A. History and development of the Bank
Our legal and commercial name is Banco Macro S.A. We are a financial institution incorporated on November 21, 1966 as a stock corporation (sociedad anónima), duly incorporated under the laws of Argentina for a 99-year period and registered on March 8, 1967 with the public registry of commerce of the City of Bahía Blanca, in the Province of Buenos Aires, Argentina under no. 1154 of book 2, volume 75 of Estatutos. We subsequently changed our legal address to the City of Buenos Aires and registered it with the IGJ on October 8, 1996, under no. 9777 of book 119, volume A of sociedades anónimas.
We file reports, including our annual reports on Form 20-F, and other information with the SEC pursuant to the rules and regulations of the SEC that apply to foreign private issuers. The SEC maintains an internet site that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC. Any filings we make electronically with the SEC are available to the public over the internet at the SEC’s website at https://www.sec.gov.
Our principal executive offices are located at Avenida Eduardo Madero 1172, City of Buenos Aires, Argentina, and our telephone number is (54) 11 5222 6500. We maintain our website at www.macro.com.ar; information contained in or otherwise accessible through this website is not a part of this annual report.
We have appointed CT Corporation System as our agent for service of process in the United States, located at 28 Liberty St., New York, New York, 10005.
Our history – Banco Macro S.A.
We began our operations as a non-banking financial institution in 1985 with the acquisition of Macro Compañía Financiera S.A., originally established in 1977. In May 1988, we received authorization to operate as a commercial bank and were incorporated as Banco Macro S.A. Through subsequent mergers with other entities, we adopted different names, including Banco Macro Bansud S.A. Since August 2006, we have operated under the name of “Banco Macro S.A.”
From then onwards and up to 1994, we operated as a wholesale bank, being a pioneer in corporate bonds issuances. We mainly acted in the areas of money markets, trading of government and corporate bonds and financial services for medium and big companies.
Since 1994, we have substantially changed our business strategy, focusing on retail banking in market areas with a low level of banking transactions and high growth potential, particularly in the regional areas outside the City of Buenos Aires. Following this strategy, in 1996, we started to acquire entities as well as assets and liabilities resulting from the privatization of provincial and other banks, including Banco Misiones, Banco Salta and Banco Jujuy.
In 2001, 2004, 2006 and 2010, we acquired control of Banco Bansud S.A., Nuevo Banco Suquía S.A., Nuevo Banco Bisel S.A. and Banco Privado de Inversiones S.A., respectively, expanding through these acquisitions our presence in the south and center of Argentina. Such entities merged with us in December 2003, October 2007, August 2009 and December 2013, respectively. In addition, during 2006, we acquired control of Banco del Tucumán S.A., which was merged with us in October 2019. Additionally, on May 21, 2019, we acquired 100% of Argenpay SAU.
Additionally, on October 1, 2021, we decided to make use of the option to reach a 24.99% interest in Fintech SGR. The purpose of this company is to facilitate access to credit for SMEs through the provision of guarantees.
On October 15, 2021, we acquired shares representing 50% of the capital stock and votes of Finova SA. The purpose of this company is to develop and commercialize the electronic platform www.facturbo.com.ar, which allows the negotiation of credit instruments issued or accepted by corporate companies in favor of SMEs.
On May 18, 2023, we acquired 100% of the shares of Comercio Interior S.A.U. (currently known as Macro Agro S.A.U.) for U.S.$. 5,218,800 payable with the proceeds of the dividends of this company. The main purpose of this company is to be a Clearing and Settlement Agent (ALyC) and acquire brokerage license.
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In August 2023, we entered into a share purchase and sale agreement with Itaú Unibanco Holding S.A., through its subsidiaries Itaú Unibanco S.A., Banco Itaú BBA S.A., and Itaú Consultoria de Valores Mobiliários e Participaçoes S.A. (collectively, “Itaú”), by virtue of which we acquired from Itaú the shares representing 100% of the capital stock and votes of Banco Itaú Argentina S.A. and directly 13% of the capital stock of Banco Itaú Argentina S.A. and directly 13% of the capital stock and votes of Itaú Asset Management S.A. and Itaú Valores S.A. and indirectly 87% of the capital stock and votes of Itaú Asset Management S.A. and Itaú Valores S.A. On November 2, 2023, the Board of Directors of the Central Bank authorized the aforementioned purchase, which became effective on November 3, 2023.
On March 6, 2024, we, as an incorporating company, together with Banco BMA S.A.U. (formerly Banco Itaú Argentina S.A.), as an incorporated company, entered into a pre-merger agreement, whereby Banco BMA would be incorporated into us retroactively as of January 1, 2024 based on the separate financial statements of each of the companies prepared as of December 31, 2023 and the special consolidated merger statement of financial position as of the same date. On November 1, 2024, the Central Bank granted authorization for the merger by incorporation with Banco BMA S.A.U., and on November 14, 2024, the merger became effective upon registration with the Public Registry.
On December 17, 2024, the Boards of Directors of Macro Fondos and Macro Securities each resolved to carry out merger by absorption processes. Macro Fondos was merged into and with BMA Asset Management SGFCISA, and Macro Securities was merged into and with BMA Valores SA. On September 11, 2025, and September 29, 2025, respectively, the Inspección General de Justicia (Public Registry) approved the aforementioned mergers and the dissolution without liquidation of BMA Valores SA and BMA Asset Management SGFCISA, which was retroactively effective from January 1, 2025.
Since 2020, we have made capital contributions to Play Digital S.A. resulting in an ownership interest of 11.04% as of the date of this annual report, including contributions made by Banco BMA prior to our acquisition of it. The company’s corporate purpose is to develop and market a payment solution linked to users’ bank accounts within the financial system, with the objective of significantly enhancing their payment experience. Initially, the shareholders, including us, were Banco de Galicia y Buenos Aires S.A.U., Banco BBVA Argentina S.A., and Banco Santander Argentina S.A. Subsequently, additional financial institutions became shareholders, expanding the original group.
On January 1, 2025, we acquired control over Alianza SGR, with significant influence exercised through our representation on the Board of Directors. The main objective of this company is the granting of guarantees.
Additionally, on January 22, 2026, we entered into a joint business agreement with Telecom Argentina S.A. and its directly and indirectly controlled subsidiaries, Micro Fintech Holding LLC and Micro Sistemas S.A.U. Pursuant to this transaction, we acquired 50% of the capital stock and voting rights of Micro Sistemas S.A.U. for an amount in Pesos equivalent to U.S.$75,000,000. The strategic purpose of this transaction is to enhance the growth and regional expansion of such entity, which operates as a payment services provider under the Personal Pay brand.
On March 20, 2026, Banco Macro and Fintech Digital LLC entered into a stock purchase agreement to jointly acquire, directly and indirectly, all of the issued and outstanding capital stock and voting rights of Banco Sáenz S.A., subject to the fulfillment of certain conditions precedent and approval by the Central Bank. This strategic transaction is part of our expansion into the digital ecosystem and complements our recent entry into Personal Pay—the digital wallet of Personal—developed by Telecom Argentina S.A.
We currently offer traditional bank products and services to companies, including those operating in regional economies, as well as to individuals, thus reinforcing our objective to be a multi-service bank.
In addition, we perform certain transactions through our subsidiaries and controlled entities, including mainly Macro Bank Limited, Macro Securities S.A.U., Macro Fiducia S.A.U., Macro Fondos S.G.F.C.I. S.A., Argenpay S.A.U., Fintech S.G.R., Macro Agro S.A.U., and Alianza S.G.R.
Our Class B shares have been listed and traded on the BYMA since November 1994 and traded on A3 Mercados since October 2015. Before March 5, 2025, A3 Mercados was known as the MAE. The trading symbol for both exchanges is ‘BMA’. Additionally, our ADSs have been trading on the NYSE since March 2006 under the symbol ‘BMA’.
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B. Business overview
We are one of the leading private banks in Argentina and the largest in terms of number of branches, with excellent face-to-face service complemented by digital channels. Through these channels, we provide solutions to key players that generate economic and social value (public sector, corporate companies, and corporations), and promote the accessibility and financial inclusion of people from vulnerable sectors, professionals, entrepreneurs, and small and medium-sized companies. We substantially conduct our activities in Argentina.
According to the Central Bank, as of December 31, 2025, we were ranked first in terms of branches, second in terms of net equity, and fourth in terms of total loans and in terms of total deposits among private banks in Argentina.
As of December 31, 2025, on a consolidated basis, we had:
• Ps.23,239,424.0 million (U.S.$15,923.8 million) in total assets;
• Ps.10,708,315.0 million (U.S.$7,337.4 million) in total loans and other financings;
• Ps.13,690,637.8 million (U.S.$9,380.9 million) in total deposits;
• approximately 6.4 million retail customers and 0.2 million corporate customers; and
• approximately, 1.2 million customers with employee payroll accounts for private sector and provincial governments and 0.8 million retiree customers.
Our consolidated net income for the fiscal year ended December 31, 2025, amounted to Ps. 290,705.8 million (U.S.$199,193.2 million), representing a return on average equity of 5.55% and a return on average assets of 1.41%.
In general, given the relatively low level of banking intermediation in Argentina, there are limited products and services being offered. We are focusing on the overall growth of our loan portfolio by expanding our customer base and encouraging them to make use of our lending products. We have a holistic approach to our banking business and do not manage by segments or divisions or by customer categories, by products and services, by regions, or by any other segmentation for the purpose of allocating resources and assessing profitability. We offer savings and checking accounts, credit and debit cards, consumer finance loans and other credit-related products and transactional services available to our retail customers and SMEs through our branch network. We also offer Plan Sueldo payroll services, lending, corporate credit cards, mortgage finance, transaction processing and foreign exchange. In addition, our Plan Sueldo payroll processing services for private companies and the public sector give us a large and stable customer deposit base.
Our competitive strengths
We believe we are well positioned to benefit from opportunities created by the economic and business environment in Argentina. Our competitive strengths include the following:
• Strong financial position. As of December 31, 2025, we had excess of regulatory capital of Ps. 3,614,321.3 million (30.6% capitalization ratio). Our excess capital is aimed at supporting growth, and consequently, a higher leverage of our balance sheet.
• Strong shareholders’ equity. As of December 31, 2025, 2024, and 2023, our total shareholders’ equity amounted to Ps. 5,234,546.4, Ps. 5,328,662.2 million, and Ps. 5,840,268.9 million, respectively.
• Strong presence in fast-growing target customer market. We have achieved a leading position with low- and middle-income individuals and among SMEs, generally located outside the City of Buenos Aires, which have been relatively underserved by the banking system. Based on our experience, this target market offers significant growth opportunities and a stable base of depositors.
• High exposure to export-led growth. Given the geographical location of the customers we target, we have acquired banks with a large number of branches outside of the City of Buenos Aires with the aim of completing our national coverage. Our focus is particularly on some export-oriented provinces. Most of these provinces engage in economic activities primarily concentrated in areas such as agriculture, mining, cargo transportation, edible oils, ranching and tourism, which have benefited from the export-driven growth in the Argentine economy.
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• Largest private-sector branch network in Argentina. With 444 branches and 2,016 ATMs, as of December 31, 2025, we have the most extensive branch network among private-sector banks in Argentina. We consider our branch network to be our key distribution channel for marketing our products and services to our entire customer base with a personalized approach. In line with our strategy, approximately 90% of these branches are located outside of the City of Buenos Aires.
• Loyal customer base. We believe that our customers are loyal to us due to our presence in traditionally underserved markets and our Plan Sueldo payroll services. We have benefited from Argentine regulations that require all employees to maintain Plan Sueldo accounts for the direct deposit of their wages. In addition, we emphasize face-to-face relationships with our customers and offer them personalized advice.
• Exclusive financial agent for four Argentine provinces. We perform financial agency services for the governments of the provinces of Salta, Jujuy, Misiones and Tucumán in northern Argentina. As a result, each provincial government’s bank accounts are held in our bank and we provide their employees with Plan Sueldo accounts, giving us access to substantial low-cost funding and a large number of loyal customers.
• Strong and experienced management team and committed shareholders. We are led by committed shareholders and a senior management team with large experience in the banking industry, who have transformed us in one of the strongest and largest banks in Argentina.
Our strategy
From a culture of closeness to the people as a differentiating seal, we seek to integrate customer knowledge with innovative systems that offer solutions, products and services that go further than the traditional banking scheme; to positively impact the communities where we are present. Our strategic vision is to change the way of banking in Argentina: Argentina to think big, in Macro.
2030 Business Strategy
During 2025, we defined our 2030 Business Strategy. We believe that we are very well positioned to capture profitable and sustainable growth opportunities in an environment of increased competition and efficiency demands. On this basis, we have developed a clear and actionable roadmap towards 2030, combining a vision of leadership in customer experience with a simpler, more efficient, and scalable operating model. This strategy is supported by pillars that integrate the best of technology with personalized human service, and is aligned with our Corporate Sustainability Strategy and our value creation model.
We are in a privileged position to capture the opportunities arising from Argentina’s new macroeconomic and financial environment, characterized by macroeconomic consolidation with growth, market opening, deregulation, and the structural transformation of the financial system, in an environment of increased competition and efficiency demands.
In this context, we have defined a clear, credible, and actionable roadmap through our 2030 Strategy, the objective of which is to consolidate our position as the leading bank for a greater Argentina, recognized for our excellence in service, closeness to customers, and a differentiated value proposition aimed at maximizing sustainable value creation for shareholders, investors, and all our stakeholders, combining the best of technology with personalized human service.
The 2030 Strategy is structured around four fundamental pillars, managed through critical enablers, which will allow us to continue growing market share by improving NPS, customer primacy, and share of wallet. At the same time, efficiency improvements will accompany the capture of growth in the local financial system and sustained value generation.
We have strong financial and positioning strengths based on a solid financial position with, one of the highest solvency levels in the system, the largest capital surplus in the market, and controlled risk. With the most extensive branch and ATM network among private banks in Argentina and a strong federal presence, we are a benchmark in customer experience, geographic capillarity, and close customer relationships.
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Operational Transformation and Value Creation
We are executing a deep transformation of our operating and commercial model, which includes:
• modernization of our technology architecture and digital platforms;
• comprehensive redesign of the onboarding process for individuals and corporate customers;
• development of a new value proposition for SMEs and corporate customers through comprehensive digital platforms;
• strengthening of our advisory and wealth management capabilities; and
• deployment of a new “primacy engine” based on loyalty programs, segmented pricing, and advanced commercial management.
We believe that this transformation will enable us to significantly improve commercial productivity, operational efficiency, customer retention, and the structural profitability of the business.
The execution of the 2030 Strategy is supported by a solid organizational culture based on values, meritocracy, accountability, customer orientation, and an entrepreneurial spirit. We have consolidated a leadership model that promotes innovation, collaboration, and execution excellence, constituting a competitive advantage that is difficult to replicate in the Argentine financial system.
To translate strategy into results, we combine financial strength, commercial leadership, federal scale, transformation capability, and disciplined execution, with a focus on converting improvements in customer experience and relationships into profitable growth.
This is complemented by greater operational efficiency and prudent risk management, in order to profitably capture the expansion of the Argentine financial system and sustain long-term value creation.
Corporate Sustainability Strategy
Our Corporate Sustainability Strategy is structured around four fundamental pillars, designed to translate our sustainability policy into concrete and measurable actions that respond to the expectations and needs of our stakeholders and actively contribute to the United Nations 2030 Agenda.
1. Governance and Ethics for Resilience and Trust Commitment: to continuously strengthen our corporate governance structure, ethics and transparency, as well as comprehensive risk management, to ensure our sustainability, the trust of our stakeholders, and sustainable economic performance that generates shareholder value and drives the country’s development.
2. Responsible and Innovative Business Commitment: to develop a banking business that not only meets the financial needs of our customers, but also promotes inclusion, information security, an exceptional customer experience, digital transformation, and the creation of financial products with a positive impact on the sustainable development of Argentina.
3. Human and Sustainable Development Commitment: to foster a work environment that promotes the well-being, development, and diversity of our human capital, while contributing to the social and sustainable development of the communities where we operate, prioritizing human rights and the generation of opportunities throughout our operations.
4. Positive Environmental Impact
Commitment: to actively manage our direct impact through carbon footprint reduction, promoting energy efficiency, emissions reduction, and environmental awareness; and through sustainable financing, thereby contributing to the fight against climate change and the protection of natural resources.
The year 2025 was particularly significant in terms of sustainability. We updated our Sustainability Policy and defined our ESG Corporate Sustainability Strategy, aligned with our purpose and with a comprehensive vision of economic, social, and environmental value creation.
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This process included a review of material topics under a double materiality approach, a systematic analysis of impacts, risks, and opportunities, and the participation of more than 85 leaders from key areas in the definition of objectives and indicators. On this basis, we advanced in the design of the ESG Action Plan 2026-2030, integrated into our value creation model and aligned with international reporting standards, the principles of the United Nations Global Compact, and the Sustainable Development Goals.
During the year, we reviewed our material topics and worked particularly on the definition of the impacts, risks, and opportunities associated with each of them, in coordination with the Risk Management Area and all our key areas. “Impacts” are understood as those that we generate towards our stakeholders (financial materiality), while “risks and opportunities” refer to the consequences that the economic, social, and environmental context has on our business (impact materiality).
As a result, a set of key performance indicators were established to measure compliance with the commitments assumed in terms of sustainable development, inclusion, integrity, and good governance, thereby strengthening our role as a relevant player in the Argentine financial system.
Additionally, during 2025 we made progress in adapting to international accountability standards and frameworks, including IFRS S1 “General Requirements for Disclosure of Sustainability-related Financial Information” and IFRS S2 “Climate-related Disclosures,” the Sustainability Accounting Standards Board (SASB) and the GRI Standards (Global Reporting Initiative).
Client portfolio, products, and services
We focus on providing financial solutions tailored to each client, prioritizing service quality and the digitalization of processes and operations. We strive to ensure that our more than six million clients have an exceptional experience with us, fostering satisfaction and the primacy of our service across a broad portfolio of individuals, businesses, and organizations of various profiles that make up our clientele. With a portfolio of products and services for every type of person, company and organization, we seek to transmit drive and optimism to think big from a wide range of solutions and services with knowledge, proximity and innovation.
This commitment is reflected in our innovation and our ability to adapt in a constantly evolving financial environment, where digitalization and customer experience are fundamental pillars in strengthening our competitive position.
We offer a relatively narrow range of standard products, which are generally available to both our retail and corporate customers. We have a holistic approach to our banking business and do not manage by segments or divisions or by customer categories, by products and services, by regions, or by any other segmentation for the purpose of allocating resources and assessing profitability. Our strategy is to grow our business, as demand for credit in Argentina increases, by focusing on cross-selling opportunities among our broad customer base. The following discussion of our business follows broad customer categories of retail and corporate as a way to understand who our customers are and the products and services that we provide.
Digital transformation constitutes a strategic pillar and is grounded in a cultural shift in how we manage the business, aimed at driving innovation, agility, and strengthening a data-driven, human-centered culture with efficient and sustainable thinking that continuously places the experience of our more than 6.5 million customers at the center.
Within this framework, during 2025, we advanced in the digitalization of processes and services, incorporating new technologies—including artificial intelligence—to optimize operations, enhance the personalization of our products and services, and improve efficiency in each interaction.
In line with this evolution, we continue to develop financial solutions tailored to the needs of individuals, companies, and organizations of various profiles, prioritizing service quality and an exceptional experience at all touchpoints. This approach reinforces our competitive positioning and commitment to an increasingly diverse, active customer base that is fully integrated into the digital ecosystem
The composition of our customer portfolio is as follows:
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Participation by banking segment in the portfolio 2025 2024 2023(1)
Companies 41.6 % 40.0 % 45.2 %
Individuals 41.3 % 46.6 % 47.3 %
Corporate 14.9 % 11.9 % 7.3 %
Government 2.0 % 1.1 % 0.2 %
Finance 0.1 % 0.4 % 0.1 %
Notes:-
(1) Banco BMA not included.
Retail customers
Overview
We serve our retail customers with the objective of satisfying their financial needs, whether savings, transactional or funding. Retail customers are classified according to their labor condition or their main income source, in the following categories: Plan Sueldo (Salary Plan), Retirees, Open Market and Professionals and Business. We provide services to them throughout Argentina, in particular in areas outside the City of Buenos Aires, which have higher concentrations of low- and middle-income individuals who are traditionally underserved by large private banks. We serve our retail customers through our extensive, nationwide branch network. Approximately 90% of our branches are located outside the City of Buenos Aires.
The table below reflects the number of retail customers broken down by category as of December 31, 2025, 2024 and 2023:
Retail Customers by category 2025 2024 2023(1)
Open Market 3,761,310 3,392,175 2,851,104
Plan Sueldo (private and public sector) 1,163,156 1,083,656 1,063,314
Retirees 805,387 816,077 766,474
Professionals and business and others 629,093 830,138 282,255
Total Retail Customers 6,358,946 6,122,046 4,963,147
Notes:-
(1) Banco BMA not included.
Additionally, based on a thorough credit evaluation, we categorize our clients according to their profile and needs into: Macro Selecta, Preferential, Mass Market, and Young clients. We completed the integration and relaunch of customized offerings for our clients across different segments.
We offer our retail customers traditional banking products and services, such as savings and checking accounts, time deposits, credit and debit cards, consumer finance loans (including personal loans), mortgage loans, automobile loans, overdrafts, credit-related services, home and car insurance coverage, tax collection, utility payments, ATMs and money transfers.
Our retail customers provide us with a key source of funding as well as a significant interest and fee income. We believe that our large retail customer client base provides us with an excellent opportunity to expand the volume of our lending business.
Our efforts have been aimed at strengthening relationships with our customers by offering them the products that are best suited to their needs and circumstances, through our individualized, professional advice, which we believe is an important feature that distinguishes us in our target markets. Likewise, we have focused on increasing the volume of new customer acquisition with focus on those segments that allow greater efficiency and better result of the cost/benefit equation.
Our main goals for the retail bank are to keep our leading position in personal loans, and steady growth in the credit cards portfolio. In this regard, and aiming to continue growing in the credit card market, we intensified efforts to increase consumption and total assets. We also improved the use of our clients’ information as a tool to implement better cross selling, client retention and default prevention commercial actions.
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The year ended December 31, 2025 was marked by strong commercial momentum, in line with brand transformation and business modernization. Growing customer interest in digital and self-service solutions was reflected in an 18% increase in digital account openings and the consolidation of the new acquisition process for our “Plan Sueldo”, which recorded a growth of 469%. These advances were made possible by an increasingly precise and effective strategy, aimed at delivering the most appropriate value proposition and message to each customer.
Savings and checking accounts and time deposits
We generate fees from providing account maintenance, account statements, check processing and other direct banking transactions, direct debits, fund transfers, payment orders and bank debit cards. In addition, our time deposits provide us with a strong and stable funding base.
Our commercial and customer bonding actions enable us to achieve growth in the deposit portfolio above market levels, mainly due to an increase in time deposits of retail customers which intensified funding diversification.
Accounts and account packages are the primary channels for cash deposits and are two of the main drivers of fee income. For this reason, we focus on the life cycle of the account packages, promoting loyalty measures and retention of our products. Account packages are growing year after year in terms of volume and quality. During the last few years, the offer was adapted in order to continue offering products and services according to the needs of each customer type and category.
In the last years, the user experience was enriched through the incorporation of new functionalities in the mobile application, providing customers with the necessary agility in their daily operations, as well as in the process of registering and unlocking passwords. The value offering was reinforced through the introduction and renewal of benefits and incentives aligned with the changing needs and demands of the various customer segments.
Growth also continued in the area of digital payments and collections, driving bankability with the strategic support of MODO. We continue to invest in digitalization and the reduction of cash usage, encouraging QR payments through virtual wallets to also include the unbanked population. In 2024, we expanded our user base within the digital payment wallet ecosystem (MODO, Google Pay, Apple Pay, viüMi, SAETA, and Macro Click).
This proactive approach reflects our ongoing commitment to innovation and adaptation to a constantly evolving financial environment.
In order to improve our customers’ experience, we implemented significant improvements in the 100% digital account opening process, allowing 7x24 management with the possibility of downloading the Macro App and starting to operate at the same time.
We continued working to improve the value proposition, with the objective of becoming the main bank for our customers. The sustained growth year after year, both in volume and quality of the packages, attests to this effort. The number of saving accounts increased 9% by 2023, 28% by 2024 and 17% by 2025.
Our “debit card” service is critical within the framework of our strategy to increase customer transactions by encouraging the use of accounts. Debit card services also help to develop account balances into transactional accounts, as deposits increase, thereby expanding our demand deposit base. During 2024, we worked on optimizing the performance of accounts and packages with a focus on customer experience and process digitalization. Every year, we grow in volume and quality of accounts, expanding our market share. This is the result of our efforts to offer a value proposition that is increasingly adapted to new needs, with the aim of positioning ourselves as the bank of choice for our customers. For example, we developed the complete digitalization of account opening and management through digital channels at any time of the day and week, while we also extended the validity of debit cards so that customers could continue to make ATM withdrawals and not be forced to go to the branch.
The number of debit cards we issued increased by 10% in 2023 and 26% in 2024. Although the number of debit cards decreased by 8% in 2025, debit card consumption increased by 11%. Active card accounts represent 20% of the total financial system.
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The following table reflects the number of retail accounts as of December 31, 2025, 2024 and 2023:
Product 2025 2024 2023(1)
Savings
Total savings accounts 9,648,201 8,268,757 6,432,367
Open Market 4,878,342 4,059,858 3,319,680
Retirees 1,519,180 1,226,303 1,096,770
Plan Sueldo (private sector) 1,480,424 1,126,427 1,015,727
Plan Sueldo (public sector) 807,412 688,878 684,090
Professionals and business and others(2) 962,843 1,167,291 316,100
Checking
Checking accounts 664,984 671,605 604,438
Electronic Account Access
Debit cards 5,897,297 6,408,185 5,102,078
Notes:-
(1) Banco BMA not included.
(2) Includes welfare programs.
Lending products and services
We offer personal loans, document discounts, residential mortgages, overdrafts, pledged loans and credit card loans to our retail customers.
We intend to continue to increase our retail lending by focusing our marketing efforts on underserved target markets such as low and middle income individuals. We also plan to continue to cross-sell our retail lending products to our existing customers, particularly targeting those who may choose to open savings and checking accounts with us because we already provide their payroll and pension services.
Also, by putting into practice the “Pensá en Grande, Pensá en Macro” and respecting our values such as closeness, agility, pride and protagonism, we incorporated the customer’s viewpoint in each process to better accompany them in the achievement of their goals.
Among the main value propositions, we offer a wide variety of credit options designed to meet our customers’ needs, even in remote locations in Argentina, and we develop small loans or personal loans based on agreements with municipalities, so that people with a low level of banking penetration can access the benefits of the financial system while limiting their exposure to unregulated loans. We offer personal loans through 100% digital channels for customers and non-customers and with new processes to finance the purchase of products or services, not only within the bank, but also at different points of sale, through a wide network of stores with agreements, incorporating people with a low level of banking penetration into the system.
The improvement of credit evaluation tools and engines generated an increase in the nominal rating ceilings, to provide a better quality of response to the client. In addition, we added the possibility of choosing the amount and term that best suits the client’s needs at the moment they take a loan through ATMs.
2025
With a commitment to implementing improvements that have a direct impact on customers, we are working on the development of a new loan pricing system that contemplates greater specificity in rate definition, allowing us to reach customers with more accurate commercial proposals and higher profitability.
In 2025, our loan portfolio recorded growth exceeding that of the prior year, with outstanding performance in the public employees and retirees segments.
More than 1.5 million personal loans were granted, representing a 92% increase in origination volume. Additionally, mortgage loans recorded a 75% year-over-year growth.
In 2025, personal loans and payroll advances were primarily processed through digital channels, while mortgage loan origination was conducted exclusively through our branch network.
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2024
In 2024, the decline in inflation and the economy showing signs of greater stability also led to exponential growth in private credit, in addition to the return of mortgage credit. By December 2024, the stock of credit in Pesos to the private sector had increased by 49.4% year-over-year in real terms. Mortgage lending, though still below 2018-2019 levels, regained momentum in the second half of the year, growing 3.7% in real terms in December and 30.1% year-over-year, with approximately 3,200 new mortgage borrowers entering the financial system, mostly under UVA-adjusted loans.
We strengthened our offering of pre-approved personal loans with significant growth in our portfolio, but the most notable development was the launch of mortgage loans for first and second homes, with financing terms of up to 20 years. In particular, the “young line” stands out, aimed at clients under 30 years old with salary deposits at Banco Macro, with the option to combine contributions with their parents, allowing financing of up to 90% of the property’s value.
