Compilation of Payment System Rules - Modifications to Article 93, Book VII

Compilation of Payment System Rules - Modifications to Article 93, Book VII Montevideo, March 5, 2026 CIRCULAR NO. 2499 Ref: Notice is hereby given that this Central Bank adopted, on March 4, 2026, Resolution No. D/66/2026, which is attached, followed by the referenced text.

VIDONI BARBERO, MARCELO (Exp. No. 2025- 1 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy

BOARD OF DIRECTORS - RESOLUTION Montevideo, March 4, 2026. BOARD OF DIRECTORS HAVING VIEWED: Article 701 of Law No. 20.446 of December 16, 2025. WHEREAS: that the aforementioned article modified Article 6 of Law No. 19.210 of April 29, 2014, providing, among other things, that institutions issuing electronic money may make advances to their clients for periods not exceeding two business days from the funds resulting from investments made by them through their electronic money instrument, in accordance with the regulation issued by the Central Bank of Uruguay. CONSIDERING: I) that the cases and conditions under which institutions issuing electronic money may use the operational framework provided for in the aforementioned Law must be established; II) that for the purposes of issuing the aforementioned regulation, it must be considered that the general principle arising from the Law is the prohibition of institutions issuing electronic money from granting credit to their clients, with the regulation only allowing it to facilitate the user's immediate availability of their funds, even if they are invested in financial instruments issued by third parties and while the settlement procedure for those investments is in operation; III) that, although there is a benefit for the user of the electronic money instrument by giving them the possibility of obtaining a certain return on the investment of the funds with which they load their instrument, strict conditions must be established to develop this operation, which do not distort its nature and imply limited risks; IV) that in this sense, the operation must be limited to those investments in securities issued by the State or the Central Bank of Uruguay in national currency and taking into account that the product is directed to the general population using electronic money instruments, these investments are made through shares of investment funds composed of said category of securities, which allows for investments in smaller amounts; V) that likewise, this operation contributes to the purpose of this Central Bank to promote competition and the development of markets in pesos in the economy, contributing to financial stability; VI) that the aforementioned advances cannot be made through the funds loaded into users' electronic money instruments, but must come from money accounts belonging to the electronic money issuing institution itself, and cannot be claimed by it from the user under any circumstances, since their restitution will occur on its own account with the settlement and payment resulting from the redemption of the corresponding shares; VII) that, given that there will be multiple operations daily involving the acquisition and redemption of shares for different users, it is necessary to resort to compensation mechanisms between institutions issuing electronic money and other institutions participating in the operation (securities intermediary and investment fund management company); VIII) that, additionally and independently of the power to grant advances referred to in the previous articles, it is appropriate to generally regulate the operation of investment in financial products or services offered by institutions issuing electronic money on their platforms, which is carried out through the money loaded into the electronic money accounts of their clients; IX) that – in this sense – it is convenient to establish regulatory conditions regarding the information that institutions issuing electronic money must comply with in relation to the investments they offer to their clients, in order to dispel any doubt about the nature of the investment and its associated risks.

IN VIEW OF: the above, the provisions of Articles 3 and 7 of Law No. 16.696 of March 30, 1995 as amended by Law No. 18.401 of October 24, 2008 and Article 6 of Law No. 19.210 of April 29, 2014 as amended by Law No. 20.446 of December 16, 2025, the information provided by the Payment System Management on March 3, 2026, and other background information appearing in file No. 2025-50-1-2349, IT IS RESOLVED:

1. Incorporate a new subsection into Article 93 of Book VII of the Compilation of Payment System Rules with the following text: "Make available products or services from other entities regulated by the Central Bank of Uruguay under the conditions established in Articles 93.1 and 93.2".
2. Incorporate into Book VII of the Compilation of Payment System Rules the following articles:

"ARTICLE 93.1 (OFFERING OF THIRD-PARTY PRODUCTS AND SERVICES THROUGH THE ELECTRONIC MONEY INSTRUMENT). Institutions issuing electronic money may offer users of the instruments they issue products or services provided by other entities regulated by the Central Bank of Uruguay. To this effect, they must inform clients clearly and prominently that: a) When they transfer funds held at the electronic money issuing institution to acquire other products or services, these funds cease to have the nature of electronic money and – in the case of electronic money referred to in Title III of Law No. 19.210 of April 29, 2014 – will cease to be part of an independent affected estate, ending the fiduciary responsibility of the issuing institution with respect to said funds. b) The acquired product or service is not provided or lent by the electronic money issuing institution and – therefore – it is not incumbent upon it to fulfill in a timely and proper manner the obligations contracted according to the terms and conditions of the product or service contracted through it. c) The acquisition of the product or service requires the prior, free, express, and informed consent of the holder, who declares knowledge and acceptance of the applicable terms and conditions and the corresponding complementary documentation.

