Reporting Obligations for Mutual Guarantee Companies

Public NBB_2025_14 – 17 December 2025 Circular – Page 1/4 boulevard de Berlaimont 14 – 1000 Brussels tel. +32 2 221 xx xx company number: 0203.201.340 RPM Brussels www.bnb.be Circular Public Brussels, 17 December 2025 Reference: NBB_2025_14 your correspondent:
Ingrid Vreven tel. +32 2 221 26 29 – GSM +32 474 60 69 47 Ingrid.vreven@nbb.be Reporting Obligations for Mutual Guarantee Companies Scope Mutual guarantee companies subject to the Royal Decree of 30 April 1999 on the status and supervision of mutual guarantee companies. Summary/Objectives This circular provides an overview of the calendar and transmission channel for the annual documents and financial reports that mutual guarantee companies must transmit to the National Bank of Belgium (NBB) in accordance with current regulations. This circular replaces circular CBFA_2009_14, which is repealed upon the publication of this circular. Structure

1. Financial reporting to be submitted annually via OneGate
2. Qualitative reports to be submitted annually via the NBB Supervision Portal
3. Information to be submitted by the auditor
   Madam,
   Sir,
   Mutual guarantee companies are required to submit annual reporting in accordance with the provisions of Articles 32, 41, 42, 44 and 46 of the Royal Decree of 30 April 1999. The National Bank of Belgium provides guidelines in this circular to facilitate this reporting obligation.
4. Financial reports to be submitted annually by mutual guarantee companies via OneGate
   From the year 2026 (reference date 31/12/2025), mutual guarantee companies are required to communicate their financial data to the Bank via the OneGate platform. Access to the OneGate platform as well as additional information on OneGate are available on the Bank's website: https://www.nbb.be/en/declarations/declarations-onegate

Public NBB_2025_14 – 17 December 2025 Circular – Page 2/4 The financial data to be reported must relate to the closure of the previous financial year. The table below indicates which reports must be submitted to the Bank via OneGate and when. Domain and OneGate Code Report Scheme Submission Deadline1 GUARANTEE_BALANCE Detailed Balance Sheet See Annex A At least three weeks before the general assembly of members GUARANTEE_RESULTS Detailed Income Statement See Annex B GUARANTEE_SOLVENCY Solvency Ratio2 See Annex C GUARANTEE_ASSETS Detailed lists of representative values by investment category See Annex D a. Securities b. Demand or term accounts
c. Real estate
GUARANTEE_TP Summary statement of representative values of technical provisions and technical debts See Annex E Please take the following points into account when calculating and declaring financial data. a. Reporting must be carried out in euros, without decimals. b. For the calculation of the solvency ratio, it is necessary to take into account the amounts appearing in explanatory note no. 5.7 concerning rights and commitments off-balance sheet. This note must contain the mutual guarantee company's own commitments, before deduction of reinsurance, as well as the ordinary commitments of Crédit Professionnel, Waarborgbeheer nv, Sowalfin sa, Socamut sa, the Brussels Guarantee Fund and other re-guarantee companies.
c. For the determination of representative values, the share of reinsurers and claims on reinsurers referred to in Article 34, 7° and 8° of the Royal Decree of 30 April 1999 on the status and supervision of mutual guarantee companies cannot be used to cover technical provisions and technical debts without the prior agreement of the NBB.
d. For the summary statements of representative values of technical provisions and technical debts, please take the following elements into account:
o Technical provisions and technical debts, without deduction of re-guaranteeing relating to the commitments of mutual guarantee companies, must be covered by representative values in accordance with the provisions of Articles 32 to 39 of the Royal Decree of 30 April 1999 on the status and supervision of mutual guarantee companies. 1 Areas that cannot be completed in the 3 weeks preceding the date of the general assembly will be left blank. 2 All mutual guarantee companies must establish a solvency ratio in accordance with Article 26 of the Royal Decree of 30 April 1999 on the status and supervision of mutual guarantee companies.

Public NBB_2025_14 – 17 December 2025 Circular – Page 3/4 o Claims for which the administrative file has been closed and for which the guarantee payment procedure by the company has been initiated must also be covered by regulatory representative values as long as the credit institution has not received the amount of the guarantee due to it, whether this amount is considered as a technical provision or as a technical debt towards the credit institution.
2. Qualitative reports to be submitted annually via the NBB Supervision Portal.
From the year 2026 (reference date 31/12/2025), mutual guarantee companies are required to submit qualitative reports via the NBB Supervision Portal. Access to this portal, as well as the associated documentation, is available on the Bank's website:
https://supervision.nbb.be/my.policy.
The table below indicates when each report must be submitted to the Bank via the NBB Supervision Portal. Domain Report Deadline GUARANTEE_ADMIN List of administrators At least three weeks before the general assembly of members GUARANTEE_MANDATE Auditor appointment3 At least three weeks before the general assembly of members GUARANTEE_ARTICLE Updated version of the statutes To be submitted only in case of modifications GUARANTEE_GM Annual report of the board of directors to the general assembly At least three weeks before the general assembly of members GUARANTEE_MINUTES Minutes of the general assembly To be transmitted within one month following the date of the general assembly GUARANTEE_PLAN Re-guaranteeing plan4 At least three weeks before the general assembly of members
3. Information to be submitted by the auditor
From the year 2026 (reference date 31/12/2025), the auditors of mutual guarantee companies will also have to submit their reports intended for the Bank via the NBB Supervision Portal. Access to the NBB Supervision Portal as well as the associated documentation are available on the Bank's website: https://supervision.nbb.be/my.policy. The table below indicates when the different reports must be submitted by the auditor to the Bank via the NBB Supervision Portal. 3 Document signed intended for the NBB in which the name of the appointed auditor is communicated. 4 Mutual guarantee companies transmit their re-guaranteeing plan for the current financial year to the NBB. This plan includes in particular the names and addresses of the reinsurers as well as the level of re-guaranteeing..

Public NBB_2025_14 – 17 December 2025 Circular – Page 4/4 Domain Report Submission Period GUARANTEE_COM Auditor's report (or the board of auditors) to the general assembly 5 At least 15 days before the date of the general assembly of members GUARANTEE_COM_NBB Auditor's report intended for the NBB 6 To be transmitted within one month following the date of the general assembly Please accept, Sir, Madam, the expression of my highest consideration, Pierre Wunsch Governor Annexes: 8

• Annex A: Detailed balance sheet scheme
• Annex B: Detailed income statement scheme
• Annex C: Solvency ratio scheme
• Annex D.a: Detailed list of representative values for securities
• Annex D.b: Detailed list of representative values for cash
• Annex D.c: Detailed list of representative values for real estate
• Annex E: Summary statement of representative values scheme
• Annex F: Auditor appointment form
  5 This is the report of the statutory auditor (or the board of auditors) which is an integral part of the annual report of mutual guarantee companies and which is intended for the general assembly of members. 6 This is the report referred to in Article 44, §2 of the Royal Decree of 30 April 1999 on the status and supervision of mutual guarantee companies.