2025-12-16 | A 8369

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Circular CONAU 1-1708: Monthly Accounting Reporting Regime. Global Net Foreign Currency Position (R.I. - P.G.). Adjustments

The Central Bank of the Argentine Republic issued Circular CONAU 1-1708 to modify the Monthly Accounting Reporting Regime for the Global Net Foreign Currency Position following Communications A 8311, A 8325, and A 8360. The adjustments update Section 2, 3, and 4 of the instructions and model effective December 2025, while introducing an optional daily reporting item for foreign financing with an original average life of at least 12 months effective March 2026. These changes specifically impact the calculation of positions, excesses, and charges for financial entities, including Group A entities whose daily monitoring requirements remain valid until February 28, 2026.

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"Year of the Reconstruction of the Argentine Nation" COMMUNICATION "A" 8369 16/12/2025 TO FINANCIAL ENTITIES: Ref.: Circular CONAU 1-1708: Monthly Accounting Reporting Regime. Global Net Foreign Currency Position (R.I. - P.G.). Adjustments.


We address you to inform you of the modifications to the reporting regime referenced, as a consequence of the issuance of Communications A 8311, A 8325, and A 8360. Regarding this, the following changes are made: RI PGMNE Monthly Requirement:

  • Adjustment of Section 2. Particular Instructions, Section 3. Information Model, and Section 4. Determination of position and calculation of charges, to reflect the cited changes (Effective: December/2025). Daily Requirement:
  • Incorporation in Section 7. Monitoring of the GNFCP, of item 41060 - Financing received from abroad whose original average life is at least 12 months (Optional) (Effective: March/2026). Monitoring of the GNFCP – Daily Requirement – Group "A" Entities (Annex I) – Valid until 02/28/2026
  • Incorporation of item 41060 - Financing received from abroad whose original average life is at least 12 months (Optional). Likewise, the sheets that are to replace the text in the consolidated text of this reporting regime are attached. We greet you attentively. CENTRAL BANK OF THE ARGENTINE REPUBLIC Rodrigo J. Danessa Estela M. del Pino Suárez Main Manager of Reporting Regime and Information Centers General Manager of Reporting Regime and Protection of Users of Financial Services ANNEX

2.1. Concepts Covered The calculation of items will be based on the monthly average of daily balances (capitals, adjustments, exchange rate differences, and interest, as applicable) recorded in the month under report. Public and private bonds - item code 10200- LEBAC in foreign currency liquidated in pesos shall be included. Bonds linked to GDP growth shall be excluded. Other credits and Other obligations by financial intermediation - item codes 10400, 20200-. In items 10400 and 20200, the average balances corresponding to the component concepts of these categories will be reported. Participation certificates or debt titles issued by financial trusts and credit rights regarding ordinary trusts, in the corresponding proportion, will be included when the underlying asset is constituted by foreign currency assets. Counterparties of Debtors and Creditors will be considered only when the settlement price has been agreed in foreign currency. Operations with titles registered in off-balance sheet items Operations with public or private titles registered in off-balance sheet items referred to to fixed-term deposits, loans from financial entities, or resale operations will be computed in the GNFCP to the extent that the receiving entity sells said securities to third parties (registered in Other Obligations by Financial Intermediation). Allocation of assets in guarantee (item 10600) Financial intermediation assets covered (e.g., foreign currency itself, securities, and other assets denominated in that currency or linked to the evolution of the exchange rate) that are allocated as guarantee for operations will be reported. Derivatives - item code 30000- Operations accounted for in "Off-balance sheet items of derivatives" - forward, options, and other derivatives - whose underlying asset is foreign currency, financial assets denominated in foreign currency, when the settlement price is agreed in pesos, except commodities, will be included. Therefore, derivatives accounted for in "Off-balance sheet items of Derivatives" will not be included when they refer to operations between different foreign currencies, or between financial assets denominated in foreign currency and their own currency. Forward operations liquidated by difference will be given the same treatment as forward purchases and sales in foreign currency, that is, the total notional value will be computed. B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME 16. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 2. Particular Instructions Version: 17th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 1

