Technical Instruction for Obligors Submitting Prescribed Information to the Official Register of Prescribed Information and the Croatian Financial Services Supervisory Agency

Based on the provisions of Article 15, item 7 of the Act on the Croatian Financial Services Supervisory Agency (Official Gazette No. 140/05 and 12/12), and in connection with Article 497, paragraph 4 and Article 498, paragraph 6 of the Capital Market Act (Official Gazette No. 65/18, 17/20, 83/21, 151/22, 85/24, 126/25 and 45/26), the Croatian Financial Services Supervisory Agency, at the session of the Management Board held on July 29, 2026, adopts the TECHNICAL INSTRUCTION FOR OBLIGORS SUBMITTING PRESCRIBED INFORMATION TO THE OFFICIAL REGISTER OF PRESCRIBED INFORMATION AND THE CROATIAN FINANCIAL SERVICES SUPERVISORY AGENCY

1. INTRODUCTION
   The Technical Instruction for obligors submitting prescribed information to the Official Register of Prescribed Information and the Croatian Financial Services Supervisory Agency (hereinafter: Technical Instruction) contains a description of signing with a qualified electronic signature, as well as the registration, access, login, and operating procedures for persons authorized to access the reporting system of the Croatian Financial Services Supervisory Agency (hereinafter: Hanfa) in the system for submitting prescribed information to the Official Register of Prescribed Information (hereinafter: SRPI) and to Hanfa's reporting system in electronic form signed with a qualified electronic signature. This Technical Instruction applies to issuers who submit prescribed and other information to Hanfa and SRPI, such as the list of insiders, the compliance questionnaire, and the governance practices questionnaire.
2. TECHNICAL PREREQUISITES FOR OPERATING IN HANFA'S REPORTING SYSTEM
   2.1. Prerequisites for signing with a qualified electronic signature
   A qualified electronic signature is an electronic signature as prescribed by Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257/73 28. 8. 2014). For signing with a qualified electronic signature, the issuer must have their own crypto device, i.e., an appropriate medium issued by an authorized certificate issuer, with two digital certificates, namely:
   a) an authentication certificate and b) a qualified certificate for electronic signature.
   When signing with a qualified electronic signature, the issuer is obliged to use the option of separate storage of the original document from the file containing the qualified electronic signature. For detailed instructions on working with the electronic signing system, the issuer is obliged to contact the authorized issuer of digital certificates (a legal entity authorized to issue digital certificates).

2.2. Prerequisites for registration and submission to Hanfa's reporting system
For successful use of Hanfa's reporting system, the issuer must meet the following prerequisites:
a) have an authentication certificate issued by the Financial Agency (hereinafter: FINA) b) install the necessary components according to FINA's instructions c) have a computer with Internet access d) be registered as a user on Hanfa's reporting system e) submit an access form for the authorized person of the Applicant (user) to Hanfa. Upon receiving the USB stick with the digital certificate, the user is obliged to register their digital certificate using the appropriate interface on Hanfa's website. A user whose valid certificate is already registered with Hanfa does not need to register it again. To obtain authorization for submitting specific types of information to Hanfa's reporting system, obligors are required to submit a completed access form to Hanfa, which constitutes Annex I of this Technical Instruction and whose form can be downloaded from Hanfa's website or the access form available at https://reports.hanfa.hr/. After successful registration of the authorized person (user) and upon receipt of a correctly completed access form for the authorized person (user), Hanfa will enter the authorized person for submitting prescribed information into the user records and assign them the necessary authorizations for submitting data to Hanfa's reporting system.
2.3. Login to the user registration interface
Launch your Internet browser and open Hanfa's website: https://www.hanfa.hr.
At the top right of the page, click on "REPORTS".

Insert the USB stick into the computer and on the top right, click on "Registracija" (Registration).
To log in to the system, first select the certificate you wish to use for login. Mark the desired certificate and then confirm the selected certificate by clicking "OK".