We continue to position ourselves as the leading private bank in benefit payments for the Plan Sueldo segment, reaching 816,077 people and managing a monthly payment volume exceeding $380 million. With the acquisition of Banco BMA, the portfolio was increased by more than 15,000 clients in this segment.
2023
With the aim of promoting banking penetration, in 2023 we carried out campaigns and commercial actions focused on offering a credit card, personal loans and credit assistance tailored to underbanked customers, to promote and consolidate various regional activities. The focus was on digital incorporation processes, facilitating the opening of accounts and access to benefits in different areas of the country through the use of channels and remote contact, simplifying interaction with the customer and encouraging self-management of processes to reinforce the message of simplicity and security in operations. In addition, the offer was complemented with a training proposal from the Cuentas Sanas program for a more conscious management of personal finances and/or their enterprises.
In 2023 we improved our positioning in the retirement segment, reaching more than 760,000 retirees and pensioners, being the private bank with the largest number of beneficiaries and with a volume of benefits paid out that reaches more than Ps.132,000 million every month. On the other hand, we launched the campaign for the recovery of retirees, aimed at people who decided to collect their assets in another bank.
As of December 31, 2025, 2024 and 2023, our consumer loan portfolio (without considering other financings) was as follows:
Consumer loan portfolio
(as of December 31, of each year)
(in millions of Pesos and as percentage of consumer loan portfolio)
2025 2024(1) 2023(1)
Overdraft 94,380.14 1.6 % 48,711.05 1.1 % 30,689.29 1.2 %
Documents 342,665.92 6.0 % 228,279.61 5.3 % 150,028.13 5.6 %
Mortgage and pledge 794,369.73 13.9 % 565,937.38 13.1 % 341,936.56 12.9 %
Credit Card 1,761,805.14 30.8 % 1,734,601.48 40.2 % 1,327,213.93 49.9 %
Personal loans 2,348,696.20 41.1 % 1,517,918.73 35.1 % 682,240.17 25.7 %
Others 379,180.23 6.6 % 223,534.20 5.2 % 126,045.56 4.7 %
Total Consumer Loans 5,721,097.36 100.0 % 4,318,982.45 100.0 % 2,658,153.64 100.0 %
Notes:-
(1) Figures stated in millions of Pesos in terms of purchasing power of Peso as of December 31, 2025.
Plan Sueldo payroll services
Since 2001, Argentine labor law has provided for the mandatory payment of wages through accounts opened by employers in the name of each employee at financial institutions within two kilometers of the workplace, in the case of urban areas, and ten kilometers of the workplace, in the case of rural areas. There are similar requirements in place for pension payments.
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We handle payroll processing for private sector companies and the public sector, which require employers to maintain an account with us for the direct deposit of employee wages. Currently, we provide payroll services for the governments of the Argentine provinces of Misiones, Salta, Jujuy and Tucumán and to the private sector for a total aggregate of 2.0 million retail clients (including retirees). Our Plan Sueldo payroll services provide us with a large and diversified deposit base with significant cross-selling potential.
2025
With the purpose of positioning ourselves as the preferred option for payroll deposit services, we have driven a strategy based on three pillars: a focused approach to expand our market share in the private sector; loyalty and engagement initiatives supported by cross-selling actions; and a value proposition that addresses customers’ needs and enhances their experience throughout their entire lifecycle.
Commercial campaigns and the improvements implemented in processes and benefits are essential to strengthen customer acquisition, retention, and loyalty within this segment.
2024
To remain competitive, we enhanced our value propositions for clients with salary deposits. This was achieved not only through organic growth but also through the acquisition of Banco Itaú Argentina S.A., resulting in a 19% year-on-year increase in the private sector and a 24% year-on-year increase in private companies with salary agreements.
Additionally, following the acquisition of Banco Itaú Argentina S.A., we added 55,000 clients to our Plan Sueldo segment and more than 3,000 corporate clients.
Corporate customers
Overview
Legal and natural persons of the private non-financial sector that develop commercial and/or industrial activities are included in the corporate customer category. We provide our corporate customers with traditional banking products and services such as deposits, lending (including overdraft facilities), check cashing advances and factoring, guaranteed loans and credit lines for financing foreign trade and cash management services. We also provide them trust, payroll and financial agency services, corporate credit cards and other specialty products.
The corporate business is focused on classification by size and sector. We have five categories of corporate customers:
(1) Corporate companies which register more than Ps.150,000 million in annual turnover, and also include subsidiaries of multinational companies;
(2) Medium and large sized companies (“MEGRAs”), which register more than Ps.20,000 million and up to Ps.150,000 million in annual turnover;
(3) SMEs, which register up to Ps.20,000 million in annual turnover;
(4) Businesses and Professionals, which includes individuals with independent commercial activity with an annual turnover of more than Ps.40 million; and
(5) Agricultural companies, which include individuals and companies who operate in agriculture or in the commerce of agricultural products.
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The following table reflects our portfolio breakdown, broken down by category as of December 31, 2025, 2024 and 2023:
2025 2024 2023(1)
Corporate companies 27 % 23 % 14 %
MEGRAs 11 % 12 % 18 %
SMEs 23 % 25 % 20 %
Business and Professionals 9 % 9 % 6 %
Agricultural companies 30 % 31 % 42 %
Notes:-
(1) Banco BMA not included.
We support productive activities through the promotion of development, new trends and innovation, since our goal is to continue offering the best services for market participants active in agriculture, industry and commerce. Based on values of close customer relationships, effort, hard work, dedication and community, we offer financing lines according to each customer profile that contribute to their growth, their development and that of their communities.
At present, we have a network of branches with business officials specialized in each category, offering a wide range of products, including working capital facilities, and credit for investment projects, leasing and foreign trade transactions.
Our corporate customer base also acts as a source of demand for our excess liquidity through overnight and short-term loans to large corporate customers.
See “Item 5.B. Operating and Financial Review and Prospects—Liquidity and Capital Resources.”
Lending products and services
We offer short-term and medium- to long-term corporate lending products.
Short-term: products include credit lines for up to 180 days and consist mainly of overdraft facilities, corporate credit and debit cards and factoring, as well as foreign trade related financing, such as pre-export, post-shipment and import financing. These products also include contingency lines, such as short-term guarantees (performance guarantees and bid bonds) and import letters of credit. The credit risk assigned to these kinds of transactions is the debtor rating described below, unless increased as a result of a pledge or a guarantee.
Medium- to long-term: products include credit lines and specific lending facilities of more than 180 days. Credits are usually asset-based, such as leasing, whereby a credit enhancement is achieved by means of the underlying asset.
Medium - to long-term facility risks are mitigated through different mechanisms that range from pledges and mortgages, to structured deals through financial trusts whereby the debtor pledges the underlying asset, mostly future income flows. Regardless of the term and based on the fact that these credit lines are devoted to small to medium-sized companies, our policy is to require personal guarantees from the owners, although the underlying debtor rating remains unchanged.
During the last years, our focus was SMEs and regional businesses, working to offer products and services tailored to each company profile, primarily based on size and the location of operations. Our management has been focused on consolidating our relationships with existing clients.
We supported the growth of SMEs through the development of businesses and sustainable links throughout the country. The geographic distribution, proximity, personalized attention and the knowledge of our clients and the regional economies allow us to detect their needs and support them in the financing of their projects, as well as to provide transactional solutions for the management of their payments and collections.
We have continued with actions aimed at financing small-scale client producers and suppliers of the value chain of our MEGRAs customers.
Within our Corporate Banking division (“Corporate Banking”), we sought to strengthen our relationship with existing and new clients, in order to position ourselves as one of the main banks in the corporate banking sector. This allowed us to provide specialized assistance to each of the companies which constitute the different value chains, with products tailored to their needs.
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2025
Within our Corporate Banking division, we support the treasury flows of our clients by offering investment and financing solutions for the different value chains. We also seek to expand digital solutions within the collection and payment ecosystem with the objective of becoming a technological partner, leveraging our strong client relationships and coordination with other related companies.
During 2025, the focus of the Megra Banking value proposition was centered on supporting the improvement of client productivity, primarily in the areas of treasury, collections, and payments. Through Macro Soluciones, we offer a set of technological tools that facilitate management: Última Milla, Collections Portal, Concentrador, Supplier Payments, Finova, among others.
In 2025, we reaffirmed our commitment to SME Banking, comprised of companies representing a wide diversity of productive sectors. We deepened our comprehensive support strategy, consolidating a more accessible, flexible credit offering adapted to the specific characteristics of each activity. In parallel, we strengthened strategic relationships with companies, promoting the centralization of their financial operations through digital solutions for collections and payments management.
We have advanced in the digital development of our Business and Professionals Banking through new functionalities in internet banking and improvements in the onboarding process, enhancing the customer experience. Among the 2025 milestones, we highlight the implementation of a federal training program for the network of business and professionals officers and select executives. Additionally, we optimized the credit offering and strengthened alliances with professionals and chambers of commerce, supporting the growth and strategic needs of this portfolio.
In 2025, we strengthened our support for the agricultural sector through solutions adapted to working capital and investment needs, expanding the client base, credit ratings, and product offerings with competitive rates. This year, we actively participated in Expoagro, the sector’s most important trade fair. We also promoted self-management through digitalization and deepened our in-person service model throughout the country. We continued strengthening the offering for the agricultural sector through digital financial solutions that support the needs of the productive ecosystem. Additionally, in 2025 we launched Crédito Simple Agro, a fully digital financing tool based on productive information and adapted to the specific characteristics of the sector. Through this solution, unique in the financial market, we qualified more than 4,000 clients, expanding access to credit and driving the sector’s development.
2024
In 2024, to enhance the corporate client ecosystem, we focused on promoting actions to increase transaction volumes across all products, especially digital ones. Collaborating with salary plan teams nationwide, we also focused on growing its salary plan base by fully leveraging our extensive branch network.
With the merger with Banco BMA, we improved our value proposition for over 12,000 clients who joined the Business and Professionals and SMEs segments.
We continued to strengthen our commitment to the country’s growth by supporting SMEs with a more flexible and accessible credit offering, tailored to the needs of a constantly evolving economic environment. Digitalization is a key pillar of our strategy, providing SMEs with new self-management tools that significantly improve the customer experience. In addition, we offer the sector a comprehensive proposal that focuses on financial accompaniment, specialized advice and strengthening their growth through internationalization with support for foreign trade operations. Our presence in strategic sectors continues to be strengthened with the launching of wine banking. At the same time, we continue to position ourselves in the franchise sector through strategic alliances with Franchising Co. and the Guía Argentina de Franquicias (Argentine Franchise Guide).
Additionally, we sponsor the NAVES Argentina Program, in a partnership spanning over ten years with IAE Business School—Universidad Austral’s Business School, to train and support the development of national SMEs and startups.
In 2024, the Business and Professionals segment saw a record client growth, driven by a leading market value proposition. Notable actions included the continued development of the referral campaign and new partnerships with trade chambers and professional associations.
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In the Agro Banking sector, we continued to support the agricultural industry by offering solutions to help businesses grow sustainably. Under this approach, we expanded the ratings, with a consistent, cost-effective and competitive offering of working capital and investment financing rates. Through digital initiatives, we also encouraged self-management. Furthermore, we deepened our service model that integrates the entire Agro value chain, offering differentiated relationship management based on operational scale and revenue levels.
We maintained our matrix-based service model across divisions and the Megra Banking Management, where joint service was provided by Megra officers and product specialists. Permanent in-person client visits foster closer relationships and improved service quality. Additionally, the integration of innovative digital solutions to increase automation and productivity in treasury management had a significant positive impact on the client portfolio, boosting cross-sell or cross-sales opportunities.
Regarding our Agro Banking division (“Agro Banking”), we continued to support regional economies with tailor-made products for sectors such as tobacco, sugar and yerba mate, by financing all value chains from the primary producer to the industrial producer.
2023
During 2023, we focused on attracting new customers, achieving annual growth rates of 11% in Business and Professionals, 10% in SMEs, and 6% in Megra and Agro. At the same time, we increased the cross-selling of the different products, improving by 10% the number of employers of Plan Sueldo and by 8% the total number of crediting capita. We deepened the value chain of the mining and oil & gas sectors, and the universe of franchises, leveraging the development of a comprehensive value proposition that includes, among other products, financing and new digital payment and collection solutions.
Corporate Banking focused on capturing the flow of customers’ cash balances, offering solutions in investment and financing products for the different value chains. We also focused on expanding digital solutions within the collection and payment ecosystem. In this way, we were able to increase the placement of non-traditional products, strengthening our position as a technological ally, leveraged on our proximity to customers and coordination with other related companies.
In 2023, the new matrix-based service model between the divisions and the Megra Banking Management, implemented in 2022, was further deepened due to the positive results achieved during its implementation. The joint approach to clients, involving Megra officers from each division along with product specialists (cash, trade, salary plan, investments), led to a significant increase in cross-selling while simultaneously improving service quality. Additionally, the integration of innovative digital solutions to enhance automation and productivity in treasury management had a widespread positive impact on the client portfolio.
We accompanied the SME segment with a better and more flexible credit offer, new self-management tools that improve the experience, digital collection and payment solutions that facilitate the daily management of customers, and the proximity and advice of specialized officers throughout the country. In addition, the year saw a significant growth in new clients as a result of the SME referral campaign and different regional actions carried out in the value chain of corporate companies. The alliance with Franchising Co. allowed us to organize events throughout the country, positioning ourselves as a benchmark bank in the franchise sector.
With the purpose of stimulating the development of regional economies, we increased the availability of credit lines backed by the national government, such as the Línea de Financiamiento para la Inversión Productiva, as well as other lines backed by the provincial governments of Salta, Jujuy, Misiones, Catamarca and Tucumán. These lines have rates subsidized by FONDEP (Fondo Nacional de Desarrollo Productivo) and guarantees provided by FOGAR (Fondo de Garantías Argentino), to encourage investments and facilitate financing for both investment and working capital through the CreAR Federal Lines.
We signed an agreement with BICE Fideicomisos to implement guarantees for first losses in order to streamline the credit operations of MSMEs and back up their transactions.
Finally, Banco Macro once again generated actions in conjunction with the Federal Investment Council (CFI), Acindar Pyme SGR and Cuyo Aval SGR in order to carry out operations with digital guarantees with the purpose of accelerating the process of execution of loans destined to the credit lines for the Productive Reactivation and for Regional Exportable Production.
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We recorded strong growth in business and professionals and commercial clients, leveraged by the simplification of the registration process, the business and professionals referral campaign and the commercial alliances made throughout the country with chambers of commerce and professional associations. In addition, we continued to develop our value proposition, making our credit offer more flexible and digitalizing our services. Among the outstanding launches, we highlight the possibility of registering commerce through internet banking for companies and the launching of QR Full Macro, which allows accepting payments with debit and credit cards.
We accompanied the countryside by expanding ratings, with a constant, profitable and competitive offer of financing rates for working capital and investment, standing out as an Argentine bank that closely accompanied the countryside, after a drought with a great impact on production levels and within the framework of a complex macroeconomic context. In this line, we boosted commercial interaction with more than 150 financing agreements (between manufacturers and suppliers of inputs), focused on the construction of digital solutions to be digital suppliers (Agro platform) and internal processes (New Agro Scoring) and on the incorporation of new non-banking commercial products within our commercial attention model, with the purchase of the Macroagro Grain brokerage firm, and the strategic alliance with the “Campo simple” input sales store within the Macroagro integral offer.
As of December 31, 2025, 2024 and 2023, our commercial loan portfolio (without considering other financings) was as follows:
Commercial loan portfolio(1) (as of December 31, of each year) (in millions of Pesos and as percentage of commercial loan portfolio)
2025 2024(2) 2023(2)
Overdraft 1,511,733.77 27.7 % 664,365.55 19.3 % 801,790.50 29.8 %
Documents 1,363,417.40 25.0 % 1,091,754.16 31.8 % 684,094.55 25.4 %
Mortgage and secured 415,182.74 7.6 % 258,571.79 7.5 % 191,767.99 7.1 %
Consumer loans(3) 84,343.35 1.5 % 79,994.64 2.3 % 61,675.83 2.3 %
Other 2,086,754.00 38.2 % 1,342,791.43 39.1 % 955,262.28 35.5 %
Total Commercial Loans 5,461,431.26 100.0 % 3,437,477.56 100.0 % 2,694,591.15 100.0 %
Notes:-
(1) Including loans to micro credit institutions and commercial loans that, for the regulatory statements of debtors, was included as consumer portfolio following the criteria described in “Argentine Banking Regulation—Credit Portfolio.”
(2) Figures stated in millions of Pesos in terms of purchasing power of Pesos as of December 31, 2025.
(3) Includes credit card loans and personal loans.
Government banking
The responsibility of government banking area is to manage the links and actions with the national, provincial and municipal public sector at both central and decentralized levels, as well as with the autonomous entities to which we provide financial services for their administration and the development of their communities.
2025
During 2025, we consolidated our leadership as a reference financial agent and as a GovTech player at the national level. We expanded our territorial coverage, deepened the digitalization of public services, and improved the financial results of the segment.
During the year, we onboarded more than 50 new clients, including provincial agencies, municipalities, and decentralized entities, with approximately 75% of these new accounts originating from jurisdictions where we do not act as financial agent. This growth reflects our ability to expand beyond our traditional base and responds to a GovTech approach that integrates technology solutions, territorial support, and a differentiated value proposition in tax collection, digitalization, and cash management.
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2024
Throughout 2024, we continued to support the development of regional economies and the growth of SMEs by expanding the availability of new financing lines. In the provinces of Salta and Jujuy, the regional governments subsidize a portion of the interest rate applicable to financing. In Misiones, subsidies are provided by the provincial government for the Productive Investment Financing Line (Línea de Financiamiento para la Inversión Productiva), as well as for specialized credit lines for tea producers and loans secured by work certificates. In San Juan, in collaboration with the provincial government, we promote a special financing line for investment projects, working capital, and technical assistance, funded through external sources, with a particular focus on productive renewal. Furthermore, together with various provinces, we have introduced working capital loan facilities secured by guarantees from Fintech S.G.R. and Alianza S.G.R., specifically intended to finance working capital needs.
2023
In 2023 from Government Banking, we continued with the purpose of digitizing governments and their communities, bringing solutions that simplify their daily lives, with a focus on providing technological solutions in the payment ecosystem, beyond traditional banking and financial services. We supported regional economies by implementing and renewing incentive programs and encouraged mass consumption, for example, through the extension to special holidays, with participation in discounts and financing during special holidays in collaboration with commerce chambers and provinces.
In 2023 we increased the availability of credit lines backed by the national government and the provincial governments of Salta, Jujuy, Misiones, Catamarca, and Tucumán. These lines have rates subsidized by FONDEP and guarantees provided by FOGAR, to encourage investments and facilitate financing for both investment and working capital.
We also promoted agreements with the government of the province of Misiones to support the wood drying kilns industry for the purchase of wood drying kilns; craft beer entrepreneurs for the acquisition of machinery and equipment and/or the adaptation of infrastructure and/or the purchase of raw materials; and yerba mate producers with working capital.
We also participated in the bidding process carried out by the San Juan Agency for the awarding of funds to be placed with MSMEs with investment projects in the province, including working capital and technical assistance.
Investment banking and finance banking
We serve the Institutionalized Financial Sector, which is regulated by the Central Bank, which includes Public and Private, National and Foreign Banks, who maintain relationships with the Central Bank of the Argentine Republic. We also serve institutional investors (Workers’ Compensation Insurers (ART), Insurance Companies, etc.). We provide financial and investment banking services -funds, bonds, corporate bonds- within the capital market.
2025
In 2025, we completed a new issuance of Notes (Class G) for U.S.$530 million, which recorded demand that tripled the offering and allowed us to close the transaction at a rate of 8% over a 5-year term.
Throughout the year, we participated in the placement of Genneia Notes Class 48 (local market) and Class 49 (international market), both classified as green bonds and aligned with ICMA’s Green Bond Principles 2021 and Argentine guidelines for sustainable issuances.
Additionally, regarding note issuances and placements, through our subsidiary Macro Securities we supported clients in transactions that reached a total of Ps.9,970,811 million, equivalent to 64% of market issuances measured in Pesos. Notable placements included those in the oil and gas, financial, consumer, and industrial sectors, earmarked for working capital, infrastructure, and liability refinancing.
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This result confirms strong investor appetite for high credit quality corporate instruments and reaffirms, once again, our strength and leadership in the Argentine financial market.
Macro Fondos, our subsidiary, consolidated its position in 2025 as the fourth-largest asset manager in the local market, managing over Ps.4.5 trillion. During the period, management focused on automation and system improvements to optimize the user experience.
Joint work with the development of our new app allowed us to eliminate operational frictions—such as those related to redemption for transfer—and advance toward a more agile and streamlined operation. In parallel, we sustained commercial and financial education initiatives aimed at offering an accessible investment product and strengthening our primacy across all segments.
Furthermore, through digital channels, Macro Securities offered brokerage services in 2025, providing clients with self-management capabilities for buying and selling shares, CEDEARs, government securities, notes, and MEP dollar. MEP dollar transactions were the prioritized product by the digital segment, representing a volume of U.S.$1,749 million. Total volume through digital channels was U.S.$480 million, with a total of 21,800 digital clients at year-end.
2024
During the first half of 2024, a decline in economic activity and a reduction in real wages were observed, primarily affecting consumption. In this context, there was a decrease in volumes generated by recurrent issuers in the trust market.
However, in the second half of 2024, a drop in interest rates, greater stability in inflation indexes, and the extension of terms helped boost the issuance of financial trusts. The market remained focused on consumer financing, with a smaller portion dedicated to agricultural financing.
The number of participants in the securitization market remained limited, with activity concentrated in a few entities that routinely issue new financial trusts. Three consumer-related companies accounted for 68% of the year’s issuances in terms of volume.
We participated in the issuance of financial trusts, with a total nominal accumulated amount of Ps.273,801 million (amount not restated) during 2024, representing 32% of the market’s frequent issuances, based on senior bond amounts.
Regarding the issuance and placement of notes, through Macro Securities, we have supported our clients, facilitating the placement of a total of Ps.4,416,425 million (amount not restated), representing 49% of market issuances, measured in Pesos.
2023
The year 2023 was characterized by constant increases in reference interest rates in response to the high levels of inflation and uncertainty in the context of an election year, complicating the structuring of the financial trusts and negatively affecting them. Additionally, the permanent increases in Peso rates generated increases in the subordination of the financial trusts due to the permanent mismatch between the rates of the assets and liabilities of the financial trusts, generating inefficient structures for the trustees.
Despite the market conditions, we continued to maintain our leadership in organizing and financing financial trusts with public offerings. Thus we participated in the issuance of Ps.127,301 million (expressed in senior bonds) (amount not restated) of financial trusts with public offering (54.72% of the issues, measured over the amount in Pesos of senior securities) and financial trusts in the order of Ps.6,202 million (amount not restated) were pre-financed. It thus remains in the top 10 of the main issuers in the market, representing 90.03% of the total issuers (always measured in senior bond amount), accompanying 57.64% of such issuers. The remaining 9.97% is distributed among different entities in the market, including us.
Regarding the placement of corporate bonds, through Macro Securities we supported our clients in the issuance and placement of corporate bonds for an aggregate amount of Ps.945,963 million (amount not restated), representing 49.85% of the market issuances, measured in Pesos. Notably, Banco Macro was the arranger, and Macro Securities was the underwriter of five green bonds for the financing of renewable energy projects. These corporate bonds are part of ByMA’s panel of Social, Green and Sustainable Bonds (SVS) and were allocated to renewable energy projects by Genneia and one by Surcos.
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Transaction services
We offer transaction services to our corporate customers, such as cash management, collection services, payments to suppliers, payroll services, foreign exchange transactions, foreign trade services, corporate credit cards, and information services, such as our Datanet and Interpymes services, described further below. There are usually no credit risks involved in these transactions, except for intra-day gapping (payments made against incoming collections), as well as settlement and pre-settlement related to foreign exchange transactions which, in general, are approved following the debtor credit rating process.
Payments to suppliers
Our payments for supplier services enable our customers to meet their payment obligations to their suppliers on a timely basis through a simple and efficient system. This service also provides payment liquidations, tax payment receipts, invoices and any other documents required by the payer.
Collection services
Our collection services include cash or check deposits at our 444 branches, automatic and direct debits from checking or savings accounts and the transportation of funds collected from corporate customers to our branches for deposit. Our extensive branch network enables us to offer fast and efficient collection services throughout Argentina, which is of critical importance to both regional and nationwide companies.
Datanet and Interpymes
We provide our corporate clients with access to the Datanet service (“Datanet”), which is an electronic banking network linking member banks in Argentina. This service permits our clients to obtain reliable online information on a real-time basis from their bank accounts in Datanet as well as, to perform certain transactions.
Interpymes is an electronic banking system designed to meet the needs of small businesses
It does not require special installation procedures and is easily accessible through the internet, helping to simplify day-to-day operations for our customers.
Tax collection and financial agency services
We also have exclusive, long-term arrangements to provide tax collection and financial agency services to four provinces: Salta, Misiones, Jujuy and Tucumán. These contracts expire in 2026, 2029, 2034 and 2031, respectively.
Payroll services
We provide payroll services to four provinces and to the private sector. See “Item 4.B. Business Overview—Retail customers.”
Our distribution network
As of December 31, 2025, we had the largest private sector branch network in the country, with 444 branches spread throughout Argentina. In particular, in line with our strategy of expanding nationally, we have extensive coverage in the Argentine provinces with 90% of our branches located outside the City of Buenos Aires. Furthermore, as of December 31, 2025, we had 2,016 ATMs, 922 self-service terminals (“TAS”) and several service points used for social security benefit payments and servicing of checking and savings accounts and internet home banking service. The following table breaks down the distribution of our branches per province as of December 31, 2025:
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Province Branches % of total
City of Buenos Aires 42 9.5 %
Buenos Aires (Province) 78 17.6 %
Catamarca 1 0.2 %
Chaco 1 0.2 %
Chubut 5 1.1 %
Cordoba 61 13.7 %
Corrientes 3 0.7 %
Entre Rios 9 2.0 %
Formosa — —
Jujuy 18 4.1 %
La Pampa 2 0.5 %
La Rioja 2 0.5 %
Mendoza 11 2.5 %
Misiones 30 6.8 %
Neuquén 5 1.1 %
Rio Negro 6 1.4 %
Salta 39 8.8 %
San Juan 1 0.2 %
San Luis 2 0.5 %
Santa Cruz 2 0.5 %
Santa Fe 81 18.2 %
Santiago del Estero 2 0.5 %
Tierra del Fuego 2 0.5 %
Tucuman 41 9.2 %
TOTAL 444 100.0 %
Technology, automated channels and credit cards processing systems
Our technological development is continuous, and the number of alternative methods to perform banking transactions is increasing. Automated channels allow our clients to perform banking transactions with enhanced speed, comfort, and safety, offering a wide variety of available transactions.
During the last three years, we have focused on automated channels, giving customers more accessible and flexible services. As a result, the use of automated channels continued to expand, both in terms of volume of transactions and number of users.
Digital transformation constitutes a strategic pillar for us and is grounded in a cultural shift in how we manage the business, aimed at driving innovation, agility, and strengthening a data-driven, human-centered culture with efficient and sustainable practices that continuously place the experience of our more than 6.5 million customers at the center.
2025
We have advanced in the comprehensive management of digital assets, unifying commercial and technological criteria to strengthen customer experience. The omnichannel approach, supported by a unified vision, data usage, CroMa, and continuous user interaction, drives dynamism, innovation, and discipline in the development of solutions.
To this end, we are working on the integration of all touchpoints—digital and in-person—to ensure a seamless, consistent, and frictionless experience, optimizing each instance of interaction. During 2025, the integration between different digital channels was key, providing direct access to BancoChat from self-service terminals and allowing customers to continue their transactions from their mobile devices.
Guided by a digitalization strategy aimed at simplifying operations for our customers, during 2025 we advanced in strengthening the digital offering and improving the usability of services. During the year, we recorded a 13% growth in digital channel users, reflecting sustained adoption and a greater preference for online transactions. Within the framework of digital channel growth, which reached 2.8 million users, around 300 thousand customers used only BancoChat, consolidating its position as a key channel for simple and assisted access to our digital services.
BancoChat consolidated its position as an initial contact channel and a companion in the digital relationship with customers, facilitating the progressive adoption of digital transactions. Through this channel, many users begin to interact with us digitally, resolving their inquiries remotely and strengthening their connection with our digital ecosystem.
