SBS Resolution No. 1923-2026: Amending the Regulation of Infractions and Sanctions of the Superintendency of Banks, Insurance and Private Pension Fund Administrators

Los Laureles Nº 214 - Lima 27 - Peru Tel. : (511)6309000 Lima, July 22, 2026 SBS Resolution No. 01923-2026

The Superintendent of Banks, Insurance and Private Pension Fund Administrators

CONSIDERING:

That, by means of SBS Resolution No. 2755-2018, the Regulation of Infractions and Sanctions of the Superintendency of Banks, Insurance and Private Pension Fund Administrators (hereinafter, the Regulation) was approved, applicable to companies of the Financial System, the Insurance System, Private Pension Fund Administrators, Derramas and Benefit Funds, and natural and legal persons who, in accordance with the General Law of the Financial System and the Insurance System and the Organic Law of the Superintendency of Banks and Insurance, Law No. 26702 and its amendments, and other special laws, fall under the regulation and supervision of the Superintendency;

That, the aforementioned regulation comprises annexes containing the typification of infractions derived from the non-compliance with provisions issued by the Superintendency and the General Law, which are classified according to their severity into minor, serious, and very serious infractions;

That, the Superintendency considers it necessary to modify Annexes 1, 2, 3, 4 and 5 of the aforementioned Regulation with the purpose of incorporating and modifying infractions linked to external auditing, investments, limits on financing, technical obligations, market conduct, evaluation and qualification of disability procedures, accreditation of contributions process, among others, which, under the principles of legality and typicity, allow the Superintendency to have effective mechanisms for the exercise of its sanctioning power;

Having the approval of the Adjunct Superintendencies of Banking and Microfinance, Insurance, Pensions, Regulation and Legal, and the Financial Intelligence Unit of Peru, as well as the Risk and Market Conduct and Financial Inclusion Directorates;

In exercise of the powers conferred by items 7 and 9 of Article 349, concordant with Articles 356 and 361 of the General Law; and, in accordance with the exception of the Thirty-Second Final and Complementary Provision of the aforementioned General Law;

RESOLVES:

Article First. - Modify the Regulation of Infractions and Sanctions of the Superintendency of Banks, Insurance and Private Pension Fund Administrators, approved by SBS Resolution No. 2755-2018 and its amending norms, according to the following:

ANNEX 1 COMMON INFRACTIONS (Annex applicable to natural or legal persons of Annexes 2 to 5 of the SBS Regulation of Infractions and Sanctions, as well as to shareholders, directors, managers, workers and supervision collaborators) (…)

III. VERY SERIOUS INFRACTIONS (…) 17) Not issuing opinions or reports in accordance with the provisions of the External Auditing Regulation or the norm that replaces it. (…)

ANNEX 2 SPECIFIC INFRACTIONS OF THE FINANCIAL SYSTEM AND COMPANIES OF COMPLEMENTARY AND RELATED SERVICES (Multiple operations companies, specialized companies, investment banks and others of similar nature under supervision, as well as representatives of financial companies not established in the country and supervision collaborators of this group; to companies of complementary and related services and to shareholders, directors, managers, workers) (…)

II. SERIOUS INFRACTIONS (…) 79) Not having prior authorization from the Superintendency for the transfer and acquisition of credit portfolios to related and unrelated persons, in accordance with current regulations. (…)

ANNEX 3 SPECIFIC INFRACTIONS OF THE INSURANCE SYSTEM (Insurance and reinsurance companies. Includes insurance intermediaries and auxiliaries, representatives of reinsurance companies and reinsurance brokers from abroad and supervision collaborators of this group. Includes shareholders, directors, managers and workers) (…)

I. MINOR INFRACTIONS (…)

Los Laureles Nº 214 - Lima 27 - Peru Tel. : (511)6309000 42) In the case of claim adjusters, not delivering simultaneously both to the insured and to the insurance company the (preliminary and/or final) claim settlement reports, in a percentage of up to 5% of the reports issued in the last twelve (12) months. 43) In the case of claim adjusters, delivering final adjustment reports outside the legal deadline in a percentage of up to 5% of the adjustments concluded in the last twelve (12) months. (…)

