Instruction on the Preparation and Submission of Financial and Statistical Reports by Persons Licensed for Insurance and/or Reinsurance Distribution (FSI-PO) – Effective 1 January 2026

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Based on Article 15, point 7 of the Act on the Croatian Financial Services Supervisory Agency (Official Gazette Nos. 140/05 and 12/12), the Croatian Financial Services Supervisory Agency, at its Management Board meeting held on 22 May 2026, adopts INSTRUCTION ON THE PREPARATION AND SUBMISSION OF FINANCIAL AND STATISTICAL REPORTS BY PERSONS LICENSED FOR INSURANCE AND/OR REINSURANCE DISTRIBUTION (FSI-PO) – Effective 1 January 2026.

1. Introduction The Croatian Financial Services Supervisory Agency (hereinafter: Hanfa) has adopted the Regulation on the Form and Content of Financial and Statistical Reports by Persons Licensed for Insurance and/or Reinsurance Distribution (hereinafter: Regulation), which prescribes the form and content of semi-annual and annual financial and statistical reports by persons licensed for insurance and/or reinsurance distribution, the method and deadlines for report submission, as well as the conditions for displaying the LEI code. Financial reports submitted by reporting obligors are: Financial Position Report (Balance Sheet) and Profit and Loss Statement (P&L). Statistical reports submitted by reporting obligors are: General Data, Policy or Guarantee, SP-1-O, SP-1-O additional sheet, SP-1-RE, and SP-1-RE additional sheet. This instruction defines the format and method of submission of the aforementioned reports by insurance and/or reinsurance intermediaries and auxiliary insurance intermediaries in electronic form (in the following text: reports), as well as the detailed method of completing them. Insurance representation companies or insurance brokerage companies and/or reinsurance (hereinafter: reporting obligors) are required to submit semi-annual and annual financial reports, as well as semi-annual and annual statistical reports, to Hanfa in electronic form, in accordance with the Insurance Act and the Regulation. Sole trader insurance representatives, sole trader insurance brokers and/or reinsurance, credit institutions, leasing companies, investment firms, auxiliary insurance intermediaries, and all legal entities holding a license for the business of insurance distribution or reinsurance distribution (hereinafter: reporting obligors) are required to submit semi-annual and annual statistical reports to Hanfa in electronic form, in accordance with the Insurance Act and the Regulation.

2. Types of Reports and Submission Deadlines Types of reports submitted electronically are:

3. semi-annual financial report of insurance representation companies or insurance brokerage companies and/or reinsurance

4. semi-annual statistical report of insurance representation companies or insurance brokerage companies and/or reinsurance, sole trader insurance representatives, sole trader insurance brokers and/or reinsurance, auxiliary insurance intermediaries, credit institutions, leasing companies, investment firms, and all legal entities holding a license for the business of insurance distribution;

5. annual financial report of insurance representation companies or insurance brokerage companies and/or reinsurance

6. annual statistical report of insurance representation companies or insurance brokerage companies and/or reinsurance, sole trader insurance representatives, sole trader insurance brokers and/or reinsurance, auxiliary insurance intermediaries, credit institutions, leasing companies, investment firms, and all legal entities holding a license for the business of insurance distribution; Submission deadlines for reports:

7. The semi-annual financial report must be submitted to Hanfa no later than the end of the month following the end of the half-year for which the report is prepared (submission deadline 31 July)

8. The semi-annual statistical report must be submitted to Hanfa by the end of the month following the end of the half-year for which the report is prepared (submission deadline 31 July)

9. The annual financial report must be submitted to Hanfa no later than within three months after the end of the calendar year for which the report is prepared (submission deadline 31 March)

10. The annual statistical report must be submitted to Hanfa no later than within three months after the end of the calendar year for which the report is prepared (submission deadline 31 March)

11. Report File in XML Format Reports from point 2 of this instruction are submitted electronically in XML format within the deadlines prescribed by the Insurance Act and the Regulation. Reporting obligors prepare report files in XML format in accordance with Hanfa's prescribed XML schema. The XML schema for preparing financial and statistical reports is published under the name FSI-PO Financial and Statistical Report of Intermediaries and Auxiliary Intermediaries in Insurance and/or Reinsurance at the following web address: http://reports.hanfa.hr/Documentation. The procedure by which reporting obligors convert report data into the specified format is determined and executed by the reporting obligor. Hanfa has enabled reporting obligors to convert the aforementioned reports into the specified format via an auxiliary interface for creating XML files for the currently valid version, which is visually depicted below: When submitting reports through the auxiliary interface for creating and viewing XML files for the currently valid version of the FSI-PO report, the basic technical assumption for correctly completing the form is that regional computer settings must be Croatian. After logging into the report submission system, the FSI-PO XML schema is selected and the following are entered or chosen from a dropdown menu: • Year for which the report is submitted (e.g., 2026) • Period 1 (semi-annual reports for the period 1.1.-30.6.20xx) or 2 (annual reports for the period 1.1.-31.12.20xx) • Institution code (name of the reporting obligor) A reporting obligor for financial and statistical reports (insurance representation company or insurance brokerage company and/or reinsurance) submits reports in a single combined XML file, meaning separate submission of only statistical or only financial reports is not permitted.

