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 UBS Group AG Postfach 8098 Zürich Todd Tuckner UBS Group Chief Financial Officer Tel. +41-44 236 8600 Todd.tuckner@ubs.com www.ubs.com Ms. Cara Lubit and Mr. Robert Klein Division of Corporation Finance Securities and Exchange Commission 100 F Street, NE Washington DC 20549-1090 October 10, 2025 UBS Group AG Form 20-F for the Fiscal Year Ended December 31, 2024 Filed March 17, 2025 File No. 001-36764 Dear Ms. Cara Lubit and Mr. Robert Klein, We have reviewed the comments   raised in the Comment   Letter dated September   12, 2025 from the Staff of the Securities and Exchange Commission relating to the annual report on Form 20-F for the fiscal   year   ended   December   31,   2024.   For   your   convenience,   we   have   set   out   the   text   of   each Comment contained in the Comment Letter, followed by our responses. Alternative performance measures, page   8 We note your disclosure, here and elsewhere,   that your alternative performance measures   ("APMs") may qualify as non-GAAP measures. Further, we note disclosure that your underlying results, which are also   discussed on   page 66,   are APMs   and are   non-GAAP financial   measures. In   future filings, please clearly identify   all APMs that   are considered to   be non-GAAP financial   measures and to   the extent that they continue to be presented, ensure that you provide required disclosures, including a reconciliation, under Regulation G and under   Item 10(e) of Regulation S-K, as applicable. UBS response:   In future filings, we   will clearly identify   all non-GAAP measures   and include a reference   to where the required disclosure and reconciliation is presented in the filing.   The APM definition under Swiss   regulations is significantly broader than the   definition of non-GAAP financial measures in Regulation   S-K, and hence not   all APMs used by   us are non-GAAP   measures. For example, “cost/income   ratio” calculated as “operating   expenses divided by total   revenues” is an APM for purposes   of the Swiss   rules (as it is   a ratio of   two required measures) but   is not a non-GAAP financial measure. With respect   to   Regulation G,   we   note   that   UBS   meets the   exemptive   criteria for   foreign   private issuers.

 UBS Group AG Postfach 8098 Zürich Todd Tuckner UBS Group Chief Financial Officer Tel. +41-44 236 8600 Todd.tuckner@ubs.com www.ubs.com 1 Group performance Net fee and commission income, page   68 We   note   your   disclosure,   here   and   on   page   288,   that   Group   Portfolio   management   and   related services and Investment   fund fees totaled $12,323   million and $5,767   million for 2024, respectively, and   that   they   are   predominantly   in   Global   Wealth   Management   and   Asset   Management, respectively. We also note your disclosure on page   382 that Recurring net   fee income includes these revenues. Please expand   your disclosure in   future filings, here   or elsewhere as   appropriate, for the following items: a. Discuss   the   nature   of   these   revenue   streams   and   services,   and   describe   any   material arrangement terms, such as   fee structures or fee rates.   For example, explain the correlation   of invested assets   and fee-generating   assets to   the corresponding   revenue line   items at   Group and, where applicable, business division levels. b. Disclose   how   Portfolio   management and   related   services and   Investment   fund   fee   revenue amounts   reconcile   to   the   Recurring   net   fee   income   and/or   any   other   applicable   business division line amounts presented on pages 73 and   79. c. To   the   extent   that   revenue line   items   at   Group   or   business   division   levels   are   impacted   by multiple change drivers,   expand your discussion   of period-over-period changes   to quantify the impacts   of   each   material   factor   (e.g.,   acquisition,   change   in   invested   asset   mix,   fee   rate movements, etc.). UBS response: UBS discloses   revenues in its   MD&A in   categories, including   recurring income   and transaction   income for Global Wealth   Management and   Personal and   Corporate Banking   and net management   fees and performance fees   for Asset   Management to   provide   investors with   a   better understanding   of the most important   revenue sources   in these   divisions and   to facilitate   discussion in   the MD&A   of the key drivers   affecting business   division results.   Definitions of   these measures   are included   in the   MD&A and the table of Alternative   Performance Measures included   in the Annual Report.   