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During 2025, we launched the new BancoChat, incorporating generative artificial intelligence. The new AI-powered transfer functionality allows customers to initiate transactions conversationally, streamlining the experience without the need to navigate through menus.
Regarding ATMs, we were one of the first to implement biometric customer validation, with fingerprint readers installed across our entire ATM network following the migration of the fingerprint database from the biometric engine to Newpay (Banelco).
Currently, we have 2,016 ATMs nationwide, representing 26% of the financial system’s network. 99% of the ATMs in our branch network are equipped with voice guidance service for visually impaired customers. In 2025, although transactions through this channel decreased due to the increased circulation of high-denomination bills, we remain the leader in the Banelco network.
As of December 31, 2025, we had 922 TAS (including smart self-service terminals (“TASI”)). During 2025, we advanced in the installation plan for the new TASI, replacing traditional TAS units. By year-end 2025, 819 TASI units were installed, covering branches throughout the country and expanding the availability of self-service solutions for customers. In branches equipped with TASI, this channel came to represent 18% of total cash deposits, contributing significantly to operational efficiency and improving customer experience by offering faster and more accessible operations.
2024
In 2024, we continued to focus on optimizing the customer experience through process digitalization. This effort encompassed both improving tools for self-management and remote operations, as well as simplifying procedures for in-person transactions, ensuring greater convenience and efficiency. Additionally, we prioritized enhancing the experience on our digital platforms.
We aimed to grow digitally, both in terms of offering and usability. The year 2024 saw significant growth, with a 24% increase in users across our digital channels, highlighted by a remarkable 466% increase in BancoChat users.
The total number of transactions through digital channels grew by 21%, with a notable 805% increase in transactions via BancoChat.
Digitalization is here to stay, as evidenced by the 2024 data:
• the use of digital services at branches exceeded 70% of all transactions;
• at the cashier counters, 73% of withdrawal transactions (accounting for more than 64% of all counter operations) were made using customer fingerprints for authentication, making the process quick, easy, and secure;
• in post-sale transactions at Self-Service Terminals, 93% used biometric authentication;
• at branches, the implementation of advanced origination allowed for almost 100% digitization of commercial processes, promoting the use of digital files and biometric holographic signatures, eliminating paper use and simplifying procedures; and
• we operate ATMs independent of branches, offering cash withdrawals, balance inquiries, and other services.
In 2024, we processed 26,376,422 monthly transactions, maintaining our leadership in the Banelco network with the largest share of operations across the entire network, handling 42% of transactions with just 25% of the equipment.
We developed a project aimed at replacing our entire TAS network, which includes the renewal of all equipment and the development of a revamped proprietary network with the latest software and hardware.
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We had 981 TAS machines distributed across our nationwide branch network, offering a wide range of services, including the ability to make deposits 24/7, every day of the year. In 2024, a total of 578,872 monetary transactions were processed via TAS, with the transaction volume increasing by 135% compared to 2023.
As part of the plan to reduce branch tasks, we continued to expand our network of TASI in recent years, allowing customers to perform transactions more efficiently and eliminating waiting times at branches.
In line with the TAS renewal project, we deployed and launched 558 TASI units, bringing the total number of operational machines to 799 nationwide. These units feature advanced technology with significant benefits: a substantial increase in the number of bills processed per transaction, immediate crediting, and improved operational efficiency. Thus, we contributed to achieving the goal of improving operational efficiency in our branches and, most importantly, providing a better experience for our customers.
2023
With a focus on proximity, digitalization and the transformation towards a new form of banking in Argentina, during 2023 the digital strategy was consolidated and deepened, leveraging on digital assets that we had already been developing and implementing.
We completed the implementation of our own biometrics system, which allows us to store the biometric features of customers (facial features and fingerprints) and perform transactions in self-management channels through this biometric identification, which reduces all kinds of friction, since the customer does not have to remember passwords and users, resolving them in a more efficient and secure way. This same process of biometric customer recognition began to be expanded to other sectors within the branch, such as the teller line, so that customers can now withdraw cash from their account with the use of their fingerprint, without the need for signatures.
Likewise, we continued to expand the technological devices located in the branches to facilitate customer self-management and digital education, both for after-sales and sales transactions, as well as the digitalization of processes with the creation of the digital file and the implementation of the biometric holographic signature, which eliminates the use of paper and simplifies procedures.
During 2023, we continued to advance in the implementation of digital solutions, incorporating operations and services to provide a better experience to customers in all segments. These advances include platform upgrades and functionalities to improve ease of use, provide more services and ensure security.
Within this framework, the role of communications and customer training was key to achieving the changes towards digitalization. To this end, actions focused on improving the self-management channels for Individual, Corporate and Organizational clients and providing online training to service users.
Seeking a new way of banking in Argentina, we implemented BancoChat, a new way of operating and interacting with customers, being pioneers in the industry, so that customers can operate in an easy, agile and safe way, leveraging security through the use of their biometric features. In this way, we bring solutions to the WhatsApp platform that customers use in their daily lives. BancoChat is a solution that operates on WhatsApp, a conversational platform that allows us to reach many more people with our products and services. In this way we bring Macro closer to where people are and with the technology, they use every day in their daily lives. BancoChat’s evolution will be constant, both in terms of expanding transactionality and improving the customer experience.
Our Macro Banca Móvil channel has developed significantly in the last years. In line with the characteristics of the users and the technological trends supporting the development of the service, the Macro Banca Móvil application is available in the main virtual stores of the principal operating systems. Over the last few years, we continue to work on new functionalities that generate value for clients: U.S. dollar purchase and sale transactions, transfers to new accounts, point checking and redemptions under our Macro Premia rewards program, and UVA loans detailed enquiries.
The significant sustained growth in the number of users and transactions made through automated channels has demonstrated the effectiveness and acceptance of this service in the market.
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Human capital
We are employment facilitators at the federal level, we support the professional development of our employees, favoring diversity and inclusion in the work environment. Considering diversity as a competitive advantage, we worked on the promotion of an inclusive culture that guarantees equal opportunities and safe spaces to grow, express opinions and debate. In each area we promote a culture of non-discrimination, respect and appreciation of diversity and inclusion so that all people feel encouraged to be authentic and feel part of it.
In recent years we have witnessed a significant change in the labor and business context, and in response to this, we took the initiative to generate changes at the level of people management, accelerating an important transformation and thinking, first and foremost, about on how to prepare the capabilities of each member to cope with these changes. Thus, this new way of managing was translated into two actions: building the loyalty of internal talent and becoming an attractive employer, in order to have the most outstanding people in the market. To this end, we began to review its value proposition, working hard on measuring the employee experience and adapting to new ways of working, becoming more agile and digital in its day-to-day management.
We focused on the continuity of a stage of organizational redesign in order to achieve a more horizontal structure that demonstrates the trust we have in each member of our organization.
With the idea of having committed and trained teams, new spaces and opportunities were created that influenced each person transversally, giving rise to a new way of working that is more autonomous, closer and based on trust. Based on the organizational redesign implemented, the foundations were laid for a new model of responsible self-management, providing more autonomy, allowing employees to take risks and make mistakes in order to improve themselves. At the same time, we fostered a leadership model, with the figure of leader-coaches who guide the actions of the teams of which they are part. These changes began to take shape in order to eliminate bureaucratic barriers to decision-making, optimizing workflows.
One of the main levers to accompany this collaborative culture was the implementation of Google Workspace for the entire staff, which fully impacted the way of working and communicating, leading us to a much more modern, agile and powerful state.
We position ourselves as an institution that values and promotes a professional profile characterized by enthusiasm, adaptability, resilience, innovation, and a strong commitment to customers. In this context, we work towards building results-oriented teams that are capable of thriving in dynamic environments and share corporate values to grow, evolve, and become a fundamental driver in the lives of millions of Argentinians.
In 2025, we developed training, internal mobility, leadership, and continuous feedback initiatives; we strengthened our employer value proposition; and we consolidated programs aimed at the comprehensive well-being, health, and safety of our employees, with nationwide reach.
We continue to promote a high-performance, innovation, and customer-oriented culture, supported by a comprehensive talent management model that drives continuous learning, adaptive leadership, and internal mobility. This model is complemented by equitable, competitive, and market-aligned compensation and benefits policies that strengthen the value proposition for our employees.
During 2025, we have implemented a restructuring plan in order to achieve operational efficiency and agility to respond to the ongoing challenges posed by local and international markets. At the same time, we optimized organizational efficiency through clear structures, defined roles, and strategic resource allocation.
We have been distinguished with the second position in the annual “Great Place to Work” ranking in Argentina (based on our employees’ perception throughout 2025), consolidating our position as one of the best companies to work for in the country. This distinction reflects the cultural evolution of the organization, enabling us to improve by five positions with respect to the previous year.
Within this framework, we continue to deepen our human capital model with a focus on people and the application of digital tools that allow employees to develop, think big, and implement their tasks in an environment of trust and personal growth in order to attract and retain the best talent.
Throughout 2024, we successfully integrated 1,292 new collaborators from Banco BMA. A series of initiatives facilitated their adaptation to the organization’s culture and processes, strengthening the integrated teams and solidifying the brand. The merger with Banco BMA presented an opportunity to incorporate new talent, but also posed a significant challenge in terms of rapidly achieving cultural and team integration. The diversity of talents was embraced as a driving force for growth.
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In 2023, with the philosophy of “para lograrlo, primero hay que pensar en grande,” we challenged the country and generated continuous growth, creating new sources of employment and ensuring the development of our teams for the new work environment.
Risk management policies
To comply with the “Risk Management Guidelines for Financial Institutions” set forth under Communication “A” 5398, as amended, we have adopted various measures at our organizational structure level and have implemented procedures to ensure the establishment of an independent risk management process.
Our Board of Directors created a Risk Management Committee (the “Risk Management Committee”) and appointed a Risk Manager and made them responsible for coordinating the application of risk management policies and the relevant responsible officers. For more information, see “Item 6.C. Board Practices.”
The Risk Management Committee, among other responsibilities, assures the establishment of an independent management of risk, lays out policies, procedures, measurement methodologies and feedback systems in charge of the identification, measurement and monitoring of risks, as well as the responsibilities of every level of the organization involved in the process.
Our risk management process includes setting of acceptable risk levels by our Board of Directors, monitoring of our compliance with such levels by responsible officers, the issuance of regular reports for the Risk Management Committee, follow up on alerts and the application of action plans in connection with such alerts and the guidelines for the development of stress tests.
Additionally, the system is supplemented with policies and procedures specific to each risk (financial, credit, operational, counterparty credit, country risk, securitization, reputational, compliance and strategic risks, among others).
The primary procedures developed by the Risk Management Department are:
• Stress tests: stress testing is a support tool for risk management and a complement to the results of risk measurement models. The objective of the tests is to assess our financial vulnerability potential in light of the sensitivity of the main variables affecting each risk.
In general, a variable with low probability of occurrence, but which if it materializes could lead to a significant overshoot in tolerance limits established for each risk. In addition, they are a tool for assessing the risk profile and are also used in the internal economic capital adequacy assessment process.
• Economic Capital Calculation: the economic capital calculation is developed for those risks that, due to their importance, could eventually affect our solvency. Risk management is directly related to the calculation of economic capital. Based on the internal models developed, we manage the risks, determine the risk profile, and therefore estimate the capital required for the development of the activities and business, adjusted to the degree of exposure to each risk.
Economic capital estimate
Economic capital is the estimated amount of unexpected losses identified for each one of the individual risks (Market, Liquidity, Interest Rate, Credit, Counterparty Credit, Concentration, Operational, Securitization, Strategic and Reputational) determined for us on a consolidated basis.
We have implemented a formal procedure for quantifying economic capital and it is a tool used in the day-to-day management of risks, in preparing the business plan and in the stress tests.
The methods used to measure the economic capital of each risk were documented and approved by management, pursuant to the internal rules on corporate governance and risk management.
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Liquidity risk
Liquidity risk is defined as the possibility that we may not be able to comply efficiently with expected and unexpected current and future cash flows, and guarantees without affecting our daily operations or financial condition.
Also, the market liquidity risk is understood as the risk that a position cannot be offset or unwound at the market price due to:
• that the assets do not have a sufficient secondary market; or
• market alterations.
We have policies on liquidity, which aim to manage it in an efficient way, optimizing the cost and diversification of funding sources, and maximize the utility of the colocations through a prudential management that assures the necessary funding for the continuity of the operations and the fulfilment of the current regulation.
We have implemented a series of measurement and risk control tools, including the regular monitoring of liquidity gaps, differentiated by currency, as well as various liquidity rations, including “bimonetary liquidity ratio,” “liquidity coverage ratio” (“LCR”), “net stable funding ratio” (“NSFR”), among others.
The Executive Risk Management Department regularly monitors compliance of the different levels set by our Board of Directors in relation to liquidity risk, which include minimum levels of liquidity, maximum concentration levels allowed by type of deposit and by type of customer, among others.
In the event of a liquidity crisis, we contemplate different actions within its contingency plan, such as: financing through interbank calls or borrowings against Central Bank; cash sale of securities portfolio; restriction in the granting of loans and increase in deposit interest rates in order to capture a greater volume of deposits. For more information, see note 52.4 to our audited consolidated financial statements as of December 31, 2025 and 2024.
Market risk
Market risk is defined as the possibility of suffering losses in our on and off-balance sheet positions as a result of adverse fluctuations in the market price of various assets.
Market risks include interest rate, foreign exchange, and price risks. We are exposed to general and specific market movements and changes in the level of price volatility such as interest rates, credit spreads, foreign exchange rates, and prices of shares and securities, among others. These risks arise from the size of the net positions held by us and/or the volatility of the risk factors involved in each financial instrument.
We have policies for the management of market risk in which the processes of monitoring and control of the risks of variations in the quotations of financial instruments are designed with the objective of optimizing the risk/return relationship, using the structure of limits, models, and adequate management tools. In addition, we have adequate procedures and tools that allow the Risk Management Committee and the Assets and Liabilities Committee to measure and manage this risk.
The risks to which the investment portfolios are exposed are monitored through Montecarlo “Value at Risk” (“VaR”) simulation techniques. We apply the VaR methodology to calculate the market risk of the main positions taken and the maximum expected loss based on a series of assumptions for a variety of changes in market conditions. For more information see note 52.5 to our audited consolidated financial statements as of December 31, 2025 and 2024.
Interest rate risk
Interest rate risk is the potential for changes in our financial condition resulting from adverse fluctuations in interest rates, which could have an adverse effect on capital or earnings.
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Within the framework of interest rate risk management, we have a series of policies, procedures and internal controls that allow us to monitor the variation of the net present value of assets, liabilities and off-balance sheet items under certain scenarios of disturbance and stress in interest rates risk through Montecarlo simulations. For more information see note 52.6 to our audited consolidated financial statements as of December 31, 2025 and 2024.
Foreign currency exchange rate risk
We are exposed to fluctuations in foreign currency exchange rates prevailing in our financial position and cash flows. The largest portion of our foreign currency assets and liabilities are denominated in U.S. dollars.
The foreign currency position is composed by assets and liabilities expressed in Pesos, at the exchange rate as of the closure of the indicated dates. The open position of an institution is composed by assets, liabilities, off-balance-sheet accounts denominated in the foreign currency in which the institution assumes the risk. Any devaluation or revaluation of those currencies affects the income statement.
Our open position as of December 31, 2025, stated in Pesos by currency, is disclosed in note 27 “Foreign currency amounts” of our audited consolidated financial statements as of December 31, 2025 and 2024.
Credit risk
Credit policy and credit risk management
The Board of Directors approves our credit policy and credit assessment in order to provide a framework for the creation of businesses to attain an adequate correlation between the risk assumed and profitability.
Credit risk results from the possibility of loss derived from customers or counterparties from fully or partially breaching financial obligations they have undertaken with us.
In order to manage and control the credit risk, we establish limits regarding the amount of risk we are willing to accept, so as to monitor the indicators with respect to such limits.
Credit risk rating and approval process
In order to determine the credit risk, we qualifiy each individual or company by means of a risk rating model, assigning a rating to each debtor, taking into consideration quantitative as well as qualitative concepts. The Credit Risk Department has focused its actions on increasing the quality and efficiency of the credit risk rating process.
There are specific policies and procedures for loan granting for corporate and retail customers, which differ according to the segment to which they belong (public or private payroll, retirees or open market).
The risk assessment process differs for Corporate Banking and Retail Banking customers. Credit risk assessment for retail customers includes the use of risk applications based on screening methods, which impose a minimum threshold for the customer to be creditworthy, related to an arrears level. Qualifications are permanently available for branches in the Customer Management System (CRM) and for clients through digital channels, which allows them to operate automatically within the limits and conditions approved centrally by the Risk Management.
The evaluation systems are based fundamentally on an admission score and certain rules of maximum indebtedness and installment/income ratio.
For the assessment of Corporate Banking customers, we feature different methods involving several responsible levels and which become more complex according to the magnitude of the transactions, as to amounts and type of assistance, weighted by terms and existing coverage.
For the approval of minor assistance, transitory or self-liquidating guarantees, credit powers are granted to senior officers based on their knowledge, experience and training. In any case, the use of these powers is associated with the result of an objective evaluation, avoiding any arbitrariness in credit approvals.
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For the granting of predefined products and limited amounts to the Small Companies and Agro segments, standardized evaluation systems are used in a decentralized manner and include origination scoring and screening methods for the admission and assignment of limits, based on economic, financial and equity information of the clients. Likewise, there is a periodic mass scale and centralized qualification process, which the Risk Management makes available to the branches on a permanent basis.
When transactions exceed the amounts authorized by delegated powers or through decentralized risk analysis, the ratings are approved by Credit Committees. Committee resolutions establish the conditions to which the assistance is subject in terms of amounts, currencies, terms, coverage with guarantees, follow-up clauses, etc.
In order to limit credit risk, guarantees are requested on the agreed financing. A specific area of Risk Management is responsible for managing the collateral received by us, as well as for evaluating and periodically updating its appraisal value and validity, in order to monitor the quality of the risk mitigators.
We have a formal, solid and well-defined process to manage the recovery management of problem loans. Procedures are differentiated according to portfolio type and delinquency status.
We have a management information system suitable for the size of our operations. Its components include an automated tool for the calculation of key performance indicators, for which alert and limit values have been determined in order to monitor business changes according to the risk appetite defined by our Board of Directors. Other credit risk management tools used are evaluation or score models, which are used at different stages of the credit cycle, attributing an internal risk rating to customers, according to which the assigned credit limits are managed and according to which the portfolio is monitored. Those tools are complemented with expected losses and provision models.
For more information see note 52.1 to our audited consolidated financial statements as of December 31, 2025 and 2024.
Operational risk
Operational risk consists of the risk of suffering losses due to inadequate or failed internal processes, systems or persons or due to external events. This definition includes legal risk but excludes strategic and reputational risk.
Within such framework, the legal risk –which may arise internally or externally- comprises, among other aspects, the exposure to penalties, sanctions or other economic consequences or results for failure to comply with any rule or regulation or contractual obligation.
The Non-Financial Risk Management Department is in charge of managing operational risk, with the main objective to secure an operational risk management plan which includes policies, programs, measurements and competencies for identifying, assessing and managing risks, with the purpose of assisting our senior management and our Board of Directors, in an environment of rapidly changing and significant risks.
We have a procedure to collect of events and losses for operational risk, which is composed of a collection process of operational events and losses to systematically register the frequency, severity, category and other relevant aspects related to the events and losses for operational risk. The objective is to evaluate the situation upon the event occurrence, to better understand the profile of operational risk and, if applicable, adopt the pertinent corrective measures.
In addition, we have a procedure that establishes the guidelines to prepare risk self-assessments and, in the cases of risks exceeding the tolerance limits admitted, guidelines to establish risk indicators and action plans.
The Non-Financial Risk Management Department produces and sends periodic reports to the Board of Directors, the risk management committee and senior management. Based on these reports, the results of the monitoring of the management of the main risks to which we are exposed are made known. Each report contains information on risk measurement, its evolution, trends, main exposures, control of main limits and the level of capital required by type of risk.
For more information see note 52.8 to our audited consolidated financial statements as of December 31, 2025 and 2024.
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For more information on risk management processes see note 52 “Capital management, Corporate Governance Transparency Policy and Risk management” to our audited consolidated financial statements as of December 31, 2025 and 2024.
Competition
We believe that we have an important advantage over our competitors in providing banking products and services to small communities in some provinces of Argentina as a result of the close community relationships and strong loyalty we have developed over time with our customers in these areas.
We consider Banco Santander Argentina S.A., Banco de Galicia y Buenos Aires S.A., Banco BBVA Argentina S.A., Industrial and Commercial Bank of China (Argentina) S.A. and Banco Patagonia S.A. to be our main competitors among private banks. We also compete with certain regional banks.
In the future, we expect competition to increase in corporate transactions products, long-term lending, mortgage lending and other secured financings, credit cards, personal loans, payroll services and investment management services.
Competitive landscape
We are the fourth-largest private bank in Argentina in terms of total loans and total deposits and rank fifth in terms of total loans and sixth in terms of total deposits in the overall ranking, as of December 31, 2025. In terms of net equity, we rank second among private banks and third in the overall ranking of banks in Argentina as of December 31, 2025.
Below are the rankings of banks across these metrics, figures were prepared based on Central Bank methodology:
Total Loans as of December 31, 2025
Bank Ps. Million Market Share
1 Banco de la Nación Argentina(1) 25,224,618 19 %
2 Banco de Galicia y Buenos Aires S.A. 17,970,336 14 %
3 Banco BBVA Argentina S.A. 13,227,331 10 %
4 Banco Santander Argentina S.A. 12,159,515 9 %
5 Banco Macro S.A. 10,595,731 8 %
6 Banco de la Provincia de Buenos Aires(1) 9,052,691 7 %
7 Industrial and Commercial Bank of China (Argentina) S.A. 6,336,825 5 %
8 Banco Patagonia S.A. 3,902,989 3 %
9 Banco Supervielle S.A. 3,647,892 3 %
10 Banco de la Ciudad de Buenos Aires S.A. 3,068,303 2 %
Remainder of the Financial System 26,040,020 20 %
Total Financial System 131,226,251 100 %
Note:-
(1) Public sector banks.
Source: Central Bank. Figures were prepared based on Central Bank methodology.
Total Deposits as of December 31, 2025
Bank Ps. Million Market Share
1 Banco de la Nación Argentina(1) 45,218,109 23 %
2 Banco de Galicia y Buenos Aires S.A. 25,566,662 13 %
3 Banco Santander Argentina S.A. 17,252,424 9 %
4 BBVA Argentina S.A. 17,249,108 9 %
5 Banco de la Provincia de Buenos Aires(1) 13,576,869 7 %
6 Banco Macro S.A. 13,575,508 7 %
7 Industrial and Commercial Bank of China (Argentina) S.A. 6,959,590 4 %
8 Banco de la Ciudad de Buenos Aires 6,684,967 3 %
9 Banco Credicoop Limitado 5,679,972 3 %
10 Banco Patagonia S.A. 5,745,077 3 %
Remainder of the Financial System 40,440,857 20 %
Total Financial System 197,949,143 100 %
Note:-
(1) Public sector banks.
Source: Central Bank. Figures were prepared based on Central Bank methodology.
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Equity as of December 31, 2025
Ps. Million Market Share
1 Banco de la Nación Argentina(1) 20,927,787 32 %
2 Banco de Galicia y Buenos Aires S.A. 6,023,617 9 %
3 Banco Macro S.A. 5,232,216 8 %
4 Banco Santander Argentina S.A. 4,797,019 7 %
5 Banco de la Provincia de Buenos Aires 3,968,181 6 %
6 BBVA Argentina S.A. 3,432,760 5 %
7 Banco Credicoop Limitado 3,102,957 5 %
8 Industrial and Commercial Bank of China (Argentina) S.A. 2,168,977 3 %
9 Sucursal de Citibank N.A. República Argentina 2,009,510 3 %
10 Banco de la Ciudad de Buenos Aires 1,958,545 3 %
Remainder of the Financial System 12,665,667 19 %
Total Financial System 66,287,236 100 %
Note:-
(1) Public sector banks.
Source: Central Bank. Figures were prepared based on Central Bank methodology.
There is a large concentration of branches in the City of Buenos Aires and in the province of Buenos Aires for the financial system as a whole, as shown by the following table. However, we have the most extensive private-sector branch network in Argentina and a leading regional presence holding 61% of our total branches in six provinces including Santa Fe, Córdoba, Misiones, Salta, Tucumán and Jujuy.
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As of December 31, 2025
Banking System Banco Macro Market Share
Province Branches % of total Branches % of total (% share of total of branches in each Province)
City of Buenos Aires 654 15.8 % 45 10.1 % 6.9 %
Buenos Aires (Province) 1,336 32.3 % 77 17.3 % 5.8 %
Catamarca 19 0.5 % 1 100.0 % 5.3 %
Chaco 65 1.6 % 1 0.2 % 1.5 %
Chubut 67 1.6 % 5 1.1 % 7.5 %
Cordoba 428 10.4 % 62 14.0 % 14.5 %
Corrientes 80 1.9 % 3 0.7 % 3.8 %
Entre Rios 127 3.1 % 7 1.6 % 5.5 %
Formosa 28 0.7 % 0.0 % 0.0 %
Jujuy 36 0.9 % 18 4.1 % 50.0 %
La Pampa 75 1.8 % 2 0.5 % 2.7 %
La Rioja 26 0.6 % 2 0.5 % 7.7 %
Mendoza 152 3.7 % 10 2.3 % 6.6 %
Misiones 63 1.5 % 30 6.8 % 47.6 %
Neuquén 78 1.9 % 5 1.1 % 6.4 %
Rio Negro 78 1.9 % 6 1.4 % 7.7 %
Salta 72 1.7 % 39 8.8 % 54.2 %
San Juan 41 1.0 % 1 0.2 % 2.4 %
San Luis 43 1.0 % 2 0.5 % 4.7 %
Santa Cruz 47 1.1 % 2 0.5 % 4.3 %
Santa Fe 446 10.8 % 81 18.2 % 18.2 %
Santiago del Estero 57 1.4 % 2 0.5 % 3.5 %
Tierra del Fuego 23 0.6 % 2 0.5 % 8.7 %
Tucuman 90 2.2 % 41 9.2 % 45.6 %
Total 4,131 100 % 444 100.0 % 10.7 %
Source: Argentine Central Bank
Argentine Banking Regulation
Overview
Founded in 1935, the Central Bank is the principal monetary and financial authority in Argentina. Its mission is to promote monetary and financial stability, employment and economic development with social equity. It operates pursuant to its charter, which was amended in 2012 by Law No. 26,739 and the provisions of the Financial Institutions Law. Under the terms of its charter, the Central Bank must operate independently from the Argentine government.
Since 1977, banking activities in Argentina have been regulated primarily by the Financial Institutions Law, which empowers the Central Bank to regulate the financial sector. The Central Bank regulates and supervises the Argentine banking system through the Superintendency. The Superintendency is responsible for enforcing Argentina’s banking laws, establishing accounting and financial reporting requirements for the banking sector, monitoring and regulating the lending practices of financial institutions and establishing rules for participation of financial institutions in the Foreign Exchange Market and the issuance of bonds and other securities, among other functions.
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The powers of the Central Bank include the authority to fix the monetary base, set interest rates, establish minimum capital, liquidity and solvency requirements, regulate credit, approve bank mergers, approve certain capital increases and transfers of stock, grant and revoke banking licenses, and to authorize the establishment of branches of foreign financial institutions in Argentina and the extension of financial assistance to financial institutions in cases of temporary liquidity or solvency problems.
The Central Bank establishes certain technical ratios that must be observed by financial entities, such as ratios related to levels of solvency, liquidity, the maximum credit that may be granted per customer and foreign exchange assets and liability positions.
In addition, financial entities need the authorization from the Central Bank for certain actions, such as opening or changing branches or ATMs, acquiring share interests in other financial or non-financial corporations and establishing liens over their assets, among others.
As supervisor of the financial system, the Central Bank requires financial institutions to submit information on a daily, monthly, quarterly, semi-annual and annual basis. These reports, which include balance sheets and income statements, information related to reserve funds, use of deposits, classifications of portfolio quality (including details on principal debtors and any allowances for loan losses), compliance with capital requirements and any other relevant information, allow the Central Bank to monitor the business practices of financial entities. In order to confirm the accuracy of the information provided, the Central Bank is authorized to carry out inspections.