II. SERIOUS INFRACTIONS (…) 19) Rejecting insurance coverage requests without communicating the basis and/or not communicating the rejection within the deadline established in current regulations. (…) 40) Not complying with current regulations regarding initial registration, subsequent measurement and/or valuation of investments, impairment of value and/or not keeping investment information available to the Superintendency. (…)

ANNEX 4 SPECIFIC INFRACTIONS OF THE PRIVATE PENSION FUND ADMINISTRATION SYSTEM (Private Pension Fund Administrators, AFP sales promoters. Includes shareholders, directors, managers and workers)

I. MINOR INFRACTIONS (…) 18) With regard to the responsibility of AFPs in the evaluation and qualification of disability process: a) Not complying with the deadlines and/or conditions established in current regulations for the receipt, identity verification, registration, validation or processing of applications linked to the evaluation and qualification of disability process; and/or, b) Not complying with the deadlines and/or conditions established in current regulations for the referral, transfer or distribution of applications and supporting information linked to the evaluation and qualification of disability process; and/or, c) Not complying with the obligations of guidance and advice to affiliates and/or beneficiaries on the processes and procedures of the Disability Evaluation System, in accordance with current regulations. (…) 21) With regard to the role of AFPs in the functioning of COMAFP and operational support processes: a) Not maintaining or not updating the information system and database that allows identifying, collecting, processing or reporting information for the risk management of operational support processes under the responsibility of COMAFP, under the conditions established in current regulations; and/or, b) Not complying with sending to the Superintendency the reports, risk management reports and indicators referred to the functioning of COMAFP, within the deadlines or conditions established in current regulations. (…) 78) With regard to the role of Medical Committees in the evaluation and qualification of disability process: a) Not evaluating, not qualifying disability or not issuing pronouncements (opinions) on disability, pre-existence, coverage exclusion and/or other administrative act, in accordance with the deadlines or conditions established in current regulations; and/or, b) Not evaluating affiliates or beneficiaries in accordance with the conditions established in current regulations; and/or not requesting, in case of discrepancies or when the nature of the case requires it, the exams, medical reports or the participation of the consulting physician provided for in current regulations; and/or, c) Not notifying the AFP, the affiliate, beneficiary, the insurance company or the Superintendency of the pronouncements, the suspension of the evaluation and/or other administrative acts, within the deadlines or conditions established by the current regulatory framework; and/or, d) Not sending to the Superintendency the documentation and information requested in relation to the Disability Evaluation System; and/or, e) Not attending to the public in cases where it is required for matters related to the competence of COMAFP or COMEC; or not communicating, substantiated, the reasons why their attendance does not correspond. (…)

II. SERIOUS INFRACTIONS (…) 21) Not having a procedure for the accreditation of contributions or not complying with what is established by the current regulatory framework. (…) 46) With regard to the role of AFPs in the functioning of COMAFP and operational support processes: a) Not implementing policies, procedures, risk management measures or quality management in the operational support processes and/or of another nature of COMAFP, or not complying with what is established in current regulations; and/or, b) Not implementing procedures to prevent, detect, manage or communicate conflicts of interest of the AFP representative members in the committees and/or of the personnel participating in the operational support processes or of another nature of COMAFP, or not complying with what is established in current regulations; and/or, c) Not implementing procedures and criteria to carry out the processes of recruitment, selection, hiring, designation or appointment of representative members and/or administrative personnel participating in the operational support processes in COMAFP, or not complying with what is established in current regulations; and/or,

