Circular SINAP 1-240 TO on National Payments System - Transfers - Complementary Rules. Update.

"2026 - YEAR OF ARGENTINE GREATNESS" COMMUNICATION "A" 8399 12/02/2026 TO FINANCIAL ENTITIES, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS, TO ELECTRONIC FUNDS TRANSFER NETWORKS, TO PAYMENT SERVICE PROVIDERS PERFORMING THE INITIATION FUNCTION, TO ADMINISTRATORS OF ELECTRONIC FUNDS TRANSFER PAYMENT SCHEMES: Ref.: Circular SINAP 1-240: TO on National Payments System - Transfers - Complementary Rules. Update.

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We address you to deliver the sheets that, in replacement of those previously provided, must be incorporated into the consolidated text on the National Payments System – Transfers – Complementary Rules, based on the provisions disseminated by Communications A 7514, 7841, 7996, 8030, 8162, and C 101314. Finally, we remind you that on this Institution's website www.bcra.gob.ar, by accessing "Sections - Financial System – LEGAL AND REGULATORY FRAMEWORK – Consolidations and summaries – Consolidated texts of general regulations," you will find the modifications made with text highlighted in special characters (strikethrough and bold). We salute you sincerely. CENTRAL BANK OF THE ARGENTINE REPUBLIC Irene T. Cano Matías A. Gutiérrez Girault Deputy Manager of Payment Systems Main Manager of Payment Systems and Current Accounts ANNEX

-Index- Section 1. Electronic funds transfers. Basic concepts 1.1. Introduction and objective 1.2. General provisions 1.3. Functions of electronic funds transfer schemes 1.4. Participants and clients of electronic funds transfer schemes 1.5. General responsibilities of participants 1.6. Surveillance Section 2. Instant transfers. Complementary provisions Section 3. Instant transfers. Modalities 3.1. General considerations 3.2. Payment with transfer 3.3. Withdrawal with transfer 3.4. Instant pull transfers Section 4. Standardized Payment Interface (SPI) Section 5. Electronic funds transfers: commercial rules 5.1. General definitions 5.2. Payment with transfer 5.3. Withdrawal with transfer Section 6. Electronic funds transfers: operational variables, prices, and interchange rates 6.1. Batch transfers 6.2. Retail transfers through the Electronic Payment Medium (MEP) 6.3. Instant transfers 6.4. Approximate peso equivalents of amounts expressed in UVA Correlation Table B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Version: 6th COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 1

1.1. Introduction and objective 1.1.1. This section aims to define the general principles governing the operation of electronic fund transfers between deposit accounts opened at financial entities (hereinafter demand deposit accounts) and even payment accounts. The electronic fund transfers covered by these rules are retail payment instruments; therefore, payments between financial entities and with the Central Bank of the Argentine Republic (BCRA), which are considered wholesale, are excluded. 1.1.2. This payment instrument is open and can also be used to perform electronic fund transfers for non-commercial purposes; thus, its objective is to provide clients with a service that allows the transfer of funds between accounts, regardless of who the account holders are or which financial entities or payment service providers offer the accounts. 1.2. General provisions 1.2.1. Functional approach: this regulation will apply by function within a payment scheme, so that it is homogeneous for different types of entities performing the same function and therefore competing, whether they are financial entities or payment service providers (PSP). Financial entities and PSPs may perform multiple functions within a payment scheme as long as these rules do not expressly limit them. 1.2.2. Payment service providers by function: electronic fund transfers may have multiple alternative payment schemes, and each scheme must have its respective administrator, according to the definitions in point 1.2. of the consolidated text (TO) on Payment Service Providers. 1.2.2.1. Payment service providers are considered to be legal entities that, without being financial entities, perform at least one function within a retail payment scheme, within the global framework of the National Payments System. 1.2.2.2. Payment schemes are systems of commercial, technical, and/or operational rules that make the operation of a payment instrument possible when at least three parties are involved: an originator, a receiver, and one or more financial entities or PSP. Every payment scheme must have an administrator who defines these rules and is responsible for their compliance with the current legal and regulatory framework. 1.2.3. Equal treatment: electronic fund transfers processed between accounts of the same financial entity or PSP must have identical characteristics for clients as those transfers made between accounts of different financial entities or PSP, equalizing them to instant transfers, payment with transfer (PCT), or batch transfers as applicable. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 2nd COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 1

