Circular No. 203-2025

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" Av. Paseo de la Republica 3617 San Isidro Central: 610 - 6300 www.smv.gob.pe Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml San Isidro, April 16, 2025 CIRCULAR No. 203-2025-SMV/11.1 Gentlemen Issuers under the General Regime Present: - Ref.: File No. 2025011847 Circular No. 198-2024-SMV/11.1 I address you regarding your obligations to prepare and present financial statements in full compliance with International Financial Reporting Standards – IFRS, internationally in force, in accordance with what is provided in Article 4, numeral 4.1 1, of the Standards on Preparation, Presentation and Dissemination of Financial Statements, Annual Report and Management Report applicable to entities supervised by the Securities Market Superintendence (hereinafter, Standards on Financial Statements), approved by SMV Resolution No. 013-2023-SMV/01, published in the Official Gazette El Peruano on December 10, 2023.

In this regard, it is important to highlight the importance of IFRS, as the only standard for the preparation of financial statements of issuer companies in Peru; since they contribute to the international comparability and quality of information, allowing investors and other market participants to make duly informed decisions about their businesses.

In that sense, it is pertinent to reiterate to your represented party, in its capacity as an issuer with securities registered in the Public Registry of the Securities Market – RPMV, to consider the following aspects in the preparation and presentation of financial statements:

I. Full Compliance with IFRS
The Standards on Financial Statements require that issuers with securities registered in the RPMV 2, prepare and present their financial statements in full compliance with IFRS, for which purpose issuers must follow every one of the principles of recognition, measurement and disclosure; as well as the criteria for presentation, consolidation and others established in the aforementioned international standards, through the presentation of a complete set of financial statements.

In this regard, it should be noted that the above requires the entity to make all applicable disclosures required by IFRS, since if this requirement is not met, it is not possible to sustain that we are facing full compliance with these standards, and it must be indicated that a condensed set of financial statements does not provide certainty of such compliance, since IAS 34 "Interim Financial Information" allows an entity to be exempt from fulfilling all disclosures.

II. Declaration of Compliance
IAS 1 "Presentation of Financial Statements", paragraph 16, establishes that financial statements that comply with IFRS must include, in notes, an explicit and unreserved declaration of such compliance.

According to said standard, an entity shall not state that its financial statements comply with IFRS unless they meet all the requirements of these, including the disclosure requirements through the presentation of a complete set of financial statements.

In that sense, issuers must present to the Securities Market Superintendence – SMV a complete set of financial statements that fully comply with IFRS, and likewise, in notes, they must present the declaration of compliance referred to in IAS 1.

Likewise, it is necessary to clarify that to the extent that a condensed set of financial statements, which generally only includes the explanatory notes established in IAS 34, the formulation of said declaration is not possible.

III. Information on Accounting Policies
Article 10 of the Standards on Financial Statements and IAS 1 paragraph 10, establish the obligation for issuers to disclose in notes a summary of information on material accounting policies or of relative importance and other explanatory information.

For the foregoing, considering the fundamental role that IFRS and the aforementioned regulation play in the quality and transparency of financial information disseminated to the market; the annual and interim financial statements of issuers with securities registered in the RPMV, must comply with the disclosure requirements established both in IFRS and in the norms issued by this Superintendence.

1 "Article 4.- Applicable Standard
4.1. The obligated subjects must prepare their financial statements in full compliance with IFRS and, to the extent applicable, the Financial Information Regulation and the Manual for the preparation of Financial Information." (Underlining added)

2 According to what is provided by Article 5, literal c), of the Organic Law of the SMV (approved by Decree Law No. 26126 and its modifications) and Article 33 of the Securities Market Law, Legislative Decree No. 861 (approved by Supreme Decree No. 020-2023-EF), the standards for the elaboration and presentation of individual and consolidated financial statements and any other complementary information, as well as the supervision of compliance with such standards, do not extend to entities that participate in the securities market and that are under the competence of the Superintendence of Banks, Insurance and Private Pension Fund Administrators, whose financial information is prepared and presented in accordance with the provisions established by said institution.

PERU Ministry of Economy and Finance

SMV
Securities Market Superintendence
"Decade of Equality of Opportunities for Women and Men" "Year of recovery and consolidation of the Peruvian economy" Av. Paseo de la Republica 3617 San Isidro Central: 610 - 6300 www.smv.gob.pe Electronically signed document in the framework of Law No. 27269, Law of Digital Signatures and Certificates, its Regulations and modifications. The integrity of the document and the authorship of the signature(s) can be verified at https://apps.firmaperu.gob.pe/web/validador.xhtml

Finally, it is appropriate to clarify that this Circular is issued with an advisory character, and its purpose is to reiterate to you the obligations established in the current regulations with the aim that your represented party adopts the pertinent actions that allow it to comply fully with the obligations of preparation and presentation of information that are exigible to it; which may be subject to supervision actions by this General Intendancy.

Without further particulars, I remain at your disposal.
Sincerely,
Alix Godos
General Intendant
General Intendancy of Conduct Supervision