Los Laureles Nº 214 - Lima 27 - Peru Tel. : (511)6309000 d) Not implementing methods for monitoring the performance of professionals in charge of the operational support processes of COMAFP and/or training procedures for professionals and physicians, or not complying with what is established in current regulations; and/or, e) Not observing, in the evaluation and qualification of disability process, the characteristics of accessibility, timeliness and service orientation; and/or, in case of implementing channels, formats or contents for the procedure or guidance, not subjecting to the safeguard mechanisms, the information security infrastructure or the prior communication of the Improvement Plan to the Superintendency. (…) 78) With regard to the role of Medical Committees in the evaluation and qualification of disability process and in their functioning: a) Not implementing regulatory provisions to determine and substantiate the date of occurrence of disability in the qualification opinion, or not complying with what is established in current regulations; and/or, b) Not complying with regulatory provisions applicable to minutes and minute books; and/or with the conservation, archiving and availability of files and opinions of the evaluation and qualification of disability process, in accordance with what is established in the current regulatory framework. (…) 86) Not having a collection management system or not complying with the minimum conditions established in current regulations. (…)

Article Second. - Incorporate the following items into the Regulation of Infractions and Sanctions of the Superintendency of Banks, Insurance and Private Pension Fund Administrators, approved by SBS Resolution No. 2755-2018 and its amendments, according to the following:

ANNEX 1 COMMON INFRACTIONS (Annex applicable to natural or legal persons of Annexes 2 to 5 of the SBS Regulation of Infractions and Sanctions, as well as to shareholders, directors, managers, workers and supervision collaborators) (…)

II. SERIOUS INFRACTIONS (…) 86) Using risk management models that have not been approved in accordance with the requirements and/or conditions established in the applicable regulations.

ANNEX 2 SPECIFIC INFRACTIONS OF THE FINANCIAL SYSTEM AND COMPANIES OF COMPLEMENTARY AND RELATED SERVICES (Multiple operations companies, specialized companies, investment banks and others of similar nature under supervision, as well as representatives of financial companies not established in the country and supervision collaborators of this group; to companies of complementary and related services and to shareholders, directors, managers, workers)

II. SERIOUS INFRACTIONS (…) 90) Not communicating the transfers and acquisitions of credit portfolios within the deadlines established in current regulations and/or sending incomplete information on the transfers and acquisitions of credit portfolios. 91) Granting financing to natural persons, legal persons or legal entities related under more advantageous conditions than the best that the company maintains with its clientele. 92) Not complying with the provisions established by the Superintendency linked to the application of interest rates and/or to the calculation of interest settlement, with an economic impact on users equal to or greater than the amount equivalent to 20 UIT.

III. VERY SERIOUS INFRACTIONS (…) 23) Not complying with the provisions established by the Superintendency linked to the application of interest rates and/or to the calculation of interest settlement, with an economic impact on users equal to or greater than the amount equivalent to 100 UIT.

ANNEX 3 SPECIFIC INFRACTIONS OF THE INSURANCE SYSTEM (Insurance and reinsurance companies. Includes insurance intermediaries and auxiliaries, representatives of reinsurance companies and reinsurance brokers from abroad and supervision collaborators of this group. Includes shareholders, directors, managers and workers)

II. SERIOUS INFRACTIONS (…) 131) In case the policyholder and/or insured does not accept the assignment of the insurance portfolio: (i) not complying with providing continuity to the insurance coverage; or, (ii) not complying with settling the policy and returning the corresponding concepts in the face of legal impossibility that prevents maintaining the contract. 132) Not fully constituting the generic provisions or specific provisions associated with GOC bonds issued, in accordance with what is established in current regulations. 133) Issuing GOC bonds when the effective equity requirement for credit risk reaches 25% of total effective equity. 134) Not paying and/or paying outside the deadline the savings and/or investment components, as well as the corresponding interests. 135) Disposing of the counter-guarantees received for the issuance of surety insurance, GOO bonds or GOC bonds, in contravention of current regulations. 136) Not increasing technical obligations by the amount of counter-guarantees received in cash or deposit, in accordance with what is established in current regulations.

