Circular SINAP 1-248 National Payments System - Checks and Other Compensable Instruments. Update.

"2026 - YEAR OF ARGENTINE GREATNESS" COMMUNICATION “A” 8438 15/05/2026 TO FINANCIAL ENTITIES, TO OTHER NON-FINANCIAL CREDIT PROVIDERS, TO ELECTRONIC CLEARING CHAMBERS, TO AUTOMATED TELLER MACHINE NETWORKS, TO PAYMENT SERVICE PROVIDERS OFFERING PAYMENT ACCOUNTS, TO FINANCIAL MARKET INFRASTRUCTURES, TO MiPyME FUNDING PLATFORMS: Ref.: Circular SINAP 1-248: National Payments System - Checks and other compensable instruments. Update.

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We address ourselves to you to deliver the sheets that, in replacement of those timely provided, must be incorporated into the ordered text of the reference based on the provisions disseminated through Communication A 8299 and CIMPRA Bulletins 537, 538, 542, and 545. It is recalled that on this Institution’s website www.bcra.gob.ar, by accessing “Sections – Financial System – LEGAL AND REGULATORY FRAMEWORK – Ordering and summaries – Ordered texts of general regulations”, the modifications made with highlighted text in special characters (strikethrough and bold) will be found. We remain, yours sincerely. CENTRAL BANK OF THE ARGENTINE REPUBLIC Jorge A. M. Golla Matías A. Gutiérrez Girault Manager of Payment Systems Principal Manager of Payment Systems and Current Accounts ANEXO

-Índice- Section 1. Introduction Section 2. Definition and characteristics of the system 2.1. Objectives 2.2. Participating entities 2.3. Documents 2.4. Scope of application Section 3. Operational instructions 3.1. Electronic clearing of checks 3.2. Particular aspects of clearing truncated checks without image 3.3. Particular aspects of clearing truncated checks with image 3.4. Particular aspects of electronically generated checks (ECHEQ) 3.5. Open circulation system (SCA) for electronic credit invoices for MiPyME (FCEM) 3.6. Electronic certificate for time deposits and investments (CEDIP) Section 4. Responsibilities of participants 4.1. Of the depositary entity 4.2. Of electronic clearing chambers 4.3. Of the drawn entity Section 5. Controls to be performed 5.1. By electronic clearing chambers 5.2. By entities Section 6. Transactions and messages 6.1. Checks and other compensable instruments 6.2. Electronic certificate for time deposits and investments (CEDIP) Section 7. Record design 7.1. Checks and other compensable instruments 7.2. Electronic certificate for time deposits and investments (CEDIP) Section 8. Agreement on truncation, electronic generation and management of checks and other compensable documents 8.1. General concepts 8.2. Participating entities 8.3. Document requirements 8.4. Determination of obligations and functions B.C.R.A. ORDERED TEXT ON NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Version: 8th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 1

-Índice- 8.5. Obligations of participating entities 8.6. Non-compliance 8.7. Service remuneration 8.8. Procedure for modifying instructions 8.9. Communications between participating entities and obligation of cooperation 8.10. Models Correlation table B.C.R.A. ORDERED TEXT ON NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Version: 5th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 2

2.2.2.5. Exchange point of the Autonomous City of Buenos Aires (CABA): It is the location where the physical exchange of rejected checks, as required, takes place, along with CPDs for registration, claims, and adjustment vouchers. The relationship between participants is described in the following table:

Deposited Bank | Drawn Bank • Branch * Branch • Head Office * Head Office • Center * Center External | External B.C.R.A. | Branch Center Transmission | CEC Center CEC Transmission | Computations Control | Signatures Information | Electronic and/or image

2.3. Documents The system covers the processing of the following types of physical checks denominated in pesos, which meet the standardization requirements established by BCRA regulations: − Common checks. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 2. Definition and characteristics of the system Version: 4th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 4

− Deferred payment checks (CPD). B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 2. Definition and characteristics of the system Version: 4th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 5

