Regulation on Information Disclosure by Asset Management Companies and Non-State Pension Fund Managers, and Document Submission to the National Securities and Stock Market Commission

NATIONAL SECURITIES AND STOCK MARKET COMMISSION DECISION Kyiv On Approval of the Regulation on the Procedure for Compiling and Disclosing Information by Asset Management Companies and Persons Managing Assets of Non-State Pension Funds, and Submission of Relevant Documents to the National Securities and Stock Market Commission

In accordance with paragraphs 1, 30, 36 of Part One of Article 7, Articles 29, 30 of the Law of Ukraine "On State Regulation of Capital Markets and Organized Commodity Markets"

The National Securities and Stock Market Commission HAS DECIDED:

1. Approve the Regulation on the Procedure for Compiling and Disclosing Information by Asset Management Companies and Persons Managing Assets of Non-State Pension Funds, and Submission of Relevant Documents to the National Securities and Stock Market Commission, attached hereto.

2. Recognize as invalid the Decision of the National Securities and Stock Market Commission dated October 2, 2012 No. 1343 "On Approval of the Regulation on the Procedure for Compiling and Disclosing Information by Asset Management Companies and Persons Managing Assets of Non-State Pension Funds, and Submission of Relevant Documents to the National Securities and Stock Market Commission", registered in the Ministry of Justice of Ukraine on October 19, 2012 under No. 1764/22076 (with amendments).

3. The Department of Methodology shall ensure the submission of this decision for state registration to the Ministry of Justice of Ukraine.

4. The Administration of Administrative Activities shall ensure the publication of this decision on the official website of the National Securities and Stock Market Commission.

5. The Department of Legal Development, after state registration of the decision by the Ministry of Justice of Ukraine, shall ensure the publication of this decision on the official website of the National Securities and Stock Market Commission.

6. This decision enters into force on October 1, 2026, but no earlier than the day following the day of its official publication.

7. Establish that quarterly data for Q3 2026 shall be submitted by persons managing assets of institutional investors to the National Securities and Stock Market Commission in accordance with the requirements defined in the Regulation on the Procedure for Compiling and Disclosing Information by Asset Management Companies and Persons Managing Assets of Non-State Pension Funds, and Submission of Relevant Documents to the National Securities and Stock Market Commission, approved by the Decision of the National Securities and Stock Market Commission dated October 2, 2012 No. 1343, registered in the Ministry of Justice of Ukraine on October 19, 2012 under No. 1764/22076.

8. Entrust control over the execution of this decision to a member of the National Securities and Stock Market Commission I. Baramiya.

Chairman of the Commission Oleksiy SEMENYUK

Protocol of the Commission meeting dated 09.07.2026 No. 31

APPROVED
Decision of the National Securities and Stock Market Commission ______________No.

Regulation on the Procedure for Compiling and Disclosing Information by Asset Management Companies and Persons Managing Assets of Non-State Pension Funds, and Submission of Relevant Documents to the National Securities and Stock Market Commission

I. General Provisions

1. This Regulation defines the list, procedure, and deadlines for submitting to the National Securities and Stock Market Commission by persons managing assets of institutional investors (hereinafter – Companies), reporting data regarding the Company and regarding collective investment schemes (hereinafter – CIS), as well as the procedure and scope of disclosure of information about CIS.

The list of reporting data includes data specified in Section II of this Regulation (hereinafter – Data), and annual (interim) financial statements / annual (interim) consolidated financial statements (in case of preparation of consolidated financial statements), which are submitted in accordance with the Requirements for Disclosure of Financial Reporting Indicators in XBRL Format for Reporting Entities that are Participants of Capital Markets and Professional Participants of Organized Commodity Markets, approved by the Decision of NSCCU dated June 6, 2025 No. 36/21/2383/K03, registered in the Ministry of Justice of Ukraine on June 20, 2025 under No. 958/44364 (hereinafter – Requirements).

2. The action of this Regulation extends to Companies that have a license for the right to conduct professional activity in capital markets – activity of managing assets of institutional investors (asset management activity), issued by the State Commission for Securities and Stock Market or NSCCU, as well as those legal entities that had the right according to legislation to conduct the specified professional activity during the period for which Data is submitted.

