NBFIRA Annual Financial Statements for the Year Ended 31 March 2025

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 General Information Country of domicile Botswana Nature of operations and principal activities Safeguard the fairness, stability and efficiency of the non-bank financial sector. Directors Mr. Thabo E. Gaadingwe (Chairperson) Ms. Patrinah P. Masalela (Ministry of Finance Representative) Dr. Lesedi S. Senatla (Bank of Botswana Representative) Ms. Hilda D. Hlanti (Board member) Mr Kgotso Gaamangwe (Board member) Ms. Tshegofatso B. Modise (Board member) Ms. Thobo Rrammidi (Board member) Ms. Lerang N. Maruping (Board member) (Appointed on 01-10-2024) Chief Executive Officer Mr. Oduetse Motshidisi Registered office 3rd Floor Exponential building Plot 54351 Central Business District Off PG Matante Gaborone Business address Plot 54351 Central Business District Off PG Matante Gaborone Botswana Bankers Stanbic Bank of Botswana Limited Auditors Forvis Mazars Certified Auditors Functional Currency Botswana Pula "BWP"

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Index The reports and statements set out below comprise the annual financial statements presented to the shareholder:
Page
Board Responsibilities and Approval of the Annual Financial Statements 3 Independent Auditor's Report 4 - 6 Statement of Profit or Loss and Other Comprehensive Income 7 Statement of Financial Position 8 Statement of Changes in Funds 9 Statement of Cash Flows 10 Accounting Policies 11 - 21 Notes to the Annual Financial Statements 22 - 36 The following supplementary information does not form part of the annual financial statements and is unaudited:
Detailed Income statement 37-38

Independent Auditor's Report
To the Members of Non-Bank Financial Institutions Regulatory Authority Opinion We have audited the annual financial statements of Non-Bank Financial Institutions Regulatory Authority set out on 7 to 36, which comprise the statement of financial position as at 31 March 2025, and the statement of profit or loss and other comprehensive income, statement of changes in funds and statement of cash flows for the year then ended, and notes to the annual financial statements, including a summary of significant accounting policies. In our opinion, the annual financial statements present fairly, in all material respects, the financial position of Non-Bank Financial Institutions Regulatory Authority as at 31 March 2025, and its financial performance and cash flows for the year then ended in accordance with IFRS Accounting standards as issued by the International Accounting Standard Board. Basis for Opinion We conducted our audit in accordance with International Standards on Auditing. Our responsibilities under those standards are further described in the Auditor's Responsibilities for the Audit of the Annual Financial Statements section of our report. We are independent of the Authority in accordance with the International Ethics Standards Board for Accountants Code of Ethics for Professional accountants (Parts A and B) (IESBA Code) and other independence requirements applicable to performing audits of Auditor's Responsibilities for the audit of financial statements in Botswana. We have fulfilled our other ethical responsibilities in accordance with the IESBA Code and in accordance with other ethical requirements applicable to performing audits in Botswana. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion. Key Audit Matters Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the annual financial statements of the current period. These matters were addressed in the context of our audit of the annual financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. Key audit matter How our audit addressed the key audit matter Recognition of Revenue Received The Authority receives Supervisory levies which are a significant portion of the total revenue received. For the year ended 31 March 2025 the supervisory levies constituted We have focused attention on this area as the Supervisory levies are significant combined with the different rates and basis applied for the nature of entities. Our audit procedures included the following:

• We reviewed the rates used as per the second schedule of
  the NBFIRA Supervisory Levies Regulations, 2023 and assessed whether these had been properly applied to the regulated entities.
• We performed recalculations on the sample of invoices
  based on the information provided by the regulatory division and verified that these have been accurately processed and recorded in the general ledger. Impairment of Trade receivables On 31 March 2025, the Authority had net trade receivables of The Authority applies a provisioning matrix as a practical expedient to determine the expected credit losses for trade receivables. Trade receivables have been assessed on a collective basis for all trade and other receivables in totality. Trade receivables are considered irrecoverable when the customer has not made any payment within 120 days,is in severe financial difficulty and there is no realistic prospect of Our audit procedures included in the following:
• We assessed the Authority's grouping assessment based
  on the credit profile.
• We assessed the authority's impairment model against the
  requirements of IFRS 9 Financial Instruments ('IFRS 9") -We tested, on the sample basis, the data utilised in the impairment model as at 31 March 2025, including ageing of debtor balances and debt recovery rates 88.97% of the total revenue received by the Authority. P 843,573 after recognising a total impairment allowance of P 2,466,256 on its statement of financial position. Plot 139, Gaborone International Finance Park, Gaborone, Botswana PO Box 401805, Gaborone, Botswana Tel: +267 395 7466 gbe.info@forvismazars.com forvismazars.com/bw

Independent Auditor's Report
Key audit matter How our audit addressed the key audit matter recovery or has entered in a bankrupcty proceedings. In determining the impairment,key judgements were applied by the Authority in selecting and applying an appropriate model and in determining the credit losses which are expected to be incurred once it is considered irrecoverable. Impairment of trade receivables was a matter of most significance to the current year audit due the significance of the trade receivable balance, as well as the judgements and estimates applied in determining an appropriate level of impairment is disclosed in:
Note 1: Accounting policy and Note 17:Trade and other receivables.
-We assessed the judgements to loss rates for forward looking macroeconomic factors through discussion with management and our knowledge of the operations and gained through our audit. In conclusion we considered the judgements applied on the valuations of the trade recievable applying the IFRS 9 model and related financial statments disclosures to appropriate. Other Information The directors are responsible for the other information. The other information comprises the Detailed income statement set out on page 37 to 38 which we obtained prior to the date of this report. Other information does not include the annual financial statements and our auditor's report theron. Our opinion on the annual financial statements does not cover the other information and we do not express an audit opinion or any form of assurance conclusion thereon. In connection with our audit of the annual financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the annual financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated. If, based on the work we have performed on the other information obtained prior to the date of this auditor's report. We conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report in this regard. Responsibilities of the Directors for the Annual Financial Statements The directors of the Authority are responsible for the preparation and fair presentation of the annual financial statements in accordance with IFRS Accounting standards as issued by the International Accounting Standard Board and for such internal control as the directors determine is necessary to enable the preparation of annual financial statements that are free from material misstatement, whether due to fraud or error. In preparing the annual financial statements, the directors are responsible for assessing the Authority’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the directors either intend to liquidate the Authority or to cease operations, or have no realistic alternative but to do so. Those charged with governance are responsible for overseeing the Authority's financial reporting processes.

Independent Auditor's Report
Auditor's Responsibilities for the Audit of the Annual Financial Statements Our objectives are to obtain reasonable assurance about whether the annual financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with International Standards on Auditing will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these annual financial statements. As part of an audit in accordance with International Standards on Auditing, we exercise professional judgement and maintain professional scepticism throughout the audit. We also:
 Identify and assess the risks of material misstatement of the annual financial statements, whether due to fraud or error, design and perform audit procedures responsive to those risks, and obtain audit evidence that is sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal controls.  Obtain an understanding of internal controls relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Authority's internal controls.  Evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates and related disclosures made by the directors.  Conclude on the appropriateness of the directors' use of the going concern basis of accounting and based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the Authority's ability to continue as a going concern. If we conclude that a material uncertainty exists, we are required to draw attention in our auditor's report to the related disclosures in the annual financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based on the audit evidence obtained up to the date of our auditor's report. However, future events or conditions may cause the Authority to cease to continue as a going concern.  Evaluate the overall presentation, structure and content of the annual financial statements, including the disclosures, and whether the annual financial statements represent the underlying transactions and events in a manner that achieves fair presentation. We communicate with the directors regarding, among other matters, the planned scope and timing of the audit and significant audit findings, including any significant deficiencies in internal control that we identify during our audit. Report on Other Legal and Regulatory Requirements As required by the Non-Bank-Financial Institutions Regulatory Act, 2023, we report to you based on our audit that:
 All the information and explanation which to the best of auditor's knowledge and belief, were necessary for the performance of the auditor's duties.  The records and related records of the Regulatory Authority have been properly kept.  The regulatory Authority has complied with the financial provisions of this Act which is its duty to comply with; and  The statement of accounts prepared by the Authority was prepared on a basis consistent with that of the preceeding year and represents a true and fair view of the transactions and the financial affairs of the regulatory Authority. __________________________________ Forvis Mazars Certified Auditors Practicing Member : Devika Rayirath Membership Number : CAP0037 2025 Date____________________________ Gaborone 17/09/2025