− Certified checks. When checks are issued in electronic format (point 3.4.), they may be denominated either in pesos or United States dollars. 2.3.1. Truncated checks Those that remain in the possession of the depositary entity, after capturing their representative data, with only the electronic information reaching the drawn entity. These data constitute all the information that the depositary entity provides to the drawn entity so that it confirms/rejects payment, without requiring the original document to be sent. Depending on the amounts of the documents, two different cases can be distinguished: − Truncated checks where only electronic information is sent, without document images. − Truncated checks where both electronic information and document images are sent. The amount from which the image must be sent will be informed via BCRA communication, as it increases over time. 2.3.2. Deferred payment checks (CPD) The deferred payment checks (CPDs) have two distinct cycles: the registration cycle and the payment cycle. The registration cycle is not included in the clearing system, as it involves an exchange of documents between entities without monetary settlement. The payment cycle begins when the CPD matures. This cycle is similar to check clearing, so the same rules and instructions governing common checks will apply. 2.3.3. Certified checks These checks will be cleared in the same manner as common checks. Each drawn entity will maintain a register of certified checks to identify them based on the electronic information received. 2.3.4. Electronically deposited checks When financial entities accept the electronic deposit of checks – that is, when they allow their customers to present common or deferred payment checks for collection by capturing and transmitting their digital image – they must comply with the following: B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 2. Definition and characteristics of the system Version: 4th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 5

3.2.7. Rejections 3.2.7.1. Rejections by the depositary entity i) Definition These are rejections made by the depositary entity when it verifies, in the physical checks received, the existence of any of the defects foreseen in current legislation and regulations. ii) Operational instructions a) Transmission of rejected checks The depositary entity will transmit to the CEC, up to the deadline for the rejection session, the file containing information corresponding to the checks it rejected, taking into account the rejection causes defined in current regulations. According to current regulations, it must transmit for the following check and/or transaction rejection reasons: − R11 “Exceeds established endorsement limit”. − R16 “Document is not a check”. − R24 “Duplicated transaction” (for checks presented electronically for collection). − R33 “Check forgery”. − R36 “Check alteration”. − R37 “Legal validity period expired”. − R38 “Drawer’s signature does not match the one endorsing on the back”. − R46 “Document/Design not compensable”. − R47 “Second presentation does not apply”. − R48 “Illegible, deficient or incomplete image” (for checks presented electronically for collection). − R49 “Missing receipt signature for deposit”. − R51 “Missing legend ‘presented electronically for collection’”. − R83 “Irregularity in the endorsement chain”. − R96 “Depository entity errors” (code applicable only to physical checks). − R97 “Early presentation” (CPD). b) Processing by the electronic clearing chamber (CEC) The CEC will receive and clear rejected checks, according to defined schedules. c) Receipt of rejections by the drawn entity The drawn entity will receive from the CEC the file with information on rejections observed by the depositary entity. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 5th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 19

Furthermore, upon conclusion of the rejection session, the CEC will clear these movements. 3.3.9.2. Settlement Settlement will be carried out according to the check clearing period: the day following presentation. 3.4. Particular aspects of electronically generated checks (ECHEQ) The particular aspects of electronically generated checks must comply with the mechanisms established in applicable regulations and the definitions made regarding this matter within the Interbank Payment Means Commission (CIMPRA). 3.4.1. Functionalities Mechanisms – own or through third parties – necessary for customers to deposit or collect ECHEQ at the counter must be adopted. 3.4.2. Clearing and settlement The clearing and settlement process for ECHEQ must be assimilated, where applicable, to the process defined in these rules and include definitions made according to point 3.4. A system for storing ECHEQ must be implemented, whose function will be to register the issuance and endorsements of such instruments. This scheme may be operated and administered exclusively or jointly by the low-value electronic chamber. Infrastructures administering the ECHEQ storage system, as well as those responsible for their clearing and settlement systems, will be considered systemically important financial market infrastructures (IMF), and therefore the “Principles for Financial Market Infrastructures” regulations will apply to them. 3.4.3. Roles There are three types of roles: issuance, management, and deposit. 3.4.3.1. Issuance: will be the exclusive function of financial entities. With authorization for issuing checks by electronic means, compliance with the check service provision foreseen in point 1.2 of the ordered text on Regulation of Bank Current Accounts will be understood as fulfilled. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 6th. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 29