After selecting the certificate, you need to enter the PIN to access the cryptographic device (USB stick) where your certificate is located. Enter the PIN and confirm the entry by clicking "OK".
If you are already a registered user, the following message will be displayed on the user interface:

If you are not a registered user, fill out the form and select the action "Registriraj" (Register).
Upon successful registration, you will receive the following notification:

3. METHOD OF DATA SUBMISSION TO HANFA'S REPORTING SYSTEM
   3.1. Prerequisites for operation
   Before logging into Hanfa's reporting system, the issuer (user) must:

• be registered (complete the procedure described under point 2.3 of this Technical Instruction) and
• submit the appropriate access form.
  3.2. Login to the data submission interface
  Launch your Internet browser and open Hanfa's website: https://www.hanfa.hr.
  At the top right of the page, click on "REPORTS".

3.3. Data entry into Hanfa's reporting system
You are at the entrance to the interface for electronic data submission to Hanfa.
Insert the USB stick into the computer and in the menu on the right, select the "Prijava" (Login) tab.
To log in to the system, first select the certificate you wish to use for login and confirm your selection by clicking "OK".

After selecting the certificate, you need to enter the PIN to access the cryptographic device (USB stick) where your certificate is located. Enter the PIN and confirm the entry by clicking "OK".
In case of unsuccessful login, the following message is displayed:

After successful login, the initial user interface is displayed.
On the left side of the menu, there is "Predaja izvješća" (Report Submission). When this link is selected, the types of reports for which you have submission authorization in Hanfa's reporting system will open.

Select SRPI when submitting prescribed and/or other information that is submitted to SRPI only in PDF format.
Select SRPI-G-ESEF when submitting the annual report that is submitted to SRPI in a single electronic reporting format in a ZIP file.
Select SRPI-G when submitting the annual report that is submitted to SRPI in PDF and XLS format.
Select SRPI-P when submitting the semi-annual report that is submitted to SRPI in PDF and XLS format.
Select SRPI-K when submitting the quarterly report that is submitted to SRPI in PDF and XLS format.
Select GFI-IZD-POD, GFI-IZD-KI, TFI-IZD-POD, TFI-IZD-KI, TFI-IZD-AIF, TFI-IZD-OSIG, TFI-IZD-ZSE, PFI-IZD-POD, PFI-IZD-KI, PFI-IZD-OSIG or PFI-IZD-ZSE when submitting financial reports that are submitted to Hanfa's reporting system in XML format (NOTE: for submission in XML format, you can use the prescribed forms in XLS format).

• When submitting semi-annual and/or quarterly reports, first submit them in XML format, as this submission includes a control for submission correctness, and only after receiving confirmation of successful XML file submission, submit them in PDF and XLS format.
  Select GIKU-UOU-DION, GIKU-UOP-DION or GIKU-UOP-OBV when submitting the compliance questionnaire for equity issuers and the governance practices questionnaire for equity/bond issuers that are submitted to Hanfa's reporting system in XML format (NOTE: for submission in XML format, you can use a file generated using the appropriate interface on Hanfa's website or another tool of your choice). Select PUO when submitting the list of insiders that is submitted to Hanfa's reporting system in XML format (NOTE: for XML format submission, you can use a file generated using the appropriate interface on Hanfa's website).
  3.3.1. Report: SRPI
  If you have selected the SRPI report, this view will appear.
  Here you submit prescribed and other information that is submitted to SRPI only in PDF format.

Select the entity for which you are submitting the report:
Select category:

Select language:
In "PDF datoteka" (PDF file), click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer)

Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in PDF format. Write the file name.
Repeat the procedure for "Potpis" (Signature).

