Decision on Amendments to the Requirements for Disclosure of Financial Reporting Indicators in XBRL Format for Capital Market Participants and Organized Commodity Market Professional Participants

NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET DECISION Kyiv On Approval of Amendments to the Requirements for Disclosure of Financial Reporting Indicators in XBRL Format for Reporting Entities that are Participants in Capital Markets and Professional Participants in Organized Commodity Markets

In accordance with paragraphs 2 and 36 of Part One of Article 7 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets", the Procedure for the Functioning of the Financial Reporting Collection Center, approved by the Resolution of the Cabinet of Ministers of Ukraine dated August 11, 2023 No. 845, with the aim of improving the regulatory legal acts of the National Commission for Securities and Stock Market regarding the disclosure of financial reporting indicators,

The National Commission for Securities and Stock Market

D E C I D E D:

1. Approve the Amendments to the Requirements for Disclosure of Financial Reporting Indicators in XBRL Format for Reporting Entities that are Participants in Capital Markets and Professional Participants in Organized Commodity Markets, approved by the Decision of the National Commission for Securities and Stock Market dated June 06, 2025 No. 36/21/2383/K03, registered in the Ministry of Justice of Ukraine on June 20, 2025 under No. 958/44364, which are attached.

2. The Management Department for the Functioning of the Financial Reporting Collection Center in XBRL Format shall ensure the submission of this decision for state registration to the Ministry of Justice of Ukraine.

3. The Management Department of Administrative Activity shall ensure the publication of this decision on the website of the National Commission for Securities and Stock Market.

4. The Department of Legal Development, after state registration of the decision by the Ministry of Justice of Ukraine, shall ensure the publication of this decision on the official website of the National Commission for Securities and Stock Market.

5. This decision enters into force on the day following the day of its official publication.

6. The requirements provided for in paragraph 13 and Appendix 1 to the Requirements for Disclosure of Financial Reporting Indicators in XBRL Format for Reporting Entities that are Participants in Capital Markets and Professional Participants in Organized Commodity Markets shall apply starting from the submission:

• interim financial reporting (consolidated interim financial reporting) for the nine months of 2026;
• annual financial reporting (consolidated annual financial reporting) for 2026.

7. Control over the execution of this decision shall be entrusted to a member of the National Commission for Securities and Stock Market, Yu. Shapoval.

Head of the Commission Oleksiy SEMENYUK

Protocol of the Commission meeting dated 16.04.2026 No. 17

APPROVED
Decision of the National Commission for
Securities and Stock Market
________________ No. _________

Amendments to the Requirements for Disclosure of Financial Reporting Indicators in XBRL Format for Reporting Entities that are Participants in Capital Markets and Professional Participants in Organized Commodity Markets, approved by the Decision of the National Commission for Securities and Stock Market dated June 06, 2025 No. 36/21/2383/K03, registered in the Ministry of Justice of Ukraine on June 20, 2025 under No. 958/44364

1. Redraft paragraph 1 of Section I as follows:
   "1. These Requirements establish requirements for the disclosure of certain indicators of financial reporting, prepared based on the taxonomy of financial reporting under international financial reporting standards in a single electronic format (hereinafter - financial reporting in XBRL format or financial reporting), for reporting entities that are participants in capital markets and professional participants in organized commodity markets, to the financial reporting collection center 'Financial Reporting System' (hereinafter - financial reporting collection center or FRC), the operational management of which is carried out by the National Commission for Securities and Stock Market (hereinafter - NCSPSM), including procedures for submitting financial reporting in XBRL format to the FRC."

2. In Section II:

1. Redraft paragraph 13 as follows:
   "13. Annual financial reporting / annual consolidated financial reporting (in case of preparation of consolidated financial reporting) is submitted by reporting entities to the FRC no later than April 30 of the year following the reporting year. Interim financial reporting is submitted by reporting entities to the FRC no later than the last day of the month following the reporting month, except for interim consolidated financial reporting, which is submitted no later than the last day of the second month following the reporting month. The deadlines for reporting entities to submit financial reporting for a reporting period other than annual and interim are determined in accordance with the requirements of legislation."

