Decision on the Obligation to Report Transactions in Debt Financial Instruments Concluded Outside Regulated Markets or MTFs

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 numbers 140/05 and 12/12), at the meeting of the Board of Directors held on July 7, 2026, adopted the

DECISION

ON THE OBLIGATION TO REPORT TRANSACTIONS IN DEBT FINANCIAL INSTRUMENTS CONCLUDED OUTSIDE REGULATED MARKETS OR MTFs

Article 1. (1) For the purposes of this Decision, certain terms have the following meanings:

1. Act means the Capital Market Act (Official Gazette, numbers 65/2018, 17/2020, 83/2021, 151/2022, 85/2024, 126/2025, and 45/2026).
2. HANFA means the Croatian Financial Services Supervisory Agency.
3. Regulated Market means a regulated market within the meaning of Article 3, point 130 of the Act, operating in the Republic of Croatia.
4. Stock Exchange means the Zagreb Stock Exchange d.d. and/or other market operators of regulated markets within the meaning of Article 284 of the Act.
5. MTF means a multilateral trading facility within the meaning of Article 3, paragraph 1, point 65 of the Act.
6. OTC transaction means a transaction in a debt financial instrument listed on a regulated market, which is concluded outside the regulated market or MTF.
7. Debt financial instruments mean bonds, treasury bills, and commercial paper.
8. APA means an approved publication arrangement within the meaning of Article 3, paragraph 1, point 80 of the Act.
9. CTP means 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) (OJ L 173, 12.6.2014, p. 84). (2) Other terms used in 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, concluded outside the regulated market or MTF, shall be reported to the Stock Exchange, unless it has already been reported to the Zagreb Stock Exchange d.d. as an APA, in which case the reporting obligation is considered fulfilled.

(2) The following persons, acting as sellers in the relevant transaction, are obligated to report the transaction referred to in paragraph 1 of this Article to the Stock Exchange:

1. Investment firm
2. Credit institution
3. Other financial institution with a license for operation issued by the competent authority in accordance with legal regulations governing their operations
4. Insurance company
5. Undertaking for collective investment in transferable securities (UCITS) and its management company
6. Pension fund management company and pension funds
7. Insurance undertaking for pension schemes
8. Commodity dealer and commodity derivatives dealer
9. Local legal entity
10. Other institutional investors whose main activity is not covered by points 1 to 9 of this paragraph, and who are subject to authorization or supervision for operating on the financial market
11. Legal entity that, in relation to the previous financial year, meets at least two of the following conditions: a. total assets amount to at least 20,000,000.00 euros b. net revenue amounts to at least 40,000,000.00 euros c. capital amounts to at least 2,000,000.00 euros
12. Other institutional investors whose main activity is investing in financial instruments, and who are not subject to authorization or supervision for operating on 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 they do not have their registered office in the Republic of Croatia, the transaction referred to in paragraph 1 of this Article shall be reported by the person referred to in paragraph 2 of this Article who is the buyer in the relevant transaction and who has their registered office 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 if it was concluded after the end of the trading day. (5) The Stock Exchange is obligated to publish data on the transactions referred to in paragraph 1 of this Article on its website without delay.

(6) The obligation under paragraph 1 of this Article does not apply to borrowing transactions based on financial instruments (for example, repo and reverse repo agreements, buy and sell back and sell and buy back, Lombard loans, and similar).

Article 3. Persons referred to in Article 2 of this Decision who report transactions concluded outside regulated markets or MTFs are responsible for the accuracy of the data on the reported transactions.

Article 4. (1) For bonds listed on a regulated market, 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, 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 obligated to provide HANFA with a daily report on reported OTC transactions.

Article 6. (1) This Decision shall be published on HANFA's website. (2) This Decision shall enter into force on the day of its adoption. (3) With the entry into force of this Decision, the Decision on the Obligation to Report Transactions in Debt Financial Instruments Concluded Outside Regulated Markets or MTFs of July 26, 2018, as amended by the Decision on the Amendment of the Decision on the Obligation to Report Transactions in Debt Financial Instruments Concluded Outside Regulated Markets or MTFs of December 21, 2022, shall cease to be valid.

CLASS: 011-01/26-01/02 FILE NUMBER: 326-011-01/26-01/02-2

Zagreb, July 7, 2026

DEPUTY CHAIRPERSON OF THE BOARD OF DIRECTORS Anamarija Staničić