Regulation on the Process of Handling Complaints by Financial Institutions

1 of 13 Pursuant to Article 35, paragraph 1, subparagraph 1.1, and Article 65 of Law No. 03/L-209 on the Central Bank of the Republic of Kosovo (Official Gazette of the Republic of Kosovo / No. 77 / 16 August 2010), as amended and supplemented by Law No. 05/L–150 (Official Gazette of the Republic of Kosovo / No. 10 / 3 April 2017, Prishtina), Article 8 and Article 76 of Law No. 08/L-304 on Banks (Official Gazette of the Republic of Kosovo / No. 2 / 27 January 2026), Article 120, Article 121, paragraph 7, and Article 122, paragraph 1, of Law No. 10/L-026 on Payment Services (Official Gazette of the Republic of Kosovo /Nr.10 / 14 May 2026), Article 114 of Law No. 04/L-093 on Banks, Microfinance Institutions and Non-Banking Financial Institutions (Official Gazette of the Republic of Kosovo / No. 11 / 11 May 2012), Articles 8 and 47 of Law 04/L-155 on Payment Systems (Official Gazette of the Republic of Kosovo / No. 11 / 2 May 2013), Article 4, paragraph 3, Article 54, paragraph 7, of Law No. 05/L-045 on Insurance (Official Gazette of the Republic of Kosovo / No. 38 / 24 December 2015, Prishtina), Article 4, paragraph 1, Article 13 and Article 20 of Law No. 04/L-101 on Pension Funds (Official Gazette of the Republic of Kosovo / No. 10 / 8 May 2012, Prishtina), Article 27, paragraph 1, of Law No. 04/L-018 on Compulsory Motor Third Party Liability Insurance (Official Gazette of the Republic of Kosovo / No. 4 / 14 July 2011, Prishtina), the Board of the Central Bank of the Republic of Kosovo, at its meeting held on 28 April .2026, approved the following: REGULATION ON THE PROCESS OF HANDLING COMPLAINTS BY FINANCIAL INSTITUTIONS Article 1 Purpose and scope

1. The purpose of this regulation is to determine the criteria and procedures for establishing the internal function of handling and managing client complaints by financial institutions, the reporting requirements on client complaints of financial institutions, as well as the rights of client to file complaints and the possibilities of using alternative dispute resolution mechanisms and procedures.
2. This regulation applies to all financial institutions licensed, authorized, registered and supervised by the Central Bank of the Republic of Kosovo (CBK). Article 2 Definitions
3. The terms and expressions used in this regulation shall have the following meaning: 3.1. “Complaint” means a statement of client dissatisfaction addressed to a financial institution regarding the financial transaction, product or service received. A request for information or clarification or a request for an opinion, which does not contain an expression of dissatisfaction for lack of service, is not considered a complaint.

2 of 13 3.2. “The complainant” means a person who files a complaint against a financial institution. The complainant may be a former, current or potential client of the financial institution; 3.3. “Automated Teller Machine/ATM” means an electromechanical device which serves for withdrawing or depositing cash, paying for services, transferring funds between accounts, issuing account statements, etc.; 3.4. “CBK” means the Central Bank of the Republic of Kosovo; 3.5. “Working day” means any day other than Saturday, Sunday or public holiday; 3.6. “Financial institution” means a bank, insurance company, non-banking financial institution, microfinance institution, payment institution, electronic money institution that is licensed, regulated and supervised by the CBK in accordance with the Law on the Central Bank and other relevant laws of the Republic of Kosovo; 3.7. “Client” means a natural or legal person who purchases or uses financial products or services offered by a financial institution or has purchased or used financial products or services offered by a financial institution in the past or is clearly attempting to purchase or use financial products or services offered by a financial institution; 3.8. “Advertising” means any form of publication, in the form of publication or broadcast in the media, such as television, radio or a website, of advertisements, labels, brochures, circulars, catalogs, price lists, as well as any other advertising material; 3.9. “Arbitration agreement” means an agreement between two or more persons to submit to arbitration all or some legal disputes that have arisen or that may arise between them; 3.10. “Mediation agreement” means the written agreement signed by the parties and the mediator to resolve the dispute between the parties in the mediation procedure. Regardless of the manner of referral of the case, the mediation agreement has the force of an executive - enforceable title and is binding on the parties. 3.11. “Senior manager” means the chief executive officer, chief financial officer, chief operating officer, chief risk officer of the bank and any person, other than the director, who reports directly to the board or participates or has the authority to participate in the key policy-making functions of the financial institution, as well as any other person who is defined as a “Senior Manager” by applicable CBK laws and regulations. 3.12. “Intermediary” means a third party, natural or legal person, engaged in the promotion or provision of financial services offered by a financial institution, as well as engaged in the preparation, conclusion and administration of agreements and contractual rights in relation to those products or services; 3.13. “Internal complaints handling process” means the financial institution's procedure and rules on handling client complaints, including how complaints shall be submitted, recorded, assessed and decided upon; 3.14. “Alternative dispute resolution” means the out-of-court settlement of disputes between legal entities, arising between the client and financial institutions or any third party beneficiary, in accordance with the conditions provided for in this regulation and the legislation in force, such as mediation, conciliation and arbitration.