3.3.2. Reports: SRPI-G, SRPI-P and SRPI-K
If you have selected one of these reports, this view will appear:
Here you submit annual (in SRPI-G), semi-annual (in SRPI-P) and quarterly (in SRPI-K) issuer reports in PDF and XLS files. Both files (PDF and XLS) for the same report must be submitted to the same SRPI report for Hanfa's reporting system to receive them as the corresponding SRPI report. Select the entity for which you are submitting the report:

Select the year for which you are submitting the report:
Select the language in which you are submitting the report:

Select whether the report is audited:
Select whether the report is consolidated:

Select whether the entity is an issuer of shares:
Select whether the entity is an issuer of debt securities:

Select the NKD code:

In "PDF datoteka" (PDF file), click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in PDF format. Write the file name. Repeat the procedure for "Potpis" (Signature). After that, in "XLS datoteka" (XLS file), click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XLS format. Write the file name. Repeat the procedure for "Potpis" (Signature). Finally, click "Predaj" (Submit) and the files will be submitted.

After the file is submitted, it is visible through SRPI.

3.3.3. Report: SRPI-G-ESEF
When an issuer submits an annual report in ESEF, during the submission of the annual report, they select as shown:
Select the entity for which you are submitting the report:

Select the year for which you are submitting the report:
Select the language in which you are submitting the report:

Select whether the report is audited:
Select whether the report is consolidated:

Select whether the entity is an issuer of shares:
Select whether the entity is an issuer of debt securities:

Select the NKD code:

When submitting the file, you need to click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer) and select the .zip file to be submitted.
Write the file name. Repeat the procedure for Signature.
After that, repeat the procedure for auditor's statements with the corresponding Signature according to audit regulations.
After the file is submitted, it is visible through SRPI. The image below shows an example of a submitted ESEF for a consolidated and an unconsolidated report.

3.3.4. Reports: GFI-IZD-POD, GFI-IZD-KI, TFI-IZD-POD, TFI-IZD-KI, TFI-IZD-AIF, TFI-IZD- OSIG, TFI-IZD-ZSE, PFI-IZD-POD, PFI-IZD-KI, PFI-IZD-OSIG, PFI-IZD-ZSE
If you have selected one of these reports, this view will appear:
Here you submit reports to Hanfa's reporting system in XML format using XLS forms.

Display of "Developer tab"
To generate an XML file, you need to enable the "Developer tab" in Excel:
By clicking on "File", the following menu will appear on the left side:
Select "Options". The following window will appear:

Select "Customize Ribbon" and then on the right side, select "Main Tabs" and check the "Developer" box.
Data entry
The appropriate Excel template needs to be filled with data. In each template, on the "Opći podaci" (General data) form, there is a "Šifra ustanove" (Institution code) field which is a number, and the codes of individual institutions can be found on the page http://reports.hanfa.hr/ by selecting the "XML sheme" (XML schemas) section. In that section are all XML schemas for all reports. After selecting the report you want to create, four files will appear:

By opening the file that contains the word "Liste" (Lists), a file with all institution codes of obligors for submitting individual reports will open. You can open the file in any internet browser. After opening the file, you will read the institution code as follows:
For example, the code of the company (institution) "Hrvatska elektroprivreda d.d." is 294. Note that the institution code is listed before the company name (Končar – Elektroindustrija d.d. has institution code 501, and Jadranski naftovod d.d. has institution code 568). Generating an XML file After you have filled in all the data, generate the XML file. The XML file is generated by selecting the "Export" function in the "Developer" tab:
After that, save the file locally to your computer.

Changing data
If for some reason you need to change data, enter the corrected data into the Excel file and repeat the procedure as described in the previous step.
Instructions for filling fields in financial statement forms (GFI, PFI and TFI) All fields in the form are mandatory to fill, meaning that if there is no specific data for a certain item, zero is entered in the cell (e.g., the part related to discontinued operations in the Statement of Comprehensive Income and all other cells for which there is no data). Similarly, if you are filling out the cash flow statement using the indirect method, you must enter zeros in the form for the direct method, and if you are filling out the cash flow statement using the direct method, you must enter zeros in the form for the indirect method. After you have generated the file in XML format. Select the entity for which you are submitting the report:

Select the year for which you are submitting the report:
Select the quarter for which you are submitting the report:

Select whether the report is consolidated:
In "XML datoteka" (XML file), click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XML format. Write the file name. Repeat the procedure for "Potpis" (Signature).

