Circular SINAP 1-241 National Payments System - Transfers - Supplementary Rules. Collection by transfer. Adaptation.

"2026 - YEAR OF ARGENTINE GREATNESS" COMMUNICATION “A” 8406 02/03/2026 TO FINANCIAL INSTITUTIONS, TO OTHER NON-FINANCIAL CREDIT PROVIDERS, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS, TO ELECTRONIC FUNDS TRANSFER NETWORKS, TO ADMINISTRATORS OF ELECTRONIC FUNDS TRANSFER PAYMENT SCHEMES, TO TRANSFER PAYMENT ACCEPTORS:

Ref.: Circular SINAP 1-241: National Payments System - Transfers - Supplementary Rules. Collection by transfer. Adaptation.

We address you to inform you that this Institution has adopted the resolution which, in its pertinent part, establishes:

“1. Approve “collection by transfer” as the sole modality of immediate transfers authorized for recurring collections. 2. Establish that collection by transfer must be available starting August 31, 2026, for the collection of any concept linked to loans. The Central Bank of the Argentine Republic will communicate the specific date from which the service may be offered for other recurring collections. 3. Provide that, without prejudice to respecting the consensus reached within the Interbank Commission for Payment Means of the Argentine Republic –including those regarding technical specifications, user experience for consent and authentication, and operational flows to be implemented–, financial institutions, payment service providers, and other participants in the collection by transfer operation must observe the specific regulation issued by the Central Bank of the Argentine Republic and, to the extent not provided therein, the provisions established generally for immediate transfers. 4. Establish that administrators of immediate transfer schemes must implement mechanisms allowing their participants to use the collection by transfer service, both for sending and receiving collection requests. 5. Provide that financial institutions and payment service providers offering payment accounts must implement all necessary functionalities to respond to collection by transfer requests.

Excluded from this obligation, as well as from those derived from point 2 of Communication A 8180 –in particular from being a recipient of scheduled DEBIN–: a) Payment service providers offering payment accounts that are not registered in the interoperable digital wallets registry; and b) Financial institutions that concurrently verify the following conditions: do not offer credit cards to individual holders, do not possess automated teller machines (ATMs), and are not registered in the interoperable digital wallets registry. Financial institutions covered by this subsection are also excluded from the obligation to participate in the immediate pull transfer service provided for in point 2 of Communication A 7514.

6. Establish the following definitions and functions for participants in the collection by transfer service: a) Collection by transfer acceptor: financial institutions, administrators of immediate transfer schemes, and authorized transfer payment acceptors enabled to provide this service. b) Ordering client: a legal entity that requires access, on its own behalf, to this service and for which funds will be credited under this concept. It cannot act on behalf of third parties. c) Receiving client: the holder of the account –checking or payment– who has given explicit consent for collection requests sent by the ordering client to be debited from it. d) Originating financial institution: the entity where the ordering client’s account is located. In cases where it accesses collection by transfer with its own services, it coincides with the ordering client. e) Receiving financial institution: the entity that receives the collection request and debits the receiving client’s account. f) Sponsoring financial institution: the entity in which a payment service provider offering payment accounts holds a checking collection account into which collection requests –sent or received by or for the holders of payment accounts opened with the provider– are posted. g) Originating payment service provider offering payment accounts: the subject that receives funds through the sponsoring financial institution in its collection account and transfers them to the ordering client’s payment account. h) Receiving payment service provider offering payment accounts: the subject that receives the collection request through the sponsoring financial institution and debits the receiving client’s payment account.

7. Provide that the collection by transfer service will be subject to the following: a) It may only be offered and provided by authorized collection by transfer acceptors, and cannot be contracted or offered by intermediaries. b) It may only be contracted by legal entities (ordering client) to receive recurring collections. c) Consent: the account –checking or payment– that the receiving client authorizes to receive debits must be linked according to a technical procedure based on the OAuth 2.0 standard (explicit consent), coordinated within the framework of the Interbank Commission for Payment Means of the Argentine Republic for pull transfers, taking into account specific adaptations to be defined in the future for collection by transfer within that framework. Furthermore, the user experience guide agreed upon within the previously marked framework will apply.

