Circular SINAP 1-249: Payment Service Providers. Update.

"2026 - YEAR OF ARGENTINE GREATNESS" COMMUNICATION "A" 8454 14/07/2026 TO AUTOMATED TELLER MACHINE NETWORKS, TO ELECTRONIC FUNDS TRANSFER NETWORKS, TO ADMINISTRATORS OF ELECTRONIC FUNDS TRANSFER PAYMENT SCHEMES, TO PAYMENT SERVICE PROVIDERS THAT OFFER PAYMENT ACCOUNTS, TO PAYMENT SERVICE PROVIDERS THAT PERFORM THE INITIATION FUNCTION, TO PAYMENT ACCEPTORS WITH TRANSFER, TO QR ADMINISTRATORS, TO CARD PAYMENT ACQUIRERS, TO PAYMENT INSTRUMENT AGGREGATORS, TO EXTRABANK COLLECTION COMPANIES FOR TAXES AND/OR SERVICES: Ref.: Circular SINAP 1-249: Payment Service Providers. Update.

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We address ourselves to you in order to deliver to you the sheets that, in replacement of those previously provided, must be incorporated into the consolidated text on Payment Service Providers, in accordance with what is established by Communications A 8411 and A 8432. It is recalled 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", the modifications made with texts highlighted in special characters (strikethrough and bold) will be found. We greet you sincerely. CENTRAL BANK OF THE ARGENTINE REPUBLIC Jorge A. M. Golla Matias A. Gutiérrez Girault Manager of Payment Systems Principal Manager of Payment Systems and Current Accounts ANNEX

-Index- Section 1. General Provisions 1.1. Scope. Functional Approach 1.2 Definitions 1.3. Exclusions 1.4. Functions 1.5. Non-compliance and sanctions Section 2. Payment service providers that must register with the BCRA 2.1. Registration of payment service providers 2.2. Enrollment procedure 2.3. Certificate of enrollment 2.4. Information update 2.5. Cessation of activities Section 3. Information regime and supervision Section 4. Payment service providers that offer payment accounts 4.1. Fund administration 4.2. Transparency 4.3. Fund transfers sent from and received in payment accounts 4.4. Identity verification 4.5. PSPCP as a Service: particular provisions 4.6. Prohibitions Section 5. Payment service providers that perform the acceptance function Section 6. Payment service providers that perform the initiation function Section 7. Prevention of money laundering, terrorist financing and other illicit activities Correlation table B.C.R.A. PAYMENT SERVICE PROVIDERS Version: 8th COMMUNICATION "A" 8454 Validity: 15/07/2026 Page 1

1.2.3. Retail payment schemes shall not be considered for the purposes of this regulation: 1.2.3.1. Payment schemes regulated by the National Securities Commission (CNV) for primary placement and/or secondary trading, and/or the clearing and/or settlement of securities. 1.2.3.2. Payment schemes whose object is the retention and/or collection and settlement of sums destined to cancel tax or other obligations with the State at any of its levels and agencies. 1.2.4. Electronic clearing houses may perform functions within a retail payment scheme, within the global framework of the national payments system, on equal terms with financial entities and PSPs, in accordance with the specific regulations that already govern them and provided that it is not limited by the specific regulation of each payment instrument. 1.3. Exclusions 1.3.1. The following may not operate as PSPs: 1.3.1.1. Legal entities that are not regularly constituted in the country, or that, being private legal entities constituted abroad, have not complied with what is required by the General Companies Law 19.550 and its modifications for the habitual exercise in the Argentine Republic of acts included in their corporate purpose. 1.3.1.2. Legal entities that the CNV regulations expressly recognize as markets, clearing houses, or agents of any type. 1.3.2. The following may not act as shareholders, partners, possess voting rights –directly or indirectly (in this case, when they exercise final control)– or be members of the administration or supervision body of a PSP: 1.3.2.1. Natural persons included in what is provided in items a), b), d), e) or f) of article 10 of the Financial Entities Law or who have a conviction for intentional crimes against property, public administration, the economic and financial order, or public faith; for violation of secrets and privacy, illicit association, or for infringement of item b) of article 1° of the Foreign Exchange Penal Regime Law. 1.3.2.2. Natural and legal persons who appear in resolutions on terrorist financing communicated by the Financial Information Unit (UIF) and/or are in the Public Registry of Persons and Entities linked to acts of Terrorism and its Financing (RePET) and/or have been designated by the Committee of the Security Council of the United Nations Organization –in this last case subject to the application of the corresponding sanctions and restrictive measures–, without prejudice to the other measures that correspond to be adopted in accordance with the current legislation in these matters. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 1. General Provisions Version: 4th COMMUNICATION "A" 8454 Validity: 01/05/2026 Page 2