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Statement of Profit or Loss and Other Comprehensive Income Figures in Pula Note 2025 2024 Revenue Government grants 3 2,873,291 4,491,404 Amortisation of government grants 4 2,453,966 1,275,902 Other operating income 5 7,885,897 5,208,123 Supervisory levies 6 106,600,340 95,820,370 Total revenue 119,813,494 106,795,799 Other operating loss Loss on sale of assets (146,430) - Movement in credit loss allowances 7 (791,934) (1,573,172) Administrative expenses 8 (14,224,641) (14,900,844) Operating expenses 9 (18,248,010) (17,772,265) Consultancy cost 10 (2,043,698) (5,838,139) Staff costs 11 (77,153,568) (69,060,366) Total operating expenses (112,608,281)(109,144,786) Operating surplus/(deficit) 7,205,213 (2,348,987) Finance income 12 1,466,134 3,136,415 Finance costs 13 (376,224) (631,961) Total operating surplus for the year 8,295,123 155,467 Other comprehensive income:
Gains on property revaluation 521,931 -
Other comprehensive income for the year 521,931 - Total comprehensive income for the year 8,817,054 155,467

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Statement of Financial Position as at 31 March 2025 Figures in Pula Note 2025 2024 Assets Non-Current Assets Property, plant and equipment 14 19,332,730 17,152,557 Right-of-use assets 15 3,642,313 8,013,087 Intangible assets 16 346,435 489,787 23,321,478 25,655,431 Current Assets Trade and other receivables 17 3,689,575 3,739,764 Cash and cash equivalents 18 56,904,787 48,937,017 60,594,362 52,676,781 Total Assets 83,915,840 78,332,212 Funds and Liabilities Funds Reserves 12,325,347 8,978,765 Accumulated Surplus 41,163,566 35,693,094 53,488,913 44,671,859 Liabilities Non-Current Liabilities Lease liabilities 15 - 4,404,454 Government grants 19 11,305,662 11,309,141 11,305,662 15,713,595 Current Liabilities Trade and other payables 20 5,080,609 6,263,022 Lease liabilities 15 4,404,454 4,767,892 Employee benefits 21 7,618,513 4,461,877 Government grants 19 2,017,689 2,453,966 19,121,265 17,946,757 Total Liabilities 30,426,927 33,660,352 Total Funds and Liabilities 83,915,840 78,332,212

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Statement of Changes in Funds Figures in Pula Revaluation reserve Statutory reserve Total reserves Accumulated surplus Total Funds Balance at 01 April 2023 624,775 8,353,990 8,978,765 35,537,627 44,516,392 Surplus for the year - - - 155,467 155,467 Balance at 31 March 2024 624,775 8,353,990 8,978,765 35,693,094 44,671,859 Surplus for the year - - - 8,295,123 8,295,123 Other comprehensive income 521,931 - 521,931 - 521,931 Transfer between reserves - 2,824,651 2,824,651 (2,824,651) - Total changes recognised directly in statement of funds

• 2,824,651 2,824,651 (2,824,651) -
  Balance at 31 March 2025 1,146,706 11,178,641 12,325,347 41,163,566 53,488,913 Statutory Reserve
  Section 31 (1) of the Non-Bank Financial Institutions Regulatory Act, 2023 requires that an annual estimate not
  exceeding 10 percent (10%) of the total expenditure provided for in the estimates,be provided for as a reserve. The Statutory Reserve provided is adequate for the level of expenditure incurred. The purpose of the reserve is to be utilised for unforseen regulatory expenditure. The Regulatory Authority believes that based on the current budget,the statutory reserve is adequate and in compliance with Section 31 (1) of Non-Bank Financial Institutions Regulatory Act ,2023.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Statement of Cash Flows Figures in Pula Note 2025 2024 Cash flows from operating activities Cash generated from/(used in) operations 22 16,429,867 (1,860,050) Finance costs (376,224) (631,961) Net cash from operating activities 16,053,643 (2,492,011) Cash flows from investing activities Purchase of property, plant and equipment 14 (4,440,935) (9,578,678) Sale of property, plant and equipment 14 96,576 - Interest income 1,466,134 3,136,415 Net cash from investing activities (2,878,225) (6,442,263) Cash flows from financing activities Movement in government grants (439,756) 4,581,596 Payment on lease liabilities (4,767,892) (4,220,977) Net cash from financing activities (5,207,648) 360,619 Total cash movement for the year 7,967,770 (8,573,655) Cash at the beginning of the year 48,937,017 57,510,672 Total cash at end of the year 18 56,904,787 48,937,017

