Decision on the Results of the Thematic Control in the Banking and Non-Bank Payment Services Sector

REPUBLIC OF MOLDOVA
NATIONAL FINANCIAL MARKET COMMISSION
77 Stefan cel Mare si Sfant Blvd., Chisinau, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md

DECISION
June 9, 2026 No. 27/4

On the results of the thematic control, conducted within banks and non-bank payment service providers

1. In accordance with the Control Activities Plan of the National Financial Market Commission for 2025 (annex to Decision of the National Financial Market Commission (CNPF) No. 13/1/2025), during the period 16.12.2025 – 12.06.2026, a thematic control was initiated among the participants — BC “COMERTBANK” S.A., BC “ENERGBANK” S.A., BC “EuroCreditBank” S.A., BC “EXIMBANK” S.A., BC “Moldindconbank” S.A., BC “MOLDOVA-AGROINDBANK” S.A., BC “ProCredit Bank” S.A., BC “VICTORIABANK” S.A., “Banca de Finante si Comert” S.A., “OTP Bank” S.A. (banks), SC “MMPS COM” S.R.L., “NOVA PAY” S.R.L., “Paymaster” S.R.L., “Paynet Services” S.R.L., “BPAY” S.R.L., “QIWI-M” SRL, “MOLDCELL” S.A. and “UP SERVICII” S.R.L. (non-bank PSPs), as ordered by Decision of the National Financial Market Commission (CNPF/authority) No. 60/2/2025 on conducting the thematic control within banks and non-bank payment service providers (Decision No. 60/2/2025).

2. The control aimed to verify the banks' compliance with the method of calculating and applying the interest rate on loans, under the provisions of Law No. 202/2013 on consumer credit contracts (Law No. 202/2013), as well as the cost elements included in the calculation of the annual effective interest rate, under Art. 23 para. (2) of Law No. 202/2013, in loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025, including regarding the non-adoption of unfair commercial practices provided for in Art. 13 of Law No. 105/2003 on consumer protection, and the verification of the conformity of the framework contract concluded by banks and non-bank PSPs with payment service users, who have the status of consumers, valid as of 16.12.2025, with the provisions of Law No. 114/2012 on payment services and electronic money (Law No. 114/2012), including regarding the identification of abusive clauses, within the meaning of Arts. 1069 – 1072, 1075 – 1079 and 1081 of the Civil Code.

3. According to Art. 70 para. (1) of the Administrative Code, Decision No. 60/2/2025 was sent to the participants via CNPF letter No. 04-5/4909 dated 18.12.2025, with the Control Plan attached.
   At the same time, according to point 26 subpoint 4) of the Regulation on the administrative control procedure (CNPF Decision No. 60/10 dated 05.12.2023, hereinafter – Regulation No. 60/10), the participants were informed of their rights and obligations under the Regulation.

4. The control was carried out by the control team at the CNPF headquarters. By letters sent on 23.12.2025, the control team requested the presentation, on durable medium, by 19.01.2026, of the List of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025, which will include: the number and date of conclusion of the loan contract; the date of granting/disbursement of the loan; the duration of the loan contract; the total value of the loan; the loan currency; commissions applied at the granting of the loan (applied in the first 30 days), the interest rate on the loan at the date of conclusion of the loan contract; the annual effective interest rate; the date of the first installment due according to the payment schedule; the interest calculated from the date of conclusion of the contract until the date of the first installment due (contract register, in Excel format, according to the annex), as well as, by 12.01.2026, the Framework Contract concluded with payment service users who have the status of consumers, in force as of 16.12.2025, as well as all documents that are an integral part of it, including, but not limited to:

1. general banking conditions applicable to natural persons;
2. fees and commissions charged;
3. specific conditions related to certain instruments or payment services (for example: payment cards, applications, other instruments or payment services offered).
   Additionally, by letter dated 06.02.2026, banks were requested to present, by 16.02.2026, copies of loan files, regarding loan contracts concluded on the 5th and 25th days of each month, for the period 01.01.2023 – 24.10.2025, and in force as of 16.12.2025, which should include:
4. the loan application;
5. standard information on consumer loans;
6. loan contracts, including the payment schedule;
7. mortgage contracts;
8. the initial insurance contract for the real estate, including the insurance policy;
9. primary documents confirming the disbursement of the loan;
10. primary documents confirming payment by the debtor of the first two installments, according to the payment schedule;
11. payment accounting reports generated and calculated regarding granted loans, as generated by the information system for accounting for granted loans, with detailed allocation of payments, as of 24.10.2025;
12. information regarding the costs of managing an account that records both payment operations and withdrawals, the costs of using a payment instrument for both payment operations and withdrawals, as well as other costs related to payment operations, related to the loan contract, if applicable.