If the Central Bank’s rules are not complied with, various sanctions may be imposed by the Superintendency, depending on the level of infringement. These sanctions range from a notice of non-compliance to the imposition of fines or, in extreme cases, the revocation of the financial entity’s operating license. Additionally, non-compliance with certain rules may result in the compulsory filing of specific adequacy or restructuring plans with the Central Bank. These plans must be approved by the Central Bank in order to permit the financial institution to remain in business.
Banking regulation and supervision
Central Bank supervision
Liquidity and solvency requirements
Since September 1994, the Central Bank has supervised the Argentine financial entities on a consolidated basis. Such entities must file periodic consolidated financial statements that reflect the operations of their head office or controlling entities, as well as those of their branches in Argentina and abroad, and of their significant subsidiaries, whether domestic or foreign. Accordingly, requirements in relation to liquidity and solvency, minimum capital, risk concentration and loan loss provisions, among others, should be calculated on a consolidated basis.
Permitted activities and investments
The Financial Institutions Law governs all individuals and entities that perform habitual financial intermediation and, as such, are part of the financial system, including commercial banks, investment banks, mortgage banks, financial companies, savings and loan companies for residential purposes and credit unions. Except for commercial banks, which are authorized to conduct all financial activities and services that are specifically established by the law or by regulations of the Central Bank, the activities that may be carried out by Argentine financial entities are set forth in the Financial Institutions Law and related Central Bank Rules. Commercial banks are allowed to perform any and all financial activities inasmuch as such activities are not forbidden by law. Some of the activities permitted for commercial banks include the ability to (i) receive deposits from the public in both local and foreign currency; (ii) underwrite, acquire, place or negotiate debt securities, including government securities, in both exchange and over-the-counter (“OTC”) markets (subject to prior approval by the CNV, if applicable); (iii) grant and receive loans; (iv) guarantee customers’ debts; (v) conduct foreign currency exchange transactions; (vi) issue credit cards; (vii) act, subject to certain conditions, as brokers in real estate transactions; (viii) carry out commercial financing transactions; (ix) act as registrars of mortgage bonds; (x) participate in foreign exchange transactions; and (xi) act as fiduciary in financial trusts. In addition, pursuant to the Financial Institutions Law and Central Bank Communication “A” 3086, as amended, commercial banks are authorized to operate commercial, industrial, agricultural and other types of companies that do not provide supplemental services to the banking services (as defined by applicable Central Bank Rules) to the extent that the commercial bank’s interest in such companies does not exceed 12.5% of its voting stock or 12.5% of its capital stock. Nonetheless, if the aforementioned limits were to be exceeded, the bank should (i) request Central Bank’s authorization; or (ii) give notice of such situation to the Central Bank, as the case may be. However, even when commercial banks’ interests do not reach such percentages, they are not allowed to operate such companies if (i) such interest allows them to control a majority of votes at a shareholders’ or Board of Directors’ meeting, or (ii) the Central Bank does not authorize the acquisition.
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Furthermore, according to the Central Bank´s rules regarding “Complementary Services of the Financial Entities and Allowed Activities,” as amended, commercial banks are authorized to operate in local or foreign companies that have one or two of the exclusive corporate purposes listed in section 2.2 of said rules, in which the commercial bank’s interest either exceeds 12.5% of such companies’ voting stock or allows the commercial bank to control a majority of votes at a shareholders’ or Board of Directors’ meeting. The financial entities shall give notice to the Superintendency if the corporate purposes of such companies include any of the corporate purposes listed in section 2.2 of Central Bank rules regarding “Complementary Services of the Financial Entities and Allowed Activities.” Financial institutions are prohibited from conducting or facilitating transactions involving digital assets—including crypto-assets and those whose returns are determined based on their price fluctuations—unless such assets are authorized by a competent national regulatory authority or the Central Bank.
Under Central Bank Rules regarding “Minimum Capital Requirements for Financial Institutions,” (the “Minimum Capital Regulations”) the holdings of a commercial bank in the capital stock of third parties, including participations in mutual funds, shall not exceed 60% of the Computable Regulatory Equity (“RPC”¸ as per its acronym in Spanish) of such commercial bank. In addition, the total amount of a commercial bank’s holdings, considered as a whole, in (i) unlisted shares, excluding holdings in companies that provide complementary services to the financial activity and holdings in state-owned companies that provide public services, (ii) listed shares and mutual fund shares that do not trigger minimum capital requirements on a market risk bases, and (iii) publicly traded shares that do not have a “market price available to the general public,” is limited to 15% of such commercial bank’s RPC. For this purpose, a given market price of the shares is considered to be “available to the general public” when market rates that measure the daily volume of significant transactions are available, and the sale of such shares held by such bank would not materially affect the share price.
Operations and activities that banks are not permitted to perform
Section 28 of Financial Institutions Law prohibits commercial banks from: (a) creating liens on their assets without prior approval from the Central Bank, (b) accepting their own shares as security, (c) conducting transactions with their own directors or managers and with companies or persons related thereto under terms that are more favorable than those regularly offered in transactions with other clients, and (d) carrying out commercial, industrial, agricultural or other activities without prior approval of the Central Bank, except those considered financially related activities under Central Bank´s Rules (this is, Central Bank rules regarding “Complementary Services of the Financial Entities and Allowed Activities”). Notwithstanding the foregoing, banks may own shares in other financial institutions with the prior approval of the Central Bank, and may own shares or debt of public services companies, if necessary to obtain those services.
Legal reserve
Pursuant to the Financial Institutions Law, we are required to maintain a legal reserve which must be funded with no more than 20% and no less than 10% of yearly income. Yet, pursuant to Central Bank Rules, we are required to maintain a legal reserve which is funded with 20% of our yearly income determined in accordance with Central Bank Rules. This reserve can only be used during periods in which a financial institution has incurred losses and has exhausted all other reserves. If a financial institution does not comply with the required legal reserve, it is not allowed to pay dividends to its shareholders.
Non-liquid assets
Since February 2004, non-liquid assets (computed on the basis of their closing balance at the end of each month, and net of those assets that are deducted to compute the regulatory capital) plus the financings granted to a financial institution’s related parties (computed on the basis of the highest balance during each month for each customer) cannot exceed 100% of the Argentine regulatory capital of the financial institution, except for certain particular cases in which it may exceed up to 150%.
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Non-liquid assets consist of miscellaneous assets and receivables, bank property and equipment, assets securing obligations, except for swaps, futures and derivative transactions, certain intangible assets and equity investments in unlisted companies or listed shares, if the holding exceeds 2.5% of the issuing company’s equity. Non-compliance with the ratio produces an increase in the minimum capital requirements equal to 100% of the excess on the ratio.
Unless otherwise indicated, the regulations explained in this section should be applied to financial information of the banks calculated in accordance with Central Bank Rules. IFRS differs in certain aspects from Central Bank Rules.
Minimum capital requirements
Until July 31, 2026, the minimum capital requirement that financial institutions must maintain shall be equal to the greater of: (i) the basic capital requirement, and (ii) the aggregate of the capital requirements determined for credit risk, market risk — including the requirement applicable to daily positions in the relevant assets — and operational risk.
As from August 1, 2026, the minimum capital requirement that financial institutions must maintain shall be equal to the greater of: (i) the basic capital requirement, and (ii) the aggregate of the capital requirements determined for credit risk (including counterparty credit risk), market risk — including the requirement applicable to daily positions in the relevant assets — and operational risk. For these purposes, positions in financial instruments must be allocated to the banking book (subject to capital requirements for credit risk, counterparty credit risk and operational risk) or to the trading book (subject to capital requirements for counterparty credit risk, market risk and operational risk), in each case in accordance with the Minimum Capital Regulations.
The capital composition to be considered in order to determine compliance with minimum capital requirements is the financial institution’s RPC.
Basic minimum capital
As from May 23, 2024, the basic minimum capital requirement to be observed by financial institutions is as follows:
Banks Other financial institutions (Except Cooperative Credit Unions)
Ps.5,000 million Ps.2,500 million
Likewise, financial entities in operation as of Junes 1, 2024, must comply with the basic capital requirement set forth in the table above as of January 1, 2025. From June 1, 2024, until December 31, 2024, such operating entities shall apply the requirements set forth in the following table:
Banks Other financial institutions (Except Cooperative Credit Unions)
Ps.1,500 million Ps.700 million
Financial institutions in operation as of June 1, 2024, that do not meet the integration of the basic capital requirement as outlined in the previous paragraph and/or the basic capital requirement from January 1, 2025, according to the information that we are periodically required to send to Central Bank pursuant to the “Business Plan and Projections and Capital Self-Assessment Report” information regime, which includes the submission of a compliance program to Superintendency within 20 calendar days following the registration or projection of non-compliance, respectively, which must not exceed a 6-month period to meet the basic requirement.
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Delineation Between the Banking Book and the Trading Book
Effective August 1, 2026, financial institutions must apply the following framework to distinguish between the banking book and the trading book for regulatory capital purposes.
Allocation to the Trading Book
The trading book includes all positions in financial instruments that are held for trading purposes or to hedge positions held for trading. Such positions must be measured at fair value and subject to prudent valuation standards in accordance with the Minimum Capital Regulations .
Positions included in the trading book must not be subject to legal or other restrictions that would prevent their sale, transfer, or effective hedging.
A position is considered held for trading if it is entered into for short-term resale, to benefit from short-term price movements, for arbitrage, or to hedge other trading book positions.
Unless an institution can provide documented justification to the contrary, consistent with its internal policies, the following instruments are presumed to belong in the trading book:
(i) instruments accounted for at fair value through profit or loss;
(ii) derivatives arising from market-making activities;
(iii) certain fund investments that meet applicable transparency, information, and valuation requirements;
(iv) equity instruments listed on recognized exchanges;
(v) securitization exposures with identifiable underlying assets and a liquid secondary market;
(vi) explicit or embedded credit-linked options;
(vii) underwriting commitments for shares, bonds, or other instruments;
(viii) instruments that create net short credit risk positions in the banking book; and
(ix) repurchase or reverse repurchase transactions not included in the banking book.
Allocation to the Banking Book
Any financial instrument that does not meet the criteria for trading book treatment must be assigned to the banking book. This includes, among other items, real estate exposures.
The following positions must be included in the banking book:
(i) equity instruments not listed on recognized exchanges;
(ii) retail and SME exposures;
(iii) exposures temporarily held pending securitization;
(iv) fund investments not allocated to the trading book;
(v) derivatives and funds whose underlying assets consist of banking book instruments;
(vi) instruments used to hedge banking book positions; and
(vii) repurchase transactions entered into for liquidity management purposes or accounted for at amortized cost.
Supervisory Oversight
The Superintendency may require institutions to demonstrate that positions classified in the trading book are in fact held for trading purposes, or that positions classified in the banking book are not held for trading purposes.
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If the supporting evidence is deemed insufficient, the Superintendency may require the reclassification of positions to the appropriate book, subject to the exceptions set forth in the Minimum Capital Regulations.
Reclassification Between Books
Reclassification of positions between the banking book and the trading book is permitted only in exceptional circumstances and must be irrevocable. As a general rule, prior approval from senior management and the Superintendency is required.
Any reduction in capital requirements resulting from a reclassification must continue to be recognized as a capital requirement, must be disclosed in accordance with applicable regulations, and must remain in place until the position is derecognized in the institution’s financial statements.
Governance, Policies and Internal Controls
Institutions must establish and maintain policies, procedures, and controls governing the initial classification and any reclassification of positions between books. These policies must be consistent with regulatory criteria and integrated into the institution’s risk management framework.
Institutions must also implement internal control functions and conduct internal audit reviews at least annually to ensure proper application of classification standards and to assess any exceptional reclassification events.
Internal Risk Transfers
An internal risk transfer refers to the offsetting of risk between the banking book and the trading book, or between positions within the same book.
The Minimum Capital Regulations impose specific conditions on internal transfers of credit risk, interest rate risk, market risk, and counterparty credit risk. These include requirements relating to external hedging, documentation, supervisory approval, and prudential capital treatment.
All internal risk transfers must be properly documented, including identification of the source and magnitude of the risk being transferred. The resulting positions must be subject to the same prudential standards that would apply if the transaction had been executed with an external counterparty.
Regulatory capital of financial institutions: Tier 1 and Tier 2 capital regulations
Argentine financial institutions must comply with guidelines similar to those adopted by the Basel Committee on Banking Regulations and Supervisory Practices, as amended in 1995 (the “Basel Rules”). In certain respects, however, Argentine banking regulations require higher ratios than those set forth under the Basel Rules.
The RPC is determined by the following formula:
RPC = PNb + PNc
Where:
• RPC: Computable equity liability (total regulatory capital).
• PNb: Basic net worth (Tier 1 capital), calculated as: PNb = COn1 - CDCOn1 + CAn1 - CDCAn1
• COn1: Ordinary Tier 1 capital.
• CDCOn1: Deductible items from ordinary Tier 1 capital.
• CAn1: Additional Tier 1 capital.
• CDCAn1: Deductible items from additional Tier 1 capital.
• PNc: Complementary net worth (Tier 2 capital), net of corresponding deductions (CDPNc).
The Central Bank takes into consideration a financial institution’s RPC in order to determine compliance with capital requirements.
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Tier 1 Capital
COn1 Capital – Ordinary Tier 1 capital
COn1 includes the following net worth items:
(i) capital stock (excluding preferred stock);
(ii) non-capitalized capital contributions (excluding share premium);
(iii) adjustments to shareholders’ equity;
(iv) earnings reserves (excluding the special reserve for debt instruments);
(v) unappropriated earnings;
(vi) other results either positive or negative, in the following terms:
(a) 100% of net earnings or losses recorded until the last quarterly financial statements with limited review report, corresponding to the last full fiscal year and in respect of which the auditor has not issued the audit report;
(b) 100% of net earnings or losses for the current year as of the date of the most recent audited quarterly financial statements;
(c) 50% of profits or 100% of losses for the most recent audited quarterly or annual financial statements; and
(d) 100% of losses not shown in the financial statements, arising from quantification of any facts and circumstances reported by the auditor;
(vii) other comprehensive income:
(a) 100% of the results recorded in the following items: revaluation of property, plant and equipment and intangibles; gains or losses on financial instruments at fair value with changes in other comprehensive income,
(b) 100% of the debit balance of each of the items recorded in other comprehensive income not mentioned in section a) above.
The recognition of these concepts, registered in accounts of other comprehensive income or other accumulated comprehensive income, as appropriate, will be made in accordance with the terms of sections 8.2.1.5. or 8.2.1.6., as the case may be, of the Minimum Capital Regulations.”
(viii) share premiums of the instruments included in COn1; and
(ix) in the case of consolidated entities, it also includes minority shareholdings (common shares issued by subsidiaries subject to consolidated supervision and belonging to third parties, if certain criteria are met).
The mentioned concepts will be reduced by applicable deductible items, as defined by the relevant regulations.
In order for the shares to fall under COn1, at the time of issuance, the financial entity must not generate any expectation that such shares will be reacquired, redeemed or amortized, and the contractual terms must not contain any clause that might generate such an expectation.
Deductible Concepts
The above-mentioned items will be considered without certain deductions pursuant to subsection 8.4.1 and 8.4.2 (as applicable) of the Minimum Capital Regulations.
Concepts deductible from COn1 include, among other things:
(i) the positive difference resulting from comparing the amount of the regulatory provision—derived from the application of the Minimum Capital Regulations—or the accounting provision corresponding to the balance of accounts as of November 30, 2019, whichever is greater, and the accounting provision derived from the application of Section 5.5 “Impairment” of IFRS 9. Before any deduction, the amount of the provision for credit risk related to the “normal situation” portfolio, computed as supplementary net worth, must be absorbed.
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(ii) favorable balances arising from the application of the minimum presumed income tax—net of provisions—that exceed 10% of the Tier 1 capital (PNb) for the previous month, and favorable balances arising from deferred tax assets;
(iii) deposits maintained in a corresponding account with a foreign financial institutions that are not rated as “investment grade,”
(iv) debt securities not held by the relevant financial institutions, except in the case of securities registered by or in custody of the Central Bank (CRYL), Caja de Valores S.A., Clearstream, Euroclear or the Depository Trust Company,
(v) securities issued by foreign governments whose credit rating is less than ‘investment grade’ according to Communication “A” 5671, as amended;
(vi) subordinated debt instruments issued by other financial institutions;
(vii) shareholders;
(viii) real property added to the assets of the financial entity and with respect to which the title deed is not duly recorded at the pertinent Argentine real property registry, except where such assets shall have been acquired in a court-ordered auction sale;
(ix) intangible assets, net of the respective accumulated depreciation;
(x) items pending allocation, debtor balances and others;
(xi) certain assets or other concepts, as required by the Superintendency resulting from differences between carry amount and the fair value of assets or actions taken to distort or disguise the true nature or scope of operations;
(xii) any deficiencies due to insufficient provisions for bad debt risk resulting from the application of Section 5.5. “Impairment of Value” under IFRS 9, as determined by the Superintendency;
(xiii) any deficiencies due to insufficiency in the calculation of regulatory provisions in accordance with the Minimum Capital Regulations as determined by Superintendency;
(xiv) equity interests in companies that have the following activities:
(a) financial assistance through leasing or factoring agreements,
(b) transitory equity acquisitions in other companies in order to further their development to the extent the ultimate purpose is selling such interest after development is accomplished, and
(c) credit, debit and similar cards emissions;
(xv) the excess to the limits set forth for secured assets on Section 3 of the rules on “Affectation of Restricted Assets;”
(xvi) the highest balance of that month’s financial assistance granted during the month, where the advance payments set forth in Section 3.2.5 of the rules on “Lending to the non-financial public sector” surpass the authorized limit and/or are not settled within the terms established therein;
(xvii) income from sales relating to securitization transactions, as applicable, pursuant to the provisions of Sections 3.1.4., 3.1.5.1. and 3.1.5.2. of the Minimum Capital Regulations, and from portfolio sales or assignments with recourse. This deduction can be applied as long as the credit risk still persists and to the extent in which the capital requirement for the underlying exposures or the sold or assigned portfolio with recourse is maintained;
(xviii) in the case of liabilities from derivatives accounted for at fair value, unrealized gains or losses due to changes in the financial institution’s credit risk will be deductible. The deduction will be limited to the financial institution’s own credit risk adjustments only plus or minus, as the case may be); such adjustments may not be offset against adjustments for counterpart risk;
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(xix) equity interests in financial institutions subject to consolidated oversight, except where not permitted due to the existence of deductible amounts; or in the case of foreign financial institutions. In these cases, the deductions will be the net amount of the allowance for impairment and, when controlled financial institutions subject to the provisions of Section 8.2.1.6., item iii) are involved, the deductions will be 50% of the net amount of profits derived by these entities on a proportional basis to their respective interests.
CAn1 Capital
CAn1 includes certain debt instruments of financial entities not included under COn1 that meet the regulatory criteria established in section 8.3.2 of the Minimum Capital Regulations, and share premiums resulting from instruments included in CAn1. Furthermore, in the case of consolidated entities, it includes instruments issued by subsidiaries subject to consolidated supervision and belonging to third parties, pursuant to applicable regulatory requirements.
The items mentioned in the previous paragraph will be reduced, if applicable, by the deductible concepts described in the previous section (See “Item 4.B. Business Overview—Deductible Concepts”)
Moreover, instruments included under CAn1 must comply with the following requirements:
(1) Must be totally subscribed and paid in full.
(2) Must be subordinated to depositors, unsecured creditors and to the subordinated debt of the financial entity. The instruments must contemplate that in the case of the entity’s bankruptcy and once all debts with all the other creditors are satisfied, its creditors shall have priority in the distributions of funds only and exclusively with respect to the shareholders (irrespective of their class), with the express waiver of any general or special privilege.
(3) Must not be insured or guaranteed by the issuer or a related entity, and with no agreement improving, either legally or economically, the payment priority in the case of the entity’s bankruptcy.
(4) They shall not contemplate any type of capital payment, except in the case of liquidation of the financial entity. Provisions gradually increasing remuneration or other incentives for anticipated amortization are not allowed.
(5) After five years, as from the issuance date, the financial entity can buy back the debt instruments if:
(i) it has the prior authorization of the Superintendency;
(ii) the entity does not create any expectations regarding the exercise of the purchase option; and
(iii) the debt instrument is replaced by a RPC of equal or greater value sustained by its revenue capacity, or if it is demonstrated that once the purchase option is exercised, its RPC significantly exceeds at least by 20% of the minimum capital requirements.
(6) Any capital repayment requires previous authorization from the Superintendency. In the case of a capital repayment, the financial entity must not create any market expectations regarding the granting of such authorization.
(7) The financial entity can cancel dividends/interest coupons at any time and at its sole discretion, which shall not be considered the default in itself and shall not grant bondholders the right to demand the conversion of their notes into ordinary shares. Furthermore, there shall be no restrictions to the financial entity, except with respect to dividend distribution to the shareholders.
(8) The payment of dividends/interest coupons shall be carried out through the noting of distributable entries, in the terms of the regulations on “Earnings Distributions” (See “Item 4.B. Business Overview—Economic Capital—Requirements applicable to dividend distribution”).
(9) The included dividends/interest coupons shall not have periodic adjustments because of the financial entity’s credit risk.
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(10) They should not have been bought by the financial entity or any other entity over which the financial entity has control or significant influence.
(11) They should not have been bought with direct or indirect financing from the financial entity.
(12) They shall not contain elements that make re-capitalization difficult.
Instruments considered liabilities must absorb losses once a pre-established triggering event takes place. The instruments must do so through their conversion into ordinary shares or a mechanism assigning final losses to the instrument with the following effects:
a) Reduction of debt represented by the instrument in the event of winding-up of the entity;
b) Reduction of the amount to be repaid in case a call option is exercised;
c) Total or partial reduction of the dividends/interest coupon payments of the instrument.
Complementary Net Worth (NWc or PNc): Tier 2
Tier 2 Capital includes:
(i) certain debt instruments of financial entities which are not included in Tier 1 Capital and meet the regulatory criteria established in section 8.3.3 of the Minimum Capital Regulations.,
(ii) share premium from instruments included in Tier 2 Capital, and
(iii) loan loss provisions on the loan portfolio of debtors classified as being in a “normal situation” pursuant to Central Bank Rules on debtor classification and of financing with preferred security “A” not exceeding 1.25% of the assets measured for credit risk.
Additionally, in the case of consolidated entities, Tier 2 Capital includes debt instruments issued by subsidiaries subject to a consolidated supervision and belonging to third parties, if they meet the criteria in order to be included under NWc.
The concepts mentioned in the preceding points shall be deducted, if applicable, by the deductible items provided in Section 8.4.2 of the Minimum Capital Regulation.
Moreover, debt instruments included under NWc must comply with the following requirements:
• Must be totally subscribed and paid in full.
• Must be subordinated to depositors, unsecured creditors and the subordinated debt of the financial entity.
• Must not be insured or guaranteed by the issuer or a related entity, and with no agreement improving either legally or economically the payment priority in case of the entity’s bankruptcy.
• Maturity:
(i) original maturity date within no less than five years;
(ii) clauses considering gradually increasing remuneration or other incentives for anticipated amortization are not allowed and
(iii) from the beginning of the last five years of life of the indebtedness, the computable amount will be diminished by 20% of its nominal issuance value.
• After five years as from the issuance date, the financial entity can buy back the debt instruments with the previous authorization of the Superintendency, and if the entity does not create any expectations regarding the exercise of the purchase option. The debt instrument must be replaced by an RPC of equal or greater value sustained by its revenue capacity, or if it is demonstrated that once the purchase option is exercised its RPC significantly exceeds at least in a 20% of the minimum capital requirements.
• The investor shall not be entitled to accelerate the repayment of future projected payments, except in the case of bankruptcy or liquidation.
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• They cannot incorporate dividends/coupons with periodic adjustments linked to the financial entity’s credit risk.
• They should not have been bought by the financial entity or any other entity over which the financial entity has control or significant influence.
• They should not have been bought with direct or indirect financing from the financial entity.
Additionally, instruments included in NWc and CAn1, shall present the following conditions in order to assure their loss-absorbency capacity:
a) Their terms and conditions must include a provision pursuant to which the instruments must absorb losses–either through a release from debt or its conversion into ordinary capital–once a triggering event has occurred, as described hereunder.
b) If the holders receive compensation for the debt release performed, it should be carried out immediately and only in the form of common shares, pursuant to applicable regulations.
c) The financial entity must have been granted the authorization required for the immediate issuance of the corresponding common shares in the case of a triggering event, as described below.
Triggering events of regulatory provisions described above are:
(I) when the solvency or liquidity of the financial entity is threatened, and the Central Bank rejects the amnesty plan submitted or revokes its authorization to function, or authorizes restructuring protecting depositors (whichever occurs first) or
(II) upon the decision to capitalize the financial entity with public funds, in the context of the application of Section 35 bis of the Financial Institutions Law, due to the impact on its liquidity and solvency.
Further criteria regarding the eligibility of items included in the RPC calculation must be followed pursuant to the regulatory requirements of minority and other computable instruments issued by subsidiaries, subject to consolidated supervision by third parties. A minority shareholding may be included in COn1 of the financial entity if the original instrument complies with the requirements established for its qualification as common shares regarding the RPC.
Deductible concepts applied to the different capital levels
(i) Investments in computable instruments under the financial entity’s RPC not subject to consolidated supervision when the entity owns up to 10% of the issuer’s ordinary capital according to the following criteria:
(a) investments include direct, indirect or synthetic interests;
(b) investments include the acquired net position;
(c) the holding of securities subscribed to be sold within a five business day term may be excluded; and
(d) the investments in capital instruments that do not satisfy the criteria to be classified as COn1 (Common Equity Tier 1), CAn1: (Additional Tier 1 capital) or NWc (Complementary Net Worth) of the financial institution shall be regarded as COn1 –common equity shares, for the purposes of this regulatory adjustment.
If the aggregate amount of these interests in the capital of financial institutions, companies providing services supplementary to the financial industry and insurance companies – which individually represent less than 10% of the COn1 of each issuer– exceeds 10% of the COn1 of the financial institution, net of applicable deductions, the amount over such 10% shall be deducted from each capital tier in accordance with the following method:
(a) Amount to be deducted from COn1: aggregate excess amount over 10% multiplied by the proportion represented by the COn1 holdings over the aggregate equity interests;
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(b) Amount to be deducted from CAn1: aggregate excess amount over 10% multiplied by the proportion represented by the CAn1 over the aggregate equity interests.
(c) Amount to be deducted from NWc: aggregate excess amount over 10% multiplied by the proportion represented by the NWc holdings over the aggregate equity interest.
If the financial institution does not have enough capital to make the deduction pertaining to a particular capital tier, the remaining amount shall be deducted from the next higher level. Amounts below the threshold, which are not deducted, are weighted based upon the risk or are taken into account in the calculation of the market risk requirement, as applicable.
(ii) Investments in instruments computed as regulatory capital of financial institutions and companies rendering services supplementary to the financial industry, not subject to consolidated oversight, and insurance companies, when the institution holds more than 10% of the common equity of the issuer, or when the issuer is a subsidiary of the financial institution, shall be subject to the following criteria:
(a) The investments include direct, indirect and synthetic interests. For these purposes, indirect interest means an investment by a financial institution in another financial institution or company not subject to consolidated oversight, which in turn has an interest in another financial institution or company not consolidated with the first one. A synthetic interest means an investment made by a financial institution in an instrument the value of which is directly related with the equity value of another financial institution or company not subject to consolidated oversight;
(b) The net acquired position is included, i.e., the gross acquired position less the position sold in the same underlying exposure, when this has the same duration than the acquired position or its residual life is at least one year;
(c) The holding of securities underwritten to be sold within a five business day term may be excluded;
(d) Investments in capital instruments that do not satisfy the criteria to be classified as COn1, CAn1 or NWc of the financial institution shall be regarded as COn1, common equity shares, for the purposes of this regulatory adjustment.
The amount of these interests, taking into account the applicable type of instrument, shall be deducted from each of the applicable capital tiers of the financial institution.
If the financial institution does not have enough capital to make the deduction pertaining to a particular capital tier, the remaining amount shall be deducted from the next higher level.
(iii) Own repurchased instruments that satisfy the criteria for being included in CAn1 or NWc must be deducted from the applicable capital tier.
Limits
Section 8 of the Minimum Capital Requirements Regulations sets forth the minimum thresholds applicable to capital integration:
(i) for COn1, the amount resulting from multiplying the capital RWA by 4.5%;
(ii) for NWb, the amount resulting from multiplying RWA by 6%; and
(iii) for the RPC, the amount resulting from multiplying RWA by 8%.