3. Data is submitted to NSCCU in the volume established by this Regulation, no later than the deadlines specified in paragraph 14 of this Regulation.
   Data must contain all references defined by this Regulation. All Data references must be filled out, containing accurate and complete information.
   Information in references must be filled out in accordance with Appendices 1 – 13 to this Regulation.

Data is compiled as of the end of the last day of the reporting period.

4. Data compiled and submitted to NSCCU is divided into Data regarding the Company and Data regarding CIS.
   Data regarding CIS, whose assets are managed by the Company, is compiled and submitted by the Company separately for each CIS.
   From the date of the decision to terminate the activities of CIS, Data regarding CIS is not submitted.

5. Data regarding CIS is compiled and submitted for unit investment funds recognized according to the order of the authorized person of NSCCU as complying with the requirements for minimum asset volume, and/or corporate investment funds included in the Unified State Register of Collective Investment Schemes.

6. In this Regulation, terms are used in the following meanings:

1. identification code – identification code of a legal entity in the Unified State Register of Enterprises and Organizations of Ukraine;
2. LEI code – identification number according to the international legal entity identifier.

7. Data is compiled using the Reference System and Classifiers of the National Securities and Stock Market Commission, approved by the Decision of the National Securities and Stock Market Commission dated May 8, 2012 No. 646, registered in the Ministry of Justice of Ukraine on May 25, 2012 under No. 831/21143 (hereinafter – Reference System and Classifiers).

8. Data is compiled in the form defined by this Regulation, in accordance with the description of sections and XML file schemas defined by a separate normative-technical document published on the official website of NSCCU, and submitted in accordance with the Regulation on Submission of Administrative Data and Information in the Form of Electronic Documents to the National Securities and Stock Market Commission, approved by the Decision of the State Commission for Securities and Stock Market dated May 13, 2011 No. 492, registered in the Ministry of Justice of Ukraine on June 25, 2011 under No. 789/19527.

II. Composition of Data and Deadlines for Submission to NSCCU

9. Data is compiled and submitted to NSCCU as:
   daily Data; monthly Data; quarterly Data; annual Data.

10. Daily Data is Data regarding CIS, consisting of a reference on net asset value (Appendix 1 to this Regulation).

11. Monthly Data is compiled and submitted as:

1. monthly Data regarding the Company, consisting of:
   a reference on the Company (Appendix 2 to this Regulation); a reference on compliance of the size of the Company's charter and equity capital with legislative requirements (Appendix 3 to this Regulation); a reference on the list of institutional investors whose assets are managed by the Company (Appendix 4 to this Regulation). Monthly Data regarding the Company for the last month of the quarter of the reporting year is included in the composition of quarterly Data regarding the Company for the corresponding reporting quarter.

2. monthly Data regarding CIS, consisting of:
   a reference on net asset value (Appendix 1 to this Regulation); a reference on dividend payments on securities of CIS (Appendix 5 to this Regulation); a reference on the composition of the supervisory board of a corporate investment fund (Appendix 6 to this Regulation). Monthly Data regarding CIS for the last month of the quarter is included in the composition of quarterly Data regarding CIS for the corresponding reporting quarter.

12. Quarterly Data is compiled and submitted as:

1. quarterly Data regarding the Company, consisting of:
   monthly Data regarding the Company for the last month of the reporting quarter; a reference on the list of issuers of mortgage bonds, whose mortgage coverage is managed by the Company (filled in if the Company has concluded a contract on management of mortgage coverage) (Appendix 7 to this Regulation). Quarterly Data regarding the Company for Q4 of the reporting year is not compiled and not submitted.

2. quarterly Data regarding CIS, consisting of:
   a reference on a corporate investment fund (Appendix 8 to this Regulation) and/or a reference on a unit investment fund (Appendix 9 to this Regulation); a reference on participants of closed-type CIS (Appendix 10 to this Regulation). The composition of quarterly Data regarding CIS includes monthly Data regarding CIS for the last month of the reporting quarter. Quarterly Data regarding CIS for Q4 of the reporting year is included in the composition of annual Data regarding CIS for the corresponding reporting year.