5. As a result of the requests sent, it is established that:
   5.1. On 24.12.2025, a letter from “NOVA PAY” S.R.L. was received, communicating that, “Although the Company holds a payment institution license issued by the National Bank of Moldova, with the right to provide payment services provided for in Art. 4 para. (1) subpoint 1)–9) of Law No. 114/2012 on payment services and electronic money, the actual activity carried out by the Company consists exclusively in providing money remittance services, within the meaning of Art. 4 para. (1) subpoint 6) of the aforementioned law.” At the same time, it mentioned that “The Company does not have a framework contract in force concluded with payment service users – consumers.”
   5.2. On 10.01.2026, a letter from “UP SERVICII” S.R.L. was received, communicating that, “currently “UP Servicii” SRL has not yet started activity as a payment service provider under the BNM license, and consequently the delivery of requested documents and information cannot be presented, as, at the present date, UP Servicii SRL has not concluded contracts with payment service users who have the status of consumers.”
   5.3. Thus, in the case of “NOVA PAY” S.R.L. and “UP Servicii” S.R.L., the object of the thematic control is missing, in the sense that no framework contract was concluded with payment service users who have the status of consumers.

6. On 02.03.2026, to the entities subject to control (except “UP SERVICII” S.R.L. and “NOVA PAY” S.R.L.), a letter was sent to the head of the control team, requesting explanations regarding the presentation of pre-contractual information, in accordance with the provisions of Art. 42 of Law No. 114/2012.
   6.1. On 30.12.2025, “MOLDCELL” S.A. sent to CNPF the materials and information requested during the control, which include:

1. Moldcell Money Framework Contract 21.03.2025;
2. Procedure on the examination of complaints_12.2024;
3. Common rules for providing services in money remittance systems_07.04.2025;
4. MIA Usage Rules_29.10.2025;
5. Payment card usage rules_16.07.2025;
6. Terms and conditions Apple Pay_Google Pay_31.12.2024;
7. MIA Instant Payments Commissions in force from 11.09.2024;
8. Western Union Commissions in force from 15.05.2024;
9. Money Gram Commissions in force from 29.04.2025;
10. List of service provider commissions in force from 01.12.2025;
11. Moldcell Visa card tariffs in force from 09.07.2025.
    At the same time, on 05.03.2026, “MOLDCELL” S.A. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.2. On 13.01.2026, “Paynet Services” S.R.L. presented the materials and information requested during the control, consisting of a set of 8 documents.
    At the same time, on 04.03.2026, “Paynet Services” S.R.L. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.3. On 13.01.2026, “QIWI-M” S.R.L. sent to CNPF the materials and information requested during the control, consisting of the following documents:
12. General Agreement for natural persons related to QMoney, which was valid as of 16.12.2025;
13. Fees and limits applicable to QMoney payment account holders;
14. Usage rules for paying services through payment terminals.
    Subsequently, on 09.03.2026, “QIWI-M” S.R.L. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.4. On 14.01.2026, “PAYMASTER” S.R.L. transmitted the materials and information requested during the control, consisting of a set of 4 documents.
    At the same time, on 06.03.2026, “PAYMASTER” S.R.L. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.5. On 14.01.2026, “BPAY” S.R.L. sent to CNPF the materials and information requested during the control, comprising a set of 10 documents, and on 22.01.2026, SC “MMPS COM” S.R.L. transmitted the materials and information requested, including a set of 3 documents.
    6.6. On 09.01.2026, BC “EuroCreditBank” S.A. sent to CNPF the materials and information requested during the control, consisting of:
15. PF Collaboration Framework Contract;
16. General conditions for providing services to consumer natural persons within BC EuroCreditBank S.A.;
17. Security Guide_ECBank;
18. ECBank User Guide;
19. Limits established on accounts_cards_ECB;
20. Tariffs for accepting cards issued by other Banks;
21. Tariffs for servicing bank cards issued within salary projects;
22. Tariffs for issuing and using bank cards for natural persons;
23. Tariffs for MIA Instant Payments;
24. Tariffs for banking services provided to natural persons.
    Subsequently, on 16.01.2026, BC “EuroCreditBank” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    Also, on 16.02.2026, BC “EuroCreditBank” S.A. sent copies of loan files, regarding loan contracts concluded on the 5th and 25th days of each month, for the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    At the same time, on 06.03.2026, BC “EuroCreditBank” S.A. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.7. Similarly, on 12.01.2026, “Banca de Finante si Comert” S.A. presented the materials and information requested during the control, according to point 2 of the letter dated 23.12.2025, consisting of a set of 77 documents.
    Subsequently, on 16.01.2026, “Banca de Finante si Comert” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    Also, on 16.02.2026, “Banca de Finante si Comert” S.A. transmitted 10 copies of loan files, related to the 5th and 25th days of each month, for the period 01.01.2023–24.10.2025.
    On 06.03.2026, “Banca de Finante si Comert” S.A. communicated to CNPF that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.8. On 12.01.2026, BC “Moldindconbank” S.A. sent to CNPF the materials and information requested during the control, according to point 2 of the request dated 23.12.2025, consisting of a set of 27 documents.
    Subsequently, by request No. 00/12-26-000385 dated 19.01.2026, BC “Moldindconbank” S.A. requested an extension of the deadline for presenting the requested information by 3 working days, explaining that it had migrated to a new banking information system, a circumstance that implied identifying, querying, and consolidating relevant data from two distinct information systems. Following the examination of the aforementioned request, taking into account the deadlines established in the Control Plan, the control team members decided on the possibility of extending the deadline for presenting information until 22.01.2026. Thus, on 21.01.2026, BC “Moldindconbank” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025. Subsequently, by request No. 00/12-26-001291 dated 12.02.2026, the bank requested an extension of the deadline for presenting the requested information until 25.02.2026. The request was motivated by the considerable volume of requested information, the large number of the Bank's clients, as well as the significant number of loan files and related documents that need to be identified, copied, and systematized. Under these conditions, the initially established deadline did not allow for the complete presentation of information in an appropriate form. As a result of examining the aforementioned request and considering the deadlines established in the Control Plan, as well as the need to ensure the continuity of the control procedure, the control team members decided to partially admit the request, by extending the deadline for presenting information and documents until 25.02.2026, respecting the obligation of phased transmission of available information, as follows:
25. by 16.02.2026 – presentation of information and documents available on that date;
26. by 20.02.2026 – presentation of information and documents available on that date;
27. by 25.02.2026 – complete presentation of the requested information and documents.
    In this context, BC “Moldindconbank” S.A. presented, within the established deadlines, copies of loan files related to the 5th and 25th days of each month, for the period 01.01.2023–24.10.2025.