2. Supplement paragraph 16 with a second paragraph of the following content:
   "Data and information of such financial reporting must be disclosed in the corresponding fields and formats of the reporting forms of information presentation in the file structure. In the fields of additional information of reporting forms (notes), only information that cannot be disclosed in the existing fields of the corresponding indicators shall be indicated." In this regard, the second paragraph of this paragraph shall be considered the third paragraph;

3. Redraft paragraph 17 as follows:
   "17. Financial reporting submitted to the FRC is considered as submitted to the NCSPSM as part of reporting data and/or regular information in accordance with the requirements of legislation regulating the procedure for submitting such information. The electronic file of annual financial reporting must contain an audit report, which is submitted together with annual financial reporting / annual consolidated financial reporting (in case of preparation of consolidated financial reporting). The electronic file of interim financial reporting, in cases defined by legislation, must contain a report on the review of interim financial reporting (interim consolidated financial reporting), which is submitted together with interim financial reporting / interim consolidated financial reporting (in case of preparation of consolidated financial reporting). The audit report and the report on the review of interim financial reporting are prepared in accordance with the Law of Ukraine "On Audit of Financial Reporting and Audit Activity", must comply with International Standards on Quality Management, Auditing, Review, Other Assurance Services and Related Services and requirements established by regulatory legal acts of the NCSPSM regarding information concerning the audit or review of financial reporting of participants of capital markets and organized commodity markets. A mandatory component of financial reporting in XBRL format for reporting entities that are issuers of securities (except for securities of collective investment institutions) is the management report. Reporting entities that, in accordance with Part Two of Article 2 of the Law of Ukraine "On Accounting and Financial Reporting in Ukraine", are classified as micro-enterprises and small enterprises and are not issuers of securities, do not submit a management report, except in cases of submission of such a report upon request of the NCSPSM, if such a report was not published. Reporting entities are obliged to disclose in annual and interim financial reporting (annual and interim consolidated financial reporting) in XBRL format additional information provided in Appendix 1."

3. Supplement paragraph 27 of Section IV with a new paragraph of the following content:
   "Only one user of a reporting entity may be registered at one email address. The email address of the reporting entity user is indicated in the 'Username' field when logging into the personal account, authorization to which occurs using the user's electronic digital signature on the state electronic identification resource https://id.gov.ua."

4. In Section V:

1. Supplement paragraph 32 with a new paragraph of the following content:
   "after receiving a justified request from the reporting entity regarding the need to submit financial reporting for another reporting period, in particular, different from annual and interim."

2. Redraft paragraph 42 as follows:
   "42. Previously submitted financial reporting, the request for resending which has been approved, is not displayed on the 'Submission History' page in the personal account of the reporting entity user, but is stored in the information systems of the FRC as having lost its validity, for the purpose of ensuring traceability and accounting of submitted reports. Such financial reporting is considered not submitted to the FRC until the moment of resubmission (uploading of the electronic file) of the corrected financial reporting to the FRC by the reporting entity user."

5. Supplement Sections VI and VII with the following content:
   "VI. Features of the procedure for disclosure of financial reporting for a period other than annual and interim
6. In case of the need to submit financial reporting for a reporting period other than annual and interim, in accordance with the requirements of legislation (as part of a package of documents for obtaining an administrative service, preparation of liquidation financial reporting, etc.), the reporting entity must send an application for creating a request for submission of financial reporting in the form provided in Appendix 2 to the email address of the FRC xbrl.registration@nssmc.gov.ua.
7. The authorized subdivision of the NCSPSM ensures the processing of such an application of the reporting entity within three working days from the date of its receipt and creates a corresponding request for submission of financial reporting.
8. The further procedure for submitting financial reporting is carried out in accordance with paragraphs 33–42 of Section V.