Positions for futures options must be measured by multiplying the delta coefficient by the notional, and in particular, in the case of US dollar futures, said notional must be multiplied by the quotation of the US dollar in spot (cash) operations. In the case of derivatives on commodities, the amount of the net position of the operations provided for in points 3.6. and 6.1.3. of the rules on "Operations to be settled for cash and forward, repos, pledges, other derivatives and with common investment funds" will be reported, computed according to what is established in point 1.1. of the rules on "Global net foreign currency position", regardless of the settlement currency. For the computation of other derivatives, the SEFyC must be consulted on the treatment to be granted in a singularized manner. Increase due to failure to compensate for prepayments of unmatured titles or for sale of Treasury securities in foreign currency acquired in primary subscription from 10/12/2025 – item 50000- The decrease in foreign currency assets due to prepayments of local financing to private sector clients or due to sales of Treasury securities in foreign currency acquired in primary subscription from 10/12/25, not compensated with the net increase in Treasury securities in foreign currency, will be computed as an increase in the GNFCP, up to the term of their original maturity. 2.1.1. General Exclusions The concepts established in point 1.2. of the rules on "Global net foreign currency position" will not be computed. 2.2. Daily Positions The positions of each of the days of the month under report will be reported, indicating their sign. For non-business days, the amount of the immediate preceding business day will be repeated. Its determination will be based on daily balances (capitals, adjustments, exchange rate differences, and interest, as applicable) recorded in the month under report, taking into account the concepts covered described in point 2.1., without computing the exclusions established in point 1.2. of the rules on "Global net foreign currency position". 2.2.1. Global Net Position - Item Code 400dd- The global net foreign currency position defined in Section 1. of the consolidated text of the norms of this regulation of each of the days of the month under report will be reported, indicating its sign. 2.2.2. Spot Position – Item Code 410dd- This position will be reported taking into account what is established in point 2.2.2 of the rules on "Global Net Foreign Currency Position". B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME 16. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 2. Particular Instructions Version: 18th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 2

2.3. Exemptions If applicable, exemptions will be reported by consigning in the last positions of the item code (dd) the day/s of the month. Code 50100 The amount of exemptions granted by the BCRA, which imply increases in the integration of the computable patrimonial responsibility (always that in the Resolution through which it is granted - or according to the criterion of the SEFyC - it is clarified that it also reaches this regulation) will be reported. Since the RPC of the month prior to the one under report is used as a parameter, it will be necessary to consider in the month being reported the GNFC the exemption referred to the RPC of month n-1. Code 502dd The amount of exemptions granted by the BCRA that imply decreases in the global net position determined is included. Code 503dd It comprises the amount of exemptions granted by the BCRA, which imply decreases in the excess of the GNFC. Code 504dd The amount of exemptions granted by the BCRA, which imply decreases in the charge determined by excess in the "Global Net Position - % limit / RPC" relationship, will be consigned. The computation criteria for exemptions will be determined by the Resolution through which they are granted. The number and date of said Resolution, or the number of note and date by which such decision was communicated, must be consigned. A detailed description of the calculation of the exemption for the reported period will also be added, according to what is established in the Resolution or note referred to in the preceding paragraph. In cases where the scope of the exemptions has not been specified, the criterion for their imputation must be consulted with the Supervision and Monitoring Area of this Institution. Other Information

  • In items 70XXX and 80XXX, the balances registered at the end of the period under report – capital and interest -, corresponding to loans and fixed-term investments with variable remuneration based on the US dollar, respectively, will be consigned, where XXX is the corresponding sector: 100 = Non-financial private sector 200 = Non-financial public sector 300 = Financial sector 400 = Residents abroad B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME
  1. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 2. Particular Instructions Version: 7th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 3
  • In each reporting period in which a swap of debt instruments ordered by the National Executive Power is verified, the following items will be reported, consigning the day of that month in which the swap or hedging operation is carried out in the code "dd", and the amount corresponding to those operations (that is, only the days in which they are carried out and the total amounts of the operations are reported): 910dd = Decrease in foreign currency debt instruments due to the swap ordered by the NEP. 920dd = Hedging of the variation in the GNFC due to the swap, with the applications of Section 2. of the rules on Credit Policy. 930dd = Hedging of the variation in the GNFC due to the swap, with foreign currency forward operations.
  • Declaration by the entity of the existence of mismatches in the daily position originated in external factors not imputable to the entity (unliquidated foreign trade operations for reasons unrelated to the entity). Item 950dd In case there is an excess in the position for any day of the period under report, originated in exogenous factors to the entity, and whose effect has been regularized by the next business day, it must be declared if, excluding said amount: Code 1 = no charge is verified; Code 2 = the charge persists. It is noted that the inclusion of this item will imply the obligation on the part of the entity to have at the disposal of the Central Bank the background information supporting the exogenous factors that caused the mismatch as well as that its effects have been regularized by the next business day. Version: 4th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 4 B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME
  1. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 2. Particular Instructions

