On Approval of Amendments to the Requirements for Synchronization of Date and Time Recording Systems

NATIONAL COMMISSION FOR SECURITIES AND STOCK MARKET DECISION Kyiv On Approval of Amendments to the Requirements for Synchronization of Date and Time Recording Systems In accordance with part seven of Article 52 of the Law of Ukraine "On Capital Markets and Organized Commodity Markets", paragraph 1 of part one of Article 7 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets", with the aim of bringing normative legal acts into compliance with legislative requirements The National Commission for Securities and Stock Market D E C I D E D:

1. Approve the Amendments to the Requirements for Synchronization of Date and Time Recording Systems, approved by the decision of the National Commission for Securities and Stock Market dated July 22, 2021 No. 558, registered in the Ministry of Justice of Ukraine on September 14, 2021 under No. 1206/36828, which are attached.
2. Operators of organized markets, participants in trading on such markets, persons conducting clearing activities, for the purpose of conducting the corresponding type of professional activity, bring their activities into compliance with the Requirements for Synchronization of Date and Time Recording Systems, approved by the decision of the National Commission for Securities and Stock Market dated July 22, 2021 No. 558, registered in the Ministry of Justice of Ukraine on September 14, 2021 under No. 1206/36828, within twelve months from the date of entry into force of this decision.
3. The Department of Information Technologies shall ensure the submission of this decision for state registration to the Ministry of Justice of Ukraine.

2 4. The Administration of Administrative Activities shall ensure the publication of this decision on the official website of the National Commission for Securities and Stock Market. 5. The Department of Legal Support and Internal Compliance Control, after state registration in the Ministry of Justice of Ukraine, shall ensure the publication of this decision on the official website of the National Commission for Securities and Stock Market. 6. This decision enters into force from the day following the day of its official publication. 7. Control over the implementation of this decision is entrusted to a member of the National Commission for Securities and Stock Market Yu. Shapoval. Chairman of the Commission Ruslan MAGOMEDOV Protocol of the Commission meeting dated 14.11.2025 No. 107

APPROVED Decision of the National Commission for Securities and Stock Market ____________ 2025 No. _______________ Amendments to the Requirements for Synchronization of Date and Time Recording Systems, approved by the decision of the National Commission for Securities and Stock Market dated July 22, 2021 No. 558, registered in the Ministry of Justice of Ukraine on September 14, 2021 under No. 1206/36828

1. In paragraph 1, replace the words "organized market for conducting the corresponding type of activity in organizing trading on capital markets and organized commodity markets" with the words and symbols "organized markets, participants in trading on such markets, persons conducting clearing activities, for conducting the corresponding type of professional activity, who must synchronize service clocks to register the date and time of any accountable event".
2. Redraft paragraph 2 as follows: "2. In these Requirements, terms are used in the following meanings: reference (reference) time source – a precise time service that provides the ability to synchronize time via NTP (Network Time Protocol) and SNTP (Simple Network Time Protocol) protocols to other servers and computers connected to the Internet; reference time (reference time) – precise time indication used to synchronize clocks in date and time recording systems. As reference (reference) time, Coordinated Universal Time (UTC) is used; ETS – electronic trading system used by the operator of an organized market to conduct the corresponding type of activity in organizing trading on capital markets and organized commodity markets; Master clock – a clock that controls other system clocks; Slave clock – a clock controlled by other system clocks; PTK – software-hardware (software) complex used by the operator of an organized market to conduct the corresponding type of activity in organizing trading on capital markets and organized commodity markets, and by participants in trading on such markets; service clock – a clock, electronic system, or software-hardware complex used to perform certain service duties, track working time, and record the time of performing certain tasks (actions, events); Precise Time System (PTS) – a set of technical means that ensures periodic transmission of digital information about the current time value from a reference source to all network elements for the purpose of synchronizing their internal clocks; Date and Time Recording System (DTRS) – a software, technical, or software-technical means that allows recording the date and time of execution of operations (performance of actions) with minimal deviation from reference date and time values; Gate-to-gate delay time – the time measured from the moment a message is received by an external gateway (ETS), its forwarding via the order submission protocol, processing by the order matching instrument, and sending back, until the moment a confirmation is sent from the gateway." The term "operator of an organized market" is used in the meaning provided in the Law of Ukraine "On Capital Markets and Organized Commodity Markets".
3. Redraft paragraph 3 as follows: "3. DTRS is necessary: for coordinating the operation of devices and applications that process data, including in real-time mode (recording the execution of operations); in monitoring and management systems for logging the occurrence of events, for cross-monitoring of events and detecting cases of market abuse, and allows clearer comparison of a transaction with market conditions prevailing at the time of its commission and timely response to them; so that competent authorities, in cases provided by law, have the ability to distinguish between different events that under other circumstances might appear to have occurred simultaneously."
4. In paragraph 5:

1. in the first paragraph, replace the words "operator of OM" with the words and symbols "operator of an organized market (hereinafter – operator OM)";
2. add two new paragraphs of the following content: "Operators of OMs must ensure that their service clocks meet the accuracy levels (Appendix) and ensure time registration with timestamp granularity specified in Table 1 of the Appendix, according to the gate-to-gate delay time of each of their trading systems. Participants in trading on organized markets must ensure that their service clocks used to register the date and time of accountable events meet the accuracy levels (Appendix) and ensure time registration with timestamp granularity specified in Table 2 of the Appendix."

3 5. Redraft paragraph 6 as follows: "6. Depending on the tasks performed by ETS and PTK, different levels of time synchronization accuracy may be required, but within ETS and PTK, a single level of accuracy is applied simultaneously. The systems most sensitive to time accuracy are those for processing orders or quotes and/or notifications of their cancellation, including in peak load modes, and systems that ensure orderly trading under conditions of strong market stress." 6. In paragraph 7, replace the words "precise signal" with the words and symbols "reference (reference)". 7. Redraft paragraph 8 as follows: "8. Time synchronization in PTS with a reference source must be performed each time ETS and PTK are started and at least once per hour in operating mode. Time synchronization during interaction between ETS and PTK of different operators of OMs and/or participants in trading on organized markets must occur before the start of interaction and periodically (no less frequently than once per hour of interaction). The time recorded during interaction between operators of OMs and/or operators of OMs and participants in trading on organized markets, including time recorded for operations during interaction, must differ from reference time by no more than the maximum deviation from reference time for the corresponding type of trading activity specified in Table 2 of the Appendix. The time recorded during interaction between operators of OMs and persons conducting clearing activities, or time recorded for operations during interaction, must differ from reference time by no more than 1 second." 8. In paragraph 12, replace the words "reference systems" with the words and symbols "reference (reference) source". 9. Add an Appendix to the Requirements, which is attached. Director of the Department of Information Technologies Andriy ZAIKA

Appendix to the Requirements for Synchronization of Date and Time Recording Systems (paragraph 5) Accuracy Levels Table 1. Accuracy Level for Operators of Organized Markets Gate-to-gate delay time of trading system Maximum deviation from UTC scale Timestamp granularity

1 millisecond 1 second 1 second or finer granularity ≤ 1 millisecond 100 microseconds 1 microsecond or finer granularity Table 2. Accuracy Level for Participants in Trading on Organized Markets Type of trading activity Maximum deviation from UTC scale Timestamp granularity Activity using high-frequency algorithmic trading technology 100 microseconds 1 microsecond or finer granularity Activity using voice trading systems 1 second 1 second or finer granularity Activity regarding quote request systems, where response requires human involvement or does not allow algorithmic trading 1 second 1 second or finer granularity Activity regarding the conclusion of negotiated transactions 1 second 1 second or finer granularity Any other types of activity or trading techniques 1 second 1 second or finer granularity

---