3.3.5. Reports: GIKU-UOU-DION, GIKU-UOP-DION, GIKU-UOP-OBV
For submission in XML format, you can use a file generated using the appropriate interface on Hanfa's website or another tool of your choice.
The interface on Hanfa's website for creating GIKU-UOU-DION, GIKU-UOP-DION and GIKU-UOP-OBV is available at https://reports.hanfa.hr/ as shown in the image below:
The link to the interface is in the pdf file named "Pristup aplikaciji za izradu XML datoteka" (Access to the application for creating XML files):

The interface opens by clicking on "Otvori aplikaciju" (Open application) or via a direct link as shown in the image below:
After filling out the questionnaire on the interface, generate an XML file, which is submitted to Hanfa's reporting system.
If you have selected one of these reports, this view will appear:
To submit reports to Hanfa's reporting system, upload the XML file generated via Hanfa's interface or another tool of your choice, and the separate signature file.

Select the entity for which you are submitting the report:
Select the year for which you are submitting the report:

In "XML izvještaj" (XML report), click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XML format. Write the file name. Repeat the procedure for "Potpis" (Signature).

3.3.6. Reports: PUO
For submission in XML format, you can use a file generated using the appropriate interface on Hanfa's website or another tool of your choice.
The interface on Hanfa's website for creating POU is available at https://reports.hanfa.hr/ as shown in the image below:
The link to the interface is in the pdf file named "Pristup aplikaciji za izradu XML datoteka" (Access to the application for creating XML files):

The interface opens by clicking on "Otvori aplikaciju" (Open application) or via a direct link as shown in the image below:
After filling out the PUO on the interface, generate an XML file, which is submitted to Hanfa's reporting system.
If you have selected this report, this view will appear:
To submit reports to Hanfa's reporting system, upload the XML file generated via Hanfa's interface or another tool of your choice, and the separate signature file.

Select the entity for which you are submitting the report:
Select the period for which you are submitting the report:

In "XML izvještaj" (XML report), click on "Odaberi datoteku" (Select file) / "Browse" (depending on the browser language Chrome/Internet Explorer). Then select the file stored on your computer that you intend to submit to Hanfa's reporting system in XML format. Write the file name. Repeat the procedure for "Potpis" (Signature).

3.3.7. Downloading confirmation
You will receive a confirmation of successful submission by clicking on "Potvrde" (Confirmations) in the menu on the left side.
Click on the icon (PDF) next to the desired report to download the confirmation.

The confirmation is generated in PDF format and looks like this (example):

TRANSITIONAL AND FINAL PROVISIONS
This Technical Instruction enters into force on July 29, 2026.
On the day this Technical Instruction enters into force, the Technical Instruction for obligors submitting prescribed information to the Official Register of Prescribed Information and the Croatian Financial Services Supervisory Agency of January 25, 2023 (CLASS: 011-01/23-01/06, REG. NO.: 326-01-60-62-23-1) ceases to be valid. CLASS: 011-01/26-01/04 REG. NO.: 326-01-60-62-26-1 Zagreb, July 29, 2026 DEPUTY CHAIRPERSON OF THE MANAGEMENT BOARD Anamarija Staničić

Annex I.
ACCESS FORM for using the data submission service to the Official Register of Prescribed Information and to the reporting system of the Croatian Financial Services Supervisory Agency

1. Information about the business entity (issuer) – obligor for submitting prescribed information
   ______________________________________________________________________________ name of the entity (issuer) ______________________________________________________________________________ registered office and address of the entity (issuer) ______________ __________________________ OIB (Personal Identification Number) contact phone number
2. Information about the authorized person designated for submitting prescribed information
   ____________________ __________________________ first and last name ID card number ________ signature of the person authorized to represent the entity (issuer) (Seal) In , dated