1.3.5. Initiation, only for financial entities. Send an electronic fund transfer to a receiving entity through the operator and receive messages from the receiving entity, debiting funds when appropriate. 1.3.6. Operation or processing. Route or switch electronic payment instructions between originating and receiving entities, ensuring the correct receipt of messages by all participants in a transaction. 1.3.7. Receipt, only for financial entities. Receive an electronic fund transfer from an originating entity and send confirmation or rejection messages, crediting funds in a timely manner and notifying the client. 1.3.8. Clearing. Establish the final positions –debtor and creditor– of the participating financial entities within the established deadlines to allow settlement. Monitors the guarantees provided by participants. 1.3.9. Settlement, only for electronic clearing houses authorized by the BCRA. Execute the payment of net balances by debtor entities to creditor entities as a result of the clearing process. Uses the guarantees provided by participants if necessary. 1.3.10. Initiation. Send a valid payment instruction at the request of a client originator to the entity or PSP providing the client's account, capturing credentials through methods such as magnetic stripe, near-field communication, QR codes, user passwords, or others. 1.3.11. Pass-through, only for financial entities or PSPCP. Credit funds to a receiving client's account when the account credited by the receiving entity is not in the name of that same receiving client, sending confirmation messages to the receiving entity and the client. 1.3.12. Acceptance. Adhere merchants to payment schemes with transfer. This includes, among other tasks: facilitating mechanisms to initiate payments, transmitting payment order information to the administrator or other participants of the relevant scheme, and, if authorized, confirming operations. 1.4. Participants and clients of electronic funds transfer schemes 1.4.1. Originating client: i) In fund sends: holder of the demand deposit account or payment account from which the sent transfers will be debited. ii) In fund requests: holder of the demand deposit or payment account that orders the fund request to the receiving client, to be credited to their account. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 4th COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 3

1.4.2. Receiving client: i) In fund sends: holder of the demand deposit account or payment account in which the sent transfers will be credited. ii) In fund requests: holder of the demand deposit or payment account that receives the fund request to be debited from their account. 1.4.3. Originating financial entity: i) In fund sends: sends valid payment instructions to the receiving entity through the operator and receives messages from the receiving financial entity, debiting funds when appropriate. ii) In fund requests: sends the fund request to the receiving financial entity, to be credited to the originating client's account. 1.4.4. Receiving financial entity: i) In fund sends: receives valid payment instructions and sends confirmation or rejection messages of the instruction, crediting funds when appropriate. ii) In fund requests: receives the fund request, debiting it from the receiving client's account when appropriate. 1.4.5. Electronic Clearing House (CEC): an institution, previously authorized by the BCRA, that administers the electronic clearing of client operations of financial entities and other entities authorized by the BCRA. 1.4.6. Originating PSPCP: i) In fund sends: sends valid payment instructions through the originating financial entity and receives messages from it, debiting funds from the originating client when appropriate. ii) In fund requests: sends the fund request through the originating financial entity to the receiving financial entity, to be credited to the originating client's account. 1.4.7. Receiving PSPCP: i) In fund sends: receives funds through the receiving financial entity in its collection account and passes them to the receiving client's payment account. ii) In fund requests: receives the fund request through the receiving financial entity, debiting it from the receiving client's payment account when appropriate. 1.4.8. Participants in electronic funds transfer schemes with special status for the purposes of their treatment by administrators: National Social Security Administration. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 4th COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 4

