Circular SINAP 1-235 National Payments System – Payment Services Update

"Year of the Reconstruction of the Argentine Nation" COMMUNICATION "A" 8303 19/08/2025 TO FINANCIAL ENTITIES, TO ELECTRONIC CLEARING HOUSES, TO ATM NETWORKS, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS, TO ELECTRONIC FUNDS TRANSFER NETWORKS, TO PAYMENT SERVICE PROVIDERS FULFILLING THE INITIATION FUNCTION, TO ADMINISTRATORS OF ELECTRONIC FUNDS TRANSFER PAYMENT SCHEMES, PAYMENT ACCEPTORS WITH TRANSFERS, CARD PAYMENT ACQUIRERS, PAYMENT INSTRUMENT AGGREGATORS: Ref.: Circular SINAP 1-235: National Payments System – Payment Services. Update.

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We address you to deliver the pages that, replacing those previously provided, should be incorporated into the consolidated text on the National Payments System – Payment Services based on the provisions disseminated through communications A 8032, 8144, 8162, 8180 and 8206 and B 12333. Finally, it is recalled that on this Institution's website www.bcra.gob.ar, by accessing “Financial System – LEGAL AND REGULATORY FRAMEWORK – Consolidations and summaries – Consolidated texts of general regulations”, the modifications made will be found with text highlighted in special characters (strikethrough and bold). We remain, yours sincerely. CENTRAL BANK OF THE ARGENTINE REPUBLIC Irene T. Cano Matías A. Gutiérrez Girault Deputy Manager of Payment Systems Chief Manager of Payment Systems and Current Accounts ANEXO

-Index- Section 1. Uniform Banking Key (CBU) 1.1. Composition 1.2. Disclosure Section 2. Uniform Virtual Key (CVU) 2.1. Characteristics 2.2. Functionalities 2.3. Composition 2.4. Other provisions Section 3. Alias Identification 3.1. Definition 3.2. Function 3.3. Objective 3.4. General characteristics 3.5. Time availability 3.6. Alias uniqueness and portability 3.7. Processes and functions 3.8. Automatic assignment of the alias 3.9. Access to the alias database Section 4. Quick Response Codes (QR) Section 5. "Digital wallet" service 5.1. Definition 5.2. Account enrollment in digital wallets 5.3. Registration in the "Registry of Interoperable Digital Wallets" 5.4. Integration with new payment acceptors with transfers 5.5. Measures to mitigate fraud 5.6. Interoperability in debit, credit and prepaid card payments through QR codes Section 6. Acceptance service for payments with transfers 6.1. Registration in the "Registry of Payment Service Providers" 6.2. Integration process with new interoperable digital wallets B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Version: 5th. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 1

-Index- Section 7. Debit, credit and charge card operations 7.1. Interchange rates 7.2. Credit periods 7.3. Commission for payments initiated with QR codes 7.4. Currency 7.5. Messaging requirements Section 8. Travel with QR (VQR) 8.1. Requirements 8.2. Integration 8.3. Certification 8.4. Functions and responsibilities Section 9. Other provisions 9.1. Controls to apply 9.2. Information requirements Correlation table B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Version: 2nd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 2

Financial entities must assign a Uniform Banking Key (CBU) to every current account and inform their clients so that it can be used in operations requiring it. 1.1. Composition The CBU must be composed according to the standard formula and the rules detailed in this point. 1.1.1. Block 1 1.1.1.1. Entity number (3 positions; uses the number assigned by the clearing house). 1.1.1.2. Branch number (4 positions). 1.1.1.3. Check digit of the first 7 positions (1 position). 1.1.2. Block 2 1.1.2.1. Individual account identification (13 positions). 1.1.2.2. Check digit of the preceding 13 positions (1 position). For the calculation of check digits, key 10 with weight 9713 must be applied. In cases of mergers, transformations or transfers of assets and liabilities of financial entities where changes occur in the entity number assigned by the Central Bank of the Argentine Republic (BCRA) and/or in the branch number, such entities will have a period of one year from the relevant BCRA resolution to reformulate the CBU composition according to the new situation. 1.2. Disclosure Financial entities are advised to adopt the precautions they deem necessary for adequate dissemination of the CBU to their clients through appropriate means, such as: − Account statements or summaries. − Written communications. − Debit/credit card summaries. − In person at the counter and/or service desk. − Other means. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 1. Uniform Banking Key (CBU) Version: 2nd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 1

