Circular SINAP 1-236 National Payments System – Immediate Debit Update

"Year of the Reconstruction of the Argentine Nation" COMMUNICATION “A” 8321 08/09/2025 TO FINANCIAL ENTITIES, TO ELECTRONIC CLEARING HOUSES, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS: Ref.: Circular SINAP 1-236: National Payments System – Immediate Debit. Update.

---

We address you to provide the pages that, replacing those previously supplied, should be incorporated into the referenced regulations based on the provisions disseminated through Communication A 8180. It is noted that on this Institution’s website www.bcra.gob.ar, by accessing “Financial System – LEGAL AND REGULATORY FRAMEWORK – Organization and summaries – Organized texts of general regulations”, the modifications made with text highlighted in special characters (strikethrough and bold) will be found. We remain, respectfully yours. BANK OF THE ARGENTINE REPUBLIC Irene T. Cano Matías A. Gutiérrez Girault Deputy General Manager of Payment Systems Chief Manager of Payment Systems and Current Accounts a/c ANNEX

1.1. Definitions 1.1.1. Immediate debit (DEBIN) is an immediate transfer mechanism that debits the client's account, requiring prior authorization. This authorization may be carried out once, at the time of adherence to the recurring DEBIN operation, or on each occasion upon receipt of an occasional DEBIN. It is implemented through internet banking, mobile banking, as well as in the interfaces provided by payment service providers offering payment accounts (PSPCP) and in other channels established by the Bank of the Argentine Republic (BCRA). The mechanism consists of: − a debit request submitted, through the explicit channels, by the ordering client or the financial entity itself; − online authorization of the debit for the receiving client (unless previously adhered to the operation); and − online debit in the receiving client's account and online credit in the ordering client's account. 1.1.2. There are two DEBIN modalities: − Spot or occasional: is that DEBIN originated occasionally for a determined amount, which in each case requires the express authorization of the receiving client. − Recurring: is that DEBIN originated for recurring and/or frequent relationship payments, which does not require specific authorization for each debit as it is adhered to the operation. This modality features a variant called “Scheduled DEBIN”, designed to pay for goods or services in a pre-established number of fixed installments. 1.1.3. Prohibitions 1.1.3.1. Recurring DEBIN cannot be used to collect any concept related to loans, which may only be processed through the occasional modality. 1.1.3.2. In addition to the restriction in point 1.1.3.1., scheduled DEBIN cannot be used by ordering clients whose commercial activity or sector is lotteries, casinos, or other games of chance. 1.2. Objective To provide clients with secure and accessible mechanisms that facilitate – through various channels – the execution of a wide range of operations involving online debits and credits, contributing to a more efficient payment system in line with international best practices. B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 1. Introduction Version: 6th COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 1

Allows clients to generate collection requests destined for other clients, producing an immediate payment – through online debit and credit – based on authorization in each operation by the receiving client or by the latter being adhered to the operation. B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 1. Introduction Version: 1st COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 2

2.1. Scope DEBIN may be ordered by natural and legal persons, holders of checking accounts in financial entities or payment accounts in PSPCP that, according to this regulation, are authorized to issue debit orders on account, or by the financial entities themselves. 2.2. Participants − Ordering clients: natural or legal persons, holders of checking or payment accounts, who request the originating entity or PSPCP to issue DEBIN. − Receiving clients: natural or legal persons, holders of checking or payment accounts, who receive DEBIN and are debited if they are adhered to the operation or expressly authorize it, as applicable. − Operators: financial entities or third parties designated by the entities or PSPCP that originate or receive DEBIN to link with clients. − Originating entities: financial entities where the ordering client's account is located, or the current account of the PSPCP where the payment account of the ordering client is held. They may originate DEBIN and, in that case, credit accounts when applicable. They may act on behalf of third parties or on their own account. − Receiving entities: financial entities where the receiving client's account is located, or the current account of the PSPCP where the payment account of the receiving client is held. They receive debit requests for their clients and must provide mechanisms for them to accept or reject them. Furthermore, they must allow their clients to request adherence to the recurring DEBIN operation, except in its scheduled DEBIN variant. − Originating PSPCP: PSPCP that may allow its clients to order DEBIN and, in that case, credits payment accounts when applicable. It participates through an originating entity. − Receiving PSPCP: PSPCP that must allow its clients to receive DEBIN and provide them with mechanisms to accept or reject them. It must allow its clients to request adherence to the recurring DEBIN operation, except in its scheduled DEBIN variant. It participates through a receiving financial entity. − Processors: financial entities or third parties designated by them to communicate with the administrator. They link the originating and receiving entities and PSPCP with the administrator. − Administrator: low-value electronic clearing house (CEC-BV). It compensates debits and credits of the operation, liquidating net balances at the BCRA. − The high-value electronic clearing house (CEC-AV) may participate as an operator and/or processor of DEBIN. B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 2. General Characteristics Version: 5th COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 1