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025

1. Significant accounting policies
   The annual financial statements have been prepared in accordance with IFRS Accounting Standards as issued by the International Accounting Standards Board. The annual financial statements have been prepared on the historical cost basis (except for certain financial instruments measured at fair value) and incorporate the principal accounting policies set out below. They are presented in Pula . These accounting policies are consistent with the previous period.
   1.1 Statement of Compliance
   The annual financial statements have been prepared in accordance with the IFRS Accounting Standards as issued by the International Accounting Standards Board and the Non-Bank Financial Institutions Regulatory Act, 2023.
   1.2 Significant judgements and sources of estimation uncertainty
   The preparation of annual financial statements in conformity with the IFRS Accounting Standards as issued by the International Accounting Standard Board requires the use of certain critical accounting estimates and judgements concerning the future. Estimates and judgements are continually evaluated and are based on historical factors coupled with expectations about future events that are considered reasonable. In the process of applying the Authority's accounting policies, management has made the following estimates that have a significant risk of causing material adjustments to the carrying amounts of assets and liabilities within the next year. Key Areas of estimation and judgement The key assumption concerning the future and other key sources of estimation uncertainty and judgements at the reporting date,that have a significant risk of causing material adjustment to the carrying amounts of assets and liabilities within the next financial year as this involves assessments or decisions that are particularly complex or subjective, are discussed below:
   Depreciation charges and residual values
   For depreciation purposes, a significant component is defined as equal to or greater than 20% of total cost of the asset and each significant component with different useful lives is depreciated separately. The depreciation methods reflects the pattern in which economic benefits attributable to the assets flow to the entity. The useful lives of these assets can vary depending on a variety of factors, including but not limited to the technological obsolescence, maintenance programs, refurbishments, product life cycles and the intention of management. Residual values of assets are determined by estimating the amount that the entity would currently obtain from the disposal of the asset already of age and in the condition expected at the end of its useful life. The estimation of the useful life and residual values of an asset is a matter of judgement based on the past experience of the Authority with similar assets and the intention of management. Assessment of the asset condition and usefulness are key assumptions used to determine the assets' useful lives and residual values. Supervisory Levies Where supervisory levies are calculated on information that has not been audited, the Regulatory Authority assumes that estimates have been used and will place reliance on the information submitted by the regulated entities as a basis for calculation. Impairment testing The recoverable amounts of cash-generating units and individual assets have been determined based on the higher of value-in-use calculations and fair values less costs to sell. These calculations require the use of estimates and assumptions. It is reasonably possible that the assumption may change which may then impact our estimations and may then require a material adjustment to the carrying value of assets.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.2 Significant judgements and sources of estimation uncertainty (continued)
The entity reviews and tests the carrying value of assets when events or changes in circumstances suggest that the carrying amount may not be recoverable. Assets are grouped at the lowest level for which identifiable cash flows are largely independent of cash flows of other assets and liabilities. If there are indications that impairment may have occurred, estimates are prepared of expected future cash flows for each group of assets. Expected future cash flows used to determine the value in use of assets are inherently uncertain and could materially change over time. They are significantly affected by a number of factors including supply and demand, together with economic factors such as exchange rates, inflation and interest. Provisions Provisions were raised and management determined an estimate based on information available.
1.3 Property, plant and equipment
Property, Plant and Equipment is stated at cost, net of accumulated depreciation and / or accumulated impairment losses, if any. All plant and equipment are measured at historical cost less depreciation and impairment losses. Historical costs includes expenditure that is directly attributable to the acquisition of the items. Subsequent costs such as replacement parts and major inspections are included in the asset’s carrying amount or recognised as a separate asset, as appropriate, only when it is probable that future economic benefits associated with the item will flow to the Authority and the cost of the item can be measured reliably. All day-to-day repairs and maintenance are charged to the surplus or deficit during the financial period in which they are incurred. Motor vehicles is subsequently measured at revalued amount, being the fair value at the date of revaluation less any subsequent accumulated depreciation and subsequent accumulated impairment losses. Revaluations are made with sufficient regularity such that the carrying amount does not differ materially from that which would be determined using fair value at the end of the reporting year.The assets are revalued every 2-3 years. When an item of property, plant and equipment is revalued, the gross carrying amount is adjusted consistently with the revaluation of the carrying amount. The accumulated depreciation at that date is adjusted to equal the difference between the gross carrying amount and the carrying amount after taking into account accumulated impairment losses. When an item of property, plant and equipment is revalued, any accumulated depreciation at the date of the revaluation is eliminated against the gross carrying amount of the asset. Any increase in an asset’s carrying amount, as a result of a revaluation, is recognised in other comprehensive income and accumulated in the revaluation reserve in equity. The increase is recognised in profit or loss to the extent that it reverses a revaluation decrease of the same asset previously recognised in profit or loss. Any decrease in an asset’s carrying amount, as a result of a revaluation, is recognised in profit or loss in the current year. The decrease is recognised in other comprehensive income to the extent of any credit balance existing in the revaluation reserve in respect of that asset. The decrease recognised in other comprehensive income reduces the amount accumulated in the revaluation reserve in equity. The revaluation reserve related to a specific item of property, plant and equipment is transferred directly to retained income when the asset is derecognised. The revaluation reserve related to a specific item of property, plant and equipment is transferred directly to retained income as the asset is used. The amount transferred is equal to the difference between depreciation based on the revalued carrying amount and depreciation based on the original cost of the asset.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.3 Property, plant and equipment (continued)
Depreciation is charged so as to write off the cost of the assets over their estimated useful lives on a straight-line basis, to estimated residual values. Where significant parts of an item have different useful lives to the item itself, these parts are depreciated separately over their useful lives. The methods of depreciation, useful lives and residual values are reviewed annually, with the effect of any change in estimates accounted for prospectively. Depreciation is not charged to an asset if its estimated residual value exceeds or is equal to its carrying amount. Depreciation of an asset ceases at the earlier of the date that the asset is classified as held for sale or derecognised. The useful lives of items of property, plant and equipment have been assessed as follows:
Item Depreciation method Average useful life
Leasehold property Lease Term Lease Term
Furniture and fixtures Straight line 10 years
Motor vehicles Straight line 4-5 years
Office equipment Straight line 6-7 years
Computer equipment Straight line 3-7 years
An item of property, plant and equipment is derecognised upon disposal or when no future economic benefits are expected from its continued use or disposal. Any gain or loss arising from the derecognition of an item of property, plant and equipment, determined as the difference between the net disposal proceeds, if any, and the carrying amount of the item, is included in profit or loss when the item is derecognised. Capital work in progress Capital work in progress represents cost incurred to date on property,plant and equipment which is still under construction but not yet completed. For capital work in progress,no depreciation is recorded until the asset is placed in service. When the project is completed,the asset is reclassified as tangible asset and is capitalised and depreciated.
1.4 Intangible assets
An intangible asset is recognised when:
 it is probable that the expected future economic benefits that are attributable to the asset will flow to the entity; and  the cost of the asset can be measured reliably. Intangible assets are initially recognised at cost. The amortisation period and the amortisation method for intangible assets are reviewed every period-end. Amortisation is provided to write down the intangible assets, on a straight line basis, to their residual values as follows:
Item Average useful life
Risk Based Supervisory System (RBSS) 5 years
Enterprise Resource Planning (ERP) 5 years
Barn owl (Risk and Audit Management System) 5 years