VII. Procedure for deactivating the reporting entity account
46. Deactivation of the reporting entity account is the establishment of the 'inactive' status for the account in the FRC, as a result of which:
access of reporting entity users to the reporting entity account and to the functionality for submitting and editing reporting is blocked; all previously submitted reports and information are preserved.
47. Deactivation of the reporting entity account in the FRC is carried out by the authorized subdivision of the NCSPSM on the basis of:

1. a justified appeal received from the reporting entity regarding the need for deactivation;

2. information discovered by the authorized subdivision of the NCSPSM about the termination of the legal entity in the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations.

48. Deactivation of the reporting entity account in the FRC on the grounds provided for in subparagraph 1 of paragraph 47 of this section is carried out by the authorized subdivision of the NCSPSM upon simultaneous presence of the following grounds:
    presence of confirmed information from the reporting entity regarding the choice of the conceptual basis for maintaining financial reporting in accordance with national provisions (standards) of accounting; incompatibility of the reporting entity with the requirements provided for in Article 12¹ of the Law of Ukraine "On Accounting and Financial Reporting in Ukraine" and the Procedure for Submission of Financial Reporting, approved by the Resolution of the Cabinet of Ministers of Ukraine dated February 28, 2000 No. 419; submission of financial reporting to the FRC for all reporting periods during which the reporting entity had an obligation to submit it.

49. The authorized subdivision of the NCSPSM carries out deactivation of the reporting entity account in the FRC within three working days from the date of discovery of information about the termination of the legal entity or receipt of the corresponding appeal of the reporting entity upon the presence of grounds provided for in paragraph 48 of this section."
    In this regard, Section VI shall be considered Section VIII, paragraph 43 of Section VI shall be considered paragraph 50 of Section VIII.

50. Supplement the Requirements with Appendices 1 and 2, which are attached.

Acting Head of the Department for the Functioning of the Financial Reporting Collection Center in XBRL Format Oleksiy ILCHENKO

Appendix 1
to the Requirements for Disclosure of Indicators of Financial Reporting in XBRL Format for Reporting Entities that are Participants in Capital Markets and Professional Participants in Organized Commodity Markets (paragraph 17 of Section II)

Information subject to disclosure by reporting entities

1. Professional judgment of the management of the reporting entity, in particular, defined by the accounting policy, regarding the main limits (thresholds) of materiality (qualitative and quantitative criteria) in the preparation of financial reporting for recognition and disclosure of certain items thereof – in the field 'Disclosure of Material Information on Accounting Policy [text block]' '[800610] Notes - List of Material Information on Accounting Policy'.

2. Income and expenses with indication of all relevant items and analytical indicators relating to the activity of the reporting entity, in accordance with '[800200] Notes – Analysis of Income and Expenses'.

3. Information on assets, liabilities and equity with indication of all relevant items and analytical indicators relating to the activity of the reporting entity, in accordance with '[800100] Notes – Subclassifications of Assets, Liabilities and Equity'.

4. Detailed information on:
   4.1. issued loans 1;
   4.2. expenses for training, consulting, advertising and marketing 1;
   4.3. payments of refundable and/or non-refundable financial assistance 1;
   4.4. income from training, consulting, advertising and marketing 1;
   4.5. received loans 1;
   4.6. income from assignment of claims or debts 1;
   4.7. financial investments (type, name and ISIN of the issuer, quantity, percentage of ownership, book value, international ISIN code if available);
   4.8. accounts receivable (name and ISIN of the counterparty, subject of debt, book (amortized) value, date of initial recognition, maturity date, number of changes (modifications) of contractual terms, including extensions, amount of overdue debt, stage of impairment in accordance with IFRS 9 (Stage 1 / Stage 2 / Stage 3) or other credit risk assessment system applied by the reporting entity, size of the provision for expected credit losses, information on restructuring (modification) of debt, amount of written-off debt);

Continuation of Appendix 1
4.9. financial assets subject to seizure, blocking and any encumbrance by court order and/or decision and/or enforcement proceedings 1.