2.3. Currency The operation will be available for debits in pesos and United States dollars, between accounts of the same currency. 2.4. Operating hours and crediting deadlines The DEBIN operation will be available every day, 24 hours a day, with immediate crediting. 2.5. Cost Debits in the receiving client's DEBIN accounts will be free of charge. Credits resulting from the DEBIN operation cannot be subject to charges and/or commissions by the entities or PSPCP receiving them. Only the originating entity or PSPCP may apply charges and/or commissions on these operations for the service provided; which must be communicated to the ordering client, prior to operation confirmation, when dealing with financial services users. For operations involving recurring DEBIN, the entities or PSPCP receiving the DEBIN may charge the originating financial entities or PSPCP an interchange rate of up to 0.3% per operation, with a cap of 0.12 value adjustment units (UVA). 2.6. Reversal and chargebacks The receiving client has a period of 30 days to dispute the debit corresponding to a recurring DEBIN; they may file the claim with the entity or PSPCP that received it or through the ordering client. Once the dispute is made, the debited amount will be automatically returned to the client within 72 business hours of the claim being filed. In turn, the entity or PSPCP that received the claim will automatically execute a chargeback against the originating entity or PSPCP of the DEBIN. This situation must be explicitly stated in the conditions subscribed by the ordering and receiving clients. For scheduled DEBIN, the provisions of this point only apply to the first payment. Occasional DEBIN cannot be disputed by the receiving client. 2.7. Notifications B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 2. General Characteristics Version: 5th COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 2

Financial entities and PSPCP must make available to their clients, through specific notifications and in an immediate manner, information on received DEBIN – both recurring and occasional. These notifications must be made through one of the electronic communication media used to communicate with their clients, such as email, text message, or any application that generates notifications on the receiving client's mobile device – cell phone or other. Furthermore, when dealing with occasional DEBIN, the notification must include the following legend prominently – in terms of visibility and size: “By accepting this transaction FUNDS WILL BE EXTRACTED FROM YOUR ACCOUNT for the indicated amount, which will be remitted to who ordered the extraction. Please note that it is NEVER necessary to give authorization to RECEIVE electronic payments”. The notification of the first recurring DEBIN must contain the following legend prominently – in terms of visibility and size: “By accepting this adherence request FUNDS WILL BE EXTRACTED FROM YOUR ACCOUNT periodically, which will be remitted to XXXXXXX [name of the ordering client]. Please note that it is NEVER necessary to give authorization to RECEIVE electronic payments”. In the case of scheduled DEBIN, prior to processing the first installment, the financial entity or PSPCP receiving the debit request must have the express authorization of the receiving client confirming the details of the operation with the exhibition of the following legend prominently – in terms of visibility and size: “By accepting this adherence request FUNDS WILL BE EXTRACTED monthly [$/U$S] XXXX FROM YOUR ACCOUNT in XX installments/payments, which will be remitted to XXXXXXX [name of the ordering client]. Please note that it is NEVER necessary to give authorization to RECEIVE electronic payments”. 2.8. Information to the client The minimum data that financial entities and PSPCP must inform to the receiving client, for each operation, through the different enabled channels, will be: − The DEBIN or scheduled DEBIN description, as applicable, followed by the name of the account holder to be credited. In case of holders that do not have the status of financial services users, the trade name will be recorded instead of the account holder's name. − Concept or a reference that univocally identifies the operation for its use as a payment receipt. − Amount. − Date. − Installment X/of XX (when dealing with a scheduled DEBIN). B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 2. General Characteristics Version: 2nd COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 3

3.1. Functionality for service adherence to the recurring DEBIN operation 3.1.1. A client – who will be the receiving client of DEBIN – may request the adherence of each service they wish to incorporate into the operation through: a. the ordering client; or b. the financial entity or PSPCP where they hold the account that will be debited by recurring DEBIN. For adherence of services to scheduled DEBIN operation, the receiving client can only request adherence through the ordering client taking into account the following particularities: − The number of installments, and their amount, are fixed and established in advance. − Each payment plan must be subject to an individual adherence. The following minimum data of the receiving client will be requested: − First and last name, or corporate name. − Uniform banking key (CBU) or CBU alias, uniform virtual key (CVU) or CVU alias, of the account to be debited. 3.1.1.1. When the receiving client requests adherence to the ordering client – subsection a) of point 3.1.1.–, express authorization by the receiving client will be required, in the financial entity or PSPCP that receives the debit request –where the receiving client holds the account to be debited–, prior to processing the first DEBIN requested by that ordering client. This authorization will give this adherence immediate effect, remaining authorized from that same moment the debit of their account upon receipt of a new DEBIN ordered by that ordering client. 3.1.1.2. Financial entities or PSPCP may resolve the development of the adherence functionality provided in subsection b) of point 3.1.1. directly or through third parties (operators). 3.1.2. Adherence termination may be carried out by the receiving client through the ordering client or the entity/PSPCP that received the DEBIN, interchangeably. In scheduled DEBIN, once the last installment is paid, no termination request for adherence by the receiving client is required. Both the receiving client and the ordering client may request plan termination at any time. 3.1.3. Receiving and originating entities and PSPCP will interact with the administration module to perform relevant validations and register in the reservoir the adherences of CBU, CVU and/or aliases that the client integrated into the recurring DEBIN operation, as well as their terminations. B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 3. Processes and Functions Version: 5th COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 1

