
accounting value throughout
its crisis. It
 
was only upon
 
the acquisition
 
by UBS and
 
our decision to
 
migrate retained Credit
 
Suisse businesses
 
onto
UBS’s existing systems that partial write-downs were required.
Additionally, a full deduction
 
of capitalized
 
software from regulatory
 
capital would
 
be misaligned
 
with international
standards, ultimately impeding on UBS’s competitiveness.
 
Only
 
a
 
handful
 
of
 
jurisdictions
 
apply
 
such
 
an
 
extreme
 
approach,
 
mainly
 
because
 
capitalized
 
software
 
in
 
those
jurisdictions
 
is
 
generally
 
treated
 
as
 
an
 
intangible
 
asset
 
for
 
financial
 
reporting
 
purposes.
 
On
 
the
 
other
 
hand,
capitalized software is afforded full
 
regulatory capital credit in the US
 
to align with its accounting treatment. And
in the EU, capitalized
 
software counts as
 
regulatory capital and
 
is required to be
 
amortized over a
 
three-year period
regardless of the applicable financial reporting treatment.
 
Slide 8 – Deduction of
 
temporary difference DTAs (TD DTAs) would be misaligned with all other major
 
jurisdictions
and would not reflect realizable asset value
 
Turning to DTAs on slide 8. The proposal
 
– to fully deduct
 
from regulatory capital –
 
deferred tax assets arising
 
from
temporary differences
 
is without
 
precedent. No
 
peer jurisdiction
 
– whether
 
the EU,
 
UK, or
 
US –
 
applies such
 
extreme
treatment.
 
Temporary
 
difference DTAs
 
are very common
 
across banks and
 
apply to a
 
wide variety of situations
 
whereby the
expense for
 
financial reporting
 
purposes precedes
 
the timing
 
of the
 
deduction for
 
tax purposes.
 
Common examples
include charges for credit
 
losses, deferred compensation and
 
litigation where the tax
 
benefit comes later in
 
time,
thereby informing an asset on the balance sheet.
 
 
4
To
 
mitigate risks
 
in ultimately
 
realizing their
 
value, international
 
standards already
 
limit the
 
recognition of
 
these
assets to 10% of regulatory capital and apply risk-weights
 
of 250%.
 
The
 
argument
 
that
 
the
 
current
 
regulatory
 
capital
 
treatment
 
of
 
temporary
 
difference
 
DTAs
 
is
 
pro-cyclical
 
is
 
not
supported
 
by
 
the
 
facts.
 
The
 
DTA
 
write-downs
 
at
 
Credit
 
Suisse
 
were
 
not
 
caused
 
by
 
flaws
 
in
 
the
 
regulatory
framework, but
 
rather were
 
a result
 
of management
 
decisions to
 
substantially restructure
 
Credit Suisse’s
 
investment
bank.
 
The majority of
 
UBS’s temporary
 
difference deferred tax assets
 
are linked to our
 
core wealth management
 
business
in the
 
US. And
 
these have
 
proven to
 
be resilient,
 
even in
 
times of
 
financial stress.
 
Moreover,
 
our fundamentally
different business model in contrast to Credit Suisse makes similar write-downs
 
of our DTAs highly unlikely.
Slide 9 – PVA measures should not be based on business combination accounting
Finally, turning to slide
 
9 on
 
PVAs. Prudential valuation
 
adjustments reflect
 
an uncertainty
 
overlay in
 
a bank’s
 
capital
relating to difficult-to-value securities and derivatives.
The Federal Council justifies stricter treatment
 
of PVAs
 
by referencing the
 
extensive security position write-downs
on Credit
 
Suisse’s balance
 
sheet at
 
the close
 
of the
 
acquisition. We
 
believe this
 
argumentation is
 
incorrect. The
write downs reflected
 
purchase price allocation adjustments that
 
UBS considered appropriate as
 
part of standard
acquisition accounting.
 
PVAs
 
are designed
 
to account
 
for valuation
 
uncertainty in
 
ongoing business
 
operations and
 
should therefore
 
be
viewed in
 
the context of
 
our Level 3
 
asset profile. Today,
 
our holdings amount
 
to only
 
one-tenth of what
 
Credit
Suisse and UBS
 
reported on a
 
pro-forma basis in
 
2007. Since 2Q23,
 
through the run-down
 
of our Non-core
 
and
Legacy portfolio we have further
 
reduced Level 3 assets by around 60%
 
to 16 billion, which is less
 
than 1% of our
total balance
 
sheet. The
 
proposed PVA measures
 
do not
 
reflect the progress
 
UBS has
 
made in
 
substantially reducing
the valuation uncertainty on its balance sheet.
Finally, a brief word on AT1. AT1
 
