Decision on the obligation to report transactions in debt financial instruments concluded outside a regulated market or MTF

Croatian Financial Services Supervisory Agency, pursuant to Article 13 and Article 15, point 1 of the Act on the Croatian Financial Services Supervisory Agency (Official Gazette No. 140/05 and 12/12), at the session of the Management Board held on July 7, 2026, adopted the DECISION ON THE OBLIGATION TO REPORT TRANSACTIONS IN DEBT FINANCIAL INSTRUMENTS CONCLUDED OUTSIDE A REGULATED MARKET OR MTF Article 1. (1) For the purposes of this Decision, certain terms have the following meaning:

1. The Act is the Capital Market Act (»Official Gazette«, No. 65/2018, 17/2020, 83/2021, 151/2022, 85/2024, 126/2025 and 45/2026)
2. Hanfa is the Croatian Financial Services Supervisory Agency
3. Regulated market is a regulated market within the meaning of Article 3, point 130 of the Act, which operates in the Republic of Croatia
4. Stock Exchange is Zagreb Stock Exchange Inc. and/or another market operator of a regulated market within the meaning of Article 284 of the Act
5. MTF is a multilateral trading facility within the meaning of Article 3, paragraph 1, point 65 of the Act
6. OTC transaction is a transaction in a debt financial instrument listed on a regulated market, which is concluded outside a regulated market or MTF
7. Debt financial instruments are bonds, treasury bills and commercial papers
8. APA is an authorized publication arrangement within the meaning of Article 3, paragraph 1, point 80 of the Act
9. CTP is a consolidated tape provider as defined in Article 2, paragraph 1, point 35 of Regulation (EU) No 600/2014 of the European Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending Regulation (EU) No 648/2012 (Text with EEA relevance) (L 173 12.6.2014, 84). (2) Other terms for the purposes of this Decision have the same meaning as the terms used in the Act. Article 2. (1) A transaction in a debt financial instrument listed on a regulated market that is concluded outside a regulated market or MTF shall be reported to the stock exchange, unless it has already been reported to Zagreb Stock Exchange Inc. as an APA, in which case the reporting obligation is considered fulfilled. (2) The transaction referred to in paragraph 1 of this Article shall be reported to the stock exchange by the following person who is the seller in the transaction:
10. Investment firm
11. Credit institution
12. Other financial institution with an operating license issued by the competent authority in accordance with legal regulations governing their operation
13. Insurance company
14. Collective investment undertaking and its management company
15. Pension fund management company and pension funds
16. Pension insurance company
17. Commodity and commodity derivatives trader
18. Local legal entity
19. Other institutional investors whose main activity is not covered by points 1 to 9 of this paragraph, and who are subject to the obligation of authorization or supervision for operating in the financial market
20. A legal entity which, in relation to the previous business year, meets at least two of the following conditions: a. total assets amount to at least 20,000,000.00 euros b. net income of at least 40,000,000.00 euros c. capital of at least 2,000,000.00 euros
21. Other institutional investors whose main activity is investing in financial instruments, and who are not subject to the obligation of authorization or supervision for operating in the financial market by the competent authority, including entities established for the purpose of asset securitization. (3) If the seller in the transaction referred to in paragraph 1 of this Article is not a person listed in paragraph 2 of this Article or if it is not seated in the Republic of Croatia, the transaction referred to in paragraph 1 of this Article shall be reported by the person from paragraph 2 of this Article who is the buyer in the transaction and who is seated in the Republic of Croatia. (4) The transaction referred to in paragraph 1 of this Article shall be reported to the stock exchange by the end of the trading day on which the transaction was concluded or by the beginning of the next trading day when it was concluded after the end of the trading day. (5) The stock exchange is obliged to publish data on transactions from paragraph 1 of this Article without delay on its website. (6) The obligation from paragraph 1 of this Article does not apply to borrowing transactions based on financial instruments (e.g., repo and reverse repo agreements, buy and sell back and sell and buy back, Lombard loans and similar). Article 3. The persons referred to in Article 2 of this Decision who report transactions concluded outside a regulated market or MTF are responsible for the accuracy of the data on the reported transaction. Article 4. (1) For bonds listed on a regulated market, the persons referred to in Article 2 of this Decision shall report all concluded OTC transactions, regardless of the transaction value. (2) For commercial and treasury bills listed on a regulated market, the persons referred to in Article 2 of this Decision shall report all concluded OTC transactions, regardless of the transaction value. Article 5. The stock exchange is obliged to submit a daily report on reported OTC transactions to Hanfa. Article 6. (1) This Decision shall be published on Hanfa's website. (2) This Decision enters into force on the day of its adoption. (3) On the day this Decision enters into force, the Decision on the obligation to report transactions in debt financial instruments concluded outside a regulated market or MTF of July 26, 2018, which was amended by the Decision on the amendment of the Decision on the obligation to report transactions in debt financial instruments concluded outside a regulated market or MTF of December 21, 2022, ceases to be valid. CLASS: 011-01/26-01/02 FILE NUMBER: 326-01-60-61-26-2 Zagreb, July 7, 2026 DEPUTY CHAIRPERSON OF THE MANAGEMENT BOARD Anamarija Staničić