2.3.2. Block 2 2.3.2.1. Reserved. (1 position). Filled with “0”. 2.3.2.2. Customer identifier (12 positions). Free for customer identification within the PSP. 2.3.2.3. Check digit 2 (1 position). The check digits are calculated according to what is indicated for CBU in the second paragraph of point 1.1. 2.4. Other provisions The low-value electronic clearing house (CEC-BV) must operate and administer the databases and computer systems necessary to enable CVU processing in different fund transfer modalities. To access the services offered by CEC-BV regarding CVU, PSPs must connect through a financial entity. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 2. Uniform Virtual Key (CVU) Version: 2nd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 2

4.4. Every printed image, device or terminal provided or facilitated by an acquirer or aggregator that allows accepting payments with debit, credit or prepaid cards through QR code reading must allow: − accepting PCT in the same QR displayed for the aforementioned payment instruments, when the acquirer or aggregator is also a PCT acceptor; − that every interoperable digital wallet registered in the "Registry of Interoperable Digital Wallets" can make payments with associated cards when businesses accept them through the corresponding aggregator or acquirer, with these latter guaranteeing that commissions and credit periods to businesses for each instrument do not discriminate by wallet brand from which the payment was ordered; and − accepting payments in US dollars with debit cards, when it allows businesses to accept payments with this type of card. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 4. Quick Response Codes (QR) Version: 2nd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 2

5.1. Definition The "digital wallet" service, also known as "electronic wallet" or "virtual wallet", is the service offered by a financial entity or PSP through an application on a mobile device or web browser that must allow –among other transactions– to make PCT and/or with other payment instruments –such as debit, credit, charge or prepaid cards–. The accounts (current or payment) that are debited for PCT and the remaining payment instruments may be provided or issued: 5.1.1. by the same financial entity or PSPCP providing the digital wallet service; and/or 5.1.2. by other financial entities and/or PSPCP. 5.2. Account enrollment in digital wallets Financial entities and PSPCPs providing the "digital wallet" service must: 5.2.1. Allow holders of those wallets to associate –indistinctly starting from a CBU or alias or a CVU or alias, as applicable– those current or payment accounts of which they are sole or joint holders and that are provided by the same financial entity or PSPCP providing them with the wallet service. 5.2.2. Establish necessary mechanisms allowing wallet holders to make PCT from the accounts referred to in 5.2.1. 5.2.3. Notify their clients through usual communication channels what is stipulated in point 5.2. 5.3. Registration in the "Registry of Interoperable Digital Wallets" Every financial entity and PSP wishing to provide a digital wallet service that allows making PCT initiated by reading QR codes must be registered in the "Registry of Interoperable Digital Wallets". 5.3.1. Financial entities To register in the "Registry of Interoperable Digital Wallets", each financial entity must access the website of the Collection and Customs Control Agency (ARCA) www.arca.gob.ar –using the tax key of the legal entity making the registration–, which will allow it to access the relevant service to make electronic registration through the application enabled by BCRA –logging in with the "user E" assigned for this registry. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 5. "Digital wallet" service Version: 3rd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 1

Through said application, it must submit a certificate issued by the legal representative of each immediate transfer scheme administrator affirming –under oath– that the service in question successfully completed integration with each of the acceptors adhered to its scheme and is ready to be used by the general public to make PCT through reading QR codes generated by each of those acceptors. The administrators must extend this certificate, at the latest, within 5 business days from the completion of tests proving said integration. Once this requirement is met, SEFYC will issue a registration certificate and grant the applicant a number in the "Registry of Interoperable Digital Wallets". Receiving this certificate is a condition for providing the service. 5.3.2. PSP To register in the "Registry of Interoperable Digital Wallets", each PSP must: 5.3.2.1. Be registered as PSPCP or PSP fulfilling the initiation function without providing payment accounts (PSI). 5.3.2.2. Satisfactorily comply with the applicable information regime. 5.3.2.3. Submit –through the application referred to in point 5.3.1., logging in with the registered CUIT–: i. Certificate issued by the legal representative of each immediate transfer scheme administrator authorized by BCRA affirming –under oath– that the service in question successfully completed integration with each of the acceptors adhered to its scheme and is ready for general public use to make PCT through reading QR codes generated by each of those acceptors. The administrators must extend this certificate, at the latest, within 5 business days from completion of tests proving said integration. ii. The following information: a. Full name, position, type and number of identity document and email address of the top manager in charge of technology and information systems. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 5. "Digital wallet" service Version: 3rd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 2