instruments play an essential role in
 
a crisis. The fact that
 
UBS was able to restart
AT1 issuances with strong
 
demand soon
 
after the rescue
 
of Credit Suisse
 
is evidence
 
of investor
 
confidence in
 
these
instruments, including importantly under
 
the current Swiss regime and notwithstanding Credit Suisse events.
We
 
support steps
 
to further
 
strengthen AT1
 
instruments as
 
an effective
 
recovery tool,
 
provided
 
reforms remain
consistent with established international
 
practice. Our principal concern
 
with the current proposal is the automatic
suspension
 
of
 
AT1
 
coupon payments
 
after
 
four
 
consecutive
 
quarters
 
of
 
cumulative losses,
 
regardless
 
of
 
capital
strength. We believe
 
a more appropriate
 
and transparent approach
 
is to link
 
any restriction on interest
 
payments
to the breach of a clearly pre-defined capital ratio trigger.
 
Slide 10 – TBTF regulatory process
As you can
 
see from the
 
timeline on slide
 
10, the regulatory
 
process remains ongoing
 
with the Federal
 
Council’s
publication of final ordinance changes expected by mid-next year at
 
the latest. The consultation on proposed law
changes relating to
 
foreign participations
 
is just underway
 
and is set
 
to conclude
 
early next year, with
 
parliamentary
deliberations expected to extend into 2027.
 
Given the
 
wide range
 
of potential
 
outcomes, it
 
is premature
 
to discuss
 
mitigating actions
 
at this
 
stage. We
 
will
share details of our
 
plans once there is sufficient
 
clarity – ideally on
 
the basis of a
 
balanced and reasonable solution
when compared to that contained in the current series
 
of proposals.
With that let’s open-up for Q&A.
5
Analyst Q&A (CEO
 
and CFO)
Giulia Aurora Miotto, Morgan Stanley
 
Yes,
 
hi, good morning. Thank you for the
 
presentation and the document. It's very
 
clear.
 
I have two questions.
The first
 
one, so
 
you make
 
a very
 
strong point
 
as to
 
why this
 
is not
 
internationally aligned, but
 
if Switzerland
doesn't change
 
anything, would
 
you consider
 
moving headquarters?
 
There have been
 
several articles
 
in the press
on this topic. Thank you.
And
 
the
 
second
 
question
 
is
 
about
 
what
 
would
 
be
 
an
 
acceptable
 
solution
 
for
 
you,
 
especially
 
on
 
the
 
foreign
subsidiary point? Thank you.
Sergio P.
 
Ermotti
 
Well, thank you, Giulia. I'm sorry to disappoint you, but I'm not really in a position to answer this question. First
of
 
all,
 
you
 
know,
 
as
 
I
 
mentioned, and
 
we
 
mentioned many
 
times,
 
our
 
ultimate goal
 
is
 
to
 
have
 
a
 
reasonable
solution out of
 
this political
 
process so that
 
we can continue
 
to compete
 
as a global
 
bank out of
 
Switzerland with
our current business
 
model. So, we're
 
not going to
 
enter into any
 
speculations or commenting even
 
on media
articles or representations about our intentions to take any
 
steps in that sense.
And also,
 
in respect
 
of, let me
 
point out
 
once again that
 
this is
 
not a
 
negotiation and I'm
 
hearing all the
 
time
that we should compromise
 
or we should be willing
 
to compromise. Well, as you
 
can hear and see that
 
our tone
and approach to these
 
topics are constructive. We do
 
recognize that there are
 
lessons to be learned out of the
Credit
 
Suisse
 
crisis,
 
but
 
they
 
need
 
to
 
be
 
comprehensive
 
and
 
they
 
need
 
to
 
be
 
balanced
 
and
 
they
 
need
 
to
 
be
internationally aligned. So,
 
in my
 
point of
 
view,
 
if they
 
fulfill those
 
requirements in
 
a balanced
 
way,
 
then it
 
is
what it is and
 
we would see that as
 
a balanced outcome. But a compromise
 
is usually something that happens
between two people negotiating, and which
 
we are not a party on any negotiation.
Giulia Aurora Miotto, Morgan Stanley
 
Thank you.
Chris Hallam, Goldman Sachs
 
Yes.
 
Good morning, everybody,
 
two questions. First, when do you expect
 
to get confirmation on the transition
period for
 
the initial
 
deductions on
 
software, DTAs,
 
PVAs?
 