13. Annual Data is compiled and submitted as:

1. annual Data regarding the Company, consisting of:
   a reference on the Company (Appendix 2 to this Regulation); a reference on compliance of the size of the Company's charter and equity capital with legislative requirements (Appendix 3 to this Regulation); a reference on the list of institutional investors whose assets are managed by the Company (Appendix 4 to this Regulation); a reference on the audit report on the financial statements of the Company/CIS for the reporting year (Appendix 13 to this Regulation). The reference on the audit report on the financial statements of the Company/CIS for the reporting year (Appendix 13 to this Regulation) is submitted within the deadlines established by the Requirements for submission of annual financial statements / annual consolidated financial statements (in case of preparation of consolidated financial statements).

2. annual Data regarding CIS, consisting of:
   quarterly Data regarding CIS for Q4 of the reporting year; a reference on compliance with requirements for the size of remuneration of the asset management company of CIS (Appendix 11 to this Regulation); a reference on the composition and size of expenses reimbursed from CIS assets (Appendix 12 to this Regulation); a reference on the audit report on the financial statements of the Company/CIS for the reporting year (Appendix 13 to this Regulation). The reference on the audit report on the financial statements of the Company/CIS for the reporting year (Appendix 13 to this Regulation) is submitted within the deadlines established by the Requirements for submission of annual financial statements.

14. The Company submits Data to NSCCU within the following deadlines:
    daily – no later than the end of the day following the reporting day, calculated:
    at the end of each working day – for open-type CIS; on the day starting from which restrictions established by legislation are applied to the asset structure of CIS; each day of receipt of funds into the bank account of CIS (during placement of securities of such institution) or crediting of CIS securities to the account of redeemed securities of such institution (during redemption of CIS securities); monthly – no later than the last day of the month following the reporting one; quarterly – no later than the last day of the month following the reporting quarter; annual – by April 1 of the year following the reporting one.

15. If the last day for submission of Data is a non-working day, the next working day is considered the last day for submission.

16. If the Company detects discrepancies in Data submitted to NSCCU, it must eliminate these discrepancies and resubmit Data in the volume defined by this Regulation, but no later than the deadlines provided for in paragraph 14 of this Regulation.
    If such Data is resubmitted with violation of the deadlines provided for in paragraph 14 of this Regulation, it must be submitted with mandatory indication in the "Notes" field of the corresponding appendix about the correction of Data by the Company and the reasons for the occurrence of discrepancies.

17. The latest Data submitted to NSCCU is considered actual.

18. The deadline for submission of Data is extended in case of receipt by NSCCU of a written notice from the Company (letter in arbitrary form) about the impossibility of submitting Data within the established deadline due to:
    seizure of software and technical means and/or documents by law enforcement agencies (with submission of copies of documents confirming the seizure of said means and/or documents); occurrence of force majeure circumstances (with submission of copies of documents confirming said circumstances).

19. The Company is obliged to inform NSCCU monthly by letter in arbitrary form about the non-elimination of circumstances that determined the impossibility of submitting Data, and in case of their elimination, submit Data to NSCCU within 15 working days from the day of elimination of such circumstances, as well as copies of documents confirming the return of software and technical means and/or documents (if returned).

IV. Procedure and Scope of Disclosure of Information about Collective Investment Schemes

20. Disclosure of information about CIS (in case of public placement of CIS securities) by placing it in the database of the person conducting activity on publishing regulated information on behalf of participants of capital markets and professional participants of organized commodity markets, is carried out by the Company once per quarter for the corresponding reporting quarter (Q1, Q2, Q3) and for the reporting year as of the end of the last day of the reporting quarter or year.

Information subject to disclosure (hereinafter – Information) consists exclusively of:
a reference on net asset value (Appendix 1 to this Regulation); a link in Universal Resource Locator (URL) format to the corresponding file of the annual financial statement of CIS, placed in the Financial Reporting Collection Center. A Company managing assets of several CIS is obliged to publish information about CIS separately for each CIS.