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.5 Financial instruments
Financial instruments held by the Authority are classified in accordance with the provisions of IFRS 9 Financial Instruments. Broadly, the classification possibilities, which are adopted by the Authority, as applicable, are as follows:
Financial assets:
 Amortised cost.
Financial liabilities:
 Amortised cost.
Note 26 Financial instruments and risk management presents the financial instruments held by the Authority based on their specific classifications. All regular way purchases or sales of financial assets are recognised and derecognised on a trade date basis. Regular way purchases or sales are purchases or sales of financial assets that require delivery of assets within the time frame established by regulation or convention in the marketplace. The specific accounting policies for the classification, recognition and measurement of each type of financial instrument held by the Authority are presented below:
Trade and other receivables
Classification
Trade and other receivables, excluding, when applicable, VAT and prepayments, are classified as financial assets subsequently measured at amortised cost (Note 17). They have been classified in this manner because their contractual terms give rise, on specified dates to cash flows that are solely payments of principal and interest on the principal outstanding, and the Authority's business model is to collect the contractual cash flows on trade and other receivables. Recognition and measurement Trade and other receivables are recognised when the Authority becomes a party to the contractual provisions of the receivables. They are measured, at initial recognition, at fair value plus transaction costs, if any. They are subsequently measured at amortised cost. The amortised cost is the amount recognised on the receivable initially, minus principal repayments, plus cumulative amortisation (interest) using the effective interest method of any difference between the initial amount and the maturity amount, adjusted for any loss allowance. Impairment The Authority recognises a loss allowance for expected credit losses on trade and other receivables, excluding VAT and prepayments. The amount of expected credit losses is updated at each reporting date. The Authority measures the loss allowance for trade and other receivables at an amount equal to lifetime expected credit losses (lifetime ECL), which represents the expected credit losses that will result from all possible default events over the expected life of the receivable.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.5 Financial instruments (continued)
Measurement and recognition of expected credit losses The Authority makes use of a provision matrix as a practical expedient to the determination of expected credit losses on trade and other receivables. The provision matrix is based on historic credit loss experience, adjusted for factors that are specific to the debtors, general economic conditions and an assessment of both the current and forecast direction of conditions at the reporting date, including the time value of money, where appropriate. The customer base is widespread and does not show significantly different loss patterns for different customer segments. The loss allowance is calculated on a collective basis for all trade and other receivables in totality. Details of the provision matrix is presented in Note 17. An impairment gain or loss is recognised in profit or loss with a corresponding adjustment to the carrying amount of trade and other receivables, through use of a loss allowance account. The impairment loss is included in other operating expenses in profit or loss as a movement in credit loss allowance Note 17. Write off policy The Authority writes off a receivable when there is information indicating that the counterparty is in severe financial difficulty and there is no realistic prospect of recovery, e.g. when the counterparty has been placed under liquidation or has entered into bankruptcy proceedings. Receivables written off may still be subject to enforcement activities under the Authority recovery procedures, taking into account legal advice where appropriate. Any recoveries made are recognised in profit or loss. Credit risk Details of credit risk are included in the trade and other receivables note (Note 17) and the financial instruments and risk management note (Note 26). Derecognition Refer to the derecognition section of the accounting policy for the policies and processes related to derecognition. Any gains or losses arising on the derecognition of trade and other receivables is included in profit or loss in the derecognition gains (losses) on financial assets at amortised cost line item. Trade and other payables Classification Trade and other payables (Note 20), excluding VAT and amounts received in advance, are classified as financial liabilities subsequently measured at amortised cost. Recognition and measurement They are recognised when the Authority becomes a party to the contractual provisions, and are measured, at initial recognition, at fair value plus transaction costs, if any. They are subsequently measured at amortised cost using the effective interest method. The effective interest method is a method of calculating the amortised cost of a financial liability and of allocating interest expense over the relevant period. The effective interest rate is the rate that exactly discounts estimated future cash payments (including all fees and points paid or received that form an integral part of the effective interest rate, transaction costs and other premiums
or discounts) through the expected life of the financial liability, or (where appropriate) a shorter period, to the amortised cost of a financial liability.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.5 Financial instruments (continued)
Trade and other payables expose the Authority to liquidity risk and possibly to interest rate risk. Refer to Note 26 for details of risk exposure and management thereof. Derecognition Refer to the "derecognition" section of the accounting policy for the policies and processes related to derecognition. Cash and cash equivalents For the purpose of the cash flow statement, cash and cash equivalents consist of cash, cash deposits on call and short-term fixed deposit accounts in banks. Cash and cash equivalents are subsequently carried at amortised cost. Due to the short-term nature of these, the amortised cost approximates its fair value. The Authority’s financial assets include cash and cash equivalents and trade and other receivables. Derecognition Financial assets The Authority derecognises a financial asset only when the contractual rights to the cash flows from the asset expire, or when it transfers the financial asset and substantially all the risks and rewards of ownership of the asset to another party. If the Authority neither transfers nor retains substantially all the risks and rewards of ownership and continues to control the transferred asset, the Authority recognises its retained interest in the asset and an associated liability for amounts it may have to pay. If the Authority retains substantially all the risks and rewards of ownership of a transferred financial asset, the Authority continues to recognise the financial asset and also recognises a collateralised borrowing for the proceeds received. Financial liabilities The Authority derecognises financial liabilities when, and only when, the Authority obligations are discharged, cancelled or they expire. The difference between the carrying amount of the financial liability derecognised and the consideration paid and payable, including any non-cash assets transferred or liabilities assumed, is recognised in profit or loss.
1.6 Leases
The Authority assesses whether a contract is, or contains a lease, at the inception of the contract. A contract is, or contains a lease if the contract conveys the right to control the use of an identified asset for a period of time in exchange for consideration. In order to assess whether a contract is, or contains a lease, management determine whether the asset under consideration is "identified", which means that the asset is either explicitly or implicitly specified in the contract and that the supplier does not have a substantial right of substitution throughout the period of use. Once management has concluded that the contract deals with an identified asset, the right to control the use thereof is considered. To this end, control over the use of an identified asset only exists when the Authority has the right to substantially all of the economic benefits from the use of the asset as well as the right to direct the use of the asset. In circumstances where the determination of whether the contract is or contains a lease requires significant judgement, the relevant disclosures are provided in the significant judgments and sources of estimation uncertainty
section of these accounting policies.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.6 Leases (continued)
Authority as lessee
A lease liability and corresponding right-of-use asset are recognised at the lease commencement date, for all lease agreements for which the Authority is a lessee, except for short-term leases of 12 months or less, or leases of low value assets. For these leases, the Authority recognises the lease payments as an operating expense on a straight-line basis over the term of the lease unless another systematic basis is more representative of the time pattern in which economic benefits from the leased asset are consumed. The various lease and non-lease components of contracts containing leases are accounted for separately, with consideration being allocated to each lease component on the basis of the relative stand-alone prices of the lease components and the aggregate stand-alone price of the non-lease components (where non-lease components exist). However as an exception to the preceding paragraph, the Authority has elected not to separate the non-lease components for leases of land and buildings. Details of leasing arrangements where the Authority is a lessee are presented in Note 15 Leases (Authority as lessee). Lease liability The lease liability is initially measured at the present value of the lease payments that are not paid at the commencement date, discounted by using the rate implicit in the lease. If this rate cannot be readily determined, the Authority uses its incremental borrowing rate. Lease payments included in the measurement of the lease liability comprise the following:
 fixed lease payments, including in-substance fixed payments, less any lease incentives;  variable lease payments that depend on an index or rate, initially measured using the index or rate at the commencement date;  the amount expected to be payable by the Authority under residual value guarantees;  the exercise price of purchase options, if the Authority is reasonably certain to exercise the option;  lease payments in an optional renewal period if the Authority is reasonably certain to exercise an extension option; and  penalties for early termination of a lease, if the lease term reflects the exercise of an option to terminate the lease. Variable rents that do not depend on an index or rate are not included in the measurement of the lease liability (or right-of-use asset). The related payments are recognised as an expense in the period incurred and are included in operating expenses (Note 15). The lease liability is presented as a separate line item on the Statement of Financial Position. The lease liability is subsequently measured by increasing the carrying amount to reflect interest on the lease liability (using the effective interest method) and by reducing the carrying amount to reflect lease payments made. Interest charged on the lease liability is included in finance costs (Note 13). The Authority remeasures the lease liability (and makes a corresponding adjustment to the related right-of-use asset) when:
 there has been a change to the lease term, in which case the lease liability is remeasured by discounting the revised lease payments using a revised discount rate;  there has been a change in the assessment of whether the Authority will exercise a purchase, termination or extension option, in which case the lease liability is remeasured by discounting the revised lease payments using a revised discount rate;