5.5.3. PSIs providing the digital wallet service must verify the identity of persons requesting that service, observing for this purpose the provisions for financial entities in point 1.3 of the consolidated text on "Savings, Salary and Special Accounts" (except what is required in its last paragraph regarding the client's sworn statement) and corresponding –points 4.1., 4.2. and 4.16.1.–. The activities performed in points 5.5.1.2., 5.5.1.3., 5.5.2.1. and 5.5.3. must be traceable and auditable. Integrity, protection and safeguarding of these records must be provided. 5.5.4. When a debit card payment –whether in pesos or US dollars–, credit or prepaid is initiated from an interoperable digital wallet through QR code reading, fraud liability will be assumed by the wallet, except: 5.5.4.1. when the wallet processes payment with the technical requirements and standards of tokenization and authentication of the card brand; 5.5.4.2. when the transaction cannot be processed with the technical requirements and standards made available by the card brand, when they have been implemented by all transaction participants except the acquirer/aggregator. Only in this case will the acquirer/aggregator be liable for fraud; 5.5.4.3. when there is a contrary agreement between issuers, wallets and/or acquirers/aggregators involved in the transaction. Except for the case provided in point 5.5.4.2., acquirers cannot be debited/charged back for operations initiated from interoperable digital wallets with QR code reading that have been unrecognized or fraudulent. 5.6. Interoperability in debit, credit and prepaid card payments through QR codes Every interoperable digital wallet allowing payment with debit, credit or prepaid card through QR code reading must allow making payments with every printed image, device or terminal provided or facilitated by any acquirer or aggregator allowing acceptance of payments with said instrument through QR code reading. In the case of debit cards, this interoperability requirement applies to both payments in pesos and US dollars. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 5. "Digital wallet" service Version: 3rd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 5

7.1. Interchange rates The interchange rate is the remuneration of the issuing financial entity –as a commission– on each transaction performed. The interchange rates applied by financial entities on the amount of each transaction performed with debit, credit and charge cards they issue must not exceed the percentages detailed below: Maximum interchange rate for debit card operations (%) Maximum interchange rate for credit/charge card operations (%) 0,60 1,30 For the application of the mentioned limits, any other remuneration or compensation mechanism to issuers established by acquirers, brand holders and/or any other intermediary in payment operations or related activities, having an object or effect equivalent to the interchange rate, is considered part of it. 7.2. Credit periods 7.2.1. Credit and/or charge cards issued by financial entities The maximum period for financial entities to credit the amount of each sale made in a single payment –using the credit and/or charge cards they issue– to the deposit account opened in the name of the adhered provider or business will be: i. 5 (five) business days when it is verified that: − their activity is "gas stations and retail outlets"; and − they have the status of micro or small enterprise and/or are natural persons; ii. 8 (eight) business days when they have the status of micro or small enterprise and/or are natural persons; iii. 10 (ten) business days for those categorized as medium enterprises and those whose activity is "accommodation, tourism, gastronomy and/or health" –not included in the latter cases in the preceding subsection–; iv. 18 (eighteen) business days for the remaining cases. In all cases, the period will be counted from the date of the corresponding consumption by the cardholder or beneficiary. B.C.R.A. NATIONAL PAYMENTS SYSTEM – PAYMENT SERVICES Section 7. Debit, credit and charge card operations Version: 3rd. COMMUNICATION "A" 8303 Effective: 20/08/2025 Page 1

Financial entities cannot charge adhered businesses interest or commission linked to the stated settlement periods, must observe what is provided in regulations on "Determination of micro, small or medium enterprise status". They must also not prevent or hinder in any way the single payment consumption mode with those cards. 7.2.2. Prepaid cards The maximum period for financial entities, payment service providers offering payment accounts and other open-scheme prepaid card issuers to credit the amount of each sale made using said cards to the current or payment account opened in the name of the adhered provider or business will be 2 (two) business days, counted from the date of the corresponding consumption by the prepaid cardholder or beneficiary. The maximum period for subacquirers to credit the amount of payments made with their intervention in the account in the name of the provider or adhered business cannot exceed 1 (one) business day from when the subacquirer receives the funds. Credit