Likewise, consideration will be given to whether the person –natural or legal– has been convicted of a fine by the UIF or with disqualification, suspension, prohibition or revocation by the BCRA, the CNV and/or the Superintendence of Insurance of the Nation (SSN). 1.4. Functions The following functions to be performed within a payment scheme are explicitly defined below: 1.4.1. Provision of accounts: both financial entities and PSPs registered with the BCRA as payment service providers that offer payment accounts (PSPCP) can offer accounts for the making of debits and credits within a payment scheme. The accounts offered by PSPs are called payment accounts; they are freely available peso accounts that allow ordering and receiving payments. PSPCPs may allow those accounts to have more than one holder. 1.4.1.1. PSPCP as a Service: comprises PSPs that offer payment accounts –and, eventually, the interoperable digital wallet service– to clients of a third-party service provider, who use the accounts through a user interface provided by that third party and technologically integrated into the PSPCP. 1.4.2. Administration: establish the operational, technical and commercial rules of the payment scheme, ensure their compliance, in accordance with the regulatory framework, establishing contractual relationships with each of the participants in the payment scheme. When the specific regulations of a payment instrument require BCRA authorization to perform the administration function, consideration will be given to the level of competition existing in the market, the efficiency and quality of service of existing administrators, systemic risk and whether there is a firm willingness of potential participants to contract with the administrator under analysis. 1.4.2.1. Electronic funds transfer payment scheme administrator: establish the operational, technical and commercial rules of the transfer scheme, in accordance with the consolidated texts (TO) on National Payments System – Transfers, National Payments System – Transfers – Complementary Rules and National Payments System – Payment Services, and ensure their compliance. Requires BCRA authorization. 1.4.2.2. QR Administrator: manage payments for QR travel schemes (VQR). 1.4.3. Acceptance: adhere merchants to payment schemes with transfer. It includes, among others, the following tasks: facilitate mechanisms to initiate payments, transmit the payment order information to the administrator or other participants in the scheme in question and, if authorized, confirm the operations. 1.4.4. Initiation: remit a valid payment instruction at the request of an ordering client to the provider of an account –payment or demand– or issuer of a payment instrument. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 1. General Provisions Version: 6th COMMUNICATION "A" 8454 Validity: 01/05/2026 Page 3

1.4.5. Automated teller machine networks: administer transactions ordered through automated teller machines. 1.4.6. Electronic funds transfer networks (processing or operation): transmit electronic instructions for fund movements between financial entities and, if applicable, notify the PSP that offers payment accounts of the crediting in its demand account, so that it proceeds to the effective fulfillment of the transfer function that falls to it according to what is defined in point 1.3.11. of the TO on National Payments System – Transfers – Complementary Rules. 1.4.7. Acquiring: adhere merchants to payment schemes with cards. It includes, among others, the following tasks: facilitate mechanisms to initiate payments, transmit the payment order information to the administrator or other participants in the scheme in question and, if authorized, confirm the operations. 1.4.8. Aggregation or sub-acquiring: provide merchants with access to payment schemes that the aggregator has contracted with one or more acquirers, using for these purposes the identifier number (merchant ID) of the aggregator or sub-acquirer, who acts as the client receiving the funds from the settlement of the different payment schemes. 1.4.9. Extrabank collection companies for taxes and/or services: provide the service of payments and/or collections of taxes and/or services on behalf and order of third parties through agent networks, using cash and/or payment instruments. 1.5. Non-compliance and sanctions Both PSPs subject to registration as provided in Section 2. and those authorized by the BCRA to perform the functions of administrator of electronic funds transfer payment schemes or electronic clearing houses and the members of their government, administration and supervision bodies, for the non-compliances that are established with respect to the regulations issued by the BCRA to regulate their activity, are subject to the application of sanctions as provided in articles 41 and 42 of the Financial Entities Law and concordant provisions. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 1. General Provisions Version: 3rd COMMUNICATION "A" 8454 Validity: 21/03/2026 Page 4