Do you
 
expect to
 
have that
 
by the
 
time of
 
fourth
quarter results in order to be
 
able to guide for 2026 capital planning and capital distribution because
 
I suppose
that’s really a, you know reflects your Jan 1
st
 
2027 capital position?
And then second, I guess
 
slightly differently on the AT1's I suppose one peculiarity
 
of the proposal is that a well-
capitalized but a
 
less profitable bank would
 
be disincentivized to
 
undertake the required restructuring
 
to fix their
business because of that four quarter look-back proposal, you
 
know, that clearly has echoes, I
 
guess, of the CS
failure. That feels fairly illogical
 
intuitively. So, what's your sense on the probability that
 
that is the end state that
we get to on Swiss AT1’s?
6
Sergio P.
 
Ermotti
 
Let me take the first
 
one and Todd can take on the second.
 
On the timing, I think
 
this is, you know, it's not
 
likely
that we're going to get clarity by the beginning of the year when we will announce our capital return policy for
2026 because the
 
submissions, as you
 
know, ended
 
yesterday.
 
So, I
 
think that the
 
SIF will
 
have to go
 
through
the analysis of all submissions and,
 
I mean, we are
 
not in control of
 
the timing but it looks a
 
little bit optimistic
to expect an outcome in such a short period of time so. And then it remains a decision of the government how
they want to
 
eventually announce and
 
implement what they
 
are proposing.
 
And the only
 
thing we know
 
that
it’s unlikely
 
to be
 
before
 
January 1
st
 
2027. And
 
there this
 
is
 
unfortunately,
 
probably early
 
on next
 
year we're
going to have more visibility on that. But you know, again, it's not a question
 
that we can answer directly.
Todd
 
Tuckner
Chris, on
 
the AT1 point,
 
I agree with
 
your general
 
comment that
 
it would
 
seem, the
 
current proposal would
 
seem
to be a disincentive to restructure because at the end of the day, it's always facts and circumstances based for a
given institution,
 
you know
 
how deep
 
would the
 
restructuring be
 
and would
 
it actually
 
be appropriate
 
in any
event to suspend payments on the AT1
 
given the depth of restructuring, but I
 
generally agree that you can get
into situations or envision situations where
 
this proposal would create
 
a real issue when
 
there isn't a real
 
issue.
So, it's making an issue out
 
of one that isn't where,
 
for example, a bank may be
 
going through financial stress
or some
 
other aspects
 
that are
 
less significant,
 
less serious.
 
And as
 
a result,
 
automatically suspending
 
the coupons
because of
 
four consecutive
 
cumulative losses
 
– quarters
 
of cumulative
 
losses –
 
would seem
 
to me
 
to be
 
pro-
cyclical. So,
 
the question
 
though on
 
restructuring, I
 
guess, is
 
a question
 
of that
 
hypothetical bank
 
and the
 
situation
it's in and the depth of the restructuring it has to
 
go through in order to recover.
Sergio P.
 
Ermotti
 
Yes.
 
Let me add
 
on to what
 
Todd
 
mentioned. I think that
 
he's touching on
 
an idiosyncratic situation in
 
such a
scenario. But let me play out another scenario
 
in which you have a more economic downturn
 
in which for some
reason the entire banking system is going through
 
a low level of profitability or small losses, but still
 
having the
resilience to be there and
 
serve clients and prepare
 
for better days. Now,
 
in such a scenario, if you
 
are the only
bank that has to
 
do that kind
 
of write-down, although
 
every other bank
 
is having similar
 
profitability issues, then
it's
 
a
 
stigma
 
that
 
you
 
create
 
on
 
a
 
single
 
institution rather
 
than
 
being
 
something that
 
is
 
aligned.
 
So,
 
it's
 
very
difficult to
 
see –
 
I mean,
 
I understand
 
the reasoning
 
because of
 
what happened
 
at Credit
 
Suisse. Those
 
were
substantial losses that were also creating an even bigger hole in their parent bank capital, but that's not a good
reason to then fix it in this way.
Chris Hallam, Goldman Sachs
 
Thank you. Very clear.
7
Kian Abouhossein, JPMorgan
 
Yes,
 
thanks for taking my questions. The first question is on the ordinance measures. Can you still bundle those
into the legislative package or
 
is that not possible
 
anymore, and what would
 
have to happen if
 
it is possible to
basically get there? What are the key hurdle dates or events that
 
we would have to watch out for?
And then the
 
second question is
 
just taking a
 
step back, who
 
are you
 
actually now talking
 
to considering that
this seems to be a very political process? Looking at the impact of the documents that are coming out, it seems
to be a
 
very domestic
 
focused audience,
 
I mean, the
 
documents are not
 
even in English,
 
most of them,
 
but rather
than do they have a good understanding of how
 
it sets you apart from international competitors? And do they
really care?
 