1.5. General responsibilities of participants 1.5.1. Originating and/or receiving financial entity 1.5.1.1. Comply with the provision of guarantees and maintain them within adequate parameters. 1.5.1.2. Make electronic fund transfer services available to all its clients. 1.5.1.3. Assume full responsibility for the proper handling of electronic fund transfers originated and/or received, including the keeping of electronic records. 1.5.1.4. Ensure that electronic fund transfers and payment with transfers processed between accounts of the same financial entity have identical characteristics for clients as those transfers made between accounts of different entities, equalizing them to instant or batch transfers as applicable. 1.5.1.5. Report information related to electronic fund transfers and payment with transfers processed between accounts of the same financial entity to the administrator of the payment scheme in which they participate. To this end, they must contemplate the mechanisms that will be established and identical characteristics to those established for operations between accounts of different entities for the purpose of their registration in the relevant transactional repository. 1.5.2. Electronic Clearing House 1.5.2.1. Ensure the proper functioning of provided guarantees and/or their settlement for each electronic funds transfer scheme in which they participate. 1.5.2.2. To the extent that CECs expand their operations beyond their specific clearing and settlement functions, they must comply with the regulation for each function as a PSP. 1.5.3. Payment Service Provider Comply with the rules and provisions of the administrator that regulate each of the functions they develop within an electronic funds transfer payment scheme, as declared in point 1.3. 1.5.4. PSPCP B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 4th COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 5

1.5.4.1. Make electronic fund transfer services available to all its clients. 1.5.4.2. Assume full responsibility for the proper handling of electronic fund transfers they initiate and/or pass through, including the keeping of electronic records. 1.5.4.3. Ensure that electronic fund transfers and payment with transfers processed between accounts of the same PSPCP have identical characteristics for clients as those transfers made with the involvement of different account providers. 1.5.4.4. Report information related to electronic fund transfers and payment with transfers processed between accounts of the same PSPCP to the administrator of the payment scheme in which they participate. To this end, they must contemplate the mechanisms that will be established and identical characteristics to those established for operations between accounts of different entities for the purpose of their registration in the relevant transactional repository. 1.5.4.5. Offer all necessary functionalities so that fund requests (pull transfers) can be successfully executed. PSPCPs that are not registered in the "Registry of Interoperable Digital Wallets" may not participate in the instant pull transfer service provided for in point 1.5.5.12. 1.5.5. Administrator of an electronic funds transfer scheme 1.5.5.1. Define the commercial, technical, and/or operational rules of the instant transfer scheme they administer, and ensure they are adequate to the current legal and regulatory framework. Establish contractual relationships with each participant, through the signing of agreements that fix the obligation of these to comply with the scheme's rules, providing for fines and sanctions in case of non-compliance. 1.5.5.2. Refrain from engaging in anti-competitive conduct to the detriment of participants in their own scheme or other subjects, especially when the administrator assumes, in addition to typical operation, authorization, and/or clearing functions, functions that are also performed by other participants, such as the acceptance function or account provision. 1.5.5.3. Ensure that prices offered to participants of the same payment scheme are the same for all those designated as equal by these rules, considering the exceptions provided for in Section 6., and that these prices are reported separately for each of the functions they remunerate within the scheme, without allowing discounts. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 4th COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 6

1.5.5.4. Ensure that their payment scheme interoperates with the rest of the instant transfer schemes when this is necessary so that their participants can originate transfers destined to any other financial entity that is not a participant, under the same conditions applicable when a transfer is resolved within the own scheme. 1.5.5.5. Define what type of participants can assume each function, which is not expressly determined in these rules. 1.5.5.6. Communicate with all their participants equally through standardized and numbered circulars when it comes to information that must be known without discrimination and simultaneously for all of them. 1.5.5.7. Ensure that messages between participants preserve the information of originating and receiving clients and when payment accounts and/or demand deposit accounts are used. 1.5.5.8. Suspend preventively, when so ordered by the BCRA Board, any procedure, operation, and/or commercial rule of the payment scheme under their administration in situations where the stability, security, and/or efficiency for electronic fund transfers are seriously compromised. 1.5.5.9. Enable channels so that participants and merchants can file complaints or claims, which must be treated as follows: i) All submissions received regarding complaints or claims –including, in particular, those alleged breaches due to defective service or lack of service contracted– must be recorded in a single, centralized database, even if they can be answered immediately. ii) The following data must be recorded at a minimum: claim number; date and channel; CUIT/CUIL of the submitter; cause; other participants involved –such as acquirers and account providers– and the status of the process, which must be kept updated (pending response, with provisional or definitive response to the submitter, along with the response provided, etc.). iii) The numbers assigned to submissions must be consecutive, and the database can only be modified for the incorporation of new claims or for the addition of new information about the updated status of the processes. iv) When the claim is initiated by calling a telephone line or center or entering data on an Internet page or mobile application enabled for that purpose, the claim number must be provided immediately to the submitter, respecting the cited consecutiveness. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 4th COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 7