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.6 Leases (continued)
 there has been a change to the lease payments due to a change in an index or a rate, in which case the lease liability is remeasured by discounting the revised lease payments using the initial discount rate (unless the lease payments change is due to a change in a floating interest rate, in which case a revised discount rate is used);  there has been a change in expected payment under a residual value guarantee, in which case the lease liability is remeasured by discounting the revised lease payments using the initial discount rate;  a lease contract has been modified and the lease modification is not accounted for as a separate lease, in which case the lease liability is remeasured by discounting the revised payments using a revised discount rate. When the lease liability is remeasured in this way, a corresponding adjustment is made to the carrying amount of the right-of-use asset, or is recognised in profit or loss if the carrying amount of the right-of-use asset has been reduced to zero. Right-of-use assets Right-of-use assets are presented as a separate line item on the Statement of Financial Position. Lease payments included in the measurement of the lease liability comprise the following:
 the initial amount of the corresponding lease liability;  any lease payments made at or before the commencement date;  any initial direct costs incurred;  any estimated costs to dismantle and remove the underlying asset or to restore the underlying asset or the site on which it is located, when the Authority incurs an obligation to do so, unless these costs are incurred to produce inventories; and  less any lease incentives received. Right-of-use assets are subsequently measured at cost less accumulated depreciation and impairment losses. Right-of-use assets are depreciated over the shorter period of lease term and useful life of the underlying asset. However, if a lease transfers ownership of the underlying asset or the cost of the right-of-use asset reflects that the authority expects to exercise a purchase option, the related right-of-use asset is depreciated over the useful life of the underlying asset. Depreciation starts at the commencement date of a lease. For right-of-use assets which are depreciated over their useful lives, the useful lives are determined consistently with items of the same class of property, plant and equipment. Refer to the accounting policy for property, plant and equipment for details of useful lives. The residual value, useful life and depreciation method of each asset are reviewed at the end of each reporting year. If the expectations differ from previous estimates, the change is accounted for prospectively as a change in accounting estimate. Each part of a right-of-use asset with a cost that is significant in relation to the total cost of the asset is depreciated separately. The depreciation charge for each year is recognised in profit or loss unless it is included in the carrying amount of another asset.
1.7 Employee benefits
Pension
The Regulatory Authority operates a defined contribution scheme for the employees. Payments to the scheme are charged as an expense to the statement of comprehensive income as they fall due.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.7 Employee benefits (continued)
Gratuity
The Regulatory Authority provides for gratuity benefits for employees on fixed term contracts in line with the Employment Act Chapter 47:01 and the relevant employment contracts. Gratuity expenses are recognised immediately, to the extent that the benefits are amortised on a straight-line basis over the period of service, until the benefits become payable. The charge is made to expenses in the statement of comprehensive income and a separate provision in the statement of financial position. Leave pay provision The Regulatory Authority recognises, in full, employee’s right to annual leave entitlement in respect of past service. The recognition is made each year and is calculated based on accrued leave days not taken during the year. The charge is made to expenses in the statement of comprehensive income and a separate provision in the statement of financial position.
1.8 Provisions
Provisions are recognised when the Authority has a present legal or constructive obligation as a result of past events, it is probable that an outflow of resources will be required to settle the obligation; and a reliable estimate of the amount can be made.Provisions are measured at the directors’ best estimate of expenditure required to settle the obligation at the reporting date, and are discounted to present value where the effect of the time value of money is material.
1.9 Government grants
Government grants are recognised when there is reasonable assurance that:
 the Authority will comply with the conditions attaching to them; and  the grants will be received. Government grants are recognised as income over the periods necessary to match them with the related costs that they are intended to compensate. A government grant that becomes receivable as compensation for expenses or losses already incurred or for the purpose of giving immediate financial support to the entity with no future related costs is recognised as income of the period in which it becomes receivable. Government grants related to assets, including non-monetary grants at fair value, are presented in the statement of financial position by setting up the grant as deferred income or by deducting the grant in arriving at the carrying amount of the asset. Grants relating to the acquisition of property, plant and equipment are credited to the income statement on a straight line basis over the expected useful lives of the related assets. The related costs are shown at cost less accumulated depreciation. When an asset financed through grants is disposed of, the total unamortised portion of the grant relating to the asset is recognised in profit and loss in the year of disposal.
1.10 Borrowing costs
Borrowing costs directly attributable to the acquisition, construction or production of an asset that necessarily takes a substantial period of time to get ready for its intended use or sale are capitalised as part of the cost of the respective assets. All other borrowing costs are expensed in the period they occur. Borrowing costs consist of interest and other costs that an entity incurs in connection with the borrowing of funds. The Regulatory Authority had no eligible assets or borrowing costs for the period reported.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025
1.11 Translation of foreign currencies
Foreign currency transactions
Transactions in foreign currencies are initially recorded at the functional currency rate ruling at the date of the transaction. Monetary assets and liabilities denominated in foreign currencies are retranslated at the functional currency rate of exchange ruling at the reporting date. Non-monetary items that are measured in terms of historical cost in a foreign currency are translated using the exchange rates as at the dates of the initial transactions. Foreign exchange translation gains or losses arising on the settlement of monetary items or on translating monetary items at rates different from those used when translating at initial recognition during the period or in the financial statements are taken to the statement of comprehensive income in the period they arise.
1.12 Impairment of non-financial assets
At each financial reporting date, the Authority reviews the carrying amount of its tangible assets to determine whether there is any indication that those assets have suffered an impairment loss. If any such indications exist, the recoverable amount of the asset is estimated in order to determine the extent of the impairment loss (if any). Where it is not possible to estimate the recoverable amount of an individual asset, the Authority estimates the recoverable amount of the cash generating section to which the asset belongs. Recoverable amount is the higher of fair value less costs to sell and value in use. In assessing value in use, the estimated future cash flows are discounted to their present value using a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the asset. If the recoverable amount of an asset (or cash-generating section) is estimated to be less than its carrying amount, its carrying amount is reduced to its recoverable amount. Impairment losses are recognised in the surplus or deficit in those categories consistent with the function of the impaired asset. Where an impairment loss subsequently reverses, the carrying amount of the asset (cash-generating-section) is increased to the revised estimate of its recoverable amount. This is done so that the increased carrying amount does not exceed the carrying amount that would have been determined had no impairment loss been recognised in the prior years. A reversal of an impairment loss is recognised in the surplus or deficit.
1.13 Revenue from regulated entities
The Authority recognises revenue from the following major sources:
 Supervisory levies
 License fees
 Penalties and interest
 Finance income
 Government Grant
Revenue is measured based on the consideration specified in a contract with a customer and excludes amounts collected on behalf of third parties. The Authority recognises revenue when it transfers control of a product or service to a customer. The Supervisory levies The supervisory levies and licence fees were promulgated into law through Statutory Instrument No.55 of 2023 of the Republic of Botswana, which was published in the Government Gazette of the 16th June 2023. Supervisory levies are charged and are payable in two equal portions, on or before the 30th April and 31st October of each financial year. Registered non-bank financial institutions are required to pay levies on an annual basis in terms of the Non-Bank Financial Institutions Regulatory Authority Act, 2023. Supervisory levies are recognised at point in time. The Regulatory Authority may, on application, waive payment of some or all of a supervisory levy, penalty levy or a fee.The levies are fixed in nature and there are no separate performance obligations identified.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 License fees License fees are recognised on licensing of the relevant supervised entities and are recognised at the point in time. Some classes of regulated entities are charged annual licence fees, such fees are recognised by the Authority as revenue. Penalties and interest Penalties and interest are recognised in the surplus or deficit on penalizing those regulated entities that have defaulted in meeting the necessary regulatory guidelines. Finance income Revenue is recognised as interest accrues (using the effective interest method). Finance income is recognised in the surplus or deficit. Government Grant Government grants are recognised where there is reasonable assurance that the grant will be received and all attached conditions will be complied with. When the grant relates to an expense item, it is recognised as income over the period necessary to match the grant on a systematic basis to the costs that it is intended to compensate. Where the grant relates to the purchase of an asset, it is recognised as capital grant in the statement of financial position and released to the statement of comprehensive income in equal amounts over the expected useful life of the related asset.Where the Authority receives a nonmonetary grant, the asset and the grant are recorded at nominal amounts and released to the total surplus or deficit over the expected useful life of the relevant asset by equal annual installments.
1.14 Related Parties
Related parties are considered to be related if one party has the ability to control or jointly control the other parties or exercise significant influence over the other party in making financial and other operating decisions. Key management personnel are also regarded as related parties. Key Management personnel are those having authority and responsibility for planning, directly and controlling the activities of the entity, directly or indirectly including all executive and non executive directors. NBFIRA was established through an Act of Parliament enacted by the Government of Botswana. Related party transactions are those where a transfer of resources or obligations between related parties occur, regardless of whether or not a price is charged.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
2. New Standards and Interpretations
2.1 Standards and interpretations not yet effective
The Authority has chosen not to early adopt the following standards and interpretations, which have been published and are mandatory for the Authority’s accounting periods beginning on or after 01 April 2025 or later periods:
 IFRS 7 Financial Instruments: Disclosure 01 April 2025 Unlikely there will be a material impact  IAS 7 Statement of Cash Flows 01 April 2025 Unlikely there will be a material impact  Classification of Liabilities as Current or Non-Current - Amendment to IAS 1 01 April 2025 Unlikely there will be a material impact  Interest Rate Benchmark Reform - Phase 2:
Amendments to IFRS 7
01 April 2025 Unlikely there will be a material impact  Interest Rate Benchmark Reform - Phase 2:
Amendments to IFRS 16
01 April 2025 Unlikely there will be a material impact  IFRS 9 Financial Instruments 01 April 2025 Unlikely there will be a material impact  Amendments to IAS 7: Disclosure initiative 01 April 2025 Unlikely there will be a material impact IAS 21 The Effect of Changes in Foreign Exchange Rates Amendment: Lack of Exchangeability  Currency exchangeability explained.  Requirement to estimate currency that is not exchangeable by using either an observable exchange rate without adjustment or using another estimation technique.  Additional disclosures are required when an exchange rate requires estimation. The effective date of the standard is for years beginning on or after 01 January 2025. It is unlikely that the standard will have a material impact on the Authority's annual financial statements.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
3. Government Grants
Revenue grants 2,873,291 4,491,404
The total grant received from the government are as follows:
Revenue grants 2,873,291 4,491,404
Capital grants 2,014,209 4,581,596
4,887,500 9,073,000
4. Amortisation of government grants
Amortisation of property, plant and equipment 2,453,966 1,275,902
5. Other operating income
Interest and penalties, registration and renewals 6,721,146 3,760,950 Other income 1,164,751 1,447,173 7,885,897 5,208,123
6. Supervisory levies
Supervisory levies-Capital Markets 169,488 169,488 Supervisory levies-Insurance 18,087,205 16,794,929 Supervisory levies-Retirement fund and investment institutions 27,132,541 24,988,533 Supervisory levies-Medical Aid 3,204,445 3,115,125 Supervisory levies-Non-Bank lending activities 58,006,661 50,752,295 106,600,340 95,820,370
7. Movement in credit loss allowance
Trade and other receivables 791,934 1,573,172
8. Administrative expenses
Advertising 482,168 427,323
Audit fees 129,960 124,545
Administrative expenses 185,364 188,955
Bank charges 50,582 64,120
Depreciation 6,910,465 6,027,101
Amortization of Barn Owl 143,352 143,352
Insurance 1,000,298 836,123
Motor vehicle expenses 38,652 46,302
Office expenses 353,564 306,611
Printing and Stationery 623,346 622,595
Recruitment 249,857 702,679
Telephone and Fax 1,116,698 1,085,556
Travel 1,183,503 2,834,233
Staff costs 700,470 620,849
Utilities 900,364 819,541
Exchange rate Variance loss 155,998 50,959
14,224,641 14,900,844

