Sec Form 3 Filing - Palomaki Daniel Scott @ HSBC HOLDINGS PLC - 2026-04-01

FORM 3 Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person Palomaki Daniel Scott 2. Issuer Name and Ticker or Trading Symbol HSBC HOLDINGS PLC [ HSBC] 5. Relationship of Reporting Person(s) to Issuer (Check all applicable) _____ Director _____ 10% Owner X __ Officer (give title below) _____ Other (specify below) Global Financial Controller (Last) (First) (Middle) 8 CANADA SQUARE, LONDON 3. Date of Earliest Transaction (MM/DD/YY) 04/01/2026 (Street) LONDONE14 5HQ 4. If Amendment, Date Original Filed (MM/DD/YY) 6. Individual or Joint/Group Filing (Check Applicable Line) __ X __ Form filed by One Reporting Person _____ Form filed by More than One Reporting Person (City) (State) (Zip)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned 1.Title of Security (Instr. 3) 2. Transaction Date (MM/DD/YY) 2A. Deemed Execution Date, if any (MM/DD/YY) 3. Transaction Code (Instr. 8) 4. Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5) 5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4) 6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 7. Nature of Indirect Beneficial Ownership (Instr. 4) Code V Amount (A) or (D) Price Ordinary shares of US$0.50 28,096 D

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned ( e.g. , puts, calls, warrants, options, convertible securities) 1. Title of Derivative Security (Instr. 3) 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (MM/DD/YY) 3A. Deemed Execution Date, if any (MM/DD/YY) 4. Transaction Code (Instr. 8) 5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4, and 5) 6. Date Exercisable and Expiration Date (MM/DD/YY) 7. Title and Amount of Underlying Securities (Instr. 3 and 4) 8. Price of Derivative Security (Instr. 5) 9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4) 10. Ownership Form of Derivative Security: Direct (D) or Indirect (I) (Instr. 4) 11. Nature of Indirect Beneficial Ownership (Instr. 4) Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares Conditional Award $ 0 ( 1 ) ( 2 ) Ordinary shares of US$0.50 27,260 D Conditional Award $ 0 ( 3 ) ( 2 ) Ordinary shares of US$0.50 19,814 D Conditional Award $ 0 ( 4 ) ( 2 ) Ordinary shares of US$0.50 15,241 D Dividend Equivalent Rights $ 0 ( 5 ) ( 5 ) ( 5 ) Ordinary shares of US$0.50 428 D

Reporting Owners Reporting Owner Name / Address Relationships Director 10% Owner Officer Other Palomaki Daniel Scott 8 CANADA SQUARE, LONDON LONDONE14 5HQ Global Financial Controller Signatures /s/ Lee Thomas Davis as attorney-in-fact for Palomaki Daniel Scott 04/02/2026 Signature of Reporting Person Date

Explanation of Responses:

( 1 )On August 15, 2024, Mr. Palomaki received a grant of a conditional award representing the right to potentially receive 80,196 ordinary shares, of which 52,936 ordinary shares have vested and been settled. The remainder of the conditional award will vest in March 2027 (18,162 ordinary shares) and March 2028 (9,098 ordinary shares). All vested conditional awards are settled in ordinary shares within 30 days of vesting, but may be cash-settled at the election of the HSBC Holdings plc board of directors. ( 2 )All vested conditional awards are settled in Ordinary Shares within 30 days of vesting, but may be cash-settled at the election of HSBC Holdings plc board of directors. ( 3 )On March 12, 2025, Mr. Palomaki received a grant of a conditional award representing the right to potentially receive 26,418 ordinary shares, 25% of which has vested and been settled in ordinary shares. The remaining 75% of the conditional award vests in three equal annual instalments in March of each of 2027, 2028, and 2029. ( 4 )On March 9, 2026, Mr. Palomaki received a grant of a conditional award representing the right to potentially receive 15,241 ordinary shares. The conditional award vests in four equal annual installments in March of each year, ending in March 2030. Mr. Palomaki is eligible to earn dividend equivalent units on this conditional award. ( 5 )Divided equivalent rights (DERs) accrued on Mr. Palomaki conditional award granted on March 9, 2026. The rights accrue when and as dividends are paid on HSBC Holdings plc ordinary shares. Each DER represents the right to receive the economic equivalent of one ordinary share, and can be settled in cash at the election of the HSBC Holdings plc board of directors. The DERs will be settled as soon as practicable following the vesting of the underlying conditional award.

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