v) When the submitter does not automatically receive their claim number, a procedure must be established that provides for the notification of the number or code assigned within three (3) business days of the submission to the scheme administrator. The information incorporated into this database must be preserved for a term of ten (10) years. With semi-annual periodicity, a report regarding: (i) the claims received and (ii) the interventions required by complaints processed before competent judicial and/or administrative instances must be submitted to the board or equivalent authority. The report will record, as applicable, a breakdown by the following criteria: causes that originate them, quantities, amounts involved, and average resolution times. Additionally, they must contain comparative statistics regarding previous periods and –if applicable– corrective proposals. 1.5.5.10. Send to the Superintendence of Financial and Exchange Entities (SEFYC) the reports referred to in point 1.5.5.9. and, with annual periodicity, a special compliance report from an independent professional based on the model that will be made available regarding compliance with what is established in points 1.2.4. and 1.5.5.2., which must contain a conclusion on whether there is (or is not) discriminatory treatment –commercial, operational, or otherwise– towards other participants (or their clients) of the transfer scheme that also perform functions assumed (directly or indirectly) by the administrator. 1.5.5.11. Prepare and make available to any financial entity and PSP –duly registered with the BCRA– that requires it, a procedure manual that allows them to integrate their interoperable digital wallet service with the payment acceptors of their respective schemes. Under no circumstances may they enable an acceptor to receive payments with transfers initiated with QR codes if they have not verified that said codes can be read by all financial entities and PSPs providing the interoperable digital wallet service registered in the BCRA registry. 1.5.5.12. Develop mechanisms for: i) To send –from a demand deposit or payment account– requests or orders for funds (instant pull transfers) in the two consent modalities defined in point 3.3.3.1. ii) To use the regulated fund requests in item i) to perform PCT from accounts –demand deposit or payment– that are not provided by the entity providing the digital wallet service from which those payments are ordered. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Version: 3rd COMMUNICATION “A” 8399 Validity: 13/02/2026 Page 8

1.5.6. Acceptor of an electronic funds transfer scheme 1.5.6.1. Comply with the rules and provisions of the administrator to carry out the acceptance function within the payment scheme. 1.5.6.2. Maintain a contractual relationship with receiving clients of payment with transfers as a result of their organized commercial activity, being responsible for ensuring that operations are initiated and/or credited according to the scheme's rules. 1.5.6.3. Do not discriminate in the treatment of payment with transfers based on the account provider. 1.5.6.4. Refrain from receiving payments for their own account, respecting the requirement to be a third party between the originating client and the receiving client. 1.6. Surveillance 1.6.1. Participants in electronic funds transfer schemes must adhere to the surveillance mechanisms that the BCRA determines for each type of participant, including real-time monitoring mechanisms. 1.6.2. Administrators of electronic funds transfer schemes must send to the BCRA the documentation containing all the rules and obligations to which the payment schemes they administer are subject, all their updates, as well as copies of all circulars and technical documents sent to their participants simultaneously with the notification of the scheme participants. B.C.R.A. NATIONAL PAYMENTS SYSTEM – TRANSFERS – COMPLEMENTARY RULES Section 1. Electronic funds transfers. Basic concepts Ve