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
9. Operating expenses
Board costs 2,089,830 1,350,562
Branding and communications 1,913,866 864,796
Cleaning 345,215 316,125
Internet 1,247,967 1,126,301
Legal fees 857,698 2,865,673
Repairs and maintenance 523,708 584,458
License fees 7,740,752 6,028,408
Security 284,482 199,670
Subscriptions 1,510,500 948,418
Training 1,733,993 3,487,854
18,248,011 17,772,265
10. Consultancy costs
Other consultancy cost 1,897,271 5,615,966
Inspection 146,426 222,173
2,043,697 5,838,139
11. Staff costs
Staff costs
Basic salaries 40,439,215 37,257,857
Allowances 28,743,117 23,894,846
Defined contribution plan expenses 7,971,236 7,907,663 77,153,568 69,060,366
12. Finance income
Interest income
Investments in financial assets:
Bank 1,466,134 3,136,415
13. Finance costs
Interest expense for leasing arrangements 376,224 631,961
14. Property, plant and equipment
2025 2024
Cost Accumulated depreciation
Carrying value
Cost Accumulated depreciation
Carrying value
Furniture and fixtures 15,434,385 (4,707,968) 10,726,417 10,928,246 (4,197,857) 6,730,389 Motor vehicles 2,022,396 (56,177) 1,966,219 1,353,314 (194,718) 1,158,596 Office equipment 630,766 (262,014) 368,752 537,105 (319,630) 217,475 IT equipment 10,346,476 (4,849,194) 5,497,282 10,913,487 (5,304,946) 5,608,541 Leasehold improvements 125,714 (125,714) - 125,714 (125,714) - Capital - Work in progress 774,060 - 774,060 3,437,556 - 3,437,556 Total 29,333,797 (10,001,067) 19,332,730 27,295,422 (10,142,865) 17,152,557

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
14. Property, plant and equipment (continued)
Reconciliation of property, plant and equipment - 2025 Opening balance Additions Disposals Transfers RevaluationsDepreciation Total Furniture and fixtures 6,730,389 - (51,682) 5,090,221 - (1,042,511) 10,726,417 Motor vehicles 1,158,596 655,530 - - 521,932 (369,840) 1,966,219 Office equipment 217,475 - - 212,166 - (60,889) 368,752 IT equipment 5,608,541 1,146,514 (191,324) - - (1,066,450) 5,497,282 Capital - Work in progress 3,437,556 2,638,891 - (5,302,387) - - 774,060 17,152,557 4,440,935 (243,006) - 521,932 (2,539,690) 19,332,730 Reconciliation of property, plant and equipment - 2024 Opening balance Additions Transfers Depreciation Total Furniture and fixtures 994,827 - 6,339,545 (603,983) 6,730,389 Motor vehicles 297,971 956,019 - (95,394) 1,158,596 Office equipment 151,246 100,480 - (34,251) 217,475 IT equipment 4,329,141 2,202,098 - (922,698) 5,608,541 Capital - Work in progress 3,457,020 6,320,081 (6,339,545) - 3,437,556 9,230,205 9,578,678 - (1,656,326) 17,152,557

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
14. Property, plant and equipment (continued)
Revaluations
The Authority's motor vehicles are stated at revalued amounts, being the fair value at the date of revaluation, less any subsequent accumulated depreciation and accumulated impairment losses. Revaluations are performed every 3 years and in intervening years if the carrying amount of the asset differs materially from their fair value. The effective date of the revaluation was 31 March 2025. Revaluations were performed by an independent valuer Julesh motor vehicle consultants who are not connected to the Authority and have recent experience in the vehicles being valued. The carrying value of the revalued assets under the cost model would have been:
Motor vehicles 1 1
Other information
Fully depreciated property, plant and equipment still in use 1,261,232 2,155,847
15. Right-of-use assets
Net carrying amounts of right-of-use assets
The carrying amounts of right-of-use assets are included in the following line items:
Buildings 3,642,313 8,013,087
Additions to right-of-use assets
Depreciation recognised on right-of-use assets Depreciation recognised on each class of right-of-use assets, is presented below. It includes depreciation which has been expensed in the total depreciation charge in profit or loss, as well as depreciation which has been capitalised to the cost of other assets. Buildings 4,370,775 4,370,775 Other disclosures Interest expense on lease liabilities 376,224 631,961 Total cash outflow from leases (5,144,115) (4,852,938) (4,767,891) (4,220,977) Lease liabilities The maturity analysis of lease liabilities is as follows:
Within one year 4,498,979 5,144,115
Two to five years - 4,498,979
4,498,979 9,643,094
Less finance charges component (94,525) (470,748) 4,404,454 9,172,346

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
15. Right-of-use assets (continued)
Non-current liabilities - 4,404,454
Current liabilities 4,404,454 4,767,892
4,404,454 9,172,346
The table below describes the nature of the Authority's leasing activities by type of right of use asset recognised on statement of financial position. There were no leases with variable payments linked to an index and termination option. Right of use assets No of right of use assets leased Range of remaining term (months) Average remaining lease term (months) No of leases with extension options No of leases with option to purchase Building 2 22 22 1 -
16. Intangible assets
2025 2024
Cost /
Valuation
Accumulated amortisation
Carrying value
Cost /
Valuation
Accumulated amortisation
Carrying value
Barn Owl 716,761 (370,326) 346,435 716,761 (226,974) 489,787 Reconciliation of intangible assets - 2025 Opening balance Amortisation Total Barn Owl 489,787 (143,352) 346,435 Reconciliation of intangible assets - 2024 Opening balance Amortisation Total Barn Owl 633,139 (143,352) 489,787
17. Trade and other receivables
Financial instruments:
Trade receivables 3,309,829 3,202,586
Loss allowance (2,466,256) (2,783,105)
Trade receivables at amortised cost 843,573 419,481 Deposits 320,764 320,764 Employees salary advance 5,667 6,667 Non-financial instruments:
BURS Other withholding taxes - 6,268
Prepayments 2,519,571 2,986,584
Total trade and other receivables 3,689,575 3,739,764 Split between non-current and current portions Current assets 3,689,575 3,739,764

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
17. Trade and other receivables (continued)
Financial instrument and non-financial instrument components of trade and other receivables At amortised cost 1,170,004 746,912 Non-financial instruments 2,519,571 2,992,852 3,689,575 3,739,764 Exposure to credit risk Trade receivables inherently expose the Authority to credit risk, being the risk that the Authority will incur financial loss if customers fail to make payments as they fall due. In order to mitigate the risk of financial loss from defaults, the authority only deals with reputable customers with consistent payment histories. Sufficient collateral or guarantees are also obtained when appropriate. Each customer is analysed individually for creditworthiness before terms and conditions are offered. Statistical credit scoring models are used to analyse customers. These models make use of information submitted by the customers as well as external bureau data (where available). Customer credit limits are in place and are reviewed and approved by credit management committees. The exposure to credit risk and the creditworthiness of customers, is continuously monitored. There have been no significant changes in the credit risk management policies and processes since the prior reporting period. Trade receivables arise from supervisory levies. The customer base is large and widespread, with a result that there is no specific significant concentration of credit risk from these trade receivables. A loss allowance is recognised for all trade receivables, in accordance with IFRS 9 Financial Instruments, and is monitored at the end of each reporting period. In addition to the loss allowance, trade receivables are written off when there is no reasonable expectation of recovery, for example, when a debtor has been placed under liquidation. Trade receivables which have been written off are not subject to enforcement activities. The authority measures the loss allowance for trade receivables by applying the simplified approach which is prescribed by IFRS 9. In accordance with this approach, the loss allowance on trade receivables is determined as the lifetime expected credit losses on trade receivables. These lifetime expected credit losses are estimated using a provision matrix, which is presented below. The provision matrix has been developed by making use of past default experience of debtors but also incorporates forward looking information and general economic conditions of the industry as at the reporting date. The authority's historical credit loss experience does not show significantly different loss patterns for different customer segments. The provision for credit losses is therefore based on past due status without disaggregating into further risk profiles. The loss allowance provision is determined as follows:

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
17. Trade and other receivables (continued)
2025 2025 2024 2024
Expected credit loss rate:
Estimated gross carrying amount at default
Loss allowance
(Lifetime expected credit loss)
Estimated gross carrying amount at default
Loss allowance
(Lifetime expected credit loss)
Not past due: 0.00%( 2024: 0.007%) 147,532 - 255,025 (208) Less than 30 days past due: 0.0041% (2024:0.347%) 50,524 (10,293) 343 - 31 - 60 days past due: 0% ( 2024:0.118%) 7,362 (2,922) - - 61 - 90 days past due: 18.626% (2024: 28.010%) 766,490 (459,055) 943,884 (779,563) More than 90 days past due: 80.907% (2024:71.981%) 2,337,922 (1,993,986) 2,003,334 (2,003,334) Total 3,309,830 (2,466,256) 3,202,586 (2,783,105) Reconciliation of loss allowances The following table shows the movement in the loss allowance (lifetime expected credit losses) for trade receivables:
Opening balance (2,783,105) (2,334,039)
Recoveries during the year 630,970 615,172
Writeoff 477,813 508,934
Provision raised on new trade receivables (791,934) (1,573,172) Closing balance (2,466,256) (2,783,105) Fair value of trade and other receivables The fair value of trade and other receivables approximates their carrying amounts.
18. Cash and cash equivalents
Cash and cash equivalents consist of:
Cash on hand 2,761 1,644
Bank balances 56,902,026 48,935,373
56,904,787 48,937,017
The cash and cash equivalents are earning interest at the floating rate based on a daily bank deposit rates. The Regulatory Authority has maintained separate gratuity account to ring-fence the post employment benefits relating to gratuity. Credit quality of cash at bank excluding cash on hand The credit quality of cash at bank, excluding cash on hand that are neither past due nor impaired can be assessed by reference to historical information about counterparty default rates. Commercial Banks in Botswana are not rated, however, these financial institutions are subsidiaries of rated banks in South Africa.

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
19. Government grants
Opening balance 13,763,108 10,457,414
Received during the year 2,014,209 3,258,596
Amortisation of government grants (2,453,966) (1,275,902) Deferred subvention received -EDRMS - 1,323,000 13,323,351 13,763,108
20. Trade and other payables
Financial instruments:
Trade payables 4,277,516 5,613,109
Other payables 803,093 649,913
5,080,609 6,263,022
Fair value of trade and other payables
The fair value of trade and other payables approximates their carrying amounts.
21. Employee benefits
Reconciliation of employee benefits - 2025
Opening balance
Additions Utilised during the year
Total
Gratuity accruals 2,118,284 2,668,834 (475,534) 4,311,585 Leave accruals 2,343,593 1,432,053 (468,719) 3,306,928 4,461,877 4,100,887 (944,253) 7,618,513 Reconciliation of employee benefits - 2024 Opening balance Additions Utilised during the year Total Gratuity accruals 783,372 1,334,912 - 2,118,284 Leave accruals 4,599,159 987,922 (3,243,488) 2,343,593 5,382,531 2,322,834 (3,243,488) 4,461,877

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
22. Cash generated from/(used in) operations
Surplus before taxation 8,295,123 155,467
Adjustments for:
Depreciation and amortisation 7,053,817 6,170,453 Losses on disposals, scrappings and settlements of assets and liabilities 146,430 - Interest income (1,466,134) (3,136,415) Finance costs 376,224 631,961 Net Impairments and movements in credit loss allowances 791,934 1,573,172 Movements in short-term employee benefits 3,156,636 (920,654) Amortisation of government grants - (1,275,902) Changes in working capital:
Trade and other receivables (741,745) (2,943,395) Trade and other payables (1,182,418) (2,114,737) 16,429,867 (1,860,050)
23. Taxation
No provision for taxation is required as the Regulatory Authority is exempt from taxation in terms of the second
Schedule of the Income Tax Act (Chapter 52:01).
24. Changes in liabilities arising from financing activities
Reconciliation of liabilities arising from financing activities - 2025 Opening balance Finance costs New lease Total repayment including interest Total Finance lease liabilities 9,172,345 376,224 - (5,144,115) 4,404,454 Total 9,172,345 376,224 - (5,144,115) 4,404,454 Reconciliation of liabilities arising from financing activities - 2024 Opening balance Finance costs New lease Total repayment including interest Total Finance lease liabilities 13,393,323 631,961 - (4,852,939) 9,172,345 Total 13,393,323 631,961 - (4,852,939) 9,172,345

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
25. Related parties
`
Relationships
The Regulatory Authority was set up by the Non- bank Financial Institutions Regulatory Authority Act 2023 and is therefore related to the Government of the Republic of Botswana. Transactions with related parties are in the normal course of business. The following transaction were carried out with related parties. Members of key management Ms Ghadie Seromelo (Chief Internal Audit Executive) Dr Kelesego Mmoilanyane (Head of Financial Stability and Statistics) Ms Gakepeo Masike (Head of Strategy) (Deceased on December 2024) Ms Ditshetsa Makepe ( Head of Enforcement) Mr Ronald Kgafela ( Head of Human Resources) (Appointed on February 2025) Mr Monkgogi Rampha ( Head of Data Management) Ms Ntema Modongo ( Director Lending Activities) Ms Juliana White( Director Capital Markets) Ms Matlakala Raphaka ( Director Insurance) Ms Boa Ntebele ( Head of Communications and Consumer Affairs) Mr. Mbiganyi Modise ( Head of Risk & Quality Assurance) Mr Oduetse Motshidisi ( Chief Executive Officer) Ms Catherine Monageng ( Head of Finance) Dr. Jonathan Thuto Mahlanza ( Director Retirement Funds) Mr Ogona Tshoswane ( Head of Licensing) Mr. Mooketsi Ramanteba ( Director AML/CFT) Mr. Cowell Habana ( Deputy CEO-Professional Services) Mr. Kaelo Radira ( Board Secretary, Legal and International Relations) Mr. Moji Bale ( Head of Information Technology) Mr. Keabetswe Mathake ( Head of Procurement & Administration) Mr. Dumedisang Dumedisang ( Head of Human Resources) (Retired on April 2024)

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024
25. Related parties (continued)
Related party transactions
Grant received
Government of Republic of Botswana 4,887,500 9,073,000 Board Costs Board allowances and other costs 2,089,830 1,350,562 Compensation to directors and other key management Short-term employee benefits 18,786,687 17,143,431 Gratuity and pension benefits 4,172,508 3,289,072 Other benefits 2,180,898 1,959,638 25,140,093 22,392,141 Compensation paid to key personnel of the Authority. The amounts presented comprise 20 executive staff members (2024:20 executive staff members). Categories of financial instruments Categories of financial assets Note(s) Amortised cost Non financial instruments Total Fair value Trade and other receivables 17 1,170,004 2,519,571 3,689,575 1,170,004 Cash and cash equivalents 18 56,904,787 - 56,904,787 56,904,787 58,074,791 2,519,571 60,594,362 58,074,791 Note(s) Amortised cost Total Fair value Trade and other receivables 17 3,739,764 Cash and cash equivalents 18 48,941,671 52,681,435 Categories of financial liabilities Note(s) Amortised cost Total Fair value Trade and other payables 20 5,080,605 Lease liabilities 15 - - 4,404,454 5,080,605
26. Financial instruments and risk management

