Credit Administrating Companies - Modifications regarding Minimum Net Equity and Risk Caps for Acquiring Activity

1 Montevideo, January 2, 2026 Ref: CREDIT ADMINISTRATING COMPANIES - Modifications regarding Minimum Net Equity and Risk Caps for Acquiring Activity

The market is informed that the Board of Directors of the Central Bank of Uruguay adopted resolution D-437-2025 on December 30, 2025.

2022-50-1-01511 Diagonal Fabini 777 - C.P. 11100 - Tel.: (598 2) 1967 - Montevideo, Uruguay - www.bcu.gub.uy PATRICIA TUDISCO Superintendent of Financial Supervision

CIRCULAR NO. 2495

BOARD OF DIRECTORS - RESOLUTION Montevideo, December 30, 2025.

BOARD OF DIRECTORS

HAVING VIEWED: Articles 174 and 241 of the Compilation of Regulations and Control of the Financial System, which regulate the minimum net equity responsibility and the included risks, respectively, for large credit administrating companies;

WHEREAS: I) The acquiring market in Uruguay was characterized by the presence of institutions providing the service exclusively for a single brand or logo, until August 23, 2021, the date when the acquiring market opened; II) The Superintendency of Financial Services considers that setting risk caps on net equity responds to best practices in risk diversification, considering international standards in prudential financial regulation; III) A working group was formed to analyze the general risks of the third-party acquiring system in the country, taking into account the regulatory perimeter in which issuers and service providers are located; IV) Currently, the acquiring activity does not have a risk cap, whereas large credit administrating companies do have one.

CONSIDERING: I) Entities are adopting business models whose operations are no longer traditional, incorporating new operations under their own license or through commercial agreements with other companies holding other licenses, which determines that a comprehensive and broad regulatory view is necessary; II) Credits in the balance sheet inherent to the acquiring activity may be excluded from the calculation of the existing credit risk cap for Credit Administrating Companies, as there are sufficient mitigants for the risks of the business; III) Indeed, for an acquirer to function as such, it is not enough to have the express authorization of the Central Bank of Uruguay to operate, but the brand/logo must also authorize its operation, for which it must meet the demanding requirements defined to achieve homologation;

IV) The risks of the same company must be considered in an integral manner regardless of the activity they perform; therefore, to eliminate a possible regulatory asymmetry in multi-acquiring activity, whether carried out by a Credit Administrating Company or by another entity under the control of the Payments System Management, Articles 174 and 241 of the Compilation of Regulations and Control of the Financial System will be modified.

IN VIEW OF: the above, the provisions of Article 36 of Law No. 16.696 of March 30, 1995, as amended by Article 9 of Law No. 18.401 of October 24, 2008, and resolution D/160/2012 of June 14, 2012; the provisions of literal A) of Article 38 of Law No. 16.696 of March 30, 1995, as amended by Article 11 of Law No. 18.401 of October 24, 2008; the information provided by the Superintendency of Financial Services on December 1, 2025, by the Legal Advisory on December 29, 2025, and other background documents appearing in file No. 2022-50-1-1511,

IT IS RESOLVED:

1. To exercise the power of assumption (Article 36 of Law No. 16.696 of March 30, 1995, as amended by Article 9 of Law No. 18.401 of October 24, 2008, and resolution D/160/2012 of June 14, 2012) regarding Articles 174 and 241 of the Compilation of Regulations and Control of the Financial System.

2. To substitute Articles 174 and 241 of the Compilation of Regulations and Control of the Financial System with the following:

ARTICLE 174 (MINIMUM NET EQUITY RESPONSIBILITY FOR LARGE CREDIT ADMINISTRATING COMPANIES). Large credit administrating companies must maintain a minimum net equity responsibility not less than 8% of assets and risks and contingent commitments (net of provisions), computed according to the following percentages:

WITH 0%: a) Cash and precious metals. b) Assets with the Central Bank of Uruguay. c) National public securities issued by the Central Government and tradable on stock exchanges. d) Fiscal asset for current tax. e) Credits arising from the activity of acquiring electronic payment means.

WITH 20%: Risks and contingent commitments corresponding to credits to be used via credit card.

WITH 100%: a) Rest of the assets, excluding the 100% deductible items established in Article 154.3. b) Rest of the risks and contingent commitments.

ARTICLE 241 (INCLUDED RISKS). The risks included in Article 240 correspond to the total of operations in which the client appears as debtor, co-debtor, or guarantor. These credits, direct or indirect, shall be computed net of provisions.

Debtors, co-debtors, or guarantors arising from the acquiring activity shall not be included.

3. To entrust the Superintendency of Financial Services with communicating the provisions herein via Circular, in accordance with Articles 105 and 106 of the Administrative Regulations.

(Today's Session – Minutes No. 3809) (File No. 2022-50-1-1511)

Jorge Christy General Secretary

Ds Publishable Resolution

Ref: D-437-2025 Signatory: Jorge Eduardo Christy Davies Date: 30/12/2025 13:46:52

CIRCULAR NO. 2495