Reporting Obligations for Public Interest Urban Transport Operators

Public NBB_2025_15 – 17 December 2025 Communication – Page 1/4 boulevard de Berlaimont 14 – 1000 Brussels tel. +32 2 221 39 24 company number: 0203.201.340 RPM Brussels www.bnb.be Circular Public Brussels, 17 December 2025 Reference: NBB_2025_15 your correspondent:
Ingrid Vreven tel. +32 2 221 26 29 – mobile +32 474 60 69 47 Ingrid.vreven@nbb.be Reporting obligations for public interest urban transport operators Scope Public interest urban transport operators subject to the Royal Decree of 27 January 1998 implementing Article 10, § 2, of the Law of 21 November 1989 on the compulsory insurance of liability in respect of motor vehicles. Summary/Objectives This circular provides an overview of the schedule and transmission channel for the annual documents and financial reports that public interest urban transport operators must transmit annually to the National Bank of Belgium (NBB). This circular replaces Circular CBFA_2009_15, which is repealed upon the publication of this circular. Structure

1. Financial reports to be submitted annually via OneGate
2. Qualitative reports to be submitted annually via the NBB Supervision Portal
3. Information to be provided by the auditor
   Madam,
   Sir,
   The Law of 21 November 1989 on the compulsory insurance of liability in respect of motor vehicles provides, in Article 10, § 2, that public interest urban transport operators may be authorized by the King to assume themselves the civil liability relating to their motor vehicles. Establishments having obtained this authorization are required, under Article 4 of the Royal Decree of 27 January 1998 implementing Article 10, § 2, of the Law of 21 November 1989 on the compulsory insurance of liability in respect of motor vehicles, to provide the NBB with all useful information and to transmit all documents necessary for the accomplishment of its supervisory mission.

Public NBB_2025_15 – 17 December 2025 Communication – Page 2/4 The National Bank of Belgium provides guidelines in this circular to facilitate this reporting obligation.

1. Financial reports to be submitted annually by public interest urban transport operators via OneGate
   From the year 2026 (reference date 31/12/2025), public interest urban transport operators are required to transmit their financial data to the Bank via the OneGate platform. Access to the OneGate platform and additional information on OneGate are available on the Bank's website: https://www.nbb.be/en/declarations/declarations-onegate The financial data to be transmitted must relate to the situation at the end of the previous calendar year. The table below indicates when each report must be submitted to the Bank via OneGate. Please take note of the following points when determining and declaring financial data. a. In accordance with Article 2, 2°, of the Royal Decree of 27 January 1998, the institution may, when calculating technical provisions, take into account insurance contracts it has concluded which cover, in whole or in part, the obligations imposed on it by the aforementioned Law of 21 November 1989. If such an insurance contract was concluded during the financial year or if modifications have been made compared to the previous financial year (for example, modification of the deductible amount or insured amounts), a copy of the contract must be transmitted to the NBB via the NBB Supervision Portal (see paragraph 2, domain TRANSPORT_POLICIES). Otherwise, confirmation that these contracts remain unchanged suffices (see paragraph 2, domain TRANSPORT_CONF).
2. Qualitative reports that public interest urban transport operators must submit annually via the NBB Supervision Portal.
   From the year 2026 (reference date 31/12/2025), public interest urban transport operators will be required to submit qualitative reports via the NBB Supervision Portal. Access to this portal and associated documentation are available on the Bank's site: https://supervision.nbb.be/my.policy The table below indicates when each report must be submitted to the Bank via the NBB Supervision Platform. Domain and OneGate Code Report Schema Submission Period TRANSPORT_STATS Statistical report on technical reserves See Annex 1 At least three weeks after the general meeting TRANSPORT_COMP Composition of technical reserves See Annex 2 At least three weeks after the general meeting

Public NBB_2025_15 – 17 December 2025 Communication – Page 3/4 Domain Report Deadline TRANSPORT_ASSETS Detailed list of corresponding assets by investment category 1 At least three weeks after the general meeting TRANSPORT_GM Annual report of the board of directors to the general meeting TRANSPORT_MINUTES Minutes of the general meeting TRANSPORT_TP Questionnaire regarding technical provisions 2 TRANSPORT_POLICIES Insurance contracts concluded or modified during the current financial year Only in case of new conventions or modifications of conventions TRANSPORT_CONF Confirmation concerning ongoing insurance contracts: no modifications to report At least three weeks after the general meeting, unless modifications have been reported (see domain TRANSPORT_POLICIES) TRANSPORT_BBAA_BBAV Confirmation of the validity of the agreement between the public interest urban transport operator and the Belgian Bureau of Automobile Insurers At least three weeks after the general meeting Please take note of the following points when determining and declaring financial data. a. The list of corresponding assets by investment category must include the following information:

• for each security: identification, book value on the balance sheet, and market value;
• for real estate: identification (location), book value on the balance sheet, market value, any privileges and mortgages encumbering the property;
• for demand and time deposits held at credit institutions: identity of the credit institution, account number, amount;
• receivables: identity of the debtor, amount of the receivable, outstanding balance, description and value of any pledge or guarantees received.
  b. It must be demonstrated that the agreement between the public interest urban transport operators and the Belgian Bureau of Automobile Insurers (Article 2, 1° of the RD of 27 January 1998) is still in force. A simple confirmation by the transport company suffices for this purpose. 1 Article 2, 3° of the Royal Decree of 27 January 1998 2 The questionnaire to be completed regarding technical reserves is available in Annex 3 of this circular

Public NBB_2025_15 – 17 December 2025 Communication – Page 4/4
3. Information to be provided by the auditor
From the year 2026 (reference date 31/12/2025), the auditors of public interest urban transport operators must also submit, via the NBB Supervision Portal, their reports intended for the Bank. Access to the NBB Supervision Portal and 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 transmitted by the auditor to the Bank via the NBB Supervision Portal. Domain Report Deadline TRANSPORT_COM Report of the auditor (or the college of auditors) to the general meeting 3 At least 3 weeks after the general meeting Please accept, Sir, Madam, the expression of my highest consideration. Pierre Wunsch Governor Annexes: 3
Annex 1: Schema for the statistical report regarding technical reserves
Annex 2: Schema for the report on the composition of technical reserves
Annex 3: Questionnaire regarding technical reserves
3 This refers to the report of the statutory auditor (or the college of auditors) which forms an integral part of the annual report of companies for public utility institutions in collective transport and which is intended for the general meeting.