8. Establish that, when collection by transfer is used for loan installment collections, the following provisions will also apply: a) Fee charged by the collection by transfer acceptor to the ordering client: without maximum, with a minimum of 0.6% (zero point six percent) of the amount of each installment. b) Interchange rate payable to the provider of the debited account: 40% (forty percent) of the fee charged by the acceptor. In cases where the collection by transfer acceptor coincides with the ordering client and, therefore, the fee provided in subsection a) of this point does not apply, the interchange rate will be 40% (forty percent) of the minimum fee established in that subsection. c) Transaction processing price: will be assumed by the acceptor and provider of the debited account in the same proportion as the fee is distributed. d) Only financial institutions, and those non-financial credit providers authorized by permanently and concurrently verifying the following conditions, may be ordering clients: i. Be registered in the registry provided for in point 1.3.1.2 of the codified text on Non-Financial Credit Providers. ii. Not have been sanctioned in the last 60 (sixty) months with a fine in their activity as non-financial credit providers by the Central Bank of the Argentine Republic, for infringements classified as “High” or “Very High” severity. iii. Not fall under point 3.2.2 of the codified text on Non-Financial Credit Providers. iv. Comply with point 3.3 of the codified text on Minimum Requirements for the Management of Technology and Information Security Risks Associated with Digital Financial Services regarding digital identification of clients. v. Observe the applicable compliance reporting requirements with professionals registered in the “Auditors Registry” enabled at the Superintendence of Financial and Foreign Exchange Entities. e) Mutual associations and cooperatives wishing to use collection by transfer to collect installments on loans they have granted, in addition, will not be subject to the exceptions and exclusions established in: i. point 10 of Communication A 7146; ii. point 2.2 (Other informational regimes) of the codified text on Non-Financial Credit Providers; iii. the first paragraph of Section 3 (Non-compliance) of the codified text on Non-Financial Credit Providers; iv. point 1 (Subjects covered) of the informational regime on Special Report on Compliance with Norms for Non-Financial Credit Providers. To that effect, the aforementioned mutual associations and cooperatives must submit upon requesting their authorization for this service through the application of the “Registry of Other Non-Financial Credit Providers” a sworn statement signed by their legal representative that identifies in the respective minutes book the decision of their governing body voluntarily subjecting themselves to the regulatory, supervisory, and sanctioning regime of the Central Bank of the Argentine Republic in such aspects and those otherwise linked to the collection by transfer mechanism, placing themselves at the disposal of the Central Bank of the Argentine Republic at the legal domicile they establish for inspection. f) Ordering clients must disburse the loan amount into the account –checking or payment– that the receiving client has linked and explicitly consented for debit –point 7 c) of this communication–. This provision is exempted for loans to acquire goods in whose operation the ordering client coincides with the seller of the good and, therefore, there is no disbursement in the receiving client’s account. g) Only loans payable in installments meeting the following requirements will be admitted for collection: i. fixed and equal installments throughout the contract term, except when a moratory or punitive interest applies due to retries provided in subsection h) or variations in charges for insurance admitted by point 2.3.12.2 of the codified text on Protection of Financial Services Users; ii. the installment/income ratio at origination does not exceed 30% (thirty percent), with verification for its calculation as established in subsection ii) of subsection b) of point 1.1.3.3 of the codified text on Credit Management. h) Only 1 (one) collection attempt per period will be allowed, according to the frequency established in the contract, and 2 (two) retries: the first after 48 (forty-eight) hours and the second at 96 (ninety-six) hours, in both cases counted from the contractual date established for the first collection attempt. In each period, exclusively the installment stipulated for that period will be collected. i) Liability regarding fraud: the operation will not include reversals. Liability for fraud will rest with the ordering client in question.

9. Establish the following particular responsibilities of service participants: a) Collection by transfer acceptor − Verify that the receiving client has given consent and that non-financial credit providers using this service were authorized by the Superintendence of Financial and Foreign Exchange Entities for this purpose in the “Registry of Other Non-Financial Credit Providers”. When the acceptor detects that the ordering client has not met these requirements, it must immediately interrupt its access to the collection by transfer service. Failure to comply with this responsibility may lead to partial or total suspension, or cancellation of the authorization granted by the Central Bank of the Argentine Republic to provide this collection acceptance service. − Facilitate for the ordering client the management of explicit consent between the receiving client and its account provider. − Obtain the consent token from the provider of the account to be debited. − Validate that the account to be debited is previously linked. − Send collection requests sent by the ordering client to the scheme administrator in which it participates with the necessary information to initiate and settle payment. b) Ordering client − Enable a channel for the receiving client to manage explicit consent with its account provider through the collection by transfer acceptor. − Allow the receiving client to cancel consent or modify the debit account from the enabled electronic channel. − Make available to receiving clients, through specific notifications, information on collection by transfers to be made on the following business day. These notifications must be sent via one of the electronic communication means used to communicate with their clients, such as email, text message, or any application that generates notifications on the client’s mobile device –cell phone or other–. c) Financial institution / payment service provider offering payment accounts to the receiving client − Allow the receiving client to cancel consent from its enabled electronic channels. − Include in the services available on interfaces made available to their clients, the term CCT to identify collection by transfers. d) Administrator of the immediate transfer scheme in which the collection acceptor participates: − Validate the consent token and applicable fees. − Initiate an interoperable collection by transfer to any account provider. − Settle the interchange rate.

10. Provide that any transfer payment acceptor offering the collection by transfer service must be previously authorized for this purpose in the “Registry of Payment Service Providers” of the Central Bank of the Argentine Republic.

11. Provide that, until the application for the “Registry of Payment Service Providers” is adapted, authorization to offer the collection by transfer service will be processed by sending a request via email to sdep_vigilancia_estadisticas@bcra.gob.ar.

12. Provide that any non-financial credit provider wishing to use the collection by transfer service must be previously authorized for this purpose in the “Registry of Other Non-Financial Credit Providers” of the Central Bank of the Argentine Republic.

13. Provide that until the application for the “Registry of Other Non-Financial Credit Providers” is adapted, authorization to use the collection by transfer service will be processed by sending a request via email to subgcia.autorizacion.enof@bcra.gob.ar.”

Furthermore, we inform you that we will subsequently send you the sheets that, in replacement of those timely provided, should be incorporated into the referenced regulation. We remain, respectfully yours,

CENTRAL BANK OF THE ARGENTINE REPUBLIC Matías A. Gutiérrez Girault Alejandra I. Sanguinetti Principal Manager of Payment Systems and Current Accounts Deputy General Manager of Payment Means