The lack of compliance with any of these limitations is considered as an infringement to minimum capital integration requirements.
Pursuant to Communication “A” 5889, as amended from time to time, RWA shall be calculated as follows:
RWA = RWAc + [(MR+OR) x 12.5]
Where:
RWA: risk weighted assets
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RWAc: credit risk weighted assets
MR: minimum capital requirement for market risk
OR: minimum capital requirement for operational risk
Economic Capital
The Central Bank’s “Guidelines for Risk Management of Financial Institutions” (the “Risk Management Guidelines”), require financial institutions to have an integrated global internal process in place to assess the adequacy of their economic capital based on their risk profile (the “Internal Capital Adequacy Assessment Process” or “ICAAP”), as well as a strategy aimed at maintaining their regulatory capital. If, as a result of this internal process, it is found that the regulatory capital is insufficient, financial institutions must increase regulatory capital based on their own estimates to meet the regulatory requirement.
The economic capital of financial institutions is the amount of capital required to pay not only unexpected losses arising from exposure to credit, operational and market risks, but also those arising from other risks to which the financial institution may be exposed.
Financial institutions must demonstrate that their internal capital targets are well-funded and adequate in terms of their general risk profile and operations. The ICAAP should take into consideration all material risks to which the institution is exposed. To this end, institutions must define an integral process for the management of credit, operational, market, interest rate, liquidity, securitization, graduation, reputational and strategic risks and use stress tests to assess potential adverse scenarios that may affect their regulatory capital.
The ICAAP must include stress tests supplementing and validating any other quantitative or qualitative approach employed by the institution in order to provide the Board of Directors and senior management with a deeper understanding of the interaction among the various types of risk under stress conditions. In addition, the ICAAP must consider the short- and long-term capital needs of the institution and ensure the prudent accumulation of excess capital during positive periods of the economic cycle.
The main elements of a strict capital evaluation include:
a) Policies and procedures to guarantee that the entity identifies, quantifies and informs all the important risks.
b) A process which relates economic capital with the current level of risk.
c) A process which sets forth capital sufficiency objectives related to the risk, taking a strategic approach from the entity and its business plan into consideration.
d) An internal process of controls, tests and audits, with the objective to guarantee that the general risk management process is exhaustive.
The required amount of capital of each institution shall be determined based on its risk profile, taking into consideration other external factors such as the effects of the economic cycle and the economic scenario.
As part of its review of compliance with Central Bank regulations, including the Minimum Capital Regulation and “Consolidated Supervision,” the Superintendency assesses the institution’s internal economic capital adequacy process. If the Superintendency determines that the results of the ICAAP conducted by the institution are unsatisfactory, or identifies non-compliance with the conditions and requirements set forth in the applicable regulations, it may consider adopting a broad range of potential measures, including requiring capital levels above the regulatory minimums or ordering or imposing additional actions, such as enhanced supervisory oversight, restrictions on dividend distributions, and the preparation and implementation of a capital restoration plan.
The Central Bank expects financial institutions to operate above the minimum capital requirements. If necessary, the Superintendency may require higher regulatory capital levels based on specific risks not fully addressed by the regulations. The Superintendency may also mandate increased capital for certain risks specific to the institution or the economy.
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Capital adequacy for interest rate risk in the investment portfolio (“IRRBB”) must be addressed in the ICAAP, aligned with the institution’s risk appetite. The capital requirement should be based on risk measurement methodologies and assumptions, ensuring sufficient capital for both current and future risks.
Financial institutions must ensure capital adequacy for IRRBB, developing their own methodologies tailored to their risk profile. The impact of IRRBB on economic value and future results must be considered, including potential effects on capital margins due to unforeseen outcomes. Capital adequacy assessments for IRRBB should consider:
(i) the magnitude and duration of internal limits on IRRBB exposures and whether these limits are reached when calculating capital needs;
(ii) the effectiveness and cost of hedging open positions based on interest rate expectations;
(iii) the sensitivity of internal IRRBB measures to key assumptions in the models;
(iv) the impact of stress scenarios and shocks on positions related to different interest rate indices (basis risk);
(v) the effect on economic value and net interest income from mismatches in different currencies;
(vi) the impact of implied losses (the difference between book value and economic value when resulting in a loss);
(vii) capital distribution among entities within a group, and total capital adequacy on a consolidated basis;
(viii) underlying risk factors; and
(ix) circumstances under which the risk may materialize.
The capital adequacy results for IRRBB should be included in the ICAAP and translated into capital needs for business lines.
Entities in Group “A” must use internal models to quantify economic capital needs based on their risk profile within the ICAAP framework.
Entities in Groups “B” or “C” may choose between using internal models or applying a simplified methodology for quantifying economic capital needs, with the decision made by the Board of Director. Those opting for the simplified methodology must adhere to general risk management provisions. Group B or C entities which have opted for the simplified methodology shall apply the following expression:
EC = (1.05 x MC) + max [0; U EVE – 15 % x NWb)]
Where:
EC: economic capital based on the risk profile (ICAAP).
MC: minimum capital requirements as provided in Section 1.1 of the Minimum Capital Regulations.
EVE: measure of risk calculated according to a standardized framework foreseen in section 5.4 of the Risk Management Guidelines”
NWb: basic net worth (tier 1 capital)
Group B Entities whose RPC is insufficient to cover the economic capital requirements arising in the first year of application of the simplified methodology will be granted a five-year phase-in period — counted from the year following the adoption of the simplified methodology — to cover the recorded economic capital shortfall (expressed as a percentage), at a minimum cumulative rate of 20% per year of such shortfall.
Requirements applicable to dividend distribution
The Central Bank has imposed restrictions on the payment of dividends, substantially limiting the ability of financial institutions to distribute such dividends subject to compliance with the rules set forth in the regulations on “Earnings Distributions,” by the Central Bank, under the criterion that the amount to be distributed cannot affect the institution’s liquidity and solvency. This requirement shall be deemed satisfied when it is verified that there are no shortfalls in the minimum capital position—both on an individual and consolidated basis.—at the close of the fiscal year to which the retained earnings under consideration relate, or at the last closed position, whichever presents the smaller excess over the requirement, in accordance with the applicable regulatory requirements set forth in the aforementioned regulations.
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Such regulations provide that the payment of dividends (other than dividends on common shares), the acquisition of treasury shares, the payment on other tier 1 equity instruments (as determined in accordance with the provisions set forth in the Minimum Capital Regulations) and/or the payment of financial incentives (bonuses) to personnel – in this case, subject to the public order labor regulations (legal, statutory and contractual) governing the financial institutions’ relationships with their personnel– shall be subject to the regulations on “Earnings Distributions.”
Institutions may distribute earnings up to the positive amount derived from the off-balance sheet calculation set forth herein, without exceeding the limits set forth in the regulations on “Earnings Distributions.”
To such effect, the registered balances, as of the end of the fiscal year to which they belong, in the “Unappropriated Retained Earnings” account and in the voluntary reserve for future distributions of earnings shall be computed, deducting the amounts – recorded on the same date – of the legal and statutory reserves – whose creation is mandatory – and the following concepts:
(1) 100 % of the negative balance of each of the items recorded under “Other comprehensive retained earnings.”
(2) The result derived from the revaluation of property, plant and equipment and intangible assets and investment properties.
(3) The net positive difference resulting from the calculation at amortized cost and the fair market value recorded by the financial institution in connection with sovereign bonds and/or currency regulation instruments issued by the Central Bank for such instruments valued at amortized cost.
(4) The asset valuation adjustments notified by the Superintendency – whether accepted or not by the institution –, that are pending registration and/or those indicated by the external audit that have not been accounted.
(5) The individual deductibles – regarding asset valuation – established by the Superintendency, including the adjustments derived from the failure to consider agreed adjustment plans.
(6) The lower level of provisions and the higher RPC resulting from the treatment set forth in section 2 of Central Bank Communication “A” 6946 (as amended), in connection with financing granted to MSMEs for the payment of salaries.
In addition, financial institutions shall not distribute earnings out of the income derived from the first application of IFRS and are obliged to create a special reserve which shall only be reversed for capitalization purposes or to absorb possible negative balances in the item “Unappropriated Retained Earnings.”
The amount to be distributed, which shall not exceed the limits set forth by the Central Bank, shall not compromise the liquidity and solvency of the institution. This requirement shall be considered satisfied once it has been verified that there are no integration defects in the minimum capital position – whether individual and consolidated – as of the end of the fiscal year to which the unappropriated retained earnings pertain or in the last closed position, whichever has the lesser integration excess, recalculating them together (for such purpose only) with the following effects based on the data relevant as of each such date:
(i) Those arising after deducting the concepts set forth above in items 1 to 5 above, if applicable, from the assets.
(ii) The failure to consider the deductibles established by the Superintendency affecting the requirements, integrations and minimum capital position.
(iii) The deduction of the amounts relating to the following concepts from the unappropriated retained earnings:
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• the amount to be distributed and, if applicable, the amount allocated to the creation of the reserve to repay debt instruments, capable of integrating the regulatory capital;
• positive balances due to the application of the minimum presumed income tax – net of allowances for impairment – that have not been deducted from the basic shareholders’ equity, in accordance with the provisions set forth in the Minimum Capital Regulations; and
• adjustments made in accordance with items 1 to 5 above.
(iv) The failure to consider the limit set forth in Section 7.2. of the Minimum Capital Regulations.
The distribution of earnings shall only be admitted if none of the following events occurs:
• institution is subject to the provisions of Section 34 “Regularization and Recovery” and Section 35 bis “Institution’s restructuring for the purpose of safeguarding loans and deposits” of the Financial Institutions Law;
• the institution has received financial assistance from the Central Bank under Section 17 of its Charter, due to illiquidity;
• the institution is delayed or in breach of the reporting regime set forth by the Central Bank;
• the institution records minimum capital integration deficits – whether individually or consolidated – (without computing the effects of the individual deductibles established by the Superintendency);
• the integration of the average minimum cash – in Pesos, in foreign currency or in sovereign securities – is smaller than the requirement applicable to the last closed position or the projected position, taking into account the effect of the earnings distribution;
• the institution has failed to comply with the additional capital margins applicable in accordance with Section 4. Financial institutions shall have prior authorization of the Central Bank for the distribution of their results.
Financial entities must obtain prior authorization from the Central Bank for the distribution of their results. In this authorization process, the Superintendency will consider, among other factors, the potential effects of the application of international accounting standards according to Communication “A” 6430 (Section 5.5 of IFRS 9 - Impairment of financial assets) and the re-expression of financial statements.
For the determination of distributable results, the increase in computable equity (RPC) resulting from the application of Section 11.4 of the Minimum Capital Regulations must be deducted from the calculations outlined above. Additionally, deductions must be made for lower provisions and higher RPC resulting from treatments established in point 2 of Communication “A” 6946 (and amendments) – for financing to SMEs intended for salary payments – in point 2 of Communication “A” 7427, in point 3 of Communication “A” 7659, and in Communication “A” 7928 – which postponed until January 1, 2025, on an optional and irrevocable basis for Group B and Group C financial institutions (as classified at the relevant time), that are not branches or subsidiaries of foreign banks designated as globally systemically important banks (“G-SIB”), the application of Section 5.5 of IFRS 9.
Pursuant to Communication “A” 8410, dated March 19, 2026, until December 31, 2026, financial entities holding prior authorization from the Central Bank may distribute results in three equal, non-cumulative monthly installments, beginning on the third business day of May and of each month in which a payment is made. The total distributable amount may not exceed 60% of the net income for fiscal year 2025, after deducting the amounts corresponding to the legal and statutory reserves —recorded as of the same date— whose constitution is required. Such distribution of results must be consistent with the information reported under the Reporting Regime for the “Business Plan and Projections and Capital Self-Assessment Report”.
The calculation of distributable income, along with the verification of liquidity and solvency, and the determination of additional capital margins, must all be conducted in the constant currency as of the date of the meeting at which the dividend distribution was decided. Furthermore, the amounts of the installments, where applicable, should be calculated using the same currency value.
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Unless otherwise indicated, the regulations explained in this section should be applied to financial information of the banks calculated in accordance with Central Bank Rules. IFRS differs in certain respects from Central Bank Rules.
Moreover, in accordance with the Foreign Exchange Regulations (as defined below), the access to the Foreign Exchange Market to pay dividends to non-resident shareholders is subject to certain requirements. For more information, see “Item 10.D. Exchange Controls.”
Capital Conservation Buffer
Central Bank regulations on “Earnings Distributions” state that financial entities shall maintain a capital conservation buffer in addition to the minimum capital requirements in order to ensure the accrual of owned resources to cope with eventual losses, reducing the non-compliance risk.
Financial entities considered as domestic systemically important banks (“D-SIBs”) or G-SIBs must have a capital level that permits a greater capacity for loss absorption. This requirement is based on the negative externalities that could arise from the contagion of an insolvency event involving such institutions or their foreign parent entities. Such events would not only impact the financial system but could also have significant repercussions on the broader real economy.
The conservation capital buffer shall be 2.5% of the amount of RWA. In cases of entities considered systemically important, the margin will be increased to 3.5% of the amount of capital risk weighted assets.
These margins can be increased once again, by the counter-cycle buffer. The objective of the countercyclical capital buffer is to ensure that the capital level of financial institutions corresponds to the accumulation of systemic risk associated with excessive credit expansion and the broader macro-financial environment. When, in the Central Bank’s judgment, credit growth is deemed excessive, leading to an increase in systemic risk, the Central Bank may require the establishment of the countercyclical capital buffer within a range of 0% to 2.5% of risk-weighted assets, but since April 1, 2016, through Central Bank Communication “A” 5938, the countercyclical buffer was established at 0%. Additionally, the Central Bank may modify the margin when it determines that the systemic risk has materialized or decreased. The requirement for the countercyclical capital margin will be satisfied by an increase in the capital conservation margin.
Financial entities with international activity shall consider the geographic location of their credit exposure with local and foreign residents of the private sector and calculate the counter-cycle margin as the weighted average of the capital margin requirements in the jurisdictions where they hold exposures. or the purpose of the weighting, credit exposures include those to the private sector subject to capital requirements for credit risk, including those recorded in the trading book. To determine the applicable jurisdiction for each exposure, financial institutions must, when possible, apply the “ultimate risk” principle, identifying the jurisdiction of the risk guarantor rather than the jurisdiction where the obligation has been booked.
The capital conservation margin and the countercyclical capital margin must be fully comprised of common equity tier 1 capital (COn1), net of deductions (CDCOn1).
When such margin is used, financial institutions are required to restore it through additional capital contributions and/or by reducing the distribution of profits. This can be achieved by limiting dividend distributions, repurchasing shares, reducing payments on other Tier 1 capital instruments, and/or adjusting economic incentives (such as bonuses) to personnel.
The dividend distribution shall be limited whenever the level and composition of the RPC, even when it complies with the minimum capital requirements, is within the range of the capital conservation buffer. This limitation applies solely the dividend distribution, but not the operation of the entity. Entities shall be able to operate normally when levels of COn1 are within the range of conservation buffer, as this does not constitute a breach of the minimum capital requirement. When the COn1 ratio, expressed as a percentage of RWA, falls within the capital conservation buffer range, extended for entities classified as systemically important—the restriction to the results distribution shall be increased whenever the coefficient of COn1 comes close to the minimum required in Section 8.5.1 of the Minimum Capital Regulations.
The concepts subject to profit distribution restrictions include dividends, repurchases of own shares, payments on other Tier 1 capital instruments, and/or economic incentives (bonuses) paid to staff.
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The table below indicates the minimum capital conservation ratios applicable for different COn1 levels, including the amounts used to meet the minimum COn1 requirement of 4.5% of RWA and the impact on COn1 of the amounts to be distributed:
COn1 ratio, net of deductions (CDCOn1) – as a percentage of RWA - Minimum capital conservation ratio - as a percentage of distributable profits -
Financial Entities that are not categorized as D-SIBs or G-SIBs D-SIBs and G-SIBs Financial Entities
4.5 – 5.13 4.5 – 5.38 100
> 5.13 – 5.75 > 5.38 – 6.25 80
> 5.75 – 6.38 > 6.25 – 7.13 60
> 6.38 – 7.0 > 7.13 – 8 40
> 7.0 > 8 0
As described above, the minimum limits required by the regulations are:
(i) for COn1, the amount resulting from multiplying the capital RWA by 4.5%;
(ii) for NWb, the amount resulting from multiplying RWA by 6%; and
(iii) for the RPC, the amount resulting from multiplying RWA by 8%.
COn1 must be used in the first place to satisfy the minimum capital requirement of 4.5% of RWA. Subsequently, and in the event the total does not have enough Additional Equity Tier 1 (CAn1) or Tier 2 Capital (NWc), the COn1 shall also be applied to meet requirements of 6% and 8% of Tier 1 Capital and total capital. Only the remaining COn1, if any, can be computed to satisfy the applicable conservation buffer, increased in function of the counter-cycle buffer, if applicable.
Any entity that desires to exceed the dividend distribution limits shall finance this distribution by new contributions of COn1 in the excess amount.
For more information, see Item 8.A “Consolidated Statements and Other Financial Information—Amounts available for distribution and distribution approval process.”
Credit Risk
For the purposes of applying the provisions of this section, financial institutions will be classified into:
(i) Group 1: Entities designated by the Central as D-SIBs and branches or subsidiaries of foreign banks classified as G-SIBs.
(ii) Group 2: Financial institutions not included in item i).
In cases where specific provisions are not established for each of these groups, the same treatment shall be applied to both grouPs. Financial institutions that undergo a change in their classification, as outlined above, will have a period of 6 months to apply the specific provisions corresponding to their new group.
The minimum capital requirement for credit risk must be calculated applying the following equation:
CRC = (k * 0.08* RWAc) + INC
Where:
• CRC: Capital requirement for credit risk.
• k: Factor linked to the credit rating assigned to the entity based on the evaluation performed by Superintendency in accordance with the following scale:
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Assigned Rating(1) k Factor
1 1.00
2 1.03
3 1.08
4 1.13
5 1.19
Note:-
(1) For the purposes of the calculation of the capital requirement, the rating will be that of the third month after the month of the most recent rating informed to the entity. For so long as no notice is given, the “k” factor will be equal to 1.03.
• “RWAc” stands for capital risk weighted assets calculated by adding the value obtained from applying the following formula:
A * p + PFB * CCF * p + non-DvP + (DVP + RCD + INC (significant investments in companies))* 12.50
Where:
“A” refers to eligible assets/exposures;
“PFB”: off-balance sheet items (computable concepts not recorded in the balance sheet).;
“CCF” the credit conversion factor;
“p” refers to the risk weighting factor, expressed on a per unit basis.
“DvP” refers to failed delivery against payment transactions (for purposes of these rules, failed payment against payment (PvP) transactions are also included). The amount is determined by the addition of the amounts arrived at by multiplying the current positive exposure by the applicable capital requirement.
In addition, “no DvP” refers to transactions that do not involve delivery against payment. The amount is determined by the addition of the amounts arrived at by applying the weighting factor (p) on the relevant transactions.
“RCD” refers counterparty credit risk for over-the-counter (OTC) derivatives transaction.
“INC (significant investments in companies)” means the incremental minimum capital requirements based on any excess over the following limits:
• equity interest held in companies: 15%
• total equity interests held in companies: 60%
The established maximum limits will be applied on the financial entity’s RPC for the last day before the relevant date, as prescribed in the Central Bank regulations on “Credit Risk Fractioning.”
INC: Increment for the following excesses:
• In the ratio of fixed assets and other concepts (Section 4 of the respective Central Bank regulations), excluding those computed for the determination of INC (significant investments in companies);
• In the limits established in the regulations on “Financing to the Non-Financial Public Sector,” excluding those computed for the determination of INC (significant investments in companies);
• In the limits established in the regulations of “Large Exposures to Credit Risk” – as outlined in the regulations on “Minimum Capital Defaults and Technical Relationships. Applicable Criteria,” excluding those computed for the determination of INC (significant investments in companies);
• In the limits for credit grading (Section of the respective Central Bank regulations);
• In the limit for derivatives on commodities or raw materials, as outlined in Section 1.2 of the regulations on “Spot and Forward Transactions, Repurchase Agreements, Collateral, Other Derivatives, and Investment Funds.”
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Excluded items are:
a) securities granted for the benefit of the Central Bank for direct obligations;
b) deductible assets pursuant to RPC regulations; and
c) financings and securities granted by branches or local subsidiaries of foreign financial entities by order and on account of their headquarters of foreign branches or the foreign controlling entity, to the extent:
(i) the rules of the country where the parent company or controlling entity is located, the latter defined according to the provisions in force in that jurisdiction, must cover the supervision on a consolidated basis of the local branches or subsidiaries,
(ii) the entity must comply with the provisions of Section 3.1. of the rules on “Credit Evaluations,” requiring for such purpose an international risk rating within the “investment grade” category;
(iii) in case of financings, such financing must be provided by the local branches or subsidiaries only with funds from lines of credit assigned to them by the aforementioned foreign intermediaries (if the assistance is granted in a currency other than that of the foreign resources, the local entity may not assume the exchange risk); and
(iv) in case of locally granted guarantees, counter-guarantees must exist, extended by the parent company or its branches in other countries, or by the foreign controlling entity. These counter-guarantees must be enforceable unconditionally upon simple request from the local branch or subsidiary and immediately effective upon potential execution by the beneficiary.
Computation of Included Concepts
(1) Monthly Individual and Consolidated Base. The included concepts shall be calculated based on the balances as of the last day of each month (principal, interest, premiums, updates—by the CER—and exchange rate differences, as applicable), net of provisions for credit risk (including, where applicable, provisions recorded in liabilities) and devaluation, as well as accumulated depreciation and amortization attributed to them and other reconciling accounts. 100% of the provision for credit risk corresponding to the portfolio of debtors classified as “in normal situation” (sections 6.5.1 and 7.2.1 of the regulations on “Debtors Classification”) and to financings covered by preferred guarantees “A” shall not be deducted.
(2) Quarterly Consolidated Base. The balances as of the end of the quarter will be considered, applying the corresponding provisions set forth in other aspects.
Due Diligence
Financial institutions in Group 1 must conduct due diligence at the time of credit issuance and at least annually thereafter to ensure they have a proper understanding of the risk profile and characteristics of their counterparties. The level of sophistication in the due diligence assessments must be proportional to the size and economic importance of the financial institutions, as well as the nature and complexity of their operations. Based on these evaluations, financial institutions must demonstrate to the Superintendency that the assigned risk weightings are appropriate for the risk profiles of their counterparties.
To this end, Group 1 financial institutions must:
(i) Implement appropriate measures to assess the financial and operational performance of each counterparty through credit analysis;
(ii) Have regular access to information on their counterparties to complete their analysis;
(iii) Conduct exposure analysis for counterparties within consolidated groups—individually where possible. When evaluating the repayment capacity of a counterparty, institutions should consider the support of the economic group and the potential negative impact on the counterparty from issues within the group;
(iv) Maintain effective policies, processes, systems, and internal controls; and
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(v) Be able to demonstrate to Superintendency that their due diligence analyses are consistent with other required evaluations, such as credit risk provisioning processes and economic capital assessments, and comply with the criteria set forth in supplementary regulations.
This requirement does not apply to exposures to governments and central banks.
Criteria for Determining Risk-Weighted Assets
• Risk weighting from the table below apply based on the institution’s group. If due diligence results in higher risk weighting, Group 1 financial institutions must apply the higher weighting.
• Risk weighting apply per transaction, with the highest applicable weighting being used if multiple weighting apply.
• Exposures in foreign currency or without credit risk coverage (such as retail exposures and residential mortgages) will have a risk weight of 150%, or 1.5 times the applicable risk weighting, whichever is higher.
• “Exposure” includes loans, securities, guarantees, and contingent obligations. Specific provisions apply to exposures to financial institutions, companies, retail exposures.
• Exposures to non-financial public sector entities are treated as private sector exposures when applicable.
• If any exposure is in default, the entire exposure is subject to default treatment.
• Foreign currency exposures settled in Pesos (U.S. dollar-linked) are treated as Peso-denominated exposures.
• Central Counterparty (CCP) exposures and credit risk coverage follow special provisions.
• Portfolio purchases are treated like credits originated by the institution, subject to conditions.
Each type of asset is weighted according to the level of risk assumed to be associated with it. In broad terms, the weights assigned to the different types of assets are:
Type of Asset Weighting (%)
Availabilities
Cash held in treasury, in transit (when the financial institution assumes responsibility and risk for transportation), in ATMs. 0
Checking accounts and in special accounts with the Central Bank and payment orders in charge of the Central Bank. 0
Monetary gold or gold bars of “good delivery” held within the entity or another financial institution – provided they are individualized under on an allocated basis clauses – and as long as the assets are backed by liabilities denominated in these forms. 0
Cash items in the process of collection (checks and drafts for collection), cash in armored cars and in custody at financial institutions 20
Exposure to governments and central banks
To the Central Bank in Pesos, when its source of funds is in that currency. 0
To the Federal Government and to the provincial and municipal governments and the City of Buenos Aires in Pesos, when their source of funds is in that currency. 0
To the public non-financial sector arising from financing granted to social security beneficiaries or public employees -in both cases with discount code-, to the extent that such transactions are denominated in Pesos, the source of funds is in that currency and the installments of all the entity’s financing with a periodic amortization system do not exceed, at the time of the agreements, thirty percent (30%) of the debtor’s income and/or, as the case may be, of the co-debtors. 0
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Type of Asset Weighting (%)
To the non-financial public sector and the Central Bank. Other(3)
AAA to AA- 0
A+ to A- 20
BBB+ to BBB- 50
BB+ to B- 100
Below B- 150
Unrated 100
To other sovereign states of their central banks(3)
AAA to AA- 0
A+ to A- 20
BBB+ to BBB- 50
BB+ to B- 100
Below B- 150
Unrated 100
To entities of the non-financial public sector of other sovereign states, in accordance with the credit rating assigned to the corresponding sovereign(3)
AAA to AA- 20
A+ to A- 50
BBB+ to BBB- 100
BB+ to B- 100
Below B- 150
Unrated 100
To the Bank for International Settlements, the International Monetary Fund, the European Central Bank, the European Stability Mechanism, and the European Financial Stability Facility. 0
To the non-financial public sector of the provinces, municipalities and/or the City of Buenos Aires arising from the acquisition of sovereign bonds issued in Pesos by the central administration, when they do not have any one of the guarantees described in the regulations on “Financing to Non-Financial Public Sector,” pursuant to the credit rating assigned to the respective jurisdiction.(3)
AAA to AA- 20
A+ to A- 50
BBB+ to BBB- 100
BB+ to B- 150
Below B- 200
Unrated 200
Exposure to the Multilateral Development Banks (MDB)
Exposure to entities that, in the judgment of the Basel Committee on Banking Supervision, meet the eligibility criteria outlined in international standards. —
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Type of Asset Weighting (%)
Other
• AAA to AA- 20
• A+ to A- 30
• BBB+ to BBB- 50
• BB+ to B- 100
• Below B- 150
• Unrated 50
Exposure to local financial institutions
Exposure to financial institutions by financial entities in Group 1 (SCRA) - Grade A(1)
Risk weight applicable to short-term exposures 20
General risk weight 40
Exposure to financial institutions by financial entities in Group 1 (SCRA) - Grade B(1)
Risk weight applicable to short-term exposures 50
General risk weight 75
Exposure to financial institutions by financial entities in Group 1 (SCRA) - Grade C(1)
Risk weight applicable to short-term exposures 150
General risk weight 150
Exposure to financial institutions by financial entities in Group 2
Short-term exposures 20
Other 100
Exposure to companies
Investment-grade companies 65
SMEs (Small and Medium Enterprises) not meeting the criteria set in Section 2.8.3 of the Minimum Capital Regulations 85
Specialized financing for large infrastructure projects - pre-operational stage 130
Others 100
Retail exposures
Regulatory Transactional Retail Exposures 45
Regulatory Non-Transactional Retail Exposures 75
Non-Regulatory Retail Exposures 100
Exposures guaranteed by reciprocal guaranty companies (sociedades de garantía recíproca) or public security funds registered with the registries authorized by the Central Bank 50
Mortgage-Backed Exposures - Regulatory Exposures with Mortgage Collateral on Residential Real Estate(2)
Regarding credit support that does not exceed 55% of the property’s value 20
On the amount exceeding 55% of the property’s value, the Counterparty Risk Weighting will apply
Mortgage-Backed Exposures - Exposures with mortgage collateral, regulatory on commercial properties. (2)
Up to the amount equivalent to 55% of the property value, the risk weighting of 60% or the Counterparty Risk Weighting will apply, whichever is lower.