3 of 13 Article 3 General requirements

1. Every financial institution establishes an internal complaint handling and management function to ensure that all clients are treated fairly and equally in order to enable the timely resolution of their complaints.
2. The complaints handling and management function handles all complaints submitted to the financial institution. Complaints shall be handled fairly, independently, impartially, and within the specified time limits in accordance with this regulation and any applicable legal or regulatory requirements.
3. The establishment and scope of this function may vary depending on the size, complexity and profile of the financial institution. Article 4 Policy and procedure for handling and managing complaints
4. The financial institution shall develop policies and procedure rules to establish a complaints handling and management function and ensure its effective implementation. Scope of the policy shall vary depending on the size, complexity and risk profile of the institution.
5. The policy under paragraph 1 of this Article shall be approved by the Board of Directors and reviewed at least once every 18 months.
6. Senior management shall adopt the necessary operational procedures for the adequate and efficient implementation of the complaints handling and management function policy.
7. Senior management shall ensure that the complaints handling and management function: 4.1. Has the necessary authorizations and competence to perform his/her independent function and is equipped with sufficient human resources to ensure efficient regulatory compliance, complaint handling and management and protection of client rights. 4.2. Be independent function from business units and not be involved in carrying out responsibilities that may cause a conflict of interest at the risk of compliance with the protection of client rights.
8. The responsible officer appointed in the department/division/unit for handling complaints shall report directly to the Senior Management of the financial institution. One of the members of the Senior Management shall have direct responsibility for overseeing the complaints handling process and ensuring that the complaints handling process is in compliance with applicable laws and regulations of the CBK. Article 5 Staff qualification and training
9. The personnel responsible for handling complaints shall be trained on the financial institution's complaint management policy and shall possess high professional skills based on the delegated responsibilities for managing and handling complaints and the financial institution's development plan.

4 of 13 2. Financial institutions shall ensure that employees engaged in the provision of banking and financial services or in advising clients have integrity, professional qualifications, knowledge and experience and inform clients fully and accurately about the conditions for using these services, including the process of filing a complaint and or exercising appropriate legal remedies. 3. Financial institutions shall train employees of business lines to ensure compliance of the protection of client interests with the requirements of applicable legislation and their internal policies. 4. The training program shall be foreseen within the policy and updated before the introduction of new products, services and activities to ensure that all staff is aware of such requirements as well as applicable laws and regulations. Article 6 Filing complaints

1. The manner of filing complaints shall be as easy as possible for clients.
2. Financial institutions shall possess and have in place all the necessary communication and logistical means for the submission of complaints by clients. Clients shall be able to file their complaints at least through the following methods: 2.1. Online via the institution's website or a dedicated page with easy access and properly identified; 2.2. Telephone; 2.3. Postcard; 2.4. Email; 2.5. Social media; or 2.6. Personally.
3. Financial institutions shall not impose restrictions on how or in what form complaints may be submitted as this discourages clients or limits their right to file a complaint. Filing complaints is not subject to any fee or charge, or requirement to use any particular format.
4. If possible, financial institutions shall establish a call center where clients may call to directly file their complaints. Under no circumstances shall financial institutions charge clients any additional fees above the regular call fee.
5. Financial institutions shall accept complaints at all their branches and sales units.
6. To ensure prompt, timely and fair handling of complaints, financial institutions shall, upon receipt of a complaint, assess whether the complaint is clear, complete and contains all relevant evidence and information necessary for its handling. Where appropriate, additional information shall be requested immediately. Article 7 Language
7. The complainant may submit his/her complaint and communicate with the financial institution in one of the official languages of the Republic of Kosovo as determined by the relevant law or in the