    At the same time, on 06.03.2026, BC “Moldindconbank” S.A. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.9. On 12.01.2026, “OTP Bank” S.A. sent to CNPF the materials and information requested during the control, consisting of:
28. General banking conditions applicable to natural persons;
29. List of fees and commissions charged.
    Subsequently, on 19.01.2026, “OTP Bank” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    Furthermore, “OTP Bank” S.A. presented, on 17.02.2026, 86 copies of loan files, related to the 5th and 25th days of each month, for the period 01.01.2023–24.10.2025.
    At the same time, on 06.03.2026, “OTP Bank” S.A. communicated that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.10. On 12.01.2026, BC “EXIMBANK” S.A. sent to CNPF the materials and information requested during the control, consisting of:
30. General Banking Conditions for natural persons (CGB PF) - in force from 12.06.2025;
31. Application-Contract for opening current account;
32. Application for opening payment account and issuing payment card;
33. Application for opening payment account and issuing payment card for a child;
34. Application for issuing additional payment card;
35. Application for activating Eximbank SMS Info service;
36. Product Sheet Current Account;
37. Product Sheet Standard Debit Card;
38. Product Sheet Deposit Debit Card;
39. Product Sheet EXIM YOUNG Debit Card;
40. Product Sheet Social Debit Card;
41. Product Sheet Salary Debit Cards;
42. Product Sheet Premium Visa Signature Debit Card;
43. Product Sheet CIAO Standard Credit Card (issuance stopped from 20.10.2023);
44. Product Sheet CIAO Executiv Credit Card (issuance stopped from 20.10.2023);
45. Application-Contract for opening time deposit for natural persons;
46. Product Sheet Classico Deposit;
47. Product Sheet Classico Fix Deposit;
48. Product Sheet Dinamico Deposit;
49. Product Sheet Dinamico+ Deposit;
50. Product Sheet Libero Deposit;
51. Product Sheet Universal Deposit;
52. Product Sheet Senior Deposit;
53. Guide on opening deposit accounts;
54. Application-Contract for activating Eximbank Internet Banking service for natural persons;
55. Product Sheet Internet Banking;
56. EXIMBANK - Web Banking Usage Guide;
57. EXIMBANK - Mobile Banking Usage Guide;
58. Basic Tariffs Natural Persons - in force from 06.10.2025;
59. Fees and commissions Standard Debit Card;
60. Fees and commissions Deposit Debit Card;
61. Fees and commissions EXIM YOUNG Debit Card;
62. Fees and commissions Salary Debit Card;
63. Fees and commissions Social Debit Card;
64. Fees and commissions Visa Signature Debit Card;
65. Fees and commissions Staff Debit Card;
66. Fees and commissions Visa Signature Staff Preferential Debit Card;
67. Fees and commissions Visa Signature Staff Top Debit Card;
68. Fees and commissions CIAO Standard and CIAO Executiv Credit Cards - issuance stopped from 20.10.2023.
    Subsequently, on 19.01.2026, BC “EXIMBANK” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    Furthermore, on 16.02.2026, BC “EXIMBANK” S.A. submitted a request, by which it requested an extension of the deadline for presenting the requested information until 17.02.2026.
    Following the examination of the aforementioned request, taking into account the deadlines established in the Control Plan, the control team members decided on the possibility of extending the deadline for presenting information until 17.02.2026.
    In this context, on 17.02.2026, BC “EXIMBANK” S.A. presented copies of loan files, related to the 5th and 25th days of each month, for the period 01.01.2023–24.10.2025.
    At the same time, by communication dated 06.03.2026, BC “EXIMBANK” S.A. specified that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.11. On 12.01.2026, BC “ProCredit Bank” S.A. presented the materials and information requested during the control, according to point 2 of the letter dated 23.12.2025, consisting of a set of 8 documents.
    Subsequently, on 19.01.2026, BC “ProCredit Bank” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    Furthermore, on 13.02.2026, BC “ProCredit Bank” S.A. presented copies of loan files, related to the 5th and 25th days of each month, for the period 01.01.2023–24.10.2025.
    At the same time, by communication dated 05.03.2026, BC “ProCredit Bank” S.A. specified that the pre-contractual information, provided for in Art. 42 of Law No. 114/2012, is provided under the conditions of para. (2) of the same article, by including them in the framework contract and by making available to the user a copy of the framework contract prior to its conclusion.
    6.12. On 12.01.2026, BC “MOLDOVA-AGROINDBANK” S.A. sent to CNPF the materials and information requested during the control, according to point 2 of the request dated 23.12.2025, consisting of a set of 3 documents.
    Subsequently, on 19.01.2026, BC “MOLDOVA-AGROINDBANK” S.A. sent the list of loan contracts secured by real estate, concluded during the period 01.01.2023 – 24.10.2025 and in force as of 16.12.2025.
    Furthermore, on 10.02.2026, BC “MOLDOVA-AGROINDBANK” S.A. submitted request No. c220/e00014, by which it requested an extension of the deadline for presenting the requested information until 27.02.2026. The request was motivated by the fact that the CNPF request involved a volume of over 350 loan files, which implied an excessive volume of information and documents requiring processing within an extended deadline. As a result of examining the aforementioned request and considering the deadlines established in the Control Plan, as well as the need to ensure the continuity of the control procedure, the control team members decided to partially admit the request, by extending the deadline for presenting information and documents until 25.02.2026, respecting the obligation of phased transmission of available information, as follows:
69. by 16.02.2026 – presentation of information and documents available on that date;