3.5.1.1. DEBIN Will contain the main functionality of the product, managing all operations related to its operation, namely: − New DEBIN: the originating entity or PSPCP must send this message at the moment a new DEBIN operation is generated. − The administrator will validate whether it corresponds to a recurring, scheduled or occasional DEBIN and will identify it in the messaging so that the entity or PSPCP receiving it processes it immediately or leaves it pending approval for the receiving client. − Debit confirmation: the entity or PSPCP receiving the DEBIN will send debit confirmation once the receiving client accepts the operation and the debit has been executed in their account for the amount reported in the operation. The administrator will perform guarantee control for the DEBIN product and inform the entity or PSPCP whether to continue with the operation or reverse the debit due to insufficient guarantees or other reasons. − Delete a DEBIN: the originating entity or PSPCP may delete it as long as the DEBIN has not yet been debited from the receiving client's account. − Query DEBIN: the receiving client and the ordering client, through their respective financial entities or PSPCP, may request information on a DEBIN and its status. − List DEBIN: both the ordering client and the receiving client may request a list of DEBIN through their entity or PSPCP. The data of the ordering and receiving clients will be requested exclusively. This list will show exclusively operations originated and received by the client. − Establish entity status: online or offline. 3.5.1.2. Guarantees Must allow the following operations: − Settlements: the entity or PSPCP may consult the status of the last closed settlement. The administrator will return the amount of each currency operating in the product, indicating in each case whether they have already been paid or are pending payment. − Movements: the entity or PSPCP may consult totals of debit and credit movements by currency. B.C.R.A. NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT Section 3. Processes and Functions Version: 6th COMMUNICATION “A” 8321 Validity: 09/09/2025 Page 5

B.C.R.A. ORIGIN OF THE PROVISIONS CONTAINED IN THE ORGANIZED TEXT ON NATIONAL PAYMENTS SYSTEM – IMMEDIATE DEBIT

Sec.	Point	Para.	Com.	Annex	Ch.	Sec.	Point	Para.	Observations
1.
1.1.	“A”	6099	S/Com.	“A”					6285, 6423, 6698, 6909, 7514, 8172, 8180 and 8321.
1.2.	“A”	6099	S/Com.	“A”					6285, 6423, 6698 and 8172.
2.
2.1.	“A”	6099	S/Com.	“A”					6285, 6423, 6698, 7514 and 8172.
2.2.	“A”	6099	S/Com.	“A”					6234, 6285, 6698, 7514, 8172, 8180 and 8321.
2.3.	“A”	6099
2.4.	“A”	6099	S/Com.	“A”					8172.
2.5	“A”	6234	S/Com.	“A”					6285, 6420, 6698, 7514, 7841 and 8172.
2.6.	“A”	6423	S/Com.	“A”					6698, 8172 and 8180.
2.7.	“A”	6423	S/Com.	“A”					6698, 7326, 7350, 7514, 7841, 7905, 7934, 8172, 8180 and 8321. Includes regulatory clarification.
2.8.	“A”	6698	S/Com.	“A”					7326, 7514, 8172, 8180 and 8321.
3.
3.1.	“A”	6099	S/Com.	“A”					6234, 6285, 6423, 6698, 7514, 8172, 8180 and 8321.
3.2.	“A”	6099	S/Com.	“A”					6285, 6698, 7514 and 8172.
3.3.	“A”	6099	S/Com.	“A”					6285, 6423, 6698, 7326, 7350, 7514 and 8172. Includes regulatory clarification.
3.4.	“A”	6698	S/Com.	“A”					7514 and 8172.
3.5.	“A”	6099	S/Com.	“A”					6285, 6423, 6698, 7514, 8172, 8180 and 8321.
4.
4.1.	“A”	6099	S/Com.	“A”					6285 and 8172.
4.2.	“A”	6099	S/Com.	“A”					6285, 6423, 6698, 7514 and 8172.
4.3.	“A”	6099	S/Com.	“A”					6285, 6423, 6698 and 8172.
4.4.	“A”	6099	S/Com.	“A”					6285, 6698 and 8172.
4.5.	“A”	7514				5.	S/Com.	“A”	8172.
5.	“A”	6099	S/Com.	“A”					8172.
6.
6.1.	“A”	6099	S/Com.	“A”					6285, 6698, 7783 and 8172.
6.2.	“A”	6698	S/Com.	“A”					8172.