21. Disclosure of information about the Company and CIS whose assets are managed by the Company by publishing it on its own website is carried out by the Company exclusively in accordance with the requirements of Article 76 of the Law of Ukraine "On Collective Investment Schemes" and this paragraph.
    In case of public placement of CIS securities, the following must also be published on the Company's own website once per quarter for the corresponding reporting quarter (Q1, Q2, Q3) and for the reporting year as of the end of the last day of the reporting quarter or year:
    a reference on net asset value (Appendix 1 to this Regulation) – for closed-type CIS; the annual financial statement of CIS, which must be prepared in accordance with the Law of Ukraine "On Accounting and Financial Reporting in Ukraine" and comply with international standards of financial reporting; Disclosure of information regarding the financial statements of CIS is carried out by indicating a link in Universal Resource Locator (URL) format to the corresponding file of the financial statement, placed in the Financial Reporting Collection Center.

22. Information specified in paragraphs 20 and 21 of this Regulation is disclosed within deadlines:
    provided for in paragraph 14 of this Regulation - for the reference on net asset value; provided for by the Requirements - for disclosure of annual financial statements.

23. The Company provides participants of CIS with private placement of CIS securities with an annual report on the activities of such CIS in the manner established by its regulations.

Director of the Department of Methodology Maksym TYMOKHIN

Appendix 1
to the Regulation on the Procedure for Compiling and Disclosing Information by Asset Management Companies and Persons Managing Assets of Non-State Pension Funds, and Submission of Relevant Documents to the National Securities and Stock Market Commission (paragraph 10)

Reference on Net Asset Value

Information about CIS
Table 1

1. Company Data: identification code
2. CIS Data: identification code (for CIF)
3. CIS Data: registration code according to USRCIS
4. CIS Data: full name
5. Type of Data: 4 - daily; 3 - monthly; 2 - quarterly; 1 - annual
6. Year for which Data is submitted
7. Date as of which Data is submitted
8. CIS Data: type1
9. CIS Data: kind2
10. Date of inclusion of CIS in USRCIS
11. Term of validity of CIS
12. Date of conclusion of contract on management of CIS assets (for CIF)
13. Notes

Notes:
1 - filled in accordance with reference book 17 "Types of Institutional Investors and Accumulative Pension Fund" of the Reference System and Classifiers;

Continuation of Appendix 1
2 - filled in accordance with reference book 18 "Types of Funds and Other Assets Managed by an Asset Management Company or Investment Firm – Investment Manager of an Investment Fund" of the Reference System and Classifiers.

Information on Net Asset Value of CIS
Table 2

1. Company Data: identification code
2. CIS Data: identification code (for CIF)
3. CIS Data: registration code according to USRCIS CIS
4. Full name of the fund
5. Type of Data: 4 - daily; 3 - monthly; 2 - quarterly; 1 - annual
6. Year for which Data is submitted
7. Date as of which Data is submitted
8. CIS Data: type1
9. CIS Data: kind2
10. CIS Class (if any)3
11. Value of fund assets, UAH, (at the end of the reporting period)
12. Fund liabilities, UAH (at the end of the reporting period)
13. Net asset value of the fund, UAH (at the end of the reporting period)
14. Number of shares or investment certificates in circulation, units (at the end of the reporting period)
15. Number of shares or investment certificates in circulation among natural persons - non-residents, units (at the end of the reporting period)4
16. Number of shares or investment certificates in circulation among natural persons - residents, units (at the end of the reporting period)4
17. Number of shares or investment certificates in circulation among legal entities - non-residents, units (at the end of the reporting period)4

Continuation of Appendix 1
18. Number of shares or investment certificates in circulation among legal entities - residents, units (at the end of the reporting period)4
19. Number of fund participants (persons) legal entities - residents4
20. Number of fund participants (persons) legal entities - non-residents4
21. Number of fund participants (persons) natural persons - residents4
22. Number of fund participants (persons) natural persons - non-residents4
23. Net asset value per share or investment certificate, UAH/unit (at the beginning of the reporting period)5
24. Net asset value per share or investment certificate, UAH/unit (at the end of the reporting period)
25. Relative change in net asset value of CIS per one security of CIS6
26. Nominal value of one security
27. Notes7