2.2.2.5. Special address –the address where the pertinent operational processes will be carried out and the records associated with said operation will be recorded must be stated–. − Street and Number − Locality − Province − Postal code − Telephone 2.2.2.6. Legal representative / attorney-in-fact − First and last names − Type and number of identity document − Email address 2.2.2.7. Data security officer –designated for the purposes of accessing the computer environments of the BCRA's Internet sites–. − First and last names − Position − Type and number of identity document − Email address 2.2.2.8. Responsible for payment system supervision − First and last names − Position − Type and number of identity document − Email address 2.2.2.9. Responsible for information regime − First and last names − Position − Type and number of identity document − Email address 2.2.2.10. Compliance Officer before the UIF –principal and alternate– (to register as a PSP that is a subject obliged before the UIF) − First and last names − Position − Type and number of identity document − Email address B.C.R.A. PAYMENT SERVICE PROVIDERS Section 2. Payment service providers that must register with the BCRA Version: 5th COMMUNICATION "A" 8454 Validity: 01/05/2026 Page 2

2.2.2.11. Operational and commercial description (does not apply to PSPs included in point 1.4.2.2.). i) To register as a PSPCP they must: − Inform which (or which ones) will be their sponsoring bank(s). − Detail the payment services that will be provided. − Include the terms and conditions of use of the payment accounts. − Inform the modes of restitution of funds if required or if the activity ceases. − Indicate if it will offer payment accounts –and, eventually, the interoperable digital wallet service– through third parties (that is, if it will operate as a PSPCP as a Service as established in point 1.4.1.1.). In the affirmative case it must: a. Register the list of entities to which it will provide the service, for which the exclusions of point 1.3. apply. For each of them it must state the information required in points 2.2.2.1. to 2.2.2.4., 2.2.2.6. and 2.2.2.12, as well as a description of the services they will provide. b. Update this list on each occasion it suffers modifications, taking into account that it cannot provide the service to an entity until this entity has the prior authorization of the BCRA. ii) For PSPs that perform the initiation function (PSI) and provide the digital wallet service: − Specify if said digital wallet service will allow initiating payments by reading QR codes and detail with which instruments –such as transfer payment and credit card– those payments can be made. − Payment schemes in which it participates initiating operations. iii) For automated teller machine network and electronic funds transfer network: − Copy of the regulations or operational manual that contemplates the service specifications and responsibilities assumed by the participants. − List of its participants, grouped by type or function assumed. iv) For PSPs that perform the acceptance function: − Present a flowchart describing the entire process behind a payment, from when the client orders it until the funds are credited to the recipient account or rejected, as appropriate. − Detail the participants that perform each function in that process. − Indicate payment schemes in which it will participate. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 2. Payment service providers that must register with the BCRA Version: 6th COMMUNICATION "A" 8454 Validity: 15/07/2026 Page 3

− Indicate if it offers point of sale terminals (POS). In the affirmative, specify under which modalities (sale and/or loan; on its own account or through another company). − Detail commission structure. − Specify the types of card payments offered and the initiation methods contemplated. v) For PSPs that perform the acquiring function: − Present a flowchart describing the entire process behind a payment, from when the client orders it until the funds are credited to the recipient account or rejected, as appropriate. − Detail the participants that perform each function in that process. Specify the list in the case of financial entities that perform acquiring on behalf and order of the PSP. − Indicate payment schemes in which it will participate. − Indicate if it offers point of sale terminals (POS). In the affirmative, specify under which modalities (sale and/or loan; on its own account or through another company). − Commissions and crediting deadlines. vi) For PSPs that perform the aggregation or sub-acquiring function: − Present a flowchart describing the entire process behind a payment, from when the client orders it until the funds are credited to the recipient account or rejected, as appropriate. − Detail the participants that perform each function in that process. − Indicate the list of acquirers with whom it will maintain a contractual relationship. − Indicate if it offers point of sale terminals (POS). In the affirmative specify under which modalities (sale and/or loan; on its own account or through another company). − Commissions and crediting deadlines. vii) For extrabank collection companies for taxes and/or services: − Present a flowchart describing the entire process behind a payment, from when the client orders it until the funds are credited to the recipient account or rejected, as appropriate. − Detail the participants that perform each function in that process. − Indicate the services provided. − Specify the payment means accepted and their different initiation modalities. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 2. Payment service providers that must register with the BCRA Version: 6th COMMUNICATION "A" 8454 Validity: 01/05/2026 Page 4