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024 Note(s) Amortised cost Leases Total Fair value Trade and other payables 20 6,263,022 - 6,263,022 6,263,022 Lease liabilities 15 - 9,172,346 6,263,022 9,172,346 15,435,368 15,435,368 Risk management Capital includes all funds and reserves as per the face of the statement of financial position. The Authority's objective when managing funds are to safeguard its ability to continue as a going concern in order to perform the mandate for which it was created for. Management is of the view that these objectives are being met. During 2025, the Authority did not have borrowings.The Regulatory Authority is supported by the licensed Non-Bank Financial Institutions and the Government of the Republic of Botswana, currently the necessary support is provided to sustain the operations of the Regulatory Authority. The NBFIRA Act stipulates that an annual estimate of the Regulatory Authority's expenditure for a financial year shall include provision for a Statutory Reserve of not more than 10% of the total expenditure provided in the estimate. Based on the regulatory Authority Act the current statutory reserve is adequate and in line with the provisions of the Act. Financial risk management Credit risk The Regulatory Authority has exposure to credit risk, which is the risk that a counterparty will be unable to pay amounts in full when due. Credit risk is the risk that the regulated and supervised Non-Bank Financial Institutions and other counter parties will not be able or willing to pay or fulfil their obligations in accordance with Non-Bank Financial Institutions Regulatory Authority Act. The Authority uses reputable financial institutions for investing purposes. All cash and cash equivalents are placed with financial institutions registered in Botswana. The maximum exposure to credit risk is represented by the carrying amount of accounts receivable and cash and cash equivalents, as shown in the statement of financial position. Concentration of credit The Regulatory Authority is currently funded by the Government of Botswana and the regulated entities through Supervisory Levies and License Fees. The Regulatory Authority's credit risk is primarily attributable to its cash and cash equivalents, and receivable from regulated entities. Financial assets that potentially subject the Board to concentration of credit risk consists primarily of cash and cash equivalent as well as accounts receivable. Cash and cash equivalents are placed with reputable financial institutions in the normal trading course. Expenditure and controls have been put in place to manage credit risk. The Regulatory Authority has no significant concentration of credit risk as its exposure is spread over a number of counterparties. The Regulatory Authority does not have any significant credit risk exposure to any single counterparty. As at year end there was no
significant credit risk, the cash position as at year end was P 56,904,787 (2024: P48,937,017)
26. Financial instruments and risk management (continued)

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024 2025 2024 Gross carrying amount Credit loss allowance Amortised cost / fair value Gross carrying amount Credit loss allowance Amortised cost / fair value Trade and other receivables 17 6,155,831 (2,466,256) 3,689,575 6,522,869 (2,783,105) 3,739,764 Cash and cash equivalents 18 56,904,787 - 56,904,787 48,937,017 - 48,937,017 63,060,618 (2,466,256) 60,594,362 55,459,886 (2,783,105) 52,676,781 Liquidity risk The Authority's approach to managing liquidity is to ensure, as far as possible, that it will always have sufficient liquidity to meet its liabilities when due, without incurring losses or risking damage to the Regulatory Authority's reputation. The ultimate responsibility for liquidity risk management procedures for the management of the Regulatory Authority's funding and liquidity management requirements. The Regulatory Authority manages liquidity risk by maintaining adequate cash and cash equivalents to settle liabilities when they become due, by continuously monitoring forecasts actual cash flows, and by matching the Government Subvention to the maturity profile of the financial liabilities. The following table summarises the maturity profile of the Regulatory Authority's financial liabilities as at 31 March 2025 based on contractual undiscounted payments:
Less than
1 year
Total Carrying amount
Current liabilities
Trade and other payables 5,080,605
Lease liabilities 4,404,454
9,485,059
Less than
1 year
2 to 5 years Total Carrying amount
Non-current liabilities
Lease liabilities - 4,404,454
Current liabilities
Lease liabilities 4,767,892 - 4,767,892 4,404,454 9,172,346 9,172,346
26. Financial instruments and risk management (continued)

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Figures in Pula 2025 2024 Interest rate risk Financial instruments that are sensitive to interest rate risk are bank balances and cash (refer to note 12). Interest rates applicable to these financial instruments compare favourably with those currently available in the market.The following table demonstrates the sensitivity to a reasonable possible change in interest rates at reporting date, with all other variables held constant, of the Regulatory Authority's (deficit)/surplus for the year (through the impact on floating rate financial instruments), funds and reserves at reporting date. The reasonable possible change is based on past trends of interest and expected future changes. The impact was calculated by applying the reasonable changes to the exposures at reporting date, and with reference to the next 12 months. There is no other direct impact on the Regulatory Authority's funds and reserves. Increase of 0.1% in interest rate 24,394 48,178 Decrease of 0.1% in interest rate (24,394) (48,178)
27. Events after the reporting period
Directors are not aware of any material events occurring between the year-end date and the date of approval of the financial statements, which require disclosure.
28. Going concern
The annual financial statements have been prepared on the basis of accounting policies applicable to a going concern. This basis presumes that funds will be available to finance future operations and that the realisation of assets and settlement of liabilities, contingent obligations and commitments will occur in the ordinary course of business. The directors believe that the Authority has adequate financial resources to continue in operation for the foreseeable future and accordingly the annual financial statements have been prepared on a going concern basis. The directors is satisfied is that the Authority is in a sound financial position and that it has access to sufficient borrowing facilities to meet its foreseeable cash requirements. The directors is not aware of any new material changes that may adversely impact the Authority. The directors is also not aware of any material non-compliance with statutory or regulatory requirements or of any pending changes to legislation which may affect the Authority.
26. Financial instruments and risk management (continued)

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Detailed Income Statement Figures in Pula Note 2025 2024 Revenue Government grants 3 2,873,291 4,491,404 Supervisory levies 6 106,600,340 95,820,370 Total revenue 109,473,631 100,311,774 Other operating income Other income 4 2,453,966 1,275,902 Other operating gains Other operating income 5 7,739,467 5,208,123 Movement in credit loss allowances 4 (791,934) (1,573,172) Expenses (Refer to page 38) (111,669,919)(107,571,614) Operating surplus ( deficit) 4 7,205,213 (2,348,987) Finance income 5 1,466,134 3,136,415 Finance costs (376,224) (631,961) Surplus for the year 8,295,123 155,467 The supplementary information presented does not form part of the annual financial statements and is unaudited

Non-Bank Financial Institutions Regulatory Authority Annual Financial Statements for the year ended 31 March 2025 Detailed Income Statement Figures in Pula Note(s) 2025 2024 Other operating expenses Administration and management fees 185,364 188,955 Advertising 482,168 427,323 Amortisation 143,352 143,352 Auditor's remuneration 4 129,960 124,545 Bank charges 50,582 64,120 Board fees 2,089,830 1,350,562 Branding and commission 1,913,866 864,796 Cleaning 345,215 316,125 Consulting and professional fees 2,043,698 5,838,139 Depreciation 6,910,465 6,027,101 Employee costs 77,153,568 69,060,366 Insurance 1,000,298 836,123 Internet 1,247,967 1,126,301 Legal fees 857,698 2,865,673 Licenses 7,740,752 6,028,408 Motor vehicle Expenses 38,652 46,302 Office expense 353,564 306,611 Printing and stationery 623,346 622,595 Recruitment 249,857 702,679 Repairs and maintenance 523,708 584,458 Security 284,482 199,670 Staff cost 700,470 620,849 Subscriptions 1,510,500 948,418 Telephone and fax 1,116,698 1,085,556 Training 1,733,993 3,487,854 Travel - local 1,339,502 2,885,192 Utilities 900,364 819,541 Total operating expenses 111,669,919 107,571,614 The supplementary information presented does not form part of the annual financial statements and is unaudited