3.6. Electronic certificate for time deposits and investments (CEDIP) Time deposits and investments regulated in the TO on Time Deposits and Investments – with the exception of: deposits with remuneration in goods or services (point 1.10.), deposits from savings account credits for fund repatriation (point 1.19.), constant term investment (point 2.2.) and term investment with option to renew for a fixed period (point 2.4.) – that are captured through internet banking and mobile banking channels, may be instrumented via an electronic certificate (CEDIP), which will be the electronic instrument representing these placements, which will be electronically transferable, fractionable, and compensable. The CEDIP operation will comply with these rules and other applicable regulations issued by the BCRA, as well as operational and technical definitions made within CIMPRA under that regulatory framework. 3.6.1. Characteristics of the CEDIP Every CEDIP will be transferable, compensable, and fractionable. 3.6.2. Electronic circulation system (SCE) 3.6.2.1. The issuance, transmission, payment and any other relevant event and information of CEDIP will be registered in the SCE. 3.6.2.2. The SCE may only be administered by systemically important financial market infrastructures (IMF), individually or jointly, which for these purposes must hold explicit authorization from the BCRA. 3.6.3. Functionalities 3.6.3.1. Financial entities must adopt the mechanisms – own or through third parties – necessary so that, according to roles and scopes defined in point 3.6.5., customers can establish, manage and collect CEDIPs. 3.6.3.2. Among the enabled transmissions, for stock exchange negotiation purposes, financial entities and IMFs covered by point 3.6.5.2 must make available the transmission for negotiation and the transmission in procurement, both in favor of the agent performing custody of the CEDIP according to current regulations. 3.6.4. Clearing and settlement 3.6.4.1. Operational instructions applicable to the CEDIP The mechanisms for presentation, clearing, communication sessions and other relevant aspects to consider for the operation of electronic certificates for time deposits and investments (CEDIP) are developed below. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 2nd. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 38

Electronic clearing of CEDIP 3.6.4.1.1. Information on CEDIP to be presented The CEC(s) must inform depositary entities which CEDIPs are next to be presented for clearing. Regarding this, there will be a prior information exchange with drawn entities concerning the determination of amounts to be collected. 3.6.4.1.2. Presentation Entities will transmit to the CEC(s) files containing information corresponding to the CEDIPs that said entity presents for electronic clearing. i) Transmission sessions and transactions to be presented Daily, two sessions will operate in which the CEC(s) receive files from entities: − The presented session. − The rejected session. The transactions to be presented electronically to the CEC(s) are as follows: − In the presented session: • CEDIP to clear: they will present all records corresponding to instruments to be collected informed by the CEC(s). • Adjustments: they will present eventual adjustments to already presented and cleared CEDIPs, transaction defined later. • Adjustments for out-of-term presentation: they will present CEDIPs not cleared due to not being presented on the corresponding date, transaction defined later. − In the rejected session: • Rejections by depositary entities for causes foreseen in this regulation or those resolved within CIMPRA. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 2nd. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 39

• Rejections by drawn entities for causes foreseen in this regulation or those resolved within CIMPRA. • Adjustment rejections. • Out-of-term presentation adjustment rejections. ii) Deadlines and schedules For each session (presented and rejected), the CEC-defined deadline hours for presenting information to the CEC will apply, which govern communications between it and its respective affiliated entities. The CEC must establish schedules that allow financial entities to credit funds to their customers early in the day. These schedules function as deadline hours for information transmissions between a CEC and its affiliated entities. This means that entities may transmit files to a CEC throughout the day, from the start of operations hour defined by the chamber until said deadline. The entities that have not been able to send presented information to the CEC before these deadline hours must wait until the next business day to transmit it via adjustments. In the case of rejection communication, it may be managed through adjustments in the presented session of the same day. 3.6.4.1.3. Information processing in the CEC i) Reception and validation The CEC will execute electronic processing of information regarding CEDIP, whether received in the presented session or the rejected session, from the corresponding deadline hours for each session. The CEC will perform a series of validations on received files against CEDIP registration databases, rejecting them in case of error. The rejection reasons will be: − Non-existent branch or destination entity. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 1st. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 40

