{"url_path":"/sec/sapgf/10-k/2026/item-16d","section_key":"item-16d","section_title":"Item 16D EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES**","topic":"sec","document":{"doc_type":"20-F","doc_date":"2026-02-26","source_url":"https://www.sec.gov/Archives/edgar/data/1000184/0001104659-26-020058-index.html","accession_number":"0001104659-26-020058","cik":"0001000184","ticker":"SAP","issuer_name":"SAP SE","edgar_url":"https://www.sec.gov/Archives/edgar/data/1000184/0001104659-26-020058-index.html","primary_entity_key":"0001000184","primary_entity_name":"SAP SE"},"word_count":202,"has_tables":true,"body_markdown":"**ITEM 16D. EXEMPTIONS FROM THE LISTING STANDARDS FOR AUDIT COMMITTEES**\n\nRule 10A-3 of the Exchange Act requires that all members of our audit committee be independent, subject to certain exceptions. In accordance with German law, the Audit and Compliance Committee consists of both employee and shareholder elected members. Rule 10A-3 provides an exception for an employee of a foreign private issuer such as SAP who is not an executive officer of that issuer and who is elected to the supervisory board or audit committee of that issuer pursuant to the issuer’s governing law. In this case, the employee is exempt from the independence requirements of Rule 10A-3 and is permitted to sit on the audit committee.\n\nWe rely on this exemption. Our Audit and Compliance Committee includes four employee representatives, Jakub Černý, César Martin, Dr. Eberhard Schick and Nina Strassner, who were appointed to our Supervisory Board pursuant to the Agreement on the Involvement of Employees in SAP SE (see “Item 6. Directors, Senior Management and Employees*.*” for details). We believe that our reliance on this exemption does not materially adversely affect the ability of our Audit and Compliance Committee to act independently and to satisfy the other requirements of Rule 10A-3."}