Instruction on the Preparation and Submission of Reports by Crypto-Asset Service Providers

Croatian Financial Services Supervisory Agency, 10000 Zagreb, Franje Račkoga 6, P.O. Box 164, Croatia Tel: 01 6173 200, Fax: 01 4811 507, Email: info@hanfa.hr, OIB: 49376181407, MB: 02016419, Web: www.hanfa.hr

Pursuant to Article 15(7) of the Act on the Croatian Financial Services Supervisory Agency ("Official Gazette" Nos. 140/05 and 12/12), the Croatian Financial Services Supervisory Agency, at the meeting of the Board of Directors held on March 26, 2026, adopts:

INSTRUCTION ON THE PREPARATION AND SUBMISSION OF REPORTS BY CRYPTO-ASSET SERVICE PROVIDERS

1. Introduction This Instruction on the preparation and submission of reports by crypto-asset service providers in electronic form (hereinafter: reports) defines the format and method of submission of reports by legal entities or other entrepreneurs who have approval to operate as crypto-asset service providers in accordance with Article 63 of Regulation (EU) 2023/1114 on markets in crypto-assets (hereinafter: CASP) and credit institutions, central securities depositories, investment firms, market operators, electronic money institutions, UCITS management companies, or alternative investment fund managers who are permitted to provide crypto-asset-related services in accordance with Article 60 of Regulation (EU) 2023/1114 on markets in crypto-assets.

2. Types of Reports The types of reports to be submitted in electronic form are:

3. Financial reports for the three-month, six-month, and nine-month periods and the unaudited annual financial report of the CASP (FI-CASP)

4. Audited annual financial reports of the CASP (GFI-CASP)

5. Report on prudential requirements of the CASP (BZ-CASP)

6. Audited reports on prudential requirements of the CASP (BZ-R-CASP)

7. Supervisory reports of crypto-asset service providers (NI-KRIPTO)

8. Submission of Reports Reports are submitted in electronic form in the following formats and files:

• An XML format file encompassing financial reports in accordance with the prescribed schema published on HANFA's website, signed by the Company's Management Board. This file relates to the three-month, six-month, nine-month, and unaudited annual financial reports of the CASP from the Rulebook on the structure and content of financial reports of crypto-asset service providers, and encompasses the forms: Report on Financial Position, Report on Comprehensive Income, Report on Cash Flows, and Report on Changes in Equity.

• An XML format file encompassing audited annual financial reports in accordance with the prescribed schema published on HANFA's website, signed by the Company's Management Board. This file relates to the annual financial reports of the CASP from the Rulebook on the structure and content of financial reports of crypto-asset service providers, and encompasses the forms: Report on Financial Position, Report on Comprehensive Income, Report on Cash Flows, and Report on Changes in Equity.

• An XML format file encompassing the report on prudential requirements of the CASP in accordance with the prescribed schema published on HANFA's website, signed by the Company's Management Board. This file relates to the report on prudential requirements of the CASP from the Rulebook on prudential requirements of crypto-asset service providers pursuant to Article 67 of Regulation (EU) 2023/1114, and encompasses the form report on prudential requirements (BZ-CASP_1 and BZ-CASP_2).

• An XML format file encompassing the audited report on prudential requirements of the CASP in accordance with the prescribed schema published on HANFA's website, signed by the Company's Management Board. This file relates to the form audited report on prudential requirements prescribed by the Rulebook on prudential requirements of crypto-asset service providers pursuant to Article 67 of Regulation (EU) 2023/1114 (BZ-CASP_1 and BZ-CASP_2).

• An XML format file relating to supervisory reports of crypto-asset service providers; in accordance with the prescribed schema published on HANFA's website, signed by the Management Board of the legal entity or by natural persons authorized for this purpose by the Management Board. This file relates to the forms General Data on Service Provision (General Data on Service Provision and General Data – Business Accounts), Report on Revenues and Turnover from the Provision of Crypto-Asset-Related Services, Report on the Management of Client Assets, and Report on Client Structure from the Rulebook on supervisory reports for legal entities authorized to provide crypto-asset-related services.

• A PDF format file encompassing the form Notes to Financial Reports, signed by the Company's Management Board. This file contains the form Notes to Financial Reports which are submitted as part of the financial reports for the three-month, six-month, and nine-month periods and unaudited annual financial reports prescribed by the Rulebook on the structure and content of financial reports of crypto-asset service providers.

• A PDF format file encompassing the form Notes to Financial Reports, signed by the Company's Management Board. This file contains the form Notes to Financial Reports which are submitted as part of the audited annual financial reports prescribed by the Rulebook on the structure and content of financial reports of crypto-asset service providers.

• A PDF format file encompassing the audited report on prudential requirements, signed by the Company's Management Board. This file contains the audited report on prudential requirements prescribed by the Rulebook on prudential requirements of crypto-asset service providers pursuant to Article 67 of Regulation (EU) 2023/1114.

4. Description of the PDF Report File PDF format report files are intended for the submission of reports in free format.

5. Description of the XML Report File Crypto-asset service providers are obliged to prepare XML format report files in accordance with the prescribed HANFA XML schema. The procedure by which the crypto-asset service provider converts report data into the specified format is determined and carried out by the crypto-asset service provider itself. XML schemas for the preparation of reports are published at the internet address: https://reports.hanfa.hr/

6. Signing of Files The signing of files that the crypto-asset service provider is obliged to submit is carried out in accordance with the current Technical Instruction on the Application of Electronic Signature in the Reporting Procedure of the Croatian Financial Services Supervisory Agency. The signing rules are the same as the rules applicable to the handwritten signature applied to the written form of the report. The Management Board of the CASP signs the financial reports for the three-month, six-month, and nine-month periods, the unaudited annual financial reports, and the forms of audited annual financial reports that the crypto-asset service provider is obliged to submit to HANFA electronically. Exceptionally, in the event of impediment, the Management Board of the CASP may, in accordance with regulations on representation, authorize another person to sign the aforementioned reports. The power of attorney must be submitted to HANFA and must necessarily contain the first and last name of the authorized person or persons and the scope of signing authority. The Management Board of the CASP or a natural person authorized for this purpose by the Management Board signs the reports on prudential requirements, the forms of audited reports on prudential requirements, and the supervisory reports prescribed by the Rulebook on supervisory reports for legal entities authorized to provide crypto-asset-related services electronically. In the event that the Management Board of the CASP authorizes another natural person to sign the File, it is obliged to submit a power of attorney to HANFA. The power of attorney must necessarily contain the first and last name of the authorized person or persons, and the scope of signing authority for the File. The Management Board of the CASP is obliged to notify HANFA without delay of any change in the authorized signatories. The supervisory reports that CASPs, credit institutions, central securities depositories, investment firms, market operators, electronic money institutions, UCITS management companies, or alternative investment fund managers, who are permitted to provide crypto-asset-related services in accordance with Article 60 of Regulation (EU) 2023/1114 on markets in crypto-assets, are obliged to submit in accordance with the Rulebook on supervisory reports for legal entities authorized to provide crypto-asset-related services, are signed by the Company's Management Board or a natural person authorized for this purpose by the Management Board. In the event that the Management Board authorizes another natural person to sign the File, it is obliged to submit a power of attorney to HANFA. The power of attorney must necessarily contain the first and last name of the authorized person or persons, and the scope of signing authority for the File. The Management Board is obliged to notify HANFA without delay of any change in the authorized signatories.

7. Submission of Reports The reports from point 2 of this Instruction by legal entities are submitted in accordance with the current Technical Instruction on registration and work with the interface of the system for the submission of data in electronic form.

8. Final Provisions This Instruction enters into force on the day of its adoption and will be published on HANFA's website. CLASS: 011-01/26-13/01 REF NO: 326-01-40-43-26-1 Zagreb, March 26, 2026

CHAIRMAN OF THE BOARD OF DIRECTORS dr. sc. Ante Žigman