Code Concept Total 10000 Foreign currency assets (+) 10100 Liquidity 10110 Cash 10120 Correspondency 10130 Others 10200 Debt securities 10210 Public securities 10220 Private securities 10230 Monetary regulation instruments 10300 Loans 10400 Other credits by financial intermediation 10500 Credits by financial leasing 10600 Assets affected in guarantee of operations 20000 Foreign currency liabilities (-) 20100 Deposits 20200 Other obligations by financial intermediation 20300 Subordinated negotiable obligations 30000 Derivatives (+) or (-) 30100 Purchased call options (+) 30200 Purchased put options (-) 30300 Sold call options (-) 30400 Sold put options (+) 30500 Other derivatives (+) or (-) 30600 Forward purchases (+) 30700 Forward sales (-) 30800 Derivatives on Commodities (+) or (-) 50000 Increase due to failure to compensate for prepayments of unmatured titles or for sale of Treasury securities in FC acquired in primary subscription from 10/12/2025 with the net increase in holdings of Treasury securities in foreign currency. (+) 400dd Daily global net position (+) or (-) 410dd Spot position (+) or (-) Exemptions 50100 Increase in the integration of Computable Patrimonial Responsibility (+) 502dd Decrease in the amount of the global net position (+) 503dd Decrease in the excess of the GNFC with respect to the limits provided (+) 504dd Decrease in the charge for excess of the GNFC (+) dd = day of the month under report Version: 17th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 1 B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME 16. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 3. Information Model.

4.1. Position, limits, and excesses GNFCP = Code 400dd = Code 100dd + Code 200dd + Code 300dd + Code 500dd 4.1.1. Daily Positions Global net position (Items 400dd -includes computation of code 50000-) Where GNFCP (dd) = Code 400dd - Code 502dd The daily excess is determined as follows: If GNFCP(dd) < 0 Excess (dd) (-) = Abs (GNFCP (dd)) - X % * (RPC (n -1) + Code 50100) - Code 503dd RPC (n -1) = the one reported in the regime of "Requirement and integration of minimum capital" in period (n-1). If GNFCP (dd) > 0 Excess (dd) (+) = GNFCP (dd) - X % * (RPC (n -1) + Code 50100) - Code 503dd Spot position (items 410dd) Where PCFCP (dd) = Code 410dd - Code 502dd The daily excess is determined as follows: If PCFCP(dd) < 0 Excess (dd) (-) = Abs (PCFCP (dd)) - X % * (RPC (n -1) + Code 50100) - Code 503dd If PCFCP (dd) > 0 Excess (dd) (+) = PCFCP (dd) - X % * (RPC (n -1) + Code 50100) - Code 503dd Final excessdd (+) = Max [Adjusted excessdd Global Net Position; Adjusted excessdd Spot Position] Where: X = % valid for the reported period B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME 16. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 4. Determination of position. Version: 20th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 1

4.2. Charges The charge will be calculated on the excesses determined according to point 4.1. preceding, applying the following methodology: Charge = ∑ Excess (dd) * [(TNA / 36500) * 1000] A debit note (Formula 3030) will be attached for the amount of the charge, indicating as the concept of the operation "Charge for excess in the Global Net Foreign Currency Position". To determine both the charges and the interest applicable on those not paid in time and form, the different rates valid during the period to which the position and/or the period of default correspond, respectively, will be considered. Version: 12th COMMUNICATION "A" 8369 Effective: 01/12/2025 Page 2 B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME 16. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 4. Determination of position.