5 of 13 language in which the agreement on the product or service that is the subject of the complaint was concluded. 2. The financial institution shall respond to the complainant in the same language in which it received the complaint. Article 8 Confirmation of receipt

1. The receipt of each complaint shall be formally confirmed and the complainant informed about the subsequent complaint handling process (confirmation of receipt).
2. Confirmation of receipt of the complaint under paragraph 1 of this Article may be made in writing and shall be sent to the complainant via a letter or via e-mail if the complainant prefers electronic communication.
3. The confirmation shall include at least the following information: 3.1. a unique identification number/reference number; 3.2. the complainant's full name, personal number and contact information; 3.3. the date the complaint was received; 3.4. the name and contact information (phone number, e-mail and postal address) of the financial institution unit responsible for handling the complaint.
4. The confirmation shall also describe the next steps the financial institution shall take and the timeframe within which the complaint is expected to be resolved.
5. If additional information or documents are needed to assess the complaint, the financial institution shall promptly request this information and shall instruct the complainant on the manner and reasonable time limit set for submitting the appropriate information.
6. If the complaint is submitted directly by telephone, the client shall be confirmed via telephone call that the complaint has been received and instructed on the procedure for handling the complaint.
7. Summary information regarding the complaint submission form is provided in Annex 1 to this R Regulation. Article 9 Complaints register
8. Financial institutions shall develop and maintain an electronic database in which all complaints shall be recorded and stored under a unique identification/reference number. The unique identification number shall be referenced throughout all communication regarding the complaint between the financial institution and the complainant.
9. Financial institutions shall record all communication and other materials related to each complaint in the database.
10. The data in the database shall be stored for up to 5 years from the date the complaint case is closed.

6 of 13 4. All documents and accompanying materials, if not part of the database, shall be maintained in the database and shall be readily accessible when requested by an authorized person of the financial institution or the CBK. 5. Based on the portfolio of products and services offered, each financial institution shall develop a complaints management database in accordance with the terms of provision of financial products and services. Article 10 Time limits

1. Complaints shall be reviewed and handled by the financial institution within the specified time limit. The decision on the complaint shall be made and communicated to the complainant within the time limit specified in this Article.
2. If the time limit for handling complaints is not provided for by a specific law applicable to the financial institution, the complaint shall be resolved within fifteen (15) calendar days from the date of its receipt. The time limit for reviewing the complaint begins to run from the day following the day of its receipt.
3. Specific complaints consisting of contesting a transaction, whether a cash deposit or withdrawal through an ATM, shall be resolved within seven (7) calendar days from the date of their receipt.
4. For complex complaints that require a deeper analysis within the financial institution, the complaint handling period may be extended up to thirty (30) calendar days.
5. Any extension of time beyond the limits set out in paragraph 2 of this Article Shall be approved from where the head of the department/division/unit for handling complaints of the financial institution and shall be recorded as evidence in the complaints database.
6. The financial institution shall promptly inform the complainant of the extension of the deadline for reviewing the complaint, the reason for it, and the expected date when the institution's review and assessment shall conclude with a final response. The total duration of the extension of the deadline shall not exceed a period of thirty (30) calendar days.
7. The period during which the financial institution is awaiting additional information from the complainant is not counted in the time limit for resolving the complaint.
8. The date when the financial institution receives the complaint via email or in physical form through the protocol shall be deemed to be the date of receipt of the complaint for the purpose of the time limit set forth in this article. If the complaint is received on a non-business day, the time limit for such complaint shall be calculated from the first following business day.

Article 11 Complaints resolution

1. Complainants shall be informed about the resolution of their complaint in writing on a paper or other durable medium, in electronic form if chosen by the complainant. The complainant shall be informed of the resolution of his/her complaint, through a written response, in electronic form or

7 of 13 other form acceptable to the complainant. The response shall be reasonably concise and written in plain language with minimum use of legalistic or professional language. 2. The final response to the complainant shall include: 2.1. identification/reference number; 2.2. information on the name and contact details of the complainant; 2.3. the date the complaint was received, 2.4. a summary of the complaint (denial or proposed resolution) correctly and in plain language; reasoning on the decisive reasons for deciding/resolving the complaint; 2.5. legal advice; 2.6. the name and contact information (telephone number, e-mail and postal address) of the financial institution unit responsible for handling the complaint. 3. Complainants shall also be informed/advised of other steps they can take if they disagree with the resolution of their complaint, in particular regarding their right to: 3.1. file a complaint with the CBK; 3.2. submit the complaint to another public authority or alternative dispute resolution mechanism, where applicable; 3.3. file a lawsuit in court. Article 12 Alternative dispute resolution procedures