This disclosure is aligned with how management assesses business   performance.   With respect to the specific comments: a. In future Annual Reports, UBS will   expand its discussion of   products, services and fee structures for each business division in “Our strategy, business model and environment” section. 1 Recurring   net   fee   income   of   GWM   includes   ”fees   for   services   provided   on   an   ongoing   basis,   such   as   portfolio management fees,   asset-based investment   fund fees   and custody   fees, which   are   generated on   client assets,   and administrative fees for accounts.” Transaction-based income of GWM includes “the non-recurring portion of net fee and commission income, mainly   composed of brokerage and   transaction-based investment fund fees,   and credit card fees, as well as   fees for payment and foreign   -exchange transactions, together with other   net income from financial instruments measured at fair value through profit or loss”. Asset Management   net management fees,   includes fund   management fees,   and transaction   fees, fund   administration revenues (including net interest and trading income from lending activities   and foreign-exchange hedging as part of the fund services offering),   distribution fees, incremental fund-related expenses,   gains or losses   from seed money and co-investments, funding   costs, the   negative pass-through   impact of   third-party performance   fees, and   other items that are not Asset Management’s performance fees

 UBS Group AG Postfach 8098 Zürich Todd Tuckner UBS Group Chief Financial Officer Tel. +41-44 236 8600 Todd.tuckner@ubs.com www.ubs.com b. The MD&A discussion of net fee and commission income   in the “Group performance” section of the MD&A on page 68   is based on the breakdown of   net fee and commission income   that is disclosed   in   Note   5   to   the   financial   statements   in   line   with   the   requirements   under IFRS   15 Revenue from Contracts with Customers and   IFRS 8 Operating Segments.   In addition to Global Wealth   Management,   Personal   &   Corporate   Banking   and   Asset   Management,   our   Group performance disclosure   also includes   amounts attributable   to the   Investment Bank   and Non-core & Legacy performance segments,   as well as   Group Items. A   breakdown of third-party   fee and commission income by   business division is   provided in the   footnotes to the   table in Note   5 to the financial statements. The information provided in the MD&A discussion for Global Wealth Management, Personal & Corporate   Banking   and   Asset   Management   regarding   recurring,   transaction-based, management   and   performance   fees   is   based   on   the   same   amounts   and   business   division allocation as set   forth in Note   5 to the   financial statements, but is   presented on a   “net basis” (that   is,   after   deduction   of   Fee   and   commission   expense,   defined   in   Note   1   to   the   financial statements Summary of material accounting policies   as “expenses that are directly attributable to   the   satisfaction   of   specific   performance   obligations   associated   with   the   generation   of revenues”) since that is the   information used by management   in evaluating the performance   of those divisions.   In   future   filings   we   will   add   disclosure   to   more   fully   explain   the   Group   performance   MD&A disclosure   of   fee   and   commission   income,   with   reference   to   the   discussion   of   recurring, transaction-based, management and   performance fees in   the MD&A   discussion of the   Global Wealth Management, Personal &   Corporate Banking and Asset   Management business divisions and to the net fee and commission income disclosed   in Note 5 to the financial statements. c. To   the extent that   revenue line items   at the Group   or business division   levels are impacted   by multiple change   drivers, we   will enhance   our disclosure   of period-over-period   changes   to provide further   quantitative   disclosures   for   each   material   driver   that   would   enhance   an   investor’s understanding of   our results   and are   reflective   of information   that management   considers in understanding revenue changes. Please do not hesitate to contact either Todd Tuckner at +41 44 236 8600 ( todd.tuckner@ubs.com ) or Dominique Crowe at +44 207 567 8158   ( dominique.crowe@ubs.com ) if you have any questions or require additional information.   Yours faithfully, UBS Group AG /s/ Todd   Tuckner   /s/ Dominique Crowe Todd   Tuckner   Dominique Crowe UBS AG Chief Financial Officer   UBS AG Chief Accounting Officer