That's the
 
impression I
 
get; they
 
don't really
 
care. So,
 
can you
 
just talk
 
about your
 
feedback from
your negotiations and talks with the other parties,
 
I guess with the government at
 
this point, or where we are?
Sergio P.
 
Ermotti
 
First, on the first
 
question, I think that,
 
yes in theory, things can somehow come
 
together if, but
 
this is a decision
of the Federal Council
 
to how to
 
then either implement immediately after
 
they consider all the
 
submissions on
the consultation or to wait until they find and they analyze the submissions related to the consultation that just
opened. So, it's in
 
their prerogative to thinking
 
what they want to
 
do. So, I have
 
no indication that they're
 
going
to take
 
one direction
 
or the
 
other.
 
So, as
 
we stand
 
right now,
 
it looks
 
like the
 
ordinance will
 
be implemented
before. But, you know, this is a political process and one in which, depending on
 
the input from various parties,
including banks and a broader economy, and, you know, it may lead into a different outcome. So, in a nutshell,
the answer to your
 
question is yes, it's still
 
possible to bring them together,
 
not formally,
 
but de-facto because
they would be then implemented and addressed at
 
the same time.
Then, well, look,
 
we are talking, well,
 
first of all, now
 
we are talking reactively
 
by, you know, in the consultation,
by answering formally to many points that we raised in the past and making it even clearer. Our position, we're
complementing it with more data points and more in-depth analysis. I think that it's fair to say that as we went
deeper in
 
analyzing not
 
only more
 
international standards and
 
how other
 
jurisdictions are
 
operating, that
 
has
given us even more conviction that the proposals we see right now
 
on capital are not balanced and not really in
line with addressing the true lessons learned
 
from the Credit Suisse crisis.
Now, in
 
respect of who
 
we are talking
 
to, we are
 
responding to solicitations, also
 
formal solicitations from the
Economic Commissions that will want to hear
 
our views, both the upper and the lower
 
Economic chambers, for
example.
 
We
 
are
 
responding
 
to
 
requests
 
for
 
comments
 
and
 
clarification
 
by
 
political
 
parties
 
and
 
the
 
broader
society and economic associations. But that's
 
the level of interaction.
Now, in response to your topic, yes, I'm sorry if our
 
machine-translated with human
 
touch English version didn't
work
 
out
 
well,
 
but
 
it's
 
our
 
first
 
best
 
attempt,
 
to
 
address
 
this
 
issue.
 
Of
 
course,
 
you
 
know,
 
being
 
a
 
political
submission, it has to be done in one of the official languages
 
in Switzerland, which in that case is – we took
 
the
most popular
 
or the
 
biggest one
 
is the
 
German version.
 
Let me
 
tell you that
 
many more people
 
than we
 
are made
to understand, they
 
care about what's
 
going on right
 
now. I think it's
 
fair to say
 
that all the
 
noises around what's
going on
 
in Switzerland are
 
quite unnecessary in
 
my point of
 
view.
 
And of
 
course, we
 
are lucky
 
that we have
been able to manage this in a fairly benign market situation.
 
Our integration is progressing well. I think that the
last things we need is
 
this kind of noise around Switzerland,
 
which in my point of
 
view did a fantastic job
 
during
the three days of the
 
crisis. But of course,
 
right now it's time
 
to really reconsider how we
 
communicate and how
we approach these kinds of
 
issues. But, again it's not in
 
my control, it’s not in
 
our control, and we do
 
our best
to contribute to a healthy and fact-based discussion.
8
Kian Abouhossein, JPMorgan
 
Thank you.
Amit Goel, Mediobanca
 
Hi,
 
thank
 
you.
 
Yes,
 
two
 
questions
 
from
 
me.
 
One,
 
just
 
in
 
terms
 
of
 
the
 
phasing
 
of
 
the
 
ordinance,
 
so
 
I
 
think
previously you stated that you would expect a
 
kind of a 4-year plus phase-in period. I
 
just wanted to just check
whether that expectation has changed or
 
not based on the commentary and the
 
response?
And then secondly, I guess within the responses,
 
commentary about there's
 
not a – and it's
 
very hard then to do
a holistic or
 
at least for
 
the government
 
to do a
 
holistic and
 
kind of impact
 
study or
 
QIS? I was
 
just kind
 
of curious
whether
 
then,
 
whether you
 
would
 
basically
 
effectively
 
do
 
that
 
and
 
could present
 
that
 
as
 
part
 
of
 
the
 
kind of
helping the
 
politicians understand potential
 
consequences and impact
 
of the
 
measures if
 
they were
 
impacted,
implemented holistically? Thank you.
Sergio P.
 