7.2. Information Model Code Day Concept Amount Foreign currency assets (+) Liquidity 10110 dd Cash 10120 dd Correspondency 10130 dd Others Debt securities Public securities 10211 dd National Treasury Bills in dollars 10212 dd Bonds linked to the dollar 10213 dd Other public securities 10220 dd Private securities 10230 dd Monetary regulation instruments 10300 dd Loans 10400 dd Other credits by financial intermediation 10500 dd Credits by financial leasing Assets affected in guarantee of operations 10610 dd Assets affected in guarantee for credit card operations 10620 dd Other assets affected in guarantee Foreign currency liabilities (-) 20100 dd Deposits 20200 dd Other obligations by financial intermediation 20300 dd Subordinated negotiable obligations 30000 dd Derivatives (+) or (-) 50000 dd Increase due to failure to compensate for prepayments of unmatured titles or for sale of Treasury securities in FC acquired in primary subscription from 10/12/2025 with the net increase in holdings of Treasury securities in foreign currency. (+) 40000 dd Daily global net position (+) or (-) 41010 dd Net position of operations to be settled for cash and other derivatives not included in item 30000. (+) or (-) 41020 dd Positive difference provided for in section c) of point 2.2.2 of the GNFCP norms (+) 41030 dd Net Position of instruments linked to the evolution of the value of the foreign currency, except those imputed in item 41040. (+) or (-) 41040 dd Export pre-financing whose foreign currency funding is imputed to liabilities linked to the evolution of the value of the foreign currency (+) 41050 dd Guarantees constituted by debit, purchase, and credit card operations abroad for up to an amount equivalent to five calendar days of consumption (+) 41060 dd Financing received from abroad whose original average life is at least 12 (twelve) months (optional). (+) 41000 dd Spot Position (40000 - 30000 - 41010 - 41020 - 41030 – 41040 – 41050 - 41060) (+) or (-) B.C.R.A. MONTHLY ACCOUNTING REPORTING REGIME 16. GLOBAL NET FOREIGN CURRENCY POSITION (R.I. – P.G.) Section 7. Monitoring of the GNFCP Version: 2nd COMMUNICATION "A" 8369 Effective: 02/03/2026 Page 2

  1. Information Model Code Day Concept Amount Foreign currency assets (+) Liquidity 10110 dd Cash 10120 dd Correspondency 10130 dd Others Debt securities Public securities 10211 dd National Treasury Bills in dollars 10212 dd Bonds linked to the dollar 10213 dd Other public securities 10220 dd Private securities 10230 dd Monetary regulation instruments 10300 dd Loans 10400 dd Other credits by financial intermediation 10500 dd Credits by financial leasing Assets affected in guarantee of operations 10610 dd Assets affected in guarantee for credit card operations 10620 dd Other assets affected in guarantee Foreign currency liabilities (-) 20100 dd Deposits 20200 dd Other obligations by financial intermediation 20300 dd Subordinated negotiable obligations 30000 dd Derivatives (+) or (-) 50000 dd Increase due to failure to compensate for prepayments of unmatured titles or for sale of Treasury securities in FC acquired in primary subscription from 10/12/2025 with the net increase in holdings of Treasury securities in foreign currency. (+) 40000 dd Daily global net position (+) or (-) 41010 dd Net position of operations to be settled for cash and other derivatives not included in item 30000. (+) or (-) 41020 dd Positive difference provided for in section c) of point 2.2.2 of the GNFCP norms (+) 41030 dd Net Position of instruments linked to the evolution of the value of the foreign currency, except those imputed in item 41040. (+) or (-) 41040 dd Export pre-financing whose foreign currency funding is imputed to liabilities linked to the evolution of the value of the foreign currency (+) 41050 dd Guarantees constituted by debit, purchase, and credit card operations abroad for up to an amount equivalent to five calendar days of consumption (+) 41060 dd Financing received from abroad whose original average life is at least 12 (twelve) months (optional). (+) 41000 dd Spot Position (40000 - 30000 - 41010 - 41020 - 41030 – 41040 – 41050 -

(+) or (-) B.C.R.A. ANNEX I Annex to Com. “A” 8369