For the amount exceeding 55% of the property value, the Counterparty Risk Weighting will apply.
Exposures with non-standard mortgage collateral. 150
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Type of Asset Weighting (%)
Exposures in Default Situations(4)
Regulatory mortgage-backed exposures on residential real estate. 100
Exposures or portions not covered by credit risk mitigants under Section 5 of the Minimum Capital Regulations, other than those covered in the previous item
With specific provisions lower than 20% of the outstanding balance. 150
With specific provisions equal to or greater than 20% but lower than 50% of the outstanding balance. 100
With specific provisions equal to or greater than 50% of the outstanding balance. 50
Exposures to instruments (non-deductible portion of the RPC).
Exposures to Instruments by Group 1 Financial Institutions
Subordinated debt and capital instruments that do not meet the characteristics to be considered as equity shares. 150
Equity shares 250
Exposures to Instruments by Group 2 Financial Institutions
Subordinated debt 150
Capital participations 250
Spot Transactions Pending Settlement (Non-Failed Transactions) 50
Exposures to Natural and Legal Persons Arising from Installment Purchases Made Until November 25, 2021 Using Credit Cards for Overseas Travel Tickets and Other Foreign Tourism Services (Such as Accommodation, Car Rentals, etc.), Whether Directly with the Service Provider or Through Travel Agencies and/or Tourism Platforms. 1,250
Other Assets and/or Off-Balance-Sheet Items(5) 100
Securitization exposures, failed DvP transactions, non DvP transaction, exposures to central counterparty institutions (CCP) and derivative transaction not included in said exposures receive special treatment.
(1) The risk weighting for exposures to financial institutions cannot be lower than the risk weighting applicable to the jurisdiction where the counterparty is established in the following cases:
(i) When the exposure is not denominated in the local currency of the counterparty’s jurisdiction; or
(ii) When the debt is incurred by a branch or subsidiary of the counterparty abroad, and is not denominated in the local currency of the jurisdiction where it operates.
However, the treatment outlined in items i) and ii) does not apply to self-liquidating contingent lines for financing foreign trade with an original contractual maturity of up to one year.
(2) The “Counterparty Risk Weighting” shall be the same as that assigned to an exposure without mortgage collateral. Accordingly, a risk weighting of 75% shall apply to exposures to natural persons, 85% to exposures to micro, small, and medium-sized enterprises (“SMEs”), and the risk weighting set forth in the table above shall apply to all other exposures.
(3) Based on ratings from an approved External Credit Assessment Institution (ECAI), such as Standard & Poor’s.
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(4) A portion of the exposures that benefit from credit risk mitigation shall be subject to the provisions set forth in Section 5 of the Minimum Capital Regulations.
(5) Off-balance sheet items, including commitments for financing and correspondent lines to foreign entities, guarantees provided, sureties on deferred payment checks, documentary credits and acceptances, rediscounted documents with other financial institutions, and other credit agreements, will be converted into credit equivalents using the applicable credit conversion factors (CCF). Subsequently, the risk weighting outlined in the table above will be applied, along with any other relevant provisions.
Credit Risk Regulation – Large Exposures
General Overview
Central Bank Communication “A” 6599, as amended and restated by Communication “A” 6620, and its consequent modifications (“Communication “A” 6620”), effective as of January 1, 2019, abrogated credit risk fractioning regulations (except for the provisions related to the non-financial public sector) and replaced the former regime by regulating “large exposures to credit risk.” The system seeks to limit the maximum loss that a financial entity may suffer upon the occurrence of an unexpected default of a counterparty or group of connected counterparties who do not belong to the non-financial public sector, therefore affecting its solvency. The regulations regarding the exposures to credit risk must be applied at all times with every counterparty of the entity.
In this regard, the regulations have established the concept of “group of connected counterparties,” which applies to all cases in which one of the counterparties of a financial entity have direct or indirect control over the rest or in those cases in which financial difficulties experimented by one of the counterparties causes a strong likelihood that its subsidiaries may struggle financially as well. According to the regulation, upon the detection of the existence of a group of connected counterparties by the financial entity, such group shall be considered as a single counterparty and the sum of the exposures to credit risk that a financial entity possesses with all the individual counterparties comprehended that group shall be subject to the information and disclosure requirements provided in section 2.
One of the main aspects of Communication “A” 6620 is the introduction of the concept of “large exposure to credit risk” in Argentine banking regulations, which is defined as the sum of all values of exposure of a financial entity with a counterparty or group of connected counterparties when it is equal or above 10% of the Tier 1 Capital registered by the financial entity the immediately preceding month of its calculation.
However, the determination of the values of exposure to risk recognize the following exceptions:
(i) intraday interbank exposures;
(ii) exposures of financial entities with qualifying central counterparties, as defined by the Minimum Capital Regulations;
(iii) exposures with the Central Bank; and
(iv) exposures with the Argentine non-financial public sector.
The balances held by financial entities in sight accounts at foreign banks, which temporarily and incidentally arise exclusively from client foreign exchange transactions, shall not be subject to the limits outlined in the “Large Credit Risk Exposures” regulations (the “Large Credit Exposures Regulations”) provided the following conditions are met:
(i) The foreign exchange transactions arise from the settlement of foreign currency inflows to the country as ordered by third parties through the respective financial entity; and
(ii) The balances result from settlement mismatches due to time zone differences between the international markets where the transactions originate and the local market.
Notwithstanding the above, such balances must be reported to the Superintendency Entities under the applicable reporting regime.
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Regarding the information regime, the Central Bank has established that the financial entities shall inform the Superintendency of all the values of exposure to credit risk before and after the application of mitigation techniques, detailing:
(i) large credit risk exposures, as defined above;
(ii) every other exposure to risk which value is equal or above 10% of the Tier 1 Capital of the financial entity, without applying credit risk mitigation techniques;
(iii) excluded exposures to risk which values are equal or above 10% of the financial entity’s Tier 1 Capital; and
(iv) the financial entity’s 20 largest applicable exposures to risk, regardless of its value in relation with the financial entity’s Tier 1 Capital.
Limits
On one side, Communication “A” 6620 sets at 15% the limit of exposure with a counterpart of the non-financial private sector. Nevertheless, the limit will be increased by 10 percentage points for the part of the exposures that are covered by preferred collaterals.
Specific criteria for exposures to and/or guaranteed by reciprocal guarantee companies (“SGRs”), public guarantee funds (“FGPs”), and financial entities are as follows: The exposure limit is set at 25%, even when the SGR is linked to the financial entity. This limit is increased by 25 percentage points if the lending financial entity belongs to Group B, provided that the exposures to the SGR (even if linked) or to the FGP do not exceed the basic margin set forth in Section 3.1.1 of the “Credit Rating” regulations.
Additionally, it sets special limits for operating with financial institutions in the country and abroad (the general rule sets it at 25%). This limit will be increased by 75 percentage points when the lending financial entity is a second-tier commercial bank and belongs to Group B. The aforementioned limits will not apply when any of the conditions set out in the following paragraph are met.
When both the lending and borrowing financial entities are rated 4 or 5 by Superintendency, the limit will be 0%. In cases where the borrower is a foreign bank, the limit is 5% if the foreign bank does not hold an international credit rating in the “investment grade” category or fails to meet the other requirements stipulated in Section 3.1 of the “Credit Ratings” regulations.
Linked counterparties to the financial institution through control or personal relationships: The limits set forth in the regulations will apply solely on an individual basis. In cases where the linked counterparty is not subject to consolidation with the lending financial institution, these limits must also be observed in relation to the consolidated Tier 1 capital.
The global exposure limits outlined in the regulations are as follows:
• For linked counterparties, the total value of risk exposure concerning the entire set of linked counterparties, excluding those subject to individual limits exceeding 10%, must not exceed 20%.
• Regarding equities and other receivables, the total value of risk exposure in relation to equities not allocated to the trading portfolio, as specified in Section 6.1.2.1 of the Minimum Capital Regulations, must not exceed 15%. Exposures to equity holdings in public utility companies, where holding such shares is necessary to receive services, as well as in companies providing complementary financial services, are excluded from this limit.
• The total exposure limit, including equities in both investment and trading portfolios, as well as credit exposures from term operations (whether related to repos or not) carried out in authorized domestic markets and institutionalized foreign markets—along with any settlement mismatches where there is no central counterparty and the counterparty cannot be identified—must not exceed 50%.
• Concentration risk limits specify that exposures to linked or non-linked counterparties that represent 10% or more of the entity’s Tier 1 capital will be considered computable exposures. The sum of these computable exposures must not exceed three times the entity’s Tier 1 capital, excluding exposures to local financial institutions. For the total of all exposures, this sum must not exceed five times the entity’s Tier 1 capital, with the preceding limit still applicable. However, for second-tier commercial banks that are lenders, this limit is increased to ten times the Tier 1 capital.
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Financial entities are prohibited from directly or indirectly extending new financial assistance to linked counterparties in the following cases:
• If the counterparties have at least one classification other than “in normal situation,” according to the most recent information available from the “Central de Deudores del Sistema Financiero.”
• If the entity has outstanding debt arising from financial assistance provided by the Central Bank.
Non-compliance with the limits should be exceptional, must be immediately reported to the Superintendency, and must be rectified promptly. In a stress scenario, the Superintendency may waive non-compliance with the interbank limit, once they have occurred, to help ensure the stability of the financial system.
Minimum controls to exposures of affiliates
The regulations set forth three stages for the control of the financial entity’s affiliates exposure:
(1) Reports for the entity’s management:
• Report by the CEO;
• Report by the supervisory committee; and
• Acknowledgment of the reports by the entity’s management.
(2) Evidence of the affiliation to the financial entity: the personnel responsible for the analysis and resolution of the credit operations shall expressly register whether or not the client is affiliated with the financial entity.
(3) Affidavit evidencing affiliation: affiliated clients shall file an affidavit stating if they belong to the lending entity or if its relationship with such entity implies the existence of a controlling influence. The submission of sworn declarations by clients regarding their linked status does not relieve the institution from its responsibility to determine this status based on its own analysis.
Interest rate risk
Until January 1, 2013, financial entities had to comply with minimum capital requirements regarding interest rate risk. These requirements were intended to capture the sensitivity of assets and liabilities to changes in the interest rates. Communication “A” 5369 removed all rules and regulations regarding minimum capital requirements for interest rate risk. Notwithstanding this change, financial entities must continue to calculate the interest rate risk and remain subject to the Superintendence’s supervision. By virtue of Communication “A” 6534, dated July 3, 2018, the Investment Portfolio Interest Rate (RTCI) risk shall be calculated.
Market risk
Market risk is defined as the possibility of incurring losses in on-and off-balance sheet recorded positions as a result of adverse changes in market prices.
Regime in Effect Until July 31, 2026
Until July 31, 2026, the capital requirement for market risk shall be the arithmetic sum of the minimum capital requirement for interest rate (trading portfolio), stock (trading portfolio), exchange rate, commodities and options risks (trading portfolio). To meet this capital requirement, entities must apply a “Standard Measurement Method” based on an aggregate of components that separately capture the specific and general market risks for securities positions.
Minimum capital requirements for market risk must be complied with on a daily basis. The information corresponding to the last day of each month must be submitted to the BCRA on a monthly basis.
The risks subject to this capital requirement include risks arising from positions in financial instruments—securities and derivatives—assigned to the trading book, as well as risks arising from positions in foreign currencies and commodities, regardless of the book to which they are assigned.
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The capital requirement for foreign exchange and commodity risk shall apply to the total position in each foreign currency and each commodity. The capital requirement for securities shall be calculated with respect to instruments assigned to the trading book, which must be prudently valued at market prices (marked to market) or using model-based valuations (marked to model). Instruments whose yield is determined by reference to the Coeficiente de Estabilización de Referencia (“CER”) shall be treated as fixed-rate instruments.
Items that must be deducted for purposes of calculating RPC, regardless of the book in which they are recorded, shall be excluded from the computation of the market risk capital requirement.
For these purposes, the trading book comprises positions in financial instruments held with trading intent or to hedge other elements of the trading book, provided that trading is unrestricted or that the instrument can be fully hedged. The trading book must be actively managed and subject to daily valuation with adequate precision.
In addition, institutions must separately calculate and hold capital for counterparty credit risk arising from derivatives and securities financing transactions recorded in the trading book, applying the methods and risk weights applicable to exposures recorded in the banking book, and must maintain clearly defined policies and procedures for assigning exposures to the trading book.
Regime in Effect as of August 1, 2026
As of August 1, 2026, the capital requirement for market risk shall be equal to the arithmetic sum of the capital charges for interest rate risk, equity risk, foreign exchange risk, and commodity risk, each multiplied by the applicable fixed scalar.
For its determination, institutions must apply the standardized approach established by the BCRA for each type of risk. Options positions shall be incorporated according to their underlying instrument and added to the relevant capital charge prior to the application of the applicable scalars.
The risks subject to this requirement include positions in financial instruments—securities and derivatives—assigned to the trading book, as well as positions in foreign currencies and commodities, regardless of the book to which they are assigned. Positions must be prudently valued at market prices or using models, as applicable, and instruments indexed to the CER shall be treated as fixed-rate instruments.
The market risk capital requirement must be calculated on a daily basis and satisfied at the close of each business day in accordance with the Minimum Capital Regulations.
Minimum capital requirement for Interest Rate Risk. Until July 31, 2026, the capital requirement for interest rate risk must be calculated in respect of any debt securities and other instruments accounted for as part of the trading portfolio, including any non-convertible preferred shares. As of August 1, 2026, the capital requirement for interest rate risk must be calculated with respect to all instruments assigned to the trading book whose value is sensitive to changes in market interest rates. This includes all fixed- and floating-rate debt instruments and instruments that behave as such, including non-convertible preferred shares, as well as derivatives. In addition, a capital charge for options on debt instruments must be included, calculated in accordance with the specific treatment provided in the Minimum Capital Regulations. This capital requirement is calculated by adding two separately calculated requirements: first, the specific risk involved in each instrument, either a short or a long position, and second, the general market risk related to the effect of interest rate changes on the portfolio. A set off of the long and short positions held in different instruments will be allowed.
Minimum capital requirement for positions in stock. Until July 31, 2026, the capital requirement for the risk of holding equity positions in the trading portfolio applies to both long and short positions in ordinary shares, convertible debt securities that function like shares and any call or put options for shares, as well as any other instrument with a market behavior similar to that of shares, excluding non-convertible preferred shares, which are subject to the minimum capital requirement for interest rate described in the preceding paragraph. Long and short positions in the same security may be computed on a net basis. As of August 1, 2026, the capital requirement applies to long and short positions in common shares, convertible debt instruments that behave like equities, commitments to purchase or sell shares, and any other instrument with equity-like behavior (such as equity or equity index futures, forwards and swaps), excluding non-convertible preferred shares, which remain subject to the interest rate risk capital charge, as well as options on equities and equity indexes.
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Minimum capital requirement for exchange rate risk: The capital requirement for exchange rate risk establishes the minimum capital required to hedge the risk involved in maintaining positions in foreign currency, including gold. To calculate the capital requirement for exchange rate risk, entities must first quantify its exposure in each currency, and then estimate the risks inherent in the combination of long and short positions in different currencies.
Minimum capital requirement for commodities risk: The capital requirement for commodities risk establishes the minimum capital required to hedge the risk involved in maintaining positions in commodities (precious metals, except for gold). For the purposes of these regulations, a commodity is defined as any physical product that is traded or negotiable on a secondary market. To calculate the capital requirements, each position in a commodity (spot and forward) must be expressed in terms of the corresponding standard unit of measurement (barrels, kilograms, grams, etc.), and following the rules set forth in the regulations on “Large Exposure to Credit Risk.”
Minimum capital requirement for positions in options: Entities that only purchase options — provided that the market value of the total options in the portfolio does not exceed 5% of their previous month’s RPC — or whose positions in sold options are fully covered by positions in purchased options with exactly the same contractual terms, may use the simplified method outlined in the regulations on “Large Exposure to Credit Risk.” In all other cases, they must use the delta-plus method, provided for in said regulation.
Consequences of a Failure to Meet Minimum Capital Requirements
In the event of non-compliance with capital requirements by an existing financial institution, Central Bank Communication “A” 6091, as amended, provides the following:
(i) Non-compliance reported by the institution: the entity must comply with the requirements no later than the second month following the month in which the non-compliance is recorded, or submit a remediation and regularization plan within 30 calendar days following the last day of the month in which the non-compliance occurred. In addition, non-compliance with minimum capital requirements will entail a number of consequences for the financial institution, including:
(a) The Superintendency may appoint an observer with powers established under the Financial Institutions Law.
(b) The Superintendency impose restrictions on: (i) transformation of financial entities; (ii) establishment of branches abroad; (iii) establishment of representative offices abroad, unless this is in replacement of a previously operational branch that is being closed contemporaneously in the same country; and (iv) participation in foreign financial entities.
(c) The distribution of cash dividends, as well as the payment of fees, shares, or bonuses arising from the distribution of the entity’s results, will be prohibited. This limitation will remain in effect until the remediation and regularization plans are either submitted or, if submitted, have been observed or found non-compliant by Superintendency.
(ii) Non-compliance detected by the Superintendency: the institution may challenge the non-compliance determination within 30 calendar days after being served notice by the Superintendency. If no challenge is made, or if the defense is dismissed, the non-compliance determination will be deemed to be final and the procedure described in item 1.3.1 of Communication “A” 6091 will apply.
Furthermore, pursuant to the Minimum Capital Regulations, in the event of a daily capital deficiency with respect to market risk capital requirements, excluding the last day of the month, arising from the calculation of requirements for interest rate, exchange rate, or equity risks, the financial institution must restore the capital and/or reduce its financial asset positions until compliance with the required standard is achieved. The institution will have a period of ten business days, starting from the first deficiency, to rectify the situation.
If the deficiency persists for more than ten business days, the entity must submit a regularization and remediation plan within the next five business days, subject to the consequences described below. In cases where deficiencies are determined by Superintendency and persist according to the most recent available information, the entity will have five business days to present an explanation, and Superintendency will respond within ten business days. For the regularization of the non-compliance as described in the previous paragraph, the institution must adhere to the ten-day deadline, starting from the date the deficiency is finalized. If the deficiency is not rectified within this period, the entity must submit a regularization and remediation plan within the next five business days, subject to the consequences described below.
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Operational risk
The regulation on operational risk (“OR”) recognizes the management of OR as a comprehensive practice separated from that of other risks, given its importance. OR is defined as the risk of loss resulting from inadequate or failed internal processes, people and systems or from external events. The definition includes legal risk but excludes strategic and reputational risk.
Financial institutions must establish a system for the management of OR that includes policies, processes, procedures and the structure for their adequate management. This framework must also allow the financial entity to evaluate capital sufficiency.
Seven OR event types are defined, according to internationally accepted criteria:
• internal fraud;
• external fraud;
• employment practices and workplace safety;
• clients, products and business practices;
• damage to physical assets;
• business disruption and system failures; and
• execution, delivery and process management.
Financial institutions generally rely on three lines of defense, the degree of implementation of which must be commensurate with the nature, size, and complexity of the institution’s operations, and aligned with its risk profile.
• The first line of defense lies within the business units, which are responsible for identifying and assessing operational risks.
• The second line of defense consists of the independent operational risk management function, which provides an objective perspective on the material operational risks identified by the business units, evaluates the design and effectiveness of key controls, and assesses risk tolerance.
• The third line of defense—typically carried out by internal or external audit—ensures that the operational risk management framework is appropriate. It is tasked with reviewing the design and implementation of the operational risk management systems and associated governance processes in both the first and second lines of defense, as well as the validation processes in place to guarantee their independence and consistent application in accordance with the institution’s policies.
Where both first and second line functions coexist within a business unit, institutions must clearly document and delineate the responsibilities of each function, emphasizing the independence of the second line.
Financial entities are charged with implementing an efficient OR management system following the Risk Management Guidelines. A solid system for risk management must have a clear assignment of responsibilities within the organization of financial entities. Thus, the regulation describes the roles prepared by each level of the organization in managing of OR (such as the roles of the Board of Directors, senior management and the business units of the financial institution).
A financial institution’s size and sophistication, and the nature and complexity of its products and processes, and the extent of the transaction determines the type of “OR unit” required. For small institutions, this unit may even consist of a single person. This unit may functionally respond to the senior management (or similar) or a functional level with risk management decision capacity that reports to that senior management.
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An effective risk management will contribute to prevent future losses derived from operational events. Consequently, financial entities must manage the OR inherent in their products, activities, processes and systems. The OR management process comprises:
(a) Identification and assessment: the identification process should consider both internal and external factors that could adversely affect the development of the processes and projections created according to the business strategies defined by the financial institution. Financial entities should use internal data, establishing a process to register frequency, severity, categories and other relevant aspects of the OR loss events. This should be complemented with other tools, operational risk self-assessments (including the analysis of inherent and residual risk), operational risk event databases, event management systems, monitoring frameworks and control testing, metrics, scenario analysis, and benchmarking and comparative assessments.
(b) Monitoring: an effective monitoring process is necessary for quickly detecting and correcting deficiencies in the policies, processes and procedures for managing OR. In addition to monitoring operational loss events, banks should identify forward-looking indicators that enable them to act upon these risks appropriately.
Financial institutions must maintain a robust control environment, supported by sound internal policies, procedures, systems, and controls, as well as effective risk mitigation and/or risk transfer strategies. Internal controls must ensure operational efficiency, asset protection, the reliability of financial reporting, and compliance with applicable laws and regulations.
A strong control framework should include risk assessments, control activities, information and communication mechanisms, and monitoring processes. Controls must also address operational resilience, proper segregation of duties, conflict of interest management, and specific safeguards such as periodic reconciliations, access controls, training programs, and mandatory leave policies.
Where internal controls prove to be insufficient, they may be supplemented through risk transfer tools, such as insurance, always under the oversight of the Board of Directors. In addition, institutions must manage risks associated with the outsourcing of services through proper due diligence processes, clearly defined contractual agreements, monitoring mechanisms, and contingency plans.
Financial institutions must also establish Business Continuity Plans (“BCPs”) designed to ensure operational continuity and minimize losses in the event of severe disruptions. BCPs must be aligned with the institution’s operational resilience framework, formally approved by the Board of Directors, and involve all three lines of defense.
Such plans must be based on scenario analyses and include impact assessments, recovery procedures, activation thresholds, and communication protocols. BCPs should address both internal and external critical functions, and must be tested on a regular basis, kept up to date, supported by role-specific training, and reported to senior management and the Board.
Technology and Information Security Risk Management. Financial institutions are required to implement a robust technology and information security risk management program, consistent with the broader operational risk management framework. This program must address the identification, assessment, mitigation, and continuous monitoring of risks, while ensuring the confidentiality, integrity, and availability of systems and data.
The program must align with the institution’s risk appetite and applicable regulatory requirements, be tested and updated regularly, and be supported by threat intelligence. Institutions must also be prepared to respond to disruptive events—including cybersecurity incidents and large-scale remote access failures—and must ensure the timely updating of systems, secure application development, and the implementation of appropriate user access management processes.
Transparency. Financial institutions must publicly disclose, on a regular basis through their websites or reports, their assessment of operational risk management practices and their exposure to such risk. These disclosures must be proportionate to the size and complexity of the institution’s operations and should include material loss events, risk management frameworks, and corporate governance practices. The institution must adopt a formal disclosure policy, approved by senior management and the Board of Directors, and subject to periodic review to ensure the adequacy and effectiveness of the published information.
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The following is a summary of the key regulatory requirements applicable to financial institutions in the area of operational risk management.
For the purposes of the provisions set forth in this section, financial institutions shall be classified into Group 1 and Group 2. Institutions that undergo a change in classification—pursuant to the criteria outlined in the preceding sections—shall have a period of six months to implement the specific requirements applicable to the new group to which they belong.
The capital requirement for OR for institutions in Group 1 will be determined on a monthly basis, using the following formula:
CRO = BIC x ILM
Where:
• CRO: OR capital requirement.
• BIC: Business indicator component, which is the product of the business indicator (BI) and a series of marginal coefficients (αi).
The BI is an approximation of operational risk based on financial statement information. It will be determined by the following formula:
BI = VA (ILDCProm + SCProm + FCProm + RMProm)
• ILDCProm: Interest, leasing, and dividend component. It will be determined by the following formula: Min. [VA (interest income – interest expenses); 5% × interest-bearing assets] + dividend income
• SCProm: Service component. It will be determined by the following formula: Max. [other operational income; other operational expenses] + Max. [fee and commission income; fee and commission expenses]
• FCProm: Financial component. It will be determined by the following formula: VA (net result of trading portfolio) + VA (net result of investment portfolio)
• RMProm: Total monetary result VA: Absolute value.
Each term within the 3 components and the monetary result must be calculated as the average of the values of the last 3 consecutive 12-month periods prior to the month in which the calculation is made, expressed in homogeneous currency at the close of the 36-month calculation period: t, t-1, and t-2. First, the net values corresponding to each 12-month period (e.g., interest income minus interest expenses) must be determined, then the average of the 3 periods must be calculated.
The Business Indicator (BI) consists of several components:
(i) Interest, Leases, and Dividends (ILDC) include income and expenses from interest and adjustments on financial assets and liabilities, such as loans, deposits, financial leases, and derivatives. It also covers income from dividends for investments in non-consolidated subsidiaries and associates.
(ii) Services (SC) include income and expenses from services like advisory fees, asset management, and commissions, as well as other operational income and expenses from routine banking activities not captured elsewhere.
(iii) Financial (FC) includes net results from trading portfolios and investment portfolios, covering assets held for trading or investment, realized gains and losses, and hedging accounting.
Certain items, such as administrative costs, insurance operations, and depreciation, are excluded from BI calculations.
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At the consolidated level, the BI is calculated based on the consolidated values of income and expenses for the entire banking group. Subconsolidated calculations should be performed using the BI figures of the entities consolidated at each specific sublevel. At the individual level, the BI figures of each subsidiary must be used.
Financial institutions may request the Superintendency’s approval to exclude discontinued operations from the BI, with the exclusion applied immediately upon approval. For business combinations, the BI calculation must include the financial data of acquired businesses from the date of acquisition, reflecting the last three consecutive 12-month periods.
The BIC is determined by the following expression: BIC = Σ BIi x αi
Where the marginal coefficients (αi) are determined based on the BI range.
Category BI Range (in billion euros*) Marginal Coefficients (αi)
1 ≤ 1 12%
2 1 < BI ≤ 30 15%
3 > 30 18%
The marginal coefficients increase as the size of the Business Indicator (BI) grows. For entities in Category 1 (BI equal to or less than the equivalent of €1 billion in local currency), the Business Indicator Component (BIC) equals BI multiplied by 12%. The marginal increase in BIC resulting from an increase of one unit of BI is 12% in Category 1, 15% in Category 2, and 18% in Category 3.
• ILM: Internal loss multiplier equal to 1.
RWA for OR are equal to 12.5 times the CRO.
The capital requirement for OR for institutions in Group 2 will be determined on a monthly basis, using the following formula:
Where:
• “Cro”: the capital requirement for OR.
• “α”: 15%.
• “n”: the number of 12-month consecutive terms with positive IB, based on the 36 months preceding the month of calculation. The maximum value of n is 3. No overlapping months are allowed when forming the periods.
• When n equals zero (n=0), the entity must comply with a requirement equivalent to the limit set in Section 7.3 of regulations on the Minimum Capital Regulations.
• “IBt”: Gross income for a 12-month consecutive period—provided it is positive—corresponding to the last 36 months prior to the month in which the calculation is made, expressed in the currency of the month preceding the calculation. Gross income is defined as the sum of: (i) financial income and income from services, minus financial expenses and service costs, (ii) other income minus other expenses, and (iii) total monetary results.
The following items, included under i) and ii), shall be excluded as applicable:
• Charges related to the creation of provisions, reversal of provisions established in prior periods, and recoveries of previously written-off credits in the current period;
• Results from investments in financial entities and companies, to the extent they relate to items deductible from computable equity;
• Gains from the sale of assets classified and measured at amortized cost or fair value with changes in Other Comprehensive Income.
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The requirement determined through application of the formula described above may not exceed:
(i) 20%, in the case of Group A entities, of the average over the preceding 36 months—prior to the month to which the requirement relates—of the minimum capital requirement for credit risk, expressed in constant currency of the month preceding the calculation;
(ii) 17%, in the case of Group B entities, of the average over the preceding 36 months—prior to the month to which the requirement relates—of the minimum capital requirement for credit risk, expressed in constant currency of the month preceding the calculation.