Notes:
1 - filled in accordance with reference book 17 "Types of Institutional Investors and Accumulative Pension Fund" of the Reference System and Classifiers; 2 - filled in accordance with reference book 18 "Types of Funds and Other Assets Managed by an Asset Management Company or Investment Firm - Investment Manager of an Investment Fund" of the Reference System and Classifiers; 3 - filled in accordance with reference book 47 "Classes of Specialized and Qualification Collective Investment Schemes" of the Reference System and Classifiers; 4 - filled at the end of the reporting quarter and reporting year (except for bearer investment certificates); 5 - filled for monthly Data - as of the beginning of the reporting month, for quarterly Data - as of the beginning of the last month of the reporting quarter, for annual - as of the beginning of the last month of the reporting year; 6 - relative change in net asset value of CIS per one security of CIS is calculated by the formula:
r = ((NAVt - NAVt–1) / NAVt - 1) x 100 %, where r - relative change in net asset value of CIS per one security of CIS; NAVt - net asset value of CIS per one security of CIS as of the end of the reporting period (t); NAVt-1 - net asset value of CIS per one security of CIS as of the beginning of the reporting period (t-1).

Continuation of Appendix 1
7 - filled at the end of the reporting month, reporting quarter, reporting year and in case of reaching the indicator "Relative change in net asset value of CIS per one security of CIS" value below or above 25 percent (detailed information regarding the reasons for the change of this indicator in respect of each operation with CIS assets for the reporting period is disclosed). Not filled for open-type CIS.

List of Investments in Securities
Table 3

1. Company Data: identification code
2. CIS Data: identification code (for CIF)
3. CIS Data: registration code according to USRCIS CIS
4. CIS Data: full name
5. Type of Data: 4 - daily; 3 - monthly; 2 - quarterly; 1 - annual
6. Year for which Data is submitted
7. Date as of which Data is submitted
8. CIS Data: type1
9. CIS Data: kind2
10. Type of security3
11. Identification code of resident issuer / identification code from trade, court or bank register of the country where non-resident issuer is officially registered
12. Name of resident/non-resident issuer
13. Country code
14. LEI code of issuer (if available)
15. OKED code of issuer (if available)
16. International Securities Identification Number (if available)
17. Rating assessment of issuer's security (if available)
18. Name of credit agency that assigned rating assessment to issuer's securities

Continuation of Appendix 1
19. Number of securities, pieces
20. Nominal value of one security, in nominal currency
21. Currency name4
22. Total value of securities, UAH
23. Share in total value of assets, %
24. Name of operator of organized capital market, average rate of which was taken for calculation
25. Share of total volume of issuance or charter capital of issuer (for issue securities), %
26. Maturity date of security (for debt term securities)
27. Notes

Notes:
1 - filled in accordance with reference book 17 "Types of Institutional Investors and Accumulative Pension Fund" of the Reference System and Classifiers; 2 - filled in accordance with reference book 18 "Types of Funds and Other Assets Managed by an Asset Management Company or Investment Firm - Investment Manager of an Investment Fund" of the Reference System and Classifiers; 3 - filled in accordance with reference book 6 "Classification of Financial and Non-Financial Instruments by Subgroups" of the Reference System and Classifiers; 4 - filled in accordance with reference book 46 "List and Codes of Currencies" of the Reference System and Classifiers. Rows 11-27 are filled for each issue of securities (object of investment - non-issue security(ies)) separately.

List of Investments in Real Estate Objects
Table 4

1. Company Data: identification code
2. CIS Data: identification code (for CIF)
3. CIS Data: registration code according to USRCIS CIS
4. CIS Data: full name
5. Type of Data: 4 - daily; 3 - monthly; 2 - quarterly; 1 - annual
6. Year for which Data is submitted

Continuation of Appendix 1
7. Date as of which Data is submitted
8. CIS Data: type1
9. CIS Data: kind2
10. Name of real estate object (for each object separately)
11. Location of real estate object
12. Date of acquisition of real estate object
13. Acquisition value, UAH
14. Value, UAH
15. Share in total value of assets, %
16. Notes

Notes:
1 - filled in accordance with reference book 17 "Types of Institutional Investors and Accumulative Pension Fund" of the...

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