2.2.2.12. Shareholders and executives i) Identification of natural persons who possess at least 10% (ten percent) of the capital and/or voting rights of the legal entity, along with the detail of their personal background required in the respective application. ii) Identification of natural persons who by other means exercise final control, direct or indirect, of the PSP, along with the detail of their personal background required in the respective application. iii) Identification of the members of the administration and/or supervision body, along with the detail of their personal background and positions required in the respective application. Likewise, the persons mentioned in the preceding points must present: − Sworn declaration in which they declare that none of the disqualifications established in items a), b), d), e) or f) of article 10 of the Financial Entities Law apply to them and that they do not have a conviction for intentional crimes against property, public administration, the economic and financial order, or public faith; for violation of secrets and privacy, illicit association, or for infringement of item b) of article 1° of the Foreign Exchange Penal Regime Law; and that they do not appear in the resolutions on terrorist financing communicated by the UIF, that they are not in the Public Registry of Persons and Entities linked to acts of Terrorism and its Financing (RePET), that they have not been designated by the Committee of the Security Council of the United Nations Organization –subject to the application of the corresponding sanctions and restrictive measures–, that they have not been convicted of money laundering and/or terrorist financing crimes and regarding whether they have been sanctioned with a fine by the UIF or with disqualification, suspension, prohibition or revocation by the BCRA, the CNV and/or the SSN. − Sworn declaration on the condition of Politically Exposed Person in accordance with the current UIF regulations on the matter. − Criminal record certificate that must have been issued by the National Registry of Recidivism within 5 (five) business days prior to the date of its presentation to the SEFYC. In the case of persons who have their real domicile abroad, certificates of an equivalent nature issued by the competent governmental authority of the country where they reside must be presented. 2.2.3. Sworn declaration signed by the legal representative that all the information presented is true, that the attached documentation is a faithful copy and that the originals are available to the SEFYC (indicating where they are located) and that the PSP has voluntarily accepted that it is subject to the regulatory, supervisory and sanctioning regime of the BCRA. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 2. Payment service providers that must register with the BCRA Version: 4th COMMUNICATION "A" 8454 Validity: 01/05/2026 Page 5

2.2.4. Sworn declaration signed by the legal representative of the PSPCP as a Service, in which it undertakes not to provide the service to an entity until the BCRA has notified the corresponding authorization of that entity in the registry, and to inform the cancellations through the registry. 2.2.5. Consent to the extension of judicial competence in favor of the Federal Justice of the Autonomous City of Buenos Aires, for all legal effects of the relationship between the entity and the BCRA. The sworn declarations requested in points 2.2.2.12., 2.2.3. and 2.2.4. must be signed with the digital signature provided for in Law 25.506. Enrollments cannot be processed simultaneously. Any PSP that wishes to perform more than one function subject to registration may only initiate the enrollment for a new function after having obtained the certificate defined in point 2.3. for the previously initiated procedure. PSPs that decide to cancel their request must do so through the application referred to in this point. 2.3. Certificate of enrollment At the end of the enrollment request process, they will receive electronically a confirmation of the start of the procedure. If deficiencies, inconsistencies or lack of compliance with some of the points of the regulation are detected from the presentation, these will be communicated to the applicant within 10 business days of the request being made. Applicants must remedy the presentation by complying with the regulatory requirements within 20 business days of the request by the BCRA. Failure to remedy within the established period will imply the automatic expiration of the procedure, considering the PSP as an entity not enrolled in the "Registry of payment service providers" (RPSP). Once the requirements are met, the SEFYC will issue a certificate of enrollment and grant the applicant a number in the RPSP, which will be a necessary condition to be able to operate. PSPs will have a period of 12 months to start operations from the date of their enrollment –counted from the day the certificate of enrollment is sent to them–; failure to meet this deadline will imply automatic cancellation from the registry. The PSP that has been cancelled for failure to start operations or whose enrollment procedure has been declared expired for failure to remedy the observations within the established periods may not initiate a new enrollment procedure until 6 months have passed from the date of cancellation or expiration, respectively. PSPs must inform through the registry application the date of the effective start of their operations. B.C.R.A. PAYMENT SERVICE PROVIDERS Section 2. Payment service providers that must register with the BCRA Version: 3rd COMMUNICATION "A" 8454 Validity: 01/05/2026 Page 6

2.4. Information update Any change registered in the information required in this section must be reported to the SEFYC within 15 business days of its occurrence through the corresponding application. 2.5. Cessation of activities 2.5.1. By decision of the PSP PSPs may decide to cancel their enrollment in the RPSP, which will imply the cancellation of the corresponding enrollment, prior notice sent to the BCRA through the registry application with an advance of no less than 30 (thirty) calendar days of