Framework for the SIRES service - Relevant Information System for Supervised Entities

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 .................................................................................................................................................................................................. Topics Supervision :: Supervision Mod. 99999940/T – 01/14 Index Text of the Instruction Text of the Instruction Subject: Framework for the SIRES service - Relevant Information System for Supervised Entities This Instruction aims to frame the new SIRES – Relevant Information System for Supervised Entities (SIRES) service within the internal legal order, which will allow the uniform processing of authorization, non-opposition, communication, and registration procedures with Banco de Portugal, discontinuing the current service “Requests for Authorization and Registration” (PAR), regulated by Banco de Portugal Instruction No. 7/2016, of May 20, which is, for this reason, revoked. This new SIRES service will ensure the authenticity of the identity of interlocutors by appropriate means and will allow the electronic submission and consultation of electronic communications addressed to Banco de Portugal or sent by it within the scope of the covered procedures and the consultation of the information registered in SIRES, at any time, relating to the covered entities and only by the entities themselves. SIRES is a service that will be available on the BPnet System, as well as, at a later stage, in the company area on Banco de Portugal's institutional website, and will be used both by entities obliged to adhere to it, and by other individuals and legal entities that wish to submit, through this channel, to Banco de Portugal one of the authorization, non-opposition, communication, and registration procedures listed in this Instruction. For this reason, all those who use the SIRES service are included in the subjective scope of this Instruction. The mandatory use of the service under the terms provided in this Instruction does not apply to procedures covered by the European Central Bank (ECB) Information Management System Portal (designated as Information Management System for the SSM, hereinafter identified only as “IMAS Portal”), nor to prior communications/notifications from credit institutions that must be addressed directly to the ECB through the Joint Supervisory Teams, by e-mail, as clarified by the ECB in the letter called Additional clarification regarding the ECB’s competence to exercise supervisory powers granted under national law, dated 31/03/2017. All procedures submitted through the PAR service will be processed, as of the SIRES entry into operation date, through this new service.

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 The draft of this Instruction was subject to public consultation in legal terms. Thus, Banco de Portugal determines, in the exercise of the competence attributed to it by Article 17 of its Organic Law, approved by Law No. 5/98, of January 31, and under Articles 30, No. 8 and 116, paragraph f) of the General Regime of Credit Institutions and Financial Companies, approved by Decree-Law No. 298/92, of December 31 (RGICSF), as well as Article 7, No. 1, paragraph c) of the Legal Regime of Payment Services and Electronic Money, approved by Decree-Law No. 91/2018, of November 12 (RJSPME), in their current wordings, the following: Article 1 Object 1 – The object of this Instruction is to regulate the conditions for adherence to and use of the SIRES service. 2 – SIRES is a service: Amended by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. a) Of the BPnet System, with participation in BPnet, including access to the infrastructure and adherence to and provision of the services of that system, regulated by Banco de Portugal Instruction No. 21/2020; Added by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. b) Made available in the company area on Banco de Portugal's institutional website. Added by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. 3 – SIRES allows, electronically and through a system that ensures the authenticity of the identity of interlocutors by appropriate means, the: a) Submission and consultation of electronic communications addressed to Banco de Portugal or sent by it within the scope of the procedures referred to in Articles 3 to 6; b) Consultation of the information registered in SIRES relating to the entities referred to in No. 1 of Article 2, under the terms provided for in Article 7. Amended by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. Article 2 Subjective scope 1 – Adherence to SIRES is mandatory for the following entities: Numbered by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. a) Credit institutions headquartered in Portugal; b) Financial companies headquartered in Portugal; c) Electronic money institutions headquartered in Portugal; d) Payment institutions headquartered in Portugal;