12. Report File in PDF Format Alongside the semi-annual and annual financial and/or statistical reports submitted in XML format, PDF documents are uploaded to reports.hanfa.hr. 4.1. Policy or Guarantee File As proof of a concluded insurance contract for professional liability, the corresponding guarantee or professional liability insurance policy from the business of insurance distribution or reinsurance distribution is uploaded. Alongside the insurance policy, all attachments to the insurance policy containing mandatory policy elements must be attached in a single PDF document. • The Policy or Guarantee PDF file must be uploaded but does not require an electronic signature 4.2. Insurance Premium Payments File When dealing with long-term or multi-year insurance policies where the policy duration is stated AS CANCELLATION, as proof of a concluded insurance contract, an additional PDF document must be uploaded regarding insurance premium payments. • The Insurance Premium Payments PDF file must be uploaded but does not require an electronic signature For insurance policies with a defined duration until a specific date, uploading proof of premium payment is not required. 4.3. Statement of Inactivity File If the reporting obligor does not conduct insurance distribution business during the period for which it submits financial and/or statistical reports, a PDF file must be uploaded: Statement of Inactivity, signed by the company's management or sole trader owner. This file is intended for explanations from the company's management/sole trader owner who submits a separate statement, and besides numerical data from financial and statistical reports, it provides textual explanations within the FSI-PO report for supervisory purposes. The Statement of Inactivity is written in free-form correspondence, alongside basic data (name of the insurance intermediary, OIB of the intermediary, name and surname of the authorized person of the intermediary, OIB of the authorized person), it must necessarily contain a note on the purpose of the statement, namely the text: “Under material and criminal liability, I declare that the data in the FSI-PO report are accurate, true, and complete, and hereby declare inactivity regarding insurance distribution for the period 1.1.-30.6. or 1.1.-31.12., and I submit financial and/or statistical reports to Hanfa with zeros. I declare that I have settled all debts related to fee payments to Hanfa.” Regarding the previous sentence of the statement, amounts and dates of fee payments must also be stated. • The Statement of Inactivity PDF file must be uploaded and signed with a qualified electronic signature. • If the reporting obligor delegates the submission of the FSI-PO report to another person who signs the Statement of Inactivity with their certificate, it must also be submitted in original form by post or directly to the registry office at Hanfa's address, hand-signed by the company's management or sole trader owner.

13. Instructions for Filling Out Forms This instruction for filling out forms refers to the description of positions for completing the fields of the FSI-PO report.

Statistical Reports 5.1. Completing the General Data Form This form is completed by all reporting obligors of the FSI-PO report.

Column Name	Position Description
Category of intermediary	The intermediary selects its category from the dropdown menu:

1. Sole trader insurance representatives*
2. Sole trader insurance brokers and/or reinsurance
3. Insurance representation companies*
4. Leasing companies authorized to conduct insurance distribution business
5. Insurance brokerage companies and/or reinsurance
6. Credit institutions
7. HP-Croatian Post d.d.
8. Financial Agency
9. Investment firms
10. Auxiliary insurance intermediaries - travel agencies
11. Other auxiliary insurance intermediaries *Insurance representation companies and sole trader insurance representatives working at Technical Inspection Stations select the category Insurance representation companies or Sole trader insurance representatives from the dropdown menu. | | Intermediary headquarters address - Postal code | The intermediary's postal code is entered without spaces. | | Intermediary headquarters address - City/town | The intermediary's city/town is entered. | | Intermediary headquarters address - Street and house number | The intermediary's street and house number are entered. | | OIB (Personal Identification Number) | The intermediary's OIB is entered. | | LEI1 | Entered by insurance representation companies if they provide cross-border insurance distribution services in another member state or achieve annual revenue from representation exceeding 132,800.00 euros, and by all insurance brokerage companies and/or reinsurance. The local LEI issuing operator is Zagreb d.d. Stock Exchange. Reporting obligors not required to obtain an LEI code leave this field blank. | | Intermediary telephone number | The intermediary's phone number is entered in the format: city code and phone number, entering only numeric values without spaces or special characters. Example from HR 016173255 Example from outside HR 0038657212345678 | | Intermediary mobile number | The responsible person's mobile number is entered in the format: operator code and mobile number, entering only numeric values without spaces or special characters. Example from HR 0916173255 Example from outside HR 003861971234567 | | Intermediary public email address | The intermediary's electronic mail address to be publicly published on Hanfa's website registry is entered. The email address also serves for correspondence with Hanfa. External collaborator (accounting or bookkeeping service) email addresses are not entered. | | Business activity according to NKD 2007 | The intermediary's business activity assigned by the Croatian Bureau of Statistics is selected from the dropdown menu. This field will be discontinued starting from the reporting period 1.1.2027. | | Business activity according to NKD 2025 | The intermediary's business activity assigned by the Croatian Bureau of Statistics is selected from the dropdown menu. | | Registration number of the authorized person for representation | The registration number of the responsible physical person who is the intermediary's responsible person and holds Hanfa's authorization for distribution is entered. If there are multiple responsible persons, the registration number of only one is entered. Two letters and numbers with one space between them are entered (ZO or PO number). Example ZO 123 or PO 123 | | Data refers to the period (semi-annual 1.1.-30.6. or annual 1.1.-31.12.) | The period for which the report is submitted is selected from the dropdown menu:
12. semi-annual report 1.1.-30.6.
13. annual report 1.1.-31.12. | | Number of employees on the last day of the reporting period | The number of employees increased by the number of management board members or sole trader owners, if they are not in an employment relationship with the intermediary, is entered. The number cannot be zero (0) if there are employee payments. Exceptionally, zero employees are possible only upon cessation of business activity. | | Hours worked by employees (total hours worked excluding annual leave, maternity leave, public holidays) | The actual hours worked by all employees of the intermediary are entered. According to Croatian Bureau of Statistics data, annual working hours per employee range from 1450 to 2250 hours. | | Number of authorized insurance representatives/brokers in (re)insurance in employment on the last day of the reporting period | The number of insurance representatives/brokers with Hanfa licenses on the last day of the reporting period in an employment relationship with the reporting obligor is entered. | | Number of authorized insurance representatives/brokers in (re)insurance in other contractual relationships on the last day of the reporting period | The number of insurance representatives/brokers with Hanfa licenses on the last day of the reporting period in other contractual relationships (e.g., work contract) with the reporting obligor is entered. | | Number of insurance or reinsurance companies for which distribution business contracts are concluded | The number of insurance or reinsurance companies with which the reporting obligor had contracted distribution business, resulting in commissions expressed in SP-1-O and SP-1-RE forms, is entered. Exceptionally, it may be 0 (zero) if the intermediary did not distribute (re)insurance products or ceases (re)insurance distribution activity. | | Number of clients for whom distribution business contracts are concluded | The number of clients with whom the reporting obligor had contracted distribution business in the observed period is entered. If no cooperation occurred, zero (0) is entered. | | Number of representation and/or brokerage companies with which distribution business contracts are concluded | The number of representation and/or brokerage companies with which the reporting obligor had contracted distribution business in the observed period is entered. If no cooperation occurred, zero (0) is entered. | | Intermediary conducts reinsurance distribution business | Selected from dropdown:
14. YES intermediaries that distributed reinsurance during the reporting period (SP-1 RE and SP-1 RE additional forms are completed)
15. NO intermediaries that did not distribute reinsurance during the reporting period (SP-1 RE and SP-1 RE additional forms are not completed) | | Intermediary delegates report submission to a third party | Selected from dropdown:
16. YES if the report is submitted by an external collaborator (e.g., accounting service) and signed with their certificate based on the reporting obligor's power of attorney
17. NO if the report is submitted by the reporting obligor and signed with their certificate |

5.2. Completing the Policy or Guarantee Form This form is completed by all reporting obligors of the FSI-PO report. Depending on whether a professional liability insurance policy is contracted or a guarantee covering professional liability from the business of insurance distribution or reinsurance distribution is obtained, the fields in the report must be completed:

Column Name	Position Description
Is a professional liability insurance policy contracted or is a guarantee covering professional liability from distribution (re)insurance business obtained?	Selected from dropdown:

1. policy
2. guarantee | | Completed if a professional liability insurance policy is contracted | | Policy concluded with