Ermotti
 
So, the issue on the phase-in is that – what we have reiterated in
 
our submissions is that, I mean – it's still clear
that it's common
 
in this
 
kind of situation
 
to have a
 
phase-in. You
 
saw that in
 
the law part
 
of the
 
proposal it’s
clearly
 
stated
 
at
 
seven
 
years.
 
We
 
have
 
been
 
made
 
to
 
understand
 
that
 
it's
 
also
 
going
 
to
 
be
 
the
 
case
 
for
 
the
ordinance. And this is going to start from 2027, but the fact that it was not clearly stated in the proposal of the
ordinance made
 
us, just
 
for good
 
order we
 
pointed out
 
that this
 
is still
 
missing. And
 
I think
 
that, I
 
believe it’s
quite common and
 
clear that we
 
will have a
 
phase-in. I think
 
that the four
 
years, I don’t
 
remember us saying
 
four
years,
 
but
 
probably
 
was
 
like,
 
if
 
we
 
mention
 
it
 
is
 
the
 
minimum
 
common
 
reasonable
 
timing
 
for
 
phasing
 
in
something like
 
that,
 
but
 
it
 
is
 
just
 
for
 
good
 
order
 
that we
 
are
 
pointing it
 
out.
 
We
 
haven’t really
 
changed our
understanding and conviction that it’s going
 
to be a phase-in also for the ordinance when
 
it comes.
In terms of, yes, we will analyze this issue. To
 
be honest, I think that we will need to seriously think about if it’s
better for us to do it, I mean a UBS one would be always taken with a little bit of, you know, I don’t know how
to formulate it
 
diplomatically,
 
but probably
 
in a
 
way that
 
is a
 
suspicious way.
 
So, we
 
rather have independent
people having such
 
studies and at being
 
able to outline
 
in a balanced
 
way what it
 
is, but in
 
case we don’t see
any of them happening, we may
 
consider having our view on the
 
matter so that at least
 
we are on the
 
record.
But hopefully it's not going to be necessary.
Amit Goel, Mediobanca
Thank you. And just
 
to clarify what you’re
 
saying, you anticipate or you
 
would expect a seven
 
year phase-in or
sorry –
 
9
Sergio P.
 
Ermotti
 
No, we
 
don’t know.
 
It’s not
 
because the
 
current proposal
 
on subsidiaries
 
is seven
 
years that
 
the same
 
will be
applied
 
to
 
the
 
ordinance.
 
We
 
would
 
say
 
that,
 
most
 
likely
 
a
 
minimum
 
of
 
four,
 
it’s
 
likely
 
to
 
happen
 
for
 
the
ordinance, while on the law one, it’s already clear it is seven.
Amit Goel, Mediobanca
 
Got it. Thank you.
Stefan Stalmann, Autonomous Research
Good morning. Thank
 
you very much
 
for the presentation.
 
Very
 
useful. I wanted
 
to ask
 
please on
 
the original
document on
 
page
 
21.
 
It
 
says
 
that
 
full
 
reduction
 
from
 
CET1
 
capital will
 
correspond
 
to
 
an
 
increase
 
in
 
capital
coverage of foreign
 
subsidiaries from 60%
 
to a 130%,
 
and I was
 
wondering what
 
the math is
 
behind the 130%,
please?
And the
 
second question, I
 
appreciate that
 
you don’t want
 
to talk
 
about mitigation yet,
 
but I’m
 
wondering in
particular about your DTAs on timing differences.
 
You have
 
quite a substantial amount there that relates to the
treatment of US real estate, and I’m
 
not quite sure what that actually
 
is and it seems a
 
bit different to what I see
at other banks.
 
Could you maybe
 
explain what’s driving
 
this relatively large
 
DTA
 
item related
 
to US real
 
estate
and whether that could actually be changed?
 
Thank you.
Todd
 
Tuckner
Hi, Stefan. So, on the first question, the math
 
on the more than 100 to 130
 
is just factoring in AT1.
 
So, it’s the
whole Tier 1 stack that is the math
 
behind.
On the DTA
 
question, in terms of the real estate,
 
so that’s part of the stack of temp
 
difference DTAs
 
in the US,
as you point out,
 
we have effectively generated
 
these temp difference
 
DTAs because
 
we have deferred the
 
tax
deduction on
 
a lot
 
of the
 
real estate
 
and leaseholds
 
that we
 
have in
 
the branch
 
network in
 
the US.
 