1. For the resolution of disputes between clients and financial institutions, the financial institution, in addition to informing about regular means, is obliged to inform clients about the possibility of using alternative mechanisms, such as mediation and arbitration in accordance with the relevant legal provisions covering alternative dispute resolution and consumer protection.
2. Pre-contractual agreements shall contain a clause for alternative dispute resolution such as the option of mediation in accordance with Law No.06/L-009 on Mediation or arbitration in accordance with Law No. 02/L-75 on Arbitration.
3. Financial institutions shall make the following information available to clients regarding dispute resolution options: 3.1. alternative dispute resolution mechanisms; 3.2. contact information or website on alternative dispute resolution mechanisms; 3.3. the language in which the procedure may be conducted; 3.4. the sectors and categories of disputes it covers alternative dispute resolution; 3.5. any information or documents that the client shall be required to provide: 3.6. information on legal recommendations on other available legal remedies, such as competent courts.

8 of 13 4. After exhausting regular legal remedies such as complaints to the financial institution and the CBK, the parties have the right to agree on the mediation option to resolve disputes arising in connection with the implementation of the contract as referred to in this article. 5. Without prejudice to the aforementioned paragraph, a dispute may be resolved by arbitration if this is provided for in the agreement between the parties. 6. The resolution of a dispute by mediation agreement or by arbitration decision is final, except as otherwise provided by applicable laws. Article 13 Intermediaries

1. If a financial institution uses intermediaries to provide financial products and services, upon signing a service contract for cooperation with the intermediary, such contract shall contain a provision that describes in detail the process for submitting a complaint to the relevant financial institution.
2. In the event of any dispute, the parties shall be informed of the regular and alternative remedies set out in Article 12 of this Regulation, in the event that the party is dissatisfied with the resolution of the complaint. Article 14 Disclosure
3. Financial institutions shall clearly inform clients about the ways to lodge a complaint. Each communication tool and material addressed to clients shall include information about the right to lodge a complaint, including all relevant contacts. Each communication tool and material addressed to clients shall include information about the right to lodge a complaint, including all relevant contacts.
4. The purpose and content of information disclosure may vary depending on the means of information/media used and the purpose of communication, as follows: 2.1. Leaflets, brochures and pre-contractual information shall include text in a clear and prominent manner that lists all contacts for lodging a complaint and describes the complaints and handling process, as well as informing the client about the next steps he can take if he is not satisfied with the resolution of the complaint. 2.2. The documentation attached to each contractual agreement shall also list all contacts for filing a complaint and describe the complaints and handling process, as well as inform the client about the next steps he can take if he is not satisfied with the resolution of the complaint. 2.3. Websites shall contain the information listed under subparagraph (2.1) of this Article and shall contain a form through which clients can submit a complaint.
5. The information listed in paragraphs 1 and 2 to be disclosed by financial institutions shall include the following:

9 of 13 3.1 Description of the complaint handling process in plain language and each step taken; 3.2 Information regarding the maximum duration for responding to the complaint; 3.3.Information about complaint options, if applicable; 3.4.Information about other mechanisms that the complainant can use to pursue the complaint if he/she is not satisfied with the solution proposed by the financial institution. The information about further options shall contain specific contact to CBK and information on how to find relevant contacts to other authorities, if applicable (e.g. for relevant courts or alternative mechanisms). 4. The information listed in paragraphs 2 and 3 of this Article shall be placed in the form of brochures or leaflets and shall be visible in all branches, units and points of sale of the financial institution. Article 15 Reporting to Senior Management and the Board

1. The financial institution shall prepare an analytical report on the review and management of complaints each quarter, which shall be submitted to the Senior Management or an internal Committee appointed by the institution for the evaluation of the complaints review process.
2. At least every six months such a report shall be presented to the Board of Directors and shall include the following information: 2.1. the number of complaints received, the types and issues of complaints, 2.2. the products or services to which the complaint relates, 2.3. the branches/units to which the complaint relates, 2.4. the average time it took to resolve complaints, and 2.5. complaint resolution, the number of complaints that were rejected or upheld, in particular complaints that requested compensation and/or forms of redress.
3. The report set out in paragraphs 1 and 2 shall also address any recurring or systematic issues, as well as the root causes of complaints submitted that may affect the correction of processes, as well as other financial products and services.
4. As an integral part of the report, proposals for reducing the number of more frequent or systematically important complaints shall be submitted to Senior Management/Board of Directors through the implementation of changes in the sales process, communication, marketing or product design or other significant changes in the institution's operations.
5. The financial institution shall discuss the report and agree on a solution regarding the content of the report and the proposed response to the most frequent or systemically important complaints.
6. The minutes of meetings of Senior Management and the Board of Directors shall disclose that the related reports and proposals have been discussed and that Senior Management and/or the Board of Directors have made relevant decisions on the grievance management processes and proposals.