The maximum cap set forth above shall be reduced to 11% where the financial institution has received a rating of 1, 2, or 3, in accordance with the assessment issued by Superintendency in connection with its most recent inspection, with respect to all of the following aspects: the institution as a whole, its information technology systems, and the performance of the officers responsible for evaluating its internal control systems.
Where the financial institution has received a rating of 1 or 2 in all of the aforementioned aspects, the maximum cap shall be further reduced to 7%. For these purposes, the most recent rating notified shall be taken into account for purposes of calculating the requirement to be met in the third month following the month in which such notification is received.
The monthly minimum capital requirement for operational risk applicable to Group 1 and Group 2 financial institutions for the first month shall be equal to 10% of the aggregate capital requirements for credit risk and market risk—calculated, in the case of market risk, based on positions as of the last day of that month.
From the second month through the thirty-sixth month, the monthly requirement shall be equal to 10% of the average of the capital requirements determined for the months elapsed up to and including the calculation period, based on the aforementioned risks, in accordance with the following formula:
Minimum cash reserve requirements
The minimum cash reserve requirement requires that a financial institution keep a portion of its deposits or obligations readily available and not allocated to lending transactions and it is included in the Central Bank “Rules of Minimum Cash,” as amended and supplemented from time to time (the “Minimum Cash Requirements Regulations”).
Minimum cash requirements are applicable to demand and time deposits and other liabilities arising from financial intermediation denominated in Pesos, foreign currency, or government and corporate securities, and any unused balances of advances in checking accounts under agreements not containing any clauses that permit the bank to discretionally and unilaterally revoke the possibility of using such balances.
Minimum cash reserve obligations exclude (i) amounts owed to the Central Bank, (ii) amounts owed to local financial institutions, (iii) obligations owed to foreign banks — including parent companies and controlling entities of local institutions and their branches — arising from financial lines granted by non-related parties (as defined in Section 1.2.2 of the Large Credit Exposures Regulations), foreign credit lines designated for the financing of foreign trade transactions, and obligations owed to multilateral development banks, (iv) cash purchases pending settlement and forward purchases, (v) cash sales pending settlement and forward sales (whether or not related to repurchase agreements), (vi) overseas correspondent banking operations, (vii) demand obligations for money orders and transfers from abroad pending settlement to the extent that they do not exceed a three business day term as from their deposit; and (viii) demand obligations with business for the sales made by debt, prepaid, credit and/or purchase cards.
The liabilities subject to these requirements shall be computed based on the principal amounts actually traded, including, where applicable, quotation differences (whether positive or negative). Accordingly, accrued interest and premiums—whether due or not yet due—on said liabilities shall be excluded, to the extent such amounts have not been credited to an account or otherwise made available to third parties, as well as, in the case of UVA- and UVI-denominated time deposits, the amount accrued as a result of increases in the value of such units.
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Passive repurchase transactions (repos) and borrower-side securities lending (cauciones bursátiles tomadoras) shall be computed on the basis of their combined net position, provided that such position is negative (borrower), where they share the same maturity and are conducted against a central counterparty (CCP) in a market authorized by the CNV.
The minimum cash requirement is determined on the basis of the average of the daily balances of the obligations covered:
• balances recorded at the close of each day during the period preceding their fulfillment, in the case of Peso-denominated requirements, except for Peso deposits held in accounts of payment service providers offering payment accounts (“PSPCPs”) in which clients’ funds are deposited; and
• balances recorded at the close of each day of each calendar month, in the case of foreign currency requirements, securities, and Peso deposits held in PSPCP accounts in which clients’ funds are deposited.
Averages shall be calculated by dividing the sum of daily balances by the total number of days in each relevant period. On days with no recorded activity, the balance as of the immediately preceding business day shall be carried forward.
The requirement shall be calculated and met separately for each currency and/or each security or monetary regulation instrument in which the covered obligations are denominated.
For term deposits in national government securities or Central Bank monetary regulation instruments, the requirement is determined in the same asset type, based on market value. National securities in Pesos with dual-currency yield are treated like Peso-denominated securities. The requirement remains even if these securities are no longer regularly quoted in significant amounts.
For term deposits in other securities, the requirement is based on market value, in:
• Pesos or national government securities in Pesos, when the asset is in Pesos; or
• U.S. dollars or national government securities in U.S. dollars, when the asset is in foreign currency.
For foreign currency transfers exceeding the maximum term of three business days, the requirement is allocated to the respective currency. If historical data is unavailable (e.g., for new entities), current period data must be used for calculations.
The table below shows the percentage rates that should be applied to determine the required minimum cash reserve requirement for financial institutions, depending on whether:
(i) the financial entities are included in Group “A,” as provided by Section 4 of the BCRA rules on “Authorities of Financial Institutions” (the “Authorities Rules”), and/or branches or subsidiaries of foreign banks are classified as systemically important (G- SIB) not included in that group; or
(ii) the remaining financial entities.
Section 4 of the Authorities Rules classifies financial institutions into Group A or Group B. The classification is based on an indicator equal to the sum of: (i) the average total assets for the 12 consecutive months from October of the second preceding year through September of the preceding year; and (ii) the average daily deposit balances for the same 12-month period, in each case as reported under the applicable regulatory reporting regimes.:
• Group “A” institutions for which the indicator is equal to or greater than 1% of the aggregate indicator for the Argentine financial system (the “Group A Entities”);
• Group “B” institutions not included in Group A (the “Group B Entities”).
Pursuant to Central Bank Communication “A” 8367, the Bank is a Group A financial entity.
The indicator is calculated on an individual basis, except for controlling financial institutions subject to consolidated supervision, in which case it is determined on a consolidated monthly basis.
The classification into Group A and Group B is made annually and applies for the calendar year following the year in which the indicator is calculated. Newly licensed financial institutions are deemed to be Group B Entities until sufficient information is available to perform the calculation described above.
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The following figures arise from Central Bank Communication “A” 8301, as amended.
Rate in %
Group A and G-SIB not included in that group Remaining financial institutions
Item Pesos Foreign Currency Pesos Foreign Currency
1- Checking account deposits and demand deposits opened at credit cooperatives 45 25 20 25
2- Savings account, salary/social security accounts, special accounts (except for deposits included on items 7, 10 and 15 of this table), and other demand deposits and liabilities, pension and social security benefits credited by ANSES pending collection and immobilized reserve funds for liabilities covered by the Minimum Cash Requirements Regulations 45 25 20 25
3- Unused balances of advances in checking accounts under executed overdraft agreements 45 25 20 25
4- Deposits in checking accounts of non-bank financial institutions, computed for purposes of meeting their required minimum cash reserve 100 — 100 —
5- Time deposits, liabilities under “acceptances” (including responsibilities for sale or transfer of credits to agents different from financial institutions), fixed-term investments with the option of early cancellation (excluding those covered under item 12 of this table) or renewal for a specified period (with variable remuneration), and other fixed-term liabilities, except deposits included in items 7, 9 and 11 of this table, as well as debt securities (including notes), classified according to their residual maturity:
(i) Up to 29 days 28.5 23 14.5 23
(ii) From 30 days to 59 days 17.5 17 10.5 17
(iii) From 60 days to 89 days 7.5 11 5.5 11
(iv) From 90 days to 179 days 3.5 5 3.5 5
(v) From 180 days to 365 days 3.5 2 3.5 2
(vi) More than 365 days 3.5 — 3.5 —
6- Liabilities arising from foreign financial credit lines — not structured as time deposits or as the purchase of debt securities (which are subject to the requirement set forth in item 5 of the table) — obtained from related parties, as defined in Section 1.2.2 of the Large Credit Exposures Regulations, according to their original maturity:to: 0 — 0 —
(i) Up to 179 days — 20 — 20
(ii) More than 179 days — — — —
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Rate in %
Group A and G-SIB not included in that group Remaining financial institutions
Item Pesos Foreign Currency Pesos Foreign Currency
7. Demand and time deposits made upon a court order with funds arising from cases pending before the court, and the related immobilized balances
(a) Demand deposits 22 15 10 15
(c)According to their residual maturity
(i) Up to 29 days 25.5 15 13.5 15
(ii) From 30 days to 59 days 17.5 15 10.5 15
(iii) From 60 days to 89 days 7.5 15 5.5 15
(iv) More than 90 days 3.5 15 3.5 15
8- Fixed-term investments formalized through non-transferable registered certificates in Pesos, held by public sector entities that have the right to exercise an early cancellation option within less than 30 days from their issuance. 28.5 14.5
9- Fixed-term deposits and investments in UVA and UVI— including savings accounts and debt securities (including notes) in UVA and UVI— classified according to their residual maturity.
(i) Up to 29 days 10.5 — 10.5 —
(ii) From 30 days to 59 days 8.5 — 8.5 —
(iii) From 60 days to 89 days 6.5 — 6.5 —
(iv) More than 90 days 3.5 — 3.5 —
10- Severance Fund for Workers in the Construction Industry and for Workers covered by Law No. 20,744, denominated in UVA 10.5 10.5
11- Deposits and fixed term investments created in the name of minors for funds they receive freely 3.5 3.5
12- Peso-denominated demand deposits and fixed-term investments with an early termination option exercisable from the date the investor may exercise such option, which constitute the assets of money market mutual funds. 40 40
13- Reverse repurchase agreements and securities lending transactions – as liabilities – classified according to their remaining term. (1).
(i) Up to 29 days 40 23 40 23
(ii) From 30 days to 59 days 35 17 35 17
(iii) From 60 days to 89 days 35 11 35 11
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Rate in %
Group A and G-SIB not included in that group Remaining financial institutions
Item Pesos Foreign Currency Pesos Foreign Currency
(iv) From 90 days to 179 days 35 5 35 5
(v) From 180 days to 365 days 35 2 35 2
(vi) More than 365 days 35 — 35 —
14- Deposits in Pesos in accounts PSPCP in which the funds of their clients are deposited 100 — 100 —
15- Deposits in special accounts:
15.1. In Pesos (“Special accounts for holders with agricultural activity” and “Special accounts for exporters”). 3.5 3.5
15.2. In U.S. dollars (“Special accounts to credit export financing”). — —
(1) The values reported for foreign currency operations apply solely to reverse repurchase agreements as liabilities.
Financial entities may meet the requirement in Pesos – both for the period and on a daily basis – with “National Treasury Bonds in Pesos, maturing May 23, 2027,” “National Treasury Bonds in Pesos, maturing November 23, 2027,” and with the national government securities in Pesos specified in the following paragraph, up to the following limits:
(a) Five percentage points above the rates set forth in item 8, in subsections (i) and (ii) of item 5, and in paragraph (a) and subsections (i) and (ii) of paragraph (b) of item 7.
(b) Two percentage points above the rates set forth in subsection (iii) of item 5 and subsection (iii) of paragraph (b) of item 7.
(c) Forty-five percentage points of the rate specified in item 14 of the preceding table.
(d) Entities classified in Group A and branches or subsidiaries of G-SIBs not included in that group: five percentage points above the rates set forth in items 1 through 3 of the preceding table
Integration with Public Securities. Financial entities may meet the minimum cash requirement in Pesos – both for the period and on a daily basis – with Central Bank Liquidity Bills (“LELIQ”), Central Bank Notes (“NOBAC”), and national government bonds in Pesos – including those adjusted by CER and with dual-currency returns (BONO DUAL), excluding those linked to the evolution of the US dollar and Liquidity Fiscal Bills (“LeFi”) – provided that the residual maturity at the time of integration does not exceed 760 calendar days, acquired through primary subscription, in accordance with the following:
• Demand deposits referred to in items 1 to 3 of the preceding table:
• Group A Entities and branches or subsidiaries of G-SIBs not included in such group: up to 0 percentage points of the prescribed rate.
• Entities not included in the foregoing category: up to 6 percentage points of the prescribed rate.
• Fixed-term deposits and fixed-term investments—excluding those covered under item 12 of the referenced table—made by holders from the non-financial private and non-financial public sectors, and those referred to in items 7 and 10: the full requirement, except for the percentage points permitted to be met through integration with public securities as provided in the following paragraph.
• Variable-yield fixed-term investments made by clients engaged in agricultural activities (pursuant to section 2.5.2.2 of Central Bank Regulations on Deposits and Fixed-Term Investments): the full requirement, except for the percentage points permitted to be met through integration with public securities as provided in the following paragraph.
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Other placements:
• Group A Entities and branches or subsidiaries of G-SIBs not included in said group:
i) up to 9 percentage points of the rate set forth in item (i) of item 5 of the preceding table;
ii) up to 7 percentage points of the rate set forth in item (ii) of item 5 of the preceding table;
iii) up to 3 percentage points of the rates set forth in items (i) through (iii) of item 9 of the above-mentioned table; and
iv) up to 2 percentage points of the rate set forth in item (iii) of item 5 of the preceding table.
• Entities not included in the preceding paragraph:
i) up to 3 percentage points of the rates set forth in item (i) of item 5, and in items (i) through (iii) of item 9 of the preceding table;
ii) up to 2 percentage points of the rate set forth in item (ii) of item 5 of the preceding table.
Financial entities may meet the Peso-denominated requirement with the Peso-denominated national public securities referred to in the preceding paragraph, provided that such securities have an original maturity of no less than 60 days at the time of subscription, as follows:
• Up to 5.5 percentage points of the rates set forth in items 1 through 3 of the preceding table, using the above-mentioned public securities subscribed through primary issuance on or after August 25, 2025.
• Up to 3.5 percentage points of the rates set forth in items 5, 7, 8 through 12, 13, and 15, using the above-mentioned public securities subscribed through primary issuance on or after August 25, 2025.
• Up to 3 percentage points of the rates set forth in items 1 through 3, using the above-mentioned public securities subscribed through primary issuance on or after November 20, 2025.
Additionally, the integration of the minimum cash reserve requirement in Pesos—both periodic and daily—that under the Minimum Cash Requirements Regulations may be fulfilled with Argentine national sovereign debt securities denominated in Pesos—including those indexed to the CER and with dual-currency yield (BONO DUAL), excluding those linked to the U.S. dollar exchange rate—acquired by primary subscription, may be performed with such securities having a residual maturity of not less than 300 days nor more than 730 calendar days at the time of subscription, received in swap operations arranged by the National Government for securities acquired either by primary subscription or in the secondary market.
For purposes of satisfying the requirement with Peso-denominated national public securities, LELIQs and/or NOBACs as provided in this section, such instruments must be valued at market prices—regardless of the valuation criteria applied for accounting purposes—and must be deposited in Subaccount 60 (minimum cash) opened at the Central Registry and Settlement System for Public Debt Instruments, Monetary Regulation Instruments and Financial Trusts (CRYL).
Additionally, for purposes of meeting the Peso-denominated minimum cash requirement provided for under the paragraph “Integration with Public Securities,” LELIQs actually used to post guarantees to cover net debit balances arising from the Peso-denominated clearing processes of electronic clearing houses shall also be admissible, up to a maximum of 50% of the guarantees required for each product.
The minimum cash requirement rates applicable to items 1, 2, 3, 12, and 13 (all Peso-denominated) shall be increased by 5 percentage points from August 19, 2025 through March 31, 2026. This additional requirement shall apply to Group A financial entities and to branches or subsidiaries of G-SIBs not included in such group, and may be met with the public securities referred to in the paragraph “Integration with Public Securities”, provided that such securities are acquired through primary issuance on or after November 20, 2025 and have an original maturity of no less than 60 days at the time of subscription.
The average minimum cash requirement in Pesos will be reduced as explained below:
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(1) Compliance with the Minimum SMEs Quota and Specific Financing. As from July 1, 2024, financial entities included in the list in Annex II of Communication “A” 7859 (which included Banco Macro) must have met the Minimum SMEs Quota for the previous quarter in order to apply this reduction each subsequent quarter.
The cash reserve requirement will be reduced based on the proportion of financing provided to SMEs in Pesos, relative to the total financing to the private non-financial sector in Pesos. The SMEs classification will be based on the criteria outlined in the regulations on “Determining the Status of Micro, Small, or Medium-Sized Enterprises,” with the classification being valid at the time of the loan issuance, as per the following table:
Participation, in the total of financing operations to SMEs with respect of total of financing operations to the non-financial private sector, in the institution Deductions (over the total of the concepts included in Pesos)
In% In%
Less than 4 0.00
From 4 to less than 6 0.50
From 6 to less than 8 0.63
From 8 to less than 10 0.75
From 10 to less than 12 0.88
From 12 to less than 14 1.00
From 14 to less than 16 1.13
From 16 to less than 18 1.25
From 18 to less than 20 1.13
From 20 to less than 22 1.50
From 22 to less than 24 1.63
From 24 to less than 26 1.75
26 or more than 26 1.88
SMEs financing includes purchases of Electronic Credit Invoices and holdings in funds under the “Special Regime for SMEs Mutual Funds.” The percentage of SMEs financing will be based on whether the financing meets the SMEs condition at the time of granting. If the borrower no longer qualifies, only financing up to that point is considered.
The 12-month moving average of SMEs financing in Pesos will be compared to total financing granted to the non-financial private sector by the entity.
(2) Depending on the cash withdrawals made through institution ATMs. The minimum reserve requirement will be reduced based on the amount calculated through the following expression, without exceeding the previously determined requirement, as outlined in the previous point.
Where:
• Msi: Monthly average of total daily cash withdrawals from ATMs located at the entity’s operating branches, for the previous month, according to the jurisdiction of the entity, as defined in the Regulation on “Branch Categorization for Financial Institutions.”
• Mni: Monthly average of total daily cash withdrawals from ATMs located outside the entity’s operating branches (neutral locations), for the previous month, according to the same jurisdictional categorization.
• Psi: Weight factor applicable to the amount Msi.
• Pni: Weight factor applicable to the amount Mni.
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Applicable weight factors based on the categories in which the ATMs are located.
i Psi Pni
1 (category III) 4.25 7.05
2 (categories IV, V, and VI) 7.50 14.80
For this purpose, the included ATMs are those that – at least – allow users to make cash withdrawals regardless of the institution in which they are customers and the network managing such equipment and that –on a monthly average, computing business and non-business days – have remained accessible to the public for at least ten hours a day.
When there is an excessive concentration of liabilities (in terms of holders and/or maturities) that presents a significant liquidity risk for the financial institution and/or has a major negative impact on systemic liquidity, additional minimum reserve requirements may be imposed on the institution’s liabilities and/or other complementary measures deemed necessary.
This situation will be considered to occur when, among other factors, any of the following conditions are met:
• A high percentage of liabilities is concentrated with a single holder or a group of holders.
• For term liabilities, the maturity is short.
• These liabilities represent a significant percentage of the required minimum reserve integration and/or the total private sector deposits held by the institution. Likewise, the minimum cash requirement may be increased due to non-compliance with the rules on the “Credit Line for productive investment.”
In addition to the minimum reserve requirements described above, any shortfall in the application of funds corresponding to foreign currency deposits—net of cash balances held at the institution, held in custody with other financial institutions, in transit, or with armored transport companies (“TV”)—identified in a given month shall be included, for an equivalent amount, in the calculation of the minimum reserve requirement for that same period and in the relevant currency. Shortfalls arising from exchange transactions mandated by the National Executive Branch are excluded and, accordingly, may not be offset through purchases of foreign currency. Deposits in “Special Accounts for the Credit of Export Financing” may not be applied toward cash held at the institution, in custody with other financial institutions, in transit, or with armored transport companies (TV) for purposes of compliance with the minimum reserve requirement.
Integration
The minimum cash reserve must be set up in the same currency or securities or debt instruments for monetary regulation to which the requirement applies, and may include the following:
(1) Accounts maintained by financial institutions with the Central Bank in Pesos.
(2) Accounts of minimum cash maintained by financial institutions with the Central Bank in U.S. dollars, or other foreign currency.
(3) Special guarantee accounts for the benefit of electronic clearing houses and to cover settlement of credit card, vouchers, and ATM transactions and immediate transfer funds.
(4) Checking accounts maintained by non-bank financial institutions with commercial banks for the purpose of meeting the minimum reserve requirement.
(5) Special accounts maintained with the Central Bank for transactions involving social security payments by the ANSES.
(6) Minimum cash sub-account 60, authorized in the Registration and Settlement Central for Public Debt and Financial Trusts – CRYL (Central de Registro y Liquidación de Pasivos Públicos y Fideicomisos Financieros or “CRYL”) for public securities and securities issued by the Central Bank at their market value.
These items are subject to review by the Central Bank and may be amended in the future.
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Pursuant to the provisions of Communication “A” 8277, financial institutions may carry forward the excess average minimum cash reserve integration in Pesos recorded during the periods from July to October 2025, on a non-cumulative basis, to the position of the month following that which generated the excess, subject to the following limits:
Period Up to the percentage of the minimum cash reserve requirement in Pesos for the period:
July 2025 4 %
August 2025 3 %
September 2025 2 %
October 2025 1 %
Before August 18, 2025, compliance with the minimum cash reserve requirement was measured on the basis of the monthly average of the daily balances of eligible items maintained during the relevant period. Such average was calculated by dividing the aggregate daily balances by the total number of days in the month. Offsetting deficit positions with surplus positions arising from different requirements was not permitted.
Effective August 18, 2025, the BCRA amended the methodology for compliance with the minimum reserve requirement in Pesos, replacing the prior measurement—based on the average of daily balances of eligible items—with a daily measurement framework. As a result, the previously available carryforward mechanisms were discontinued. However, effective as of the February 2026 position, institutions may again make use of the carryforward mechanism provided under the Minimum Reserve Rules for purposes of integrating the Peso reserve requirement. Any such carryforward may not exceed 5% of the applicable requirement and must be fully offset in the immediately following month.
In the event that a reserve requirement transfer has been made pursuant to section 1.7 of the Minimum Cash Requirements Regulations, the applicable requirement shall be the Adjusted Minimum Cash Requirement (EEMA). For the calculation of the transfer of the integration, the amounts transferred from the relevant period will be prorated based on the number of days in the period to which the transfer is applied.
Minimum Daily Integration in Pesos. On no day of the relevant period may the aggregate balance of the items eligible for integration, as recorded at the close of each day, be less than 75% of the period’s minimum cash requirement.
Minimum Daily Integration in Foreign Currency. On no day of the relevant period may the aggregate balance of the items eligible for integration, as recorded at the close of each day, be less than 25% of the total minimum cash requirement, as determined for the immediately preceding period, recalculated based on the requirements and eligible items in effect during the period to which the reserves relate. Such daily requirement shall be 50% where, during the preceding computation period, an average integration shortfall exceeding the permitted carryover margin was recorded.
No minimum daily integration shall be required for deposits in securities and Central Bank monetary regulation instruments.
Non-Compliance
Shortfalls in the integration of the minimum cash requirement in Pesos, foreign currency, and securities and Central Bank monetary regulation instruments, as well as shortfalls in minimum daily integration, shall be subject to a charge payable in Pesos equivalent to three times the Argentina Wholesale Rate (TAMAR) – total banks, as reported for the last business day of the relevant period, or, if unavailable, the most recently published rate. Where shortfalls in the average position and in minimum daily integration occur concurrently within the same period, the higher resulting charge shall apply. For purposes of determining average position shortfalls, the following shall be taken into account: (i) shortfalls for which the carryover option is not exercised, and (ii) shortfalls that cannot be carried forward to the following period because they exceed the permitted margin.
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Minimum SMEs Quota
As noted above, financial institutions included in Annex II to Communication “A” 7859, including us, as from April 1, 2024, are required to maintain a quarterly average of daily balances (April–June; July–September; October–December; and January–March of the following year) of covered funding equal to at least 7.5% of the institution’s Peso-denominated deposits from the non-financial private sector that are subject to fractional reserve requirements — excluding the deposits referred to in Sections 3.12 and 3.13 of the BCRA rules on “Savings Deposits, Payroll Accounts and Special Accounts”. Such percentage shall be calculated on the basis of the monthly average of daily balances corresponding to the second month preceding the relevant quarter (i.e., February, May, August and November, respectively).
For Group B Entities, the applicable minimum percentage shall be 25% of the percentage indicated above.
For these purposes, eligible balances include the outstanding residual amounts of financings allocated to: (i) the 2020, 2021, 2021/2022, 2022, 2022/2023, 2023 and 2023/2024 tranches under the BCRA rules on the “Credit Line for Productive Investment for MiPyMEs”; (ii) Sections 7.2.1 and 7.2.2 thereof, provided such financings were disbursed on or before October 15, 2020; and (iii) prior quarters of the present quota.
In addition, in order to comply with the Minimum SMEs Quota, at least 30% of the quota must be used to finance investment projects.
Entities complying with this Minimum SMEs Quota may compute the reduction of the minimum cash requirement in Pesos described above during the following quarter.
LELIQ global daily position
Pursuant to Section 8 “net position in LELIQ and NOTALIQ” of the Central Bank rules “Cash settled and forward transactions, futures, bonds, surety bonds, other derivatives and mutual funds” financial institutions may maintain a net position in short term LELIQ (including those effectively allocated to integrate the minimum cash requirement as stipulated above) up to an amount equivalent to the average daily balance of time deposits in Pesos of the previous reporting period.
Financial institutions that have a percentage of time deposits in Pesos in relation to the total deposits in Pesos -measured as a monthly average of daily balances of the previous period, considering only capital without interest or adjustments- equal to or higher than 20%, may maintain a joint positive net position of longer term LELIQ and variable rate Liquidity Notes (NOTALIQ).
Since the current administration took office, the Central Bank has ceased issuing Leliq and Notaliq instruments. The remaining balances of Leliqs and Notaliqs matured in January 2024 and March 2024, respectively.
Pursuant to the provisions of Communication “A” 8277, financial institutions may carry forward the excess average minimum cash reserve integration in Pesos recorded during the periods from July to October 2025, on a non-cumulative basis, to the position of the month following that which generated the excess, subject to the following limits:
Period Up to the percentage of the minimum cash reserve requirement in Pesos for the period:
July 2025 4 %
August 2025 3 %
September 2025 2 %
October 2025 1 %
In the event that a reserve requirement transfer has been made pursuant to section 1.7 of the Minimum Cash Requirements Regulations, the applicable requirement shall be the Adjusted Minimum Cash Requirement (EEMA). For the calculation of the transfer of the integration, the amounts transferred from the relevant period will be prorated based on the number of days in the period to which the transfer is applied.
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Liquidity Coverage Ratios
Financial institutions classified as Group “A” shall be required to comply with Central Bank regulations on “Liquidity Coverage Ratios.” For the purposes of said provisions, institutions classified as Group “A” will be considered as “internationally active banks.”
Under regulations on “Liquidity Coverage Ratios,” financial institutions must maintain an adequate stock of high-quality liquid assets (“HQLA”), which are “free of restrictions.” This stock should consist of cash or assets that can be immediately converted into cash—monetized—with minimal or no loss of market value. The HQLA must be sufficient to meet the institution’s liquidity needs for a 30-day period under a stress scenario, that includes both idiosyncratic and systemic risk factors that could lead to:
(i) Partial loss of retail deposits;
(ii) Partial loss of unsecured wholesale funding capacity;
(iii) Partial loss of secured funding;
(iv) Additional fund outflows due to contractually anticipated situations, including the establishment and replenishment of margin calls resulting from a significant deterioration in the financial institution’s credit quality;
(v) Increases in market volatility affecting the quality of collateral or potential future exposures from derivative positions, requiring higher or additional collateral, or leading to other liquidity needs;
(vi) Unexpected use of committed but unused credit and liquidity facilities granted by the financial institution to its clients; and
(vii) he need for the financial institution to repurchase debt or fulfill extracontractual obligations to mitigate reputational risk.
The HQLA can only be made up of the following portfolio assets (considered as Tier 1 (An1)) at the day of the calculation of the LCR: cash in hand, in transit, in armored transportation companies and ATMs; deposits with the Central Bank; certain national public bonds in Pesos or in foreign currency; securities issued or guaranteed by the International Payments Bank, the IMF, the European Central Bank, the European Union or Multilateral Development Banks that comply with certain conditions and debt securities issued by other sovereign entities (or their central banks), as prescribed in the relevant regulations.
The stock must enable the institution, at a minimum, to cover liquidity issues until the thirtieth day of such period.
Financial institutions must anticipate potential cash flow mismatches during the specified period and ensure sufficient HQLA are available to cover them. They must also actively manage liquidity risk and financing needs across branches and subsidiaries, considering legal and operational constraints on liquidity transfer. Moreover, institutions must conduct stress tests to determine liquidity levels above the regulatory minimum, considering scenarios that extend beyond the 30-day period.
