Compilation of Rules for the Control of Pension Funds - Modification in the Calculation of the Deadline to Inform Insurance Companies (Art. 155.1.1)

Montevideo, January 2, 2026 Ref: COMPILATION OF RULES FOR THE CONTROL OF PENSION FUNDS - Modification in the calculation of the deadline to inform insurance companies (Art. 155.1.1)

The market is informed that the Superintendence of Financial Services adopted Resolution SSF No. 2025-705 on December 17, 2025.

2025-50-1-00617 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy PATRICIA TUDISCO Superintendent of Financial Supervision

CIRCULAR NO. 2493

SUPERINTENDENCE OF FINANCIAL SERVICES – RESOLUTION SUPERINTENDENCE OF FINANCIAL SERVICES

VIEWING: Circular No. 2450 of March 8, 2024, which communicates the resolution of the Superintendence of Financial Services dated March 1, 2024, which introduces adjustments to the regulations governing the pension regime.

RESULTING:

I) That Article 28 of Decree No. 413/023 of December 19, 2023, which regulates Law No. 20.130 of May 2, 2023 (Social Security Reform Law), establishes that pension rights, pensions, or subsidies for temporary partial disability charged to the individual savings regime shall always operate provided that the corresponding pension entity expressly communicates to the Administrator that the affiliate or beneficiary meets the pertinent legal requirements.

II) That the resolution of the Superintendence of Financial Services mentioned in the VIEWING section modified the wording of Article 155.1.1 (Information to be supplied to insurance companies regarding pension insurance) of the Compilation of Rules for the Control of Pension Funds (RNCFP), expressly establishing that the Pension Savings Fund Administrator (AFAP) shall have a period of 5 business days from when it took knowledge of the claim based on the information provided by the corresponding pension entity, to make available to the insurance company the necessary background to substantiate the same and allow for its correct settlement.

III) That complaints were received from AFAPs indicating that complying with the provision in the regulation implies contacting the affiliate or beneficiary and requesting that they appear to carry out the procedure by providing the necessary documentation for the correct settlement of the claim, and then sending this information to the insurer, which is operationally impracticable within the aforementioned 5-business-day period.

IV) That, consequently, they request that the wording of Article 155.1.1 of the RNCFP be modified, establishing that this period be calculated from when the Administrator took knowledge of the claim based on the submission of the necessary documentation provided by the affiliate or beneficiaries in cases of death pension.

CONSIDERING:

I) That the exchanges held with the Administrators have made evident the difficulties that arise from a practical standpoint, not only in contacting the interested parties or beneficiaries but also because their effective presentation within the deadline is conditioned by their will and possibility.

II) That, in cases of death pension, the pension entity sends information of the termination due to death to the Administrator, but it is when the beneficiaries appear that the AFAP takes effective knowledge of their existence and that they meet the conditions to access the benefit.

III) That, in cases of total disability pension, the Administrator receives from the pension entity a letter informing of the occurrence of the claim, but in some situations the presentation of the affiliate is required to provide additional information.

IV) That in both cases it can be considered that the beneficiary meets the pertinent legal requirements for the right to the benefit to operate once they appear and substantiate their status before the AFAP, attaching all the required documentation.

V) That the Central Bank of Uruguay has the authority to modify the start of the calculation of the period provided for in Article 155.1.1 of the RNCFP, to make available to the insurance company the necessary background to substantiate the same and allow for its correct settlement.

ATTENTIVE: To what is provided in Article 38 of Law No. 16.696 of March 30, 1995, as amended by Article 2 of Law No. 20.345 of September 19, 2024, in Law No. 20.130 of May 2, 2023, in Decree No. 413/023 of December 19, 2023, in the Legal Advisory Opinion No. 2025/193 of May 16, 2025, and in the reports issued by this Superintendence of Financial Services.

RESOLVES:

1. SUBSTITUTE in Chapter V – BIS – Information to insurance companies and to the Social Security Bank, of Title II – Information Regime, of Part I – Pension Savings Fund Administrators, of Book VI – Information and documentation, Article 155.1.1 with the following:

ARTICLE 155.1.1 (INFORMATION TO BE SUPPLIED TO INSURANCE COMPANIES REGARDING PENSION INSURANCE). It is the obligation of the Pension Savings Fund Administrator to provide the insurance company with information regarding pension annuity insurance and the collective disability and death insurance, that which allows for the correct appreciation of the risk that may influence the conditions of the contract.

Once the claim has occurred, and within a period of 5 (five) business days from when the Pension Savings Fund Administrator took knowledge of the same based on the information provided by the pension entity and the submission of necessary documentation by the affiliate or beneficiary as applicable, it must make available to the insurance company the necessary background to substantiate the referred claim and allow for its correct settlement.

Regarding the partial disability benefit, the period during which it must be paid must be indicated.

2. COMMUNICATE the foregoing by Circular.

JUAN PEDRO CANTERA Superintendent of Financial Services

RR-SSF-2025-705 Date: 17/12/2025 18:55:47 Exp. 2025-50-1-00617 Publishable: Yes - Signatory: JUAN PEDRO CANTERA SENCIÓN CIRCULAR NO. 2493