Upstart Holdings, Inc.

(c) Securities Trading Plans of Executive Officers and Directors

From time to time, some of the Company’s executive officers or directors may enter into trading plans that are designed to comply with the Company’s Insider Trading Policy and intended to satisfy the affirmative defense conditions of Rule 10b5-1(c) of the Exchange Act.

During the quarter ended June 30, 2026, the following officers (as defined in Rule 16a-1(f) of the Exchange Act) of the Company each adopted a “Rule 10b5-1 trading arrangement” (as defined under Item 408(a) of Regulation S-K).

Name and title of officer: Andrea Blankmeyer, Chief Financial Officer

Date ofadoption: May 16, 2026

Duration of the trading arrangement: Through December 18, 2026 or earlier if all transactions under the trading arrangement are completed

Aggregate number of securities to be sold from time to time: up to 43,784 shares, including shares to be received upon the vesting of RSUs (including any RSU grants awarded during the duration of the trading arrangement), net of shares withheld to cover tax obligations upon the vesting.

Name and title of officer: Scott Darling, Chief Legal Officer and Secretary

Date ofadoption: May 13, 2026

Duration of the trading arrangement: Through February 28, 2027 or earlier if all transactions under the trading arrangement are completed

Aggregate number of securities to be sold from time to time: up to 260,344 shares, including shares issuable upon the exercise of outstanding options upon reaching the pricing targets defined in the trading arrangement, plus any additional shares to be received upon the vesting of RSUs to occur on various dates within the duration of the trading arrangement, net of shares withheld to cover tax obligations upon the vesting, plus any shares purchased under the ESPP.

Name and title of officer: Natalia Mirgorodskaya, Chief Accounting Officer

Date ofadoption: May 22, 2026

Duration of the trading arrangement: Through March 2, 2027 or earlier if all transactions under the trading arrangement are completed

Aggregate number of securities to be sold from time to time: up to 28,243 shares, including shares issuable upon the exercise of outstanding options upon reaching the pricing targets defined in the trading arrangement, and shares to be received upon the vesting of RSUs (including any RSU grants awarded during the duration of the trading arrangement), net of shares withheld to cover tax obligations upon the vesting, and any shares purchased under the ESPP.

None of the Company’s other officers or directors adopted, modified, or terminated a “Rule 10b5-1 trading arrangement” oradopted, modified, orterminated a “non-Rule 10b5-1 trading arrangement” (as defined under Item 408(a) of Regulation S-K) during the quarter ended June 30, 2026.