10 of 13 Article 16 Internal Audit

1. The internal auditor should include the complaints handling and management process in the annual work plan based on the assessment of the risk methodology.
2. The scope and frequency of internal audits should be guided by the comprehensive assessment of risk control. Article 17 Report to the Central Bank of Kosovo
3. Financial institutions shall report to the CBK on a quarterly basis on the internal complaints process, namely the number of complaints received, the type of complaints, the category of complaints, complaints handled and in the process of review.
4. The quarterly report shall be submitted to the CBK, electronically, no later than thirty (30) calendar days after the end of each reporting quarter.
5. Reports are prepared in the formats and guidelines established by the CBK and may be amended from time to time.
6. The CBK may request additional reports and carry out foreseen controls if it considers this necessary for further supervision. Article 18 Handling of complaints by the Central Bank of Kosovo
7. If a complaint is not resolved in a timely manner in accordance with Article 10 of this Regulation, or if a complainant disagrees with the resolution of the complaint, the complainant has the right to submit his/her complaint to the CBK for its handling.
8. Financial institutions are obliged to appoint an official who is responsible for customer care within the institution and to designate the same as the point of contact to provide the CBK with information regarding any complaint reviewed by the CBK, within a reasonable timeframe determined by the CBK to provide the CBK with information regarding any complaint reviewed by the CBK, within a reasonable timeframe determined by the CBK.
9. The contact person shall be responsible for collecting all relevant information from the financial institution regarding the complaint and providing it to CBK within a maximum period of five (5) business days. Any extension beyond the specified time limit for which the CBK is awaiting additional information from the financial institution shall not exceed ten (10) business days.
10. The CBK shall establish rules of procedure for the internal handling of complaints within the CBK. Article 19 Protection of personal data

11 of 13 Any processing of personal data’s under this regulation, in connection with complaints handling procedures, shall be carried out in accordance with the legislation in force on the protection of personal data. Article 20 Enforcement, remedial measures and administrative penalties Any violation of the provisions of this regulation shall be subject to corrective measures, administrative penalties and monetary sanctions as defined in Law No. 03/L-209 on the Central Bank of the Republic of Kosovo, as amended and supplemented by Law No. 05/L –150, Law No. 08/L-304 on Banks, Law No. 10/L-026 on Payment Services, Law No. 04/L-093 on Banks, Microfinance Institutions and Non￾Banking Financial Institutions, Law No. 04/L-155 on the Payment System, Law No. 05/L -045 on Insurance, Law No. 04/L-101 on Pension Funds of Kosovo, as well as Law No. 04/L-018 on Compulsory Motor Third Party Liability Insurance. Article 21 Annex An integral part of this regulation is Annex 1, Complaint Submission Form. Article 22 Repeal With the entry into force of this regulation, the Regulation on the internal process of complaints handling approved by the Board of the Central Bank of the Republic of Kosovo on September 25, 2014 shall be repealed. Article 23 Entry into force This Regulation enters into force on 1 June 2026. Dr. sc. Bashkim Nurboja Chairman of the Board of the Central Bank of the Republic of Kosovo

12 of 13 ANNEX 1 - COMPLAINT SUBMISSION FORM Standard form for filing complaints 1.a Personal data of the complainant Name / Business Name Last name Personal Number / Unique number of the legal entity Residential address/business location Town Phone number E-mail 1.b Personal data of the legal representative (if applicable) (a power of attorney or other official document as proof of the appointment of the representative) Name / Business Name Last name Personal Number / Unique number of the legal entity Residential address/business location Town Phone number E-mail 1.c. Information on the complaint Description of the purpose of the complaint (please clearly specify the object of the complaint) Please attach all the information that supports the mentioned facts. Description of the damage, loss or harm caused (where relevant) Other comments or relevant information (where necessary)

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