We have
deferred
 
the
 
deductions in
 
relation
 
to
 
leaseholds that
 
create
 
temp
 
difference
 
DTAs
 
and
 
historically have
 
also
accounted for
 
at least
 
up to
 
10% regulatory
 
capital. But
 
in addition
 
to that,
 
we also
 
have the
 
more standard
temporary differences
 
that I have
 
called out including
 
deferred compensation as
 
one example, expected
 
credit
losses as another.
 
So, it’s an
 
array of that,
 
but the real
 
estate position that
 
you point out
 
does in fact
 
relate to
the branch network and in the US business, and historically
 
has been a substantial component of our DTA stack
in the US.
Stefan Stalmann, Autonomous Research
Are you effectively depreciating your leaseholds faster than the IRS recognized
 
for your taxable purposes?
10
Todd
 
Tuckner
Yes,
 
we
 
effectively
 
have,
 
we’ve
 
pushed
 
out
 
the
 
tax
 
deduction
 
beyond
 
the
 
book
 
expense,
 
correct.
 
So,
 
we
amortized the
 
leaseholds under
 
the accounting
 
standard and we
 
take the
 
tax benefit
 
over a longer
 
period of
 
time
under US tax principles.
Stefan Stalmann, Autonomous Research
Thank you. Very helpful. Thank you very much.
Sergio P.
 
Ermotti
 
It was the last question.
 
Thanks for calling in.
 
I hope you found the
 
document useful and my
 
colleagues in the IR
team are at your disposal, if you have any further
 
clarification. Thank you and have a nice day.
 
11
Cautionary
 
Statement
 
Regarding
 
Forward-Looking
 
Statements
 
|
 
This
 
document
 
contains
 
statements
 
that
 
constitute
 
“forward-looking
 
statements”,
including but not limited to management’s outlook for
 
UBS’s financial performance, statements relating to the anticipated effect
 
of transactions and strategic
initiatives on UBS’s business and future development and goals or intentions to achieve climate, sustainability and other social objectives. While these forward-
looking
 
statements
 
represent
 
UBS’s
 
judgments, expectations
 
and
 
objectives concerning
 
the
 
matters
 
described, a
 
number
 
of
 
risks,
 
uncertainties and
 
other
important factors
 
could cause
 
actual developments
 
and results
 
to differ
 
materially from
 
UBS’s expectations.
 
In particular, the
 
global economy
 
may suffer
 
significant
adverse effects
 
from increasing
 
political tensions
 
between world
 
powers, changes
 
to international trade
 
policies, including those
 
related to
 
tariffs and
 
trade
barriers, and
 
ongoing conflicts in
 
the Middle East,
 
as well
 
as the
 
continuing Russia–Ukraine war.
 
UBS’s acquisition of
 
the Credit
 
Suisse Group
 
has materially
changed its outlook
 
and strategic direction
 
and introduced new
 
operational challenges. The integration
 
of the Credit
 
Suisse entities into
 
the UBS structure
 
is
expected to
 
continue through
 
2026 and
 
presents significant
 
operational and
 
execution risk,
 
including the
 
risks that
 
UBS may
 
be unable
 
to achieve
 
the cost
reductions and business benefits
 
contemplated by the
 
transaction, that it
 
may incur higher costs
 
to execute the integration
 
of Credit Suisse and
 
that the acquired
business may have
 
greater risks or
 
liabilities than expected. Following
 
the failure of
 
Credit Suisse, Switzerland is
 
considering significant changes to
 
its capital,
resolution and
 
regulatory regime,
 
which, if
 
proposed and
 
adopted, may
 
significantly increase
 
our capital
 
requirements or
 
impose other
 
costs on
 
UBS. These
factors create greater uncertainty about forward-looking statements. Other
 
factors that may affect UBS’s performance and ability
 
to achieve its plans, outlook
and other objectives
 
also include, but
 
are not limited
 
to: (i) the degree
 
to which UBS
 
is successful in
 
the execution of
 
its strategic plans,
 
including its cost
 
reduction
and efficiency initiatives and
 
its ability to manage
 
its levels of risk-weighted
 
assets (RWA) and leverage ratio
 
denominator (LRD), liquidity
 
coverage ratio and
 
other
financial resources, including changes in
 
RWA assets and liabilities arising
 
from higher market volatility and
 
the size of the
 
combined Group; (ii) the degree
 
to
which UBS
 
is successful
 
in implementing changes
 
to its
 
businesses to meet
 
changing market, regulatory
 
and other
 
conditions; (iii) inflation
 
and interest
 
rate
volatility in
 
major markets;
 