Likewise, the regulated entity by the Central Bank of Uruguay that effectively provides the contracted product or service must be identified."

"ARTICLE 93.2 (ADVANCES FOR REDEMPTION OF SHARES OF INVESTMENT FUNDS). When the services referred to in the previous article consist of the offering of shares of open-end investment funds constituted in accordance with Law No. 16.774 of September 27, 1996 and its amendments, institutions issuing electronic money may advance to the holder of the electronic money – at no charge to them – the funds corresponding to the value of the redemption of the shares provided that all of the following conditions are verified: a) They are shares in Uruguayan pesos. b) The investment funds are composed exclusively of all or some of the following securities in national currency or in units of account linked to said currency: Monetary Regulation Letters, securities issued by the Uruguayan State, or deposit certificates issued by financial intermediation institutions that are part of the national financial system. Likewise, temporary liquidity may be deposited in sight accounts at the Central Bank of Uruguay. c) The maximum remaining maturity of the securities that make up the investment fund does not exceed twenty-four months from the moment of their incorporation into it. d) The securities that make up the investment fund are held in custody at the Central Bank of Uruguay. e) The shares issued by the fund are placed exclusively among the holders of electronic money instruments. f) It is not electronic money for food. g) The holder of the electronic money instrument consents in advance and expressly that all funds credited to their electronic money instrument are destined to acquire shares of the offered investment funds. The holder's consent will be granted at the time of contracting the service and accepting the terms and conditions contained in the investment fund's regulations and other complementary documentation signed. The holder may revoke consent at any time, and such revocation will have immediate effect. To this effect, the electronic money issuing institution must make available on the main interface of the digital channel used, a clear, visible, and permanent access that allows the exercise of revocation in a simple and immediate manner. The revocation of consent will imply the immediate redemption of the investments made by the holder. h) On each occasion when the holder of the instrument instructs a redemption, makes payments, or withdraws cash through it, the electronic money issuing institution will advance with its own funds – which must be accounted for in a separate account from that corresponding to clients' electronic money – the amounts necessary to immediately satisfy the request, reimbursing said amount with the subsequent settlement and payment of the shares to be redeemed. Under no circumstances will the advance of funds give the electronic money issuing institution the right to require reimbursement of the advanced sum from the holder, with the institution assuming entirely the risk arising from the redemption, settlement, and payment procedure of the value of the shares. The reciprocal payments, which must be made between the entities receiving the investments and the institutions issuing electronic money for the concept of investments and redemptions of shares, will be made through their current accounts at the Central Bank of Uruguay and may be carried out through one or several daily compensations. Settlement will be effected within a period that may not exceed the second business day following that in which the advance of funds was made."

"ARTICLE 93.3 (GUARANTEES). Electronic Money Issuing Institutions that participate in the operation referred to in Article 93.2 must constitute and maintain, permanently, a guarantee in favor of the Central Bank of Uruguay for an amount of 2,000,000 IU (two million indexed units) and an additional guarantee of 0.5% calculated on the nominal value of the shares issued at the end of each quarter to be adjusted in the months of March, June, September, and December, which must be constituted in the following calendar month, as pledges on the securities indicated: a) deposit denominated in indexed units, constituted at the Central Bank of Uruguay; b) negotiable national public securities, denominated in indexed units, deposited at the Central Bank of Uruguay. For these purposes, the securities will be computed at their nominal value."

3. Entrust the communication of the provisions, by means of Circular, to the Payment System Management. (Today's Session - Minutes No. 3819) (File No. 2025-50-1-2349) Jorge Christy General Secretary Aar/am/ds Publishable Resolution Resolution No.: D-66-2026 Signatory: Jorge Eduardo Christy Davies Date: 04/03/2026 13:52:33 CIRCULAR NO. 2499