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 e) Entities referred to in the preceding paragraphs with headquarters in European Union Member States when established in Portugal in the form of a branch; f) Entities referred to in paragraphs a) to c) above with headquarters in third countries when established in Portugal in the form of a branch; and g) Entities subject to the supervision of Banco de Portugal, under the terms of Article 117 of the RGICSF. 2 – Individuals and legal entities not subject to the supervision of Banco de Portugal may submit the requests and communications referred to in this Instruction, which are applicable to them, through SIRES. Added by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. Article 3 Procedures relating to credit institutions, financial companies, payment institutions, and electronic money institutions 1 – The following requests and communications relating to the entities referred to in paragraphs a) to d) of No. 1 of Article 2 must be submitted and processed through SIRES: Amended by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4. a) Authorization for statutory changes, under the terms provided for in the RGICSF, the RJSPME, and the RJCAM, with the exception of what is provided for in No. 3; b) Authorization for merger and spin-off operations, under the terms provided for in the RGICSF and the RJSPME, with the exception of what is provided for in No. 3; c) Communication of the voluntary dissolution project, under the terms provided for in the RGICSF and the RJSPME; d) Authorization for the exercise of functions of members of administrative and supervisory bodies, under the terms provided for in the RGICSF, the RJSPME, the RJCAM, and the regulatory instruments governing these procedures, with the exception of what is provided for in No. 2; e) Authorization and eventual new assessment for the exercise of functions of holders of essential functions, under the terms provided for in the RGICSF and the regulatory instruments governing these procedures, with the exception of what is provided for in No. 2; f) Authorization for the exercise of functions of branch managers, established in third countries, under the terms provided for in the RGICSF and the regulatory instruments governing these procedures, with the exception of what is provided for in No. 2; g) Authorization for the exercise of functions of branch managers, established in the European Union, under the terms provided for in the RGICSF and the regulatory instruments governing these procedures;

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 h) Communication of subsequent facts to the processes referred to in paragraphs d) to g), under the terms provided for in the RGICSF, the RJSPME, the RJCAM, and the regulatory instruments governing these procedures; i) Notification of replacement of holders of essential functions of institutions not categorized as other systemically important institutions (O-SII), under the terms provided for in the RGICSF and the regulatory instruments governing this procedure; j) Prior communication of acquisition or increase of qualified shareholding in credit institutions, financial companies, payment institutions, and electronic money institutions, headquartered in Portugal, under the terms provided for in the RGICSF, the RJSPME, and the regulatory instruments governing these procedures, with the exception of what is provided for in No. 4; Amended by Instruction No. 2/2026, published in BO No. 3/2026 Supplement, of March 26. k) Prior communication of direct or indirect acquisition of qualified shareholding in a credit institution headquartered abroad, under the terms provided for in the RGICSF and the regulatory instruments governing these procedures, with the exception of what is provided for in No. 3; l) Subsequent communication of acquisition of qualified shareholding, under the terms provided for in the RGICSF and the RJSPME; m) Prior communication of decrease of qualified shareholding, under the terms provided for in the RGICSF and the RJSPME; n) Communication of changes relating to qualified shareholdings, under the terms provided for in Article 108, No. 1 of the RGICSF and Article 41, No. 1 of the RJSPME; o) Communication of the identity of qualified participants under the terms provided for in Article 108, No. 2 of the RGICSF and Article 41, No. 2 of the RJSPME; p) Prior notification of establishment of a branch in a European Union Member State by a credit institution or financial company headquartered in Portugal, including respective changes, under the terms provided for in the RGICSF, with the exception of what is provided for in No. 2; Amended by Instruction No. 2/2026, published in BO No. 3/2026 Supplement, of March 26. q) Prior notification of establishment of a branch in a third country by a credit institution or financial company headquartered in Portugal, including respective changes, under the terms provided for in the RGICSF, with the exception of what is provided for in No. 3; r) Prior communication of establishment of a branch or free provision of services by payment institutions and electronic money institutions headquartered in Portugal, under the terms provided for in the RJSPME; s) Communication of modification of elements relating to free provision of services and branches, under the terms provided for in the RJSPME;

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 t) Prior notification of provision of services in another European Union Member State by a credit institution or financial company headquartered in Portugal, under the terms provided for in the RGICSF, with the exception of what is provided for in No. 2; Amended by Instruction No. 2/2026, published in BO No. 3/2026 Supplement, of March 26. u) Prior communication of establishment or acquisition of a subsidiary in a third country, under the terms provided for in the RGICSF, the RJSPME, and the regulatory instruments governing these procedures, with the exception of what is provided for in No. 3; v) Request for registration, under the terms provided for in the RGICSF, the RJSPME, and the RJCAM; w) Prior communication for purposes of opposition or non-opposition to the accumulation of positions under the terms provided for in the RGICSF, the RJSPME, and the regulatory instruments governing these procedures; x) Other communications relating to the matters referred to in the preceding paragraphs. 2 – Paragraphs d), e), f), p) and t) of No. 1 of this article are not applicable to institutions subject to direct ECB supervision (Significant Institutions classified according to ECB Regulation (EU) No. 468/2014, of April 16, 2014), and the procedures referred to therein must be submitted through the ECB Information Management System Portal, as established in Banco de Portugal Instruction No. 2/2026. Amended by Instruction No. 2/2026, published in BO No. 3/2026 Supplement, of March 26. 3 - Paragraph j) is not applicable to credit institutions subject to the supervision of Banco de Portugal or the ECB, and the procedure referred to therein must be submitted through the ECB Information Management System Portal, as established in Banco de Portugal Instruction No. 2/2026. Amended by Instruction No. 2/2026, published in BO No. 3/2026 Supplement, of March 26. Article 4 Procedures relating to branches of credit institutions authorized in European Union Member States The following requests and communications relating to credit institutions authorized in European Union Member States must be submitted and processed through SIRES: a) [Revoked]; Revoked by Instruction No. 2/2026, published in BO No. 3/2026 Supplement, of March 26. b) Request for registration of the elements provided for in the RGICSF. Article 5 Procedures relating to credit institutions authorized in third countries The following requests and communications relating to branches in Portugal of credit institutions authorized in third countries must be submitted and processed through SIRES:

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 a) Authorization for the exercise of functions of branch managers, established in Portugal, of credit institutions authorized in third countries, under the terms provided for in the RGICSF; b) Prior communication of opening new establishments in Portugal by a credit institution authorized in a third country that already has a branch in Portugal, under the terms provided for in the RGICSF; c) Communication of alteration of elements under the terms provided for in the RGICSF; and d) Request for registration of the elements provided for in the RGICSF. Article 6 Procedures relating to entities subject to the supervision of Banco de Portugal under Article 117 of the RGICSF 1 - The following requests and communications relating to entities subject to the supervision of Banco de Portugal, under the terms of Article 117 of the RGICSF, must be submitted and processed through SIRES: a) Prior communication in case of establishment of subsidiaries in countries that are not members of the European Union under the terms provided for in the RGICSF; b) Prior communication in case of acquisition of qualified shareholdings in companies headquartered abroad under the terms provided for in the RGICSF; c) Authorization for the exercise of functions of members of administrative and supervisory bodies, as well as communications regarding subsequent facts, under the terms provided for in the RGICSF and the regulatory instruments governing this procedure; and d) Request for special registration, under the terms provided for in Decree-Law No. 495/88 of December 30 and the RGICSF. 2 – Paragraph c) of No. 1 of this article is not applicable to entities subject to the supervision of Banco de Portugal, under the terms of Article 117 of the RGICSF, that are parent companies of institutions subject to direct ECB supervision (Significant Institutions classified according to ECB Regulation (EU) No. 468/2014, of April 16, 2014), and the procedures referred to therein must be submitted through the ECB Information Management System Portal, as established in Banco de Portugal Instruction No. 7/2021. Article 7 Consultation of registered information The entities referred to in No. 1 of Article 2 of this Instruction may, at any time, consult updated information regarding themselves that, at the time of consultation, is registered in SIRES. Amended by Instruction No. 5/2024, published in BO No. 3/2024 Supplement, of April 4.

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 Article 8 Exceptional processing In exceptional situations, duly justified, Banco de Portugal may allow the requests, notifications, and communications provided for in Articles 3 to 6 of this Instruction to be submitted, respecting the applicable legal and regulatory norms, through appropriate physical support, to the following address: BANCO DE PORTUGAL PRUDENTIAL SUPERVISION DEPARTMENT RUA CASTILHO, NO. 24 1250-069 LISBON Article 9 Archiving of original documents 1 – Except as provided in a special provision, entities must keep in their archives, for the period corresponding to the limitation period for the administrative offense procedure applicable for offenses related to the procedures provided for in this Instruction, the following documents submitted through SIRES: a) Documents signed by an individual, in their own name or on behalf of another; or b) Other original documents. 2 – The presentation of the documents referred to in the preceding number may be required by Banco de Portugal until the end of the period established in the preceding number. Article 10 Representativeness Applicant entities may be represented in interactions occurring through the SIRES service under the terms provided for in Banco de Portugal Instruction No. 21/2020, as well as by a representative with duly proven powers of representation. Article 11 Procedures submitted through the PAR service Procedures that have been submitted through the PAR service will be processed in the SIRES service.

Instruction No. 11/2023 BO No. 5/2023 • 2023/05/15 Topics Supervision :: Supervision .................................................................................................................................................................................................. Mod. 99999940/T – 01/14 Article 12 References References made, in any regulatory instrument in force, to Banco de Portugal Instruction No. 7/2016 and to the PAR service are considered to be made respectively to this Instruction and to the SIRES service. Article 13 Revocation Banco de Portugal Instruction No. 7/2016, of May 20, is revoked. Article 14 Entry into force This Instruction enters into force 7 days after its publication.