Los Laureles Nº 214 - Lima 27 - Peru Tel. : (511)6309000 137) Not complying with the application of general guidelines and/or specific guidelines of the fair value model for the valuation of real estate investments, in accordance with current regulations. 138) Not backing liabilities for counter-guarantees received in cash or deposits with assets permitted by the Regulation of Credit, Surety and Bonds Insurance issued by Insurance Companies or the norm that replaces it, even if such assets qualify as eligible investments in accordance with what is provided by the General Law and/or the Regulation of Investments of Insurance Companies or the norm that replaces it. 139) Not having or not keeping updated, as appropriate, the appraisals required by applicable regulations regarding real estate properties adjudicated, for own use or investments in real estate valued under the cost model, carried out by an appraiser registered in the Register of Appraisers (REPEV), with a valid code at the date of the appraisal.

Intermediaries, Auxiliaries and Representatives of reinsurance companies from abroad 140) In the case of claim adjusters, not delivering simultaneously both to the insured and to the insurance company the (preliminary and/or final) claim settlement reports, in a percentage greater than 5% of the reports issued in the last twelve (12) months. 141) In the case of claim adjusters, not delivering final adjustment reports; or, delivering final adjustment reports outside the legal deadline in a percentage greater than 5% of the adjustments concluded in the last twelve (12) months.

III. VERY SERIOUS INFRACTIONS (…) 7) Issuing without Superintendency authorization bonds considered as guarantees on credit obligations and that have no link with the obligations referred to in the definition of surety risk of the chart of accounts for companies of the insurance system. 8) Not having prior authorization from the Superintendency to act as trustees. 9) Not complying with applying policies of disclosure and resolution of conflicts of interest in the management of investments of insurance products with savings and/or investment components, through decisions that go against the interests of the insured, to the benefit of the company itself or of persons or legal entities related to it, or of persons or legal entities of its economic group or conglomerate. 10) Carrying out operations with financial derivatives and/or combined financial instruments without prior authorization from the Superintendency.

ANNEX 4 SPECIFIC INFRACTIONS OF THE PRIVATE PENSION FUND ADMINISTRATION SYSTEM (Private Pension Fund Administrators, AFP sales promoters. Includes shareholders, directors, managers and workers)

I. MINOR INFRACTIONS (…) 84) Not carrying out administrative or judicial collection actions in accordance with the deadlines or conditions of current regulations or the collection management system. 85) Not carrying out the accreditation of collected, transferred or transferred and identified contributions, in accordance with the deadlines or conditions of current regulations.

III. VERY SERIOUS INFRACTIONS (…) 42) With regard to the role of AFPs in the functioning of COMAFPs: a) Not improving technological platforms and/or service processes; and/or, b) Not providing human, logistical and/or information technology resources, in accordance with what is established in current regulations; and/or, c) Not requesting the Superintendency to constitute decentralized bodies for the evaluation and qualification of disability, under the conditions established in current regulations.

ANNEX 5 INFRACTIONS APPLICABLE TO DERRAMAS, BENEFIT FUNDS, OTHER FUNDS THAT RECEIVE RESOURCES FROM THEIR AFFILIATES AND GRANT UNEMPLOYMENT, RETIREMENT AND SIMILAR PENSIONS, FACTORING COMPANIES NOT INCLUDED IN THE SCOPE OF THE GENERAL LAW, FINANCIAL LEASING COMPANIES NOT INCLUDED IN THE SCOPE OF THE GENERAL LAW, COMPANIES WITH AUTHORIZATION FOR ORGANIZATION AND OTHER SUPERVISED NOT CONSIDERED IN THE OTHER ANNEXES (Includes directors or members of equivalent body, managers, workers)

I. SERIOUS INFRACTIONS (…) 6) With regard to the annual report: (i) not approving it by board agreement or equivalent body, or not approving it within the established deadline; and/or, (ii) not presenting it or presenting it outside the legal deadline to the Superintendency, in accordance with current regulations.

Article Third. - Repeal the following infractions:

• Items 66 and 67 of Section II of Annex 3.
• Items 24, 43, 64, 65, 79 and 81 of Section I and item 26 of Section II of Annex 4.

Article Fourth. - This Resolution enters into force from the day following its publication in the Official Gazette El Peruano.

Register, communicate and publish.

SERGIO JAVIER ESPINOSA CHIROQUE Superintendent of Banks, Insurance and AFP