EXHIBIT 8.1
LLOYDS BANKING GROUP STRUCTURE
The following is list of the principal subsidiaries of Lloyds Banking Group plc at 31 December 2025.

Name of subsidiary undertaking | Country of registration/ incorporation | Percentage of equity share capital and voting rights held | Nature of business | Registered office
Lloyds Bank plc | England | 100% | Banking and financial services | 25 Gresham Street, London EC2V 7HN
Scottish Widows Limited | England | 100% * | Life assurance | 25 Gresham Street, London EC2V 7HN
HBOS plc | Scotland | 100% * | Holding company | The Mound, Edinburgh EH1 1YZ
Bank of Scotland plc | Scotland | 100% * | Banking and financial services | The Mound, Edinburgh EH1 1YZ
Lloyds Bank Corporate Markets plc 1 | England | 100% | Banking and financial services | 25 Gresham Street, London EC2V 7HN
LBG Equity Investments Limited 1 | England | 100% | Financial services | 25 Gresham Street, London EC2V 7HN

*Indirect interest
1 Subsidiary that does not meet quantitative threshold for significance. Included for consistency with the consolidated financial statements.