− Format errors. − Incorrect clearing date. − Incorrect amount. − Record counter error. − Already effected reversal. − Chamber back-out. − Non-existent CEDIP ID. − Duplicated presentation. − Entity code does not match the CBU for crediting. − Incorrect CEDIP status. − Invalid presentation date for the reported maturity date. − Non-existent CBU. − Incorrect deposit date. − Incorrect crediting type. − Date format error. − Invalid currency. − Incorrect transaction code. − Rejections on non-existent transactions. If files pass all validations performed by the CEC, it will send an acceptance response, assuming responsibility for their correct treatment. If they do not pass validations, the CEC reserves the right to request retransmission of the file in whole or in part, which may be remedied by the entity on the same day – always before the stipulated deadline hour. ii) Electronic clearing a) Clearing in the CEC B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 1st. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 41

There will be two sessions for sending CEDIP transactions as indicated in section i) of point 3.6.4.1.2. b) Clearing between CECs The provisions of point 3.1.2.2.ii) apply. iii) Adjustments a) Definition In the presented session, depositary entities may report as “adjustments” presentations that could not be sent within the stipulated deadlines and/or eventual interest to be received from crediting funds after the maturity period indicated in the CEDIP – when such situation is not generated by their own responsibility. Additionally, financial entities may use adjustments for situations detected in their internal control processes. b) Operational instructions − When the depositary entity cannot perform presentation for clearing within the corresponding period – resulting in deferred collection for the customer – it must proceed as follows: • Send the adjustment file with the total amount to be received considering the originally agreed amount in the CEDIP (principal plus interest). • When the deferral was not a result of its own responsibility, send a second adjustment file with the amount corresponding to interest payable for the deferral in the CEDIP crediting period. • Identify in the transmitted file the information of the CEDIP to which the adjustment corresponds. • The drawn entity may reject the received file(s). − When a deferral occurs in the collection period foreseen in the CEDIP for any cause other than that indicated in the previous point – for example, resulting from a rejection allowing a second presentation –, and is not the responsibility of the depositary entity, it must send, in addition to the presentation file, an adjustment for the interest corresponding to the CEDIP holder. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 1st. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 42

3.6.4.1.4. Sending to entities i) Movement communication Following the clearing process, all participating entities will receive from the CEC files containing: − The detail of cleared movements. − Bilateral balances resulting from clearing. The drawn entities will be the recipients of information resulting from the presented session clearing, and depositary entities will receive information resulting from the rejected session – when any rejection by the depository applies, the recipient will be the drawn entity. This information will be received separately by each currency type. ii) Processing of received information Entities will receive from the CEC files resulting from clearing, up to the reception hours defined by the chamber. The entities may perform rejections, according to this regulation. The rejection reasons for CEDIP are included within Section 7. The entities reserve the right to request retransmission of the file in whole or in part. 3.6.4.1.5. Other operational aspects i) Business days for clearing All days defined by the BCRA as business days will be considered business days for clearing. ii) Holidays a) Definition A foreseen local holiday is considered any declared by competent authority (national, provincial, municipal or CABA), that can be included in advance in the local holiday calendar administered by CECs. B.C.R.A. NATIONAL PAYMENTS SYSTEM CHECKS AND OTHER COMPENSABLE INSTRUMENTS Section 3. Operational instructions Version: 1st. COMMUNICATION “A” 8438 Validity: 16/05/2026 Page 43

An unforeseen local holiday is considered any declared by competent authority (national, provincial, municipal or CABA), that cannot be included in advance in the calendar administered by CECs. If an unforeseen local holiday is known well in advance, it may be informed by entities to the administrator of the electronic circulation system (SCE) for CEDIP, adjusting its amount and maturity date. When it is not known well in advance or, if known, not informed to adjust data reported in the SCE, it will give rise to adjustment transactions. Upon announcement of an unforeseen national holiday, the CEC will load the holiday for the CEDIP product in the holiday table and execute the date shift process, to perform the date deferral of those CEDIP transactions whose clearing date coincides with the date of the unforeseen holiday. b) Operational instructions − Foreseen holidays: Must send files to the CEC before the start of the period described in point 3.6.4.1.1 “Information on CEDIP to be presented”. The CEC will update the information with corresponding data