In the absence of a financial stress scenario, the LCR must, at all times, be greater than or equal to 1. This means that the stock of HQLA must not be less than the total net cash outflows. During financial stress periods, financial institutions may use their HQLA fund, allowing the LCR to fall below 1. However, they must still comply with the requirements set forth in Section 1.6.2 of the regulations on “Liquidity Coverage Ratios. The Superintendency will assess the situation and adjust its actions based on the specific circumstances.
The LCR must be greater than or equal to 1, as follows:
LCR = FALAC / SENT
Where:
• FALAC: Represents the value of the stock of HQLA in a stress scenario.
• SENT: Refers to the total net cash outflows anticipated over a 30-day period in a stress scenario.
The LCR must be observed and reported in the national currency, including all foreign currency items expressed in Pesos. However, financial institutions must ensure liquidity coverage in each significant currency in which they operate, whenever liabilities and other obligations in that currency represent at least 5% of the total liabilities and obligations of the institution. Additionally, the composition of the HQLA by currency should be aligned with the financial institution’s operational needs.
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Financial institutions must ensure that, except for the situation outlined in the following paragraph, the value of the LCR is never below 1. To achieve this, they must calculate it regularly and report it monthly, along with their liquidity profile, to the Superintendency. In stress scenarios, the Superintendency may require more frequent reports.
Pursuant to Section 1.6.2 of the regulations on “Liquidity Coverage Ratios,” in case the LCR falls or is expected to fall below 1, the financial institution must immediately inform the Superintendency and provide an assessment of their liquidity position, the factors contributing to the decrease, and the measures they have or will take, along with their expectations on how long the situation may last. The Superintendency will evaluate each situation and may require institutions to take actions to reduce liquidity risk exposure, strengthen their overall liquidity risk management framework, or improve their contingency funding plan. A drop below 1 does not necessarily trigger the application of article 41 of the Financial Institutions Law.
Moreover, the Superintendency may require corrective actions if they detect a negative trend from the tools used to monitor liquidity, such as mismatches in contractual terms, funding concentration, availability of unencumbered assets, significant currency LCR, or other market-related monitoring tools.
In addition to the LCR, there are other parameters that are used as systematic tools of control. These policies contain specific information regarding cash flows, balance structure and available underlying assets free of charge. These parameters, along with the LCR, offer basic information to evaluate the liquidity risk. The included parameters are:
• gaps in contractual terms;
• funding concentration;
• available assets free of restrictions;
• LCR for relevant currency; and
• market-related monitoring tools.
Internal liquidity policies
Financial institutions must adopt management and control policies that ensure the maintenance of reasonable liquidity levels to efficiently manage their deposits and other financial commitments. Such policies should establish procedures for evaluating the liquidity of the institutions in the framework of prevailing market conditions to allow them to revise projections, take steps to eliminate liquidity constraints and obtain sufficient funds, at market terms, to maintain a reasonable level of assets over the long term. Such policies should also address (i) the concentration of assets and liabilities in specific customers, (ii) the overall economic and market situation, likely trends and the effect on credit availability and (iii) the ability to obtain funds by selling government debt securities and/or own assets, among others.
The organizational structure of the entity must place a specific unit or person in charge of managing liquidity and assign levels of responsibility to the individuals who will be responsible for managing the LCR, which will require daily monitoring. The participation and coordination of the entity’s top management authority (e.g., CEO) will be necessary.
In addition, financial institutions must designate a director or advisor who will receive reports at least weekly, or more frequently if circumstances so require, such as when changes in liquidity conditions require new courses of action to safeguard the entity. In the case of branches of foreign financial institutions, the reports must be delivered to the highest authority in Argentina.
Appointed officers and managers will be responsible for managing the liquidity policy that, in addition to monitoring the LCR, includes taking the necessary steps to comply with minimum cash requirements.
Financial institutions must report the list of such officers and directors, as well as any subsequent changes, to the Superintendency within ten calendar days from the date of any such change.
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Net Stable Funding Ratio (NSFR)
Financial institutions that belong to Group “A” – considered internationally active banks – must comply with these provisions. For the purposes of these regulations, the term “financial sector” includes financial institutions, foreign exchange entities, insurance companies, agents regulated by the CNV – or an equivalent foreign authority – and trustees of non-financial trusts.
The purpose of the NSFR is to allow financial institutions to finance their activities with sufficiently stable sources to mitigate the risk of future stress situations derived from their funding requirements. By requiring financial institutions to maintain a stable funding profile relative to the breakdown of their off-balance sheet assets and transactions, the NSFR limits the strong dependence on short term wholesale funding, promotes a better assessment of balance sheet and off-balance sheet items funding risk, and favors funding sources stability. The definitions of the components of the NSFR are similar to those set forth in the “Liquidity Coverage Ratio” regulations, unless otherwise expressly set forth herein.
The NSFR is defined as the ratio between the available stable funding amount and the required stable funding amount:
Where:
• MDFE (Available Stable Funding Amount) is the portion of the capital and liabilities of the financial institution that is expected to remain available over a one-year period.
• MRFE (Required Stable Funding Amount) is the amount of funding required during this period based on the liquidity and remaining maturity of the institution’s assets and off-balance sheet commitments.
The available and required stable funding amounts, as determined by these provisions, are calibrated to reflect the expected stability of the institution’s liabilities and the liquidity expected from its assets over a one-year period.
The NSFR shall be at all times greater than or equal to 1 (NSFR > 1). It shall be supplemented with the assessment made by the Superintendency. The Superintendency may demand the institution to adopt stricter standards to reflect its funding risk profile, also taking into account the assessment made in connection with the Risk Management Guidelines in connection with the institution’s liquidity.
The Financial Institutions shall observe the NSFR all times and report it on a quarterly basis to the Superintendency.
Leverage Ratio
Through Communication “A” 6431, effective as of March 1, 2018, the Central Bank incorporated a ratio to limit the leverage of financial institutions in order to avoid the adverse consequences of an abrupt reduction in leverage in the supply of credit and the economy in general, and reinforce the minimum capital requirement with a minimum capital requirement simple and not based on risk.
The leverage ratio, which must be greater than or equal to 3%, arises from the following expression:
Ratio (as %) = Capital measure / Exposure measure
Where
• Capital measure: The capital to be considered will be the basic equity (PNb) –Tier 1 capital, as defined in the Minimum Capital Regulations.
• Exposure measure: Will be the sum of (i) the exposures in the asset (excluding the items corresponding to derivatives and Securities Financing Transactions (SFT)), (ii) exposures by derivatives; (iii) exposures for SFT transactions and (iv) off-balance-sheet items.
Both measures must be calculated based on the closing balances of each quarter.
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Interest rate and fee regulations
Since 2020, maximum interest rates applicable to the lending transactions were restated.
Compensatory interest rates will be freely agreed upon between financial institutions and clients, taking into account, where applicable, the provisions established under specific regulatory regimes.
The compensatory interest rate for credit card-linked financing must not exceed 25% above the average interest rate that the financial institution applied during the immediate previous month, weighted by the corresponding amount of unsecured personal loans granted in the same period. In the case of bank issuers, this refers to the rate the issuer applies to personal loan transactions in local currency for clients, whereas non-bank issuers must refer to the average system rates for such transactions, as published by the Central Bank between the 1st and the 5th of each month. Loans established under programs and/or social assistance measures, which additionally have an interest rate not exceeding the rate published by the Central Bank for deposits of more than one million Pesos for terms between 30 to 35 days, from the third month prior, may be excluded from the base to be averaged. This rate is determined based on the type of financial institution (public or private), increased in accordance with the minimum cash requirement. Additionally, Section16 of Credit Card Law No. 25,065 provides the legal basis for this limitation, establishing that the issuer may not charge compensatory or financial interest exceeding 25% above the applicable personal loan rate, depending on whether the issuer is a bank or a non-bank entity as described above.
Regulations set forth that the fixed-rate loan agreements shall not contain clauses that allow their modification under certain circumstances, unless those modifications come from decisions taken by the competent authority and the variable-rate loan contracts must clearly specify the parameters that will be used for its determination and periodicity of variation.
With respect to credit card transactions, in addition to the foregoing, Section 16 of Credit Card Law No. 25,065 provides that the compensatory or financial interest rate charged by the issuer to the cardholder may not exceed by more than 25% the rate applied by such issuer to personal loans granted in local currency to its customers. In the case of non-bank issuers, the compensatory or financial interest rate charged to the cardholder may not exceed by more than 25% the average rate for personal loan transactions in the financial system, as published by the BCRA between the 1st and the 5th day of each month.
In the past, regulations established a minimum deposit rate for time deposits. Currently, the remuneration for time deposits at fixed rates will be freely agreed upon.
The base remuneration for variable interest rate deposits will be equivalent to:
(i) The interest rate derived from one of the surveys conducted and published daily by the Central Bank, such as BADLAR, TAMAR, etc.
(ii) For deposits in U.S. dollars, British pounds, Japanese yen, Swiss francs, or euros, the applicable rate will be one of the following: Secured Overnight Financing Rate (SOFR), Sterling Overnight Index Average (SONIA), Tokyo Overnight Average Rate (TONAR), Swiss Average Rate Overnight (SARON), or Euro Short-Term Rate (ESTER).
(iii) The higher of either the rate mentioned in sections i) and ii), plus any additional remuneration that may be agreed upon, or the fixed rate freely negotiated.
To determine the rate, each institution may consider the average of the daily rates specified within the period from 2 to 5 banking days immediately prior to the start of each computation subperiod. The minimum duration for this period is 30 days, and this option will remain fixed for the entire duration of the deposit.
Once the rate is determined, it must remain unchanged for a period no shorter than 30 days.
The amount of points that the deposit-taking institutions freely agree upon with depositors, which must remain unchanged for the entire term of the deposit agreement.
Central Bank regulations on the “Protection of Financial Services Users” grant broad protection to customers, including, among other things, the regulation of fees and commissions charged by financial institutions for services provided. All commissions, fees, costs, expenses, insurance, and/or any other charges—excluding the interest rate—that the obligated parties receive or intend to receive from users of financial services must derive from a real, direct, and demonstrable cost, and be duly justified from both a technical and economic standpoint.
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Commissions and fees should only apply to services that have been requested, agreed upon, or authorized by the user. Commissions relate to services provided by the obligated parties and may include compensation beyond the service cost, while fees relate to third-party services and can only be passed on at cost.The amount of fees charged to users cannot exceed the amount received by third-party providers in similar conditions. In credit operations, commissions can be applied to unused allocated funds. Early repayment of financing may result in commissions, but no commissions will apply if one-quarter of the original term or 180 days have passed since the financing was granted, whichever is greater.
The charging of users for concepts that do not meet the conditions set out above or that result from a service whose commission or fee is already included in other charges by the financial service provider is not allowed. Commissions or fees cannot be applied to users for financial services that were not requested, agreed upon, or authorized by them. Even if such services were requested, agreed upon, or authorized, and the provider communicated them to the user, fees cannot be charged if the service was not actually provided.
There are specific cases where commissions or fees cannot be applied. First, in-person transactions carried out by individual users at a branch are exempt, including cash deposits and withdrawals in Pesos, as well as the receipt of checks for deposit at branches other than the one where the account is held. This applies regardless of commissions related to check collection or services that require in-person handling, such as check certification and international transfers. Second, cash deposits in Pesos into accounts held by individuals or SMEs are exempt, in accordance with the rules on determining the status of such enterprises. Third, no charges can be applied for the contracting or management of insurance policies. Fourth, generating and sending account statements, including virtual statements, must be included in the account maintenance fee and cannot be charged separately. Fifth, no separate charges can be applied for the evaluation, granting, or administration of financing. Finally, charges for appraisals, notary services, or public registry fees associated with granting or canceling financing, such as for the establishment of pledges or mortgages, are not admissible.
Also, fees and charges are not applicable for immediate electronic transfers when: (i) they are ordered by final customers of financial services; (ii) the same individual or entity is the one ordering and receiving the transfer; (iii) they are ordered or received in accounts for judicial use, among others.
Regulations on the “National Payment System—Payment Services” establish that interchange fees applied by financial institutions on the amount of each transaction made with debit, credit, and charge cards they issue must not exceed the following percentages:
Maximum interchange fee for debit card transactions Maximum interchange fee for credit/charge card transactions
0.60% 1.30%
For the purposes of applying the aforementioned limits, any other mechanism of remuneration or compensation to the issuers, established by acquirers, brand holders, and/or any other intermediaries in payment operations or related activities, that has an object or effect equivalent to that of the interchange fee, is considered part of the interchange fee.
Financial institutions and PSPs (Payment Service Providers) that offer interoperable digital wallet services from which the customer initiates the payment, but have not issued the credit card used, will be entitled to charge the issuer a commission of up to 0.07% of the transaction amount for each transaction.
Maximum term for payments to merchants and providers
By virtue of Communication “A” 6680, effective as of May 1, 2019, the Central Bank established a maximum term of ten business days for financial entities to deposit payments to merchants and suppliers for sales made via credit cards or purchase cards, calculated from the sale date. Furthermore, financial entities shall not charge any fee or interest related to such payment term, nor block this payment mechanism in any way. Financial institutions may not charge merchants any interest or commission related to the specified settlement period. They must also not impede or hinder in any way the use of a single-payment transaction with those cards.
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Nevertheless, by virtue of Communication “A” 6680, the Central Bank excluded from the scope of its provisions the credit and/or purchase cards issued to individuals or legal entities that are intended for the payment of purchases with a deferred term or more than one month related to their productive activity, i.e. agricultural o distribution activities.
Furthermore, the regulations governing the “National Payment System – Payment Services” establish that the maximum period for financial institutions, Payment Service Providers and Card Processors (Proveedores de Servicios de Pago que ofrecen Cuentas de Pago or PSPCP), and other issuers of open-loop prepaid cards to credit the proceeds of each sale made using such cards to the demand or payment account opened in the name of the affiliated supplier or merchant shall be two business days, counted from the date the corresponding purchase is made by the prepaid cardholder or beneficiary. Additionally, the maximum period for sub-acquirers to credit the amount of payments processed through their intervention to the account in the name of the affiliated supplier or merchant shall not exceed one business day from the date the sub-acquirer receives the funds. The scope of these provisions excludes payment credits processed through sub-acquirers that correspond to: (i) purchases made through e-commerce platforms; and/or (ii) payments via transfers and other immediate transfers, which in all cases must be made available to the payment beneficiary within 15 seconds, even if the payment is processed without the involvement of an administrator of the immediate funds transfer scheme (i.e., under a closed-loop modality).
Loans and Housing Units
The Central Bank has adopted measures for taking deposits and extending loans expressed in a special measuring unit adjustable by the CER. These special units are referred to as UVAs.
In addition, Law No. 27,271 provides for the adjustment of deposits and loans by reference to the construction index, expressed in a special measuring unit referred to as Housing Units (“UVIs”).
Consequently, UVAs and UVIs coexist and may be used both with respect to bank loans and deposits. The initial value of the UVI was Ps.14.05 (the same as the UVA), representing the cost of construction of one thousandth square meter of housing as of March 31, 2016. As of April 17, 2025 the value of UVI and UVA were Ps.1,355.77 and Ps.1,884.86, respectively.
Both units are amended based on the indices published by the INDEC and the Central Bank on its website.
Foreign Exchange System
On September 1, 2019, with the purpose of strengthening the normal functioning of the economy, the Argentine government reinstated exchange controls. Except for individuals, the new foreign exchange controls apply with respect to access to the foreign exchange market by residents for savings and investment purposes abroad, the payment of external financial debts abroad, the payment of dividends in foreign currency abroad, payments of imports of goods and services, and the obligation to repatriate and settle for Pesos the proceeds from exports of goods and services, among others.
For further information on this topic, please refer to “Item D – Exchange Controls.”
Foreign Currency Lending Capacity
Regulations on “Credit Policy” applicable to the Application of the Loan Capacity of Foreign Currency Deposits establish that the lending capacity from foreign currency deposits must be applied, in the corresponding deposit currency, indiscriminately to the following destinations:
a) pre-financing and financing of exports to be made directly or through principals, trustees or other brokers, acting on behalf of the owner of the merchandise;
b) other financing to exporters, who have a flow of future income in foreign currency and verify, in the year prior to granting the financing, a billing in foreign currency for an amount that is reasonably related to that financing;
c) financing to producers, processors or goods collectors, provided that:
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(i) They have sale contracts of their merchandise to an exporter, with a fixed price or fixed in foreign currency -independently of the currency in which the operation is settled- and in the case of fungible merchandise with quotation, in foreign currency, normal and customary in local or foreign markets, with wide diffusion and easy access to public knowledge;
(ii) Their main activity is the production, processing and / or collection of fungible goods with quotation, in foreign currency, normal and usual in foreign markets, widely disseminated and easy access to public knowledge, and it is found, in the year prior to the granting of financing, a total billing of these merchandise for an amount that is reasonably related to that activity and its financing; and also operations aimed to finance service providers directly used in exporting process of goods (such as those provided at port terminals, international loading and unloading services, leasing containers or port warehouses, international freights). This, provided it is verified that the flow of future income linked to sales to exporters registers a periodicity and magnitude that it is enough for the cancellation of the financing and it is verified, in the year prior to the granting of the financing, a billing to exporters for an amount that is reasonably related to that activity and its financing.
d) financing for manufacturers of goods to be exported, as final products or as part of other goods, by third-party purchasers, provided that they have full foreign currency guarantees or endorsements from such third parties and/or firm sales contracts in foreign currency and/or in exportable goods;
e) financing to suppliers of goods and / or services that are part of the merchandise production process fungibles with quotation, in foreign currency, normal and usual in local or foreign markets, widely disseminated and easy access to public knowledge, provided they have firm sales contracts for those goods and / or services in foreign currency and / or on said merchandise;
f) financing of investment projects, working capital and/or acquisition of all kinds of goods, including temporary imports of inputs, which increases or are linked to the production of exporting products. Even if exporters’ revenues do not come entirely from foreign sales, financing may be allocated as long as the repayment is sufficiently covered by the foreign currency inflows from their exports. Transactions in which financing is granted through the entity’s participation in “syndicated loans,” whether with local or foreign entities, are included.
g) financing for commercial and commercial portfolio clients of credits for consumption or housing -according to the provisions established in the rules on “Debtor Classification,” whose destination is the importation of capital goods (“BK” in accordance with the Mercosur’s Common Nomenclature established in Annex I to Decree No. 690/02 and other complementary provisions), which increase the production of merchandise destined for the domestic market;
h) foreign currency debt securities or financial trust participation certificates including other payment rights specifically recognized on trust agreements whose underlying assets are loans made by the financial entities in the manners set forth in (a) to (d) above and first sentence of (f), or documents in which cash flows in Pesos or foreign currency have been assigned to the trustee, in foreign currency credit agreements, under the terms and conditions set forth in items mentioned before;
i) financings for purposes other than those mentioned in (a) to (d) and (f) above, included under the IDB credit program (“Préstamos BID N° 119/OC-AR”), not exceeding 10% of the lending capacity;
j) inter-financing loans;
k) Central Bank bills (Letras y Notas) denominated in U.S. dollars;
l) direct investments abroad by companies that reside in Argentina, which seek the development of productive activities of non-financial goods and/or services, either through contributions and/or purchases of shares in companies, to the extent that they are constituted in countries or territories considered cooperators for the purposes of fiscal transparency according to the provisions of Section 1 of Decree No. 589/13 as amended;
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m) financing of investment projects, including working capital, which allows the increase of production in the energy sector and have firm sales contracts and/or endorsements or guarantees in foreign currency;
n) National Treasury bills in foreign currency, up to an amount equivalent to one third of the total of the applications made in accordance with the provisions of this section;
o) financing of investment projects for bovine cattle, including their working capital, without exceeding 5% of deposits in foreign currency of the entity;
p) financing of foreign importers for the acquisition of goods and / or services produced in the country, either directly or through credit lines to foreign banks; and
q) financing of local residents that are secured by letters of credit (“stand-by letters of credit”) issued by foreign banks or multilateral development banks that comply with the provisions of point 3.1. of regulations on “Credit assessments,” requiring for that purpose an international rating of investment grade risk, to the extent that such letters of credit are unrestricted and that the accreditation of the funds is made immediately at the simple request of the beneficiary entity.
The application of the lending capacity of foreign currency deposits to import-related operations (as provided in items (e), (f), and the portion attributable to these under items (g) and (h)) may not exceed the value determined by the following formula:
Ct x max (Fbase / Cbase ; 0.05)
Where:
• Ct: Lending capacity for the relevant month.
• Fbase: Financing of eligible imports corresponding to the August–October 2008 quarter.
• Cbase: Lending capacity corresponding to the August–October 2008 quarter.
Financing granted to debtors classified as “unrecoverable” and fully provisioned cannot be allocated to the lending capacity of foreign currency deposits.
The lending capacity shall be determined for each foreign currency captured, and is calculated as the sum of deposits and interbank loans received, provided that the lending financial institution has reported them as derived from its foreign currency deposit lending capacity, net of the minimum cash requirement on deposits. The computation of assets and liabilities is based on the monthly average of daily balances (principal and interest) recorded in each calendar month.
Financing is accounted for net of provisions for uncollectible risks, depreciation, and, where applicable, the “portfolio acquisition difference.”
Net shortfalls in application, after deducting cash balances held by financial institutions, those held in custody by other institutions, in transit, and in Cash Transport Companies (“TV”), up to the amount of such shortfall, will be subject to an equivalent increase in the minimum cash requirement in the respective foreign currency.
Shortfalls resulting from exchange transactions mandated by the Federal Government cannot be offset by foreign currency purchases. Additionally, deposits in “Special Accounts for Crediting Export Financing” cannot be applied to cash balances in financial institutions, custody in other banks, in transit, or in TV.
Regarding the capacity to extend foreign currency loans, on February 20, 2025, the Central Bank issued Communication “A” 8202, whereby the provisions of section 1.4 of the “Credit Policy” regulations were repealed, and consequently, certain limitations applicable to loans granted by financial institutions using foreign currency resources derived from their liabilities allocated to financial intermediation ceased to be in effect.
Foreign Currency Net Global Position
The foreign currency net global position (the “FCNGP”) shall consider all assets, liabilities, commitments and other instruments and transactions through financial intermediation in foreign currency or linked to exchange rate movements, including cash, forward transactions and other derivative contracts, deposits in foreign currency in accounts opened with the Central Bank, gold position, the Central Bank monetary regulation instruments in foreign currency, subordinated debt in foreign currency and debt instruments in foreign currency.
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Forward transactions under master agreements executed in local markets authorized by the CNV paid by settlement of the net amount without delivery of the underlying asset are also included. Likewise, certificates or notes issued by financial trusts and claims under common trusts are also included in the relevant proportion, provided that the underlying assets are denominated in foreign currency. The net position amount of transactions involving commodities will be included in the FCNGP. For this purpose, all opposing positions must be netted, regardless of whether they involve different products, maturities, or whether there is a legal possibility of contractual offsetting between them.
The value of the position in currencies other than U.S. dollars shall be expressed in that currency, at the respective exchange rate published by the Central Bank.
Decreases in foreign currency assets, due to the pre-cancellation of local financing to private sector customers, can only offset the FCNGP up to the original term of maturity, accompanied by the net increase in holdings of National Treasury securities in foreign currency.
Secondary market sales of foreign currency–denominated negotiable obligations acquired through primary issuance on or after June 9, 2023 shall not be subject to the offset mechanism set forth in the preceding paragraph, provided that such sales are carried out after 90 consecutive days have elapsed from the date of primary subscription.
Where a financial institution has acquired National Treasury securities denominated in foreign currency through primary issuance on or after December 10, 2025, any secondary market sales that result in a reduction of its FCNGP may be offset only up to the original maturity date of such securities against the net increase in holdings of other foreign currency–denominated National Treasury securities, unless such sale is carried out after 90 consecutive days have elapsed from the date of primary subscription.
At the original maturity of local financing in foreign currency, offsetting may occur with the purchase of any foreign currency assets eligible for inclusion in the FCNGP.
When determining a bank’s FCNGP, the following concepts shall be excluded from the calculation:
(i) deductible assets to determine the Banks’s RPC,
(ii) the included concepts that the financial entity registers in its branches abroad,
(iii) Federal government securities in Pesos with dual-currency returns,
(iv) the balances corresponding to the “Special accounts for holders with agricultural activity” and the “Special accounts for exporters,”
(v) the non-transferable domestic bills of the Central Bank of the Argentine Republic in Pesos settleable at the Reference Exchange Rate Communication “A” 3500 (“LEDIV”) at zero rate (LEDIVs were rendered ineffective through Communication “A” 7898 dated November 30, 2023), and
(vi) the public and private securities in Pesos adjustable by the exchange rate, provided they do not exceed the net between the deposits referenced in item (iv) and the LEDIV.
Negative FCNGP: This position (where liabilities exceed assets) calculated as the daily balance converted into Pesos at the reference exchange rate as of the close of the month preceding the month in which this ratio is calculated, may not exceed 30% of the RPC for the month immediately preceding the relevant period.
Positive FCNGP (assets exceeding liabilities): The Net Global Foreign Currency Position, calculated as the daily balance converted into Pesos at the reference exchange rate as of the close of the month preceding the month in which this ratio is calculated, may not exceed 5% of the RPC for the month immediately preceding the relevant period. Any variation in this position arising from exchange transactions ordered by the National Executive Branch may be covered only through one of the applications provided for in Section 2 of the “Credit Policy” regulations or through foreign exchange forward transactions settled in Pesos.
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• Spot Foreign Currency Position: The spot position includes the net global foreign currency position as previously defined, minus the following:
(i) The net position in transactions conducted on a term basis, spot-to-settle, futures, options, and other derivative products. For foreign exchange transactions, only those with an original term greater than one business day will be considered.
(ii) The net position in instruments linked to the evolution of the foreign currency’s value (except those accounted for in item d).
(iii) The positive difference between the cash balances and the foreign currency resource application deficit – as outlined in Section 1.8 of the Minimum Capital Regulations– measured as the average of daily accumulated balances up to the date of the spot position calculation, provided the cash in hand does not exceed 10% of the foreign currency deposits measured on the previous business day.
(iv) Pre-financings of exports whose foreign currency funding, for the same amount, is accounted for as liabilities linked to the evolution of the foreign currency’s value.
(v) The balance of guarantees established for operations with debit, credit, and purchase cards abroad for an amount equivalent to five consecutive days of consumption.
At the entity’s option, the balance of foreign financing received with an original average life of at least 12 months may be excluded from the spot foreign currency position. In any event, this daily position—calculated as the daily balance converted into Pesos at the reference exchange rate as of the close of the month preceding the month in which this ratio is calculated—must remain within a range between an amount equivalent to minus 30% and 0% of the RPC for the month immediately preceding the relevant period. In addition, this position may not increase on the last business day of the month compared to the balance recorded on the immediately preceding day.
The Central Bank allows that the Positive FCNGP may reach up to 30% of the RCP, while the total excess over the general limit originates only as a result of:
a) National Treasury Bills, as of June 18, 2018, due to:
i) An increase in the position in U.S. National Treasury bills in U.S. dollars with respect to those held as of June 15, 2018, and/or
ii) The institution´s position in U.S. National Treasury bills in U.S. dollars as of June 15, 2018, maintained as excess admitted to the current limit as of that date.
iii) An increase in the position in U.S. National Treasury bills linked to U.S. dollars with respect to those held as of May 13, 2019.
b) Peso-denominated financings with variable remuneration based on the variation of the U.S. dollar exchange rate, whose purpose is not included in section 2.1 of the Central Bank’s Credit Policy Regulations, granted as of July 10, 2025.
As provided by Communication “A” 7093 (as amended), it includes national treasury bills denominated in foreign currency that the institutions receive in exchange for National Treasury Bills – under Law 27,556 – that they have imputed to this point on the Business Day immediately preceding the day on which they are delivered in exchange.
To determine the FCNGP, loans in Pesos with a variable return based on the fluctuation of the U.S. dollar exchange rate, agreed until May 27, 2020, will be excluded if they are not covered by term investments with a variable return based on the U.S. dollar exchange rate.
Furthermore, any foreign currency position that financial institutions might hold – under the framework established in Communication “A” 7997 related to the regulations on “Earnings Distributions” – due to the subscription of BOPREAL until credited to non-resident shareholders will also be excluded from the calculation of their FCNGP.
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The excesses of these ratios are subject to a charge equal to 3 times the Argentine Wholesale Rate (TAMAR) – total for banks. To determine the charge, the rate provided by the Central Bankwill be applied on the excess amount in Pesos, based on the rate for the last business day of the reporting period, or, if unavailable, the most recent one. If excesses occur