(iv) developments
 
in the
 
macroeconomic climate
 
and in
 
the markets
 
in which
 
UBS operates
 
or to
 
which it
 
is exposed,
 
including
movements in securities prices
 
or liquidity, credit spreads, currency exchange rates, residential
 
and commercial real estate markets,
 
general economic conditions,
and changes to national trade policies on the financial position or creditworthiness of UBS’s clients
 
and counterparties, as well as on client sentiment and levels
of activity;
 
(v) changes
 
in the
 
availability of
 
capital and
 
funding, including any
 
adverse changes
 
in UBS’s
 
credit spreads
 
and credit
 
ratings of
 
UBS, as
 
well as
availability and
 
cost of
 
funding to
 
meet requirements
 
for debt
 
eligible for
 
total loss-absorbing
 
capacity (TLAC);
 
(vi) changes
 
in central
 
bank policies
 
or
 
the
implementation of financial legislation and
 
regulation in Switzerland, the US,
 
the UK, the EU
 
and other financial centers
 
that
 
have imposed, or resulted
 
in, or
may do so in the future, more stringent or entity-specific capital, TLAC, leverage ratio, net stable funding ratio, liquidity and funding requirements, heightened
operational resilience requirements, incremental tax requirements, additional levies, limitations on permitted activities, constraints on remuneration, constraints
on transfers
 
of capital
 
and liquidity
 
and sharing
 
of operational
 
costs across
 
the Group
 
or other
 
measures, and
 
the effect
 
these will
 
or would
 
have on
 
UBS’s
business
 
activities; (vii) UBS’s ability to successfully implement resolvability and related regulatory requirements and the potential need to make further changes
to the legal structure
 
or booking model of UBS
 
in response to legal and
 
regulatory requirements and any additional
 
requirements due to its acquisition
 
of the
Credit Suisse Group, or other developments;
 
(viii) UBS’s ability to maintain
 
and improve its systems and controls
 
for complying with sanctions in
 
a timely manner
and for the detection and prevention
 
of money laundering to meet evolving regulatory
 
requirements and expectations, in particular in the
 
current geopolitical
turmoil; (ix) the uncertainty arising from domestic stresses in certain major economies; (x) changes in UBS’s competitive position, including whether differences
in regulatory capital and other requirements among the
 
major financial centers adversely affect UBS’s
 
ability to compete in certain lines of business;
 
(xi) changes
in the standards of conduct applicable to its businesses that may result from
 
new regulations or new enforcement of existing standards, including measures to
impose new and enhanced duties when interacting with customers and
 
in the execution and handling of customer transactions; (xii)
 
the liability to which UBS
may be
 
exposed, or
 
possible constraints
 
or sanctions
 
that regulatory
 
authorities might
 
impose on
 
UBS, due
 
to litigation,
 
contractual claims
 
and regulatory
investigations, including the
 
potential for disqualification
 
from certain businesses,
 
potentially large fines
 
or monetary penalties,
 
or the loss of
 
licenses or privileges
as
 
a
 
result
 
of
 
regulatory or
 
other governmental
 
sanctions, as
 
well as
 
the effect
 
that litigation,
 
regulatory and
 
similar matters
 
have on
 
the operational
 
risk
component of its RWA; (xiii) UBS’s
 
ability to retain and attract the
 
employees necessary to generate
 
revenues and to manage, support
 
and control its businesses,
which may
 
be affected
 
by competitive
 
factors; (xiv)
 
changes in
 
accounting or
 
tax standards
 
or policies,
 
and determinations
 
or interpretations
 
affecting
 
the
recognition of gain or loss, the valuation of goodwill,
 
the recognition of deferred tax assets and other matters;
 
(xv) UBS’s ability to implement new technologies
and business methods,
 
including digital services,
 
artificial intelligence and other
 
technologies, and ability to
 
successfully compete with both
 
existing and new
financial service
 
providers, some of
 
which may
 
not be
 
regulated to
 
the same
 
extent; (xvi)
 
limitations on the
 
effectiveness of
 
UBS’s internal processes
 
for risk
management, risk control,
 
measurement and modeling,
 
and of financial
 
models generally; (xvii)
 
the occurrence of
 
operational failures, such
 
as fraud, misconduct,
unauthorized trading, financial crime, cyberattacks, data leakage and systems failures, the risk of which is increased with persistently high levels of
 
cyberattack
threats; (xviii) restrictions
 
on the ability of
 
UBS Group AG, UBS
 
AG and regulated subsidiaries of
 
UBS AG to make
 
payments or distributions, including due
 
to
restrictions on the
 
ability of its
 
subsidiaries to make
 
loans or distributions,
 
directly or indirectly, or, in the case
 
of financial difficulties,
 
due to the
 
exercise by FINMA
or
 
the
 
regulators
 
of
 
UBS’s
 
operations
 
in
 
other
 
countries
 
of
 
their
 
broad
 
statutory
 
powers
 
in
 
relation
 
to
 
protective
 
measures,
 
restructuring
 
and
 
liquidation
proceedings; (xix) the degree to which changes
 
in regulation, capital or legal structure, financial results
 
or other factors may affect UBS’s ability
 
to maintain its
stated capital return objective; (xx)
 
uncertainty over the scope of
 
actions that may be required by UBS, governments
 
and others for UBS to achieve goals
 
relating
to climate, environmental and social matters, as well as the evolving
 
nature of underlying science and industry and the possibility of conflict
 
between different
governmental standards and regulatory regimes; (xxi) the ability of UBS to access capital markets; (xxii) the ability of UBS to successfully recover from
 
a disaster
or other business continuity problem
 
due to a
 
hurricane, flood, earthquake, terrorist attack, war,
 
conflict, pandemic, security breach, cyberattack, power
 
loss,
telecommunications failure or
 
other natural or man-made
 
event; and (xxiii) the
 
effect that these or other
 
factors or unanticipated
 
events, including media reports
and speculations, may have on its reputation and the additional consequences that this may have on its business and performance. The sequence in which the
factors above are
 
presented is not
 
indicative of their
 
likelihood of occurrence
 
or the potential
 
magnitude of their
 
consequences. UBS’s business and
 
financial
performance could be affected
 
by other factors identified
 
in its past
 
and future filings
 
and reports, including
 
those filed with
 
the US Securities
 
and Exchange
Commission (the SEC).
 
More detailed information
 
about those factors
 
is set forth
 
in documents furnished
 
by UBS and
 
filings made by
 
UBS with the
 
SEC, including
the UBS Group AG and
 
UBS AG Annual Reports
 
on Form 20-F for the
 
year ended 31 December
 
2024. UBS is not
 
under any obligation to
 
(and expressly disclaims
any obligation to) update or alter its forward-looking
 
statements, whether as a result of new information,
 
future events, or otherwise.
Disclaimer:
This document and the information contained herein are provided solely for information purposes, and are not to be construed as a solicitation of
an offer to buy or sell any securities or other financial instruments in Switzerland, the United States or any other jurisdiction. No investment decision relating to
securities of or relating to UBS Group AG, UBS
 
AG, or their affiliates should be made on the basis of
 
this document. No representation or warranty is made or
implied concerning, and UBS assumes no responsibility for, the accuracy,
 
completeness, reliability or comparability of the information contained herein relating
to third parties, which is based solely on publicly
 
available information. UBS undertakes no obligation
 
to update the information contained
 
herein.
Alternative Performance Measures:
 
In addition to reporting results in accordance with International
 
Financial Reporting Standards (IFRS), UBS reports certain
measures that
 
may qualify
 
as Alternative
 
Performance Measures
 
as defined
 
in the
 
SIX Exchange
 
Directive on
 
Alternative Performance
 
Measures, under
 
the
guidelines published by
 
the European Securities
 
Market Authority (ESMA), or
 
defined as Non-GAAP financial
 
measures in
 
regulations promulgated by
 
the US
Securities and Exchange
 
Commission (SEC).
 
Please refer to “Alternative
 
Performance Measures” in
 
the appendix of
 
UBS’s Quarterly Report
 
for the second
 
quarter
of 2025 for a list of all measures UBS uses that may qualify as APMs. Underlying results are non-GAAP financial measures as defined by SEC regulations and as
APMs in Switzerland and the EU.
© UBS 2025. The key symbol and UBS are among
 
the registered and unregistered trademarks of UBS. All rights
 
reserved.
 
 
 
 
SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934, the
 
registrants have duly
caused this report to be signed on their behalf by the undersigned, thereunto
 
duly authorized.
UBS Group AG
By:
 
/s/ David Kelly
 
_
Name:
 
David Kelly
Title:
 
Managing Director
 
By:
 
/s/ Ella Copetti-Campi
 
_
Name:
 
Ella Copetti-Campi
Title:
 
Executive Director
UBS AG
By:
 
/s/ David Kelly
 
_
Name:
 
David Kelly
Title:
 
Managing Director
 
By:
 
/s/ Ella Copetti-Campi
 
_
Name:
 
Ella Copetti-Campi
Title:
 
Executive Director
Date:
 
October 1, 2025