Each subparagraph 4.1. - 4.6. is disclosed regarding the essential terms of the contract if the aggregate amount of all relevant operations according to this subparagraph for the reporting period exceeds 25 percent of the total amount of assets 2, in the corresponding field of financial reporting:

• subparagraphs 4.1., 4.3., 4.4., 4.6. - in the field 'Disclosure of Additional Information [text block]' '[880000] Notes – Additional Information';
• subparagraph 4.2. - in the field 'Disclosure of Information on Classification of Expenses by Nature to their Function [text block]' '[800200] Notes – Analysis of Income and Expenses';
• subparagraph 4.5. - in the field 'Disclosure of Detailed Information on Borrowings [text block]' '[822390-18] Notes – Sensitivity Analysis'.

Each subparagraph 4.7. - 4.8. is disclosed if the total book value of assets according to this subparagraph is more than 10% of the total amount of assets 2, regarding the five largest issuers by the amount of financial investments and the five largest counterparties by the amount of accounts receivable – in the field 'Disclosure of Information on Financial Assets [text block]' '[822390-01] Notes - Financial Assets'.

Subparagraph 4.9. is disclosed in the field 'Disclosure of Information on Financial Assets [text block]' '[822390-01] Notes - Financial Assets'.

5. Amount of cash, separately regarding amounts placed in:
   accounts in banks where a temporary administration has been introduced or liquidation procedures are being conducted; checking accounts in banks; deposit accounts in banks; amount of cash belonging to clients under contracts concluded with them in the course of sub-brokerage, brokerage activities and portfolio management activities for financial instruments,3 - in the field 'Disclosure of Information on Financial Assets [text block]' '[822390-01] Notes - Financial Assets'.

6. Amount of liabilities:
   total amount of liabilities of the reporting entity; amount of liabilities under contracts with clients in the course of sub-brokerage, brokerage activities and portfolio management activities for financial instruments, 3 - in the field 'Disclosure of Information on Financial Liabilities [text block]' '[822390-03] Notes - Financial Liabilities'.

7. Amount of unpaid share capital - in the field 'Disclosure of Information on Classes of Share Capital' of the item 'Number of shares issued,

Continuation of Appendix 1 but not fully paid' '[861200] Notes - Share Capital, Reserves and Other Equity Interests'.

8. List of related parties to whom dividends were accrued and/or paid, and list of related parties from whom dividends were received, with indication of the corresponding amounts (accrued, paid or received dividends) - in the field 'Disclosure of Information on Transactions between Related Parties [text block]' '[818000] Notes - Related Party'.

9. Information on the engaged independent appraiser and assets whose valuation he conducted: type of asset, value of the asset before and after revaluation, details of the independent appraiser (name or surname, first name and patronymic) - in the field 'Disclosure of Information on Fair Value Assessment [text block]'
   '[823000-1] Notes - Fair Value Assessment of Assets'.

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Notes:
1 - disclosed by professional participants of capital markets and organized commodity markets.
2 – calculation of threshold values is carried out based on the 'Report on Financial Position' data at the end of the corresponding reporting period, unless otherwise established by legislation.
3 - disclosed by investment firms.

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Appendix 2
to the Requirements for Disclosure of Indicators of Financial Reporting in XBRL Format for Reporting Entities that are Participants in Capital Markets and Professional Participants in Organized Commodity Markets (paragraph 43 of Section VI)

Application for creating a request for submission of financial reporting

1 Name of the reporting entity
2 Identification code of the reporting entity (EDRIS code for a unit trust investment fund) 3 Date, as of which the financial reporting must be prepared 1 4 Date, by which the financial reporting must be submitted 1 5 Grounds for the need to submit financial reporting 6 Details of the contact person of the reporting entity 7 Information on the conduct of audit of financial reporting as required by legislation Conducted / Not conducted ___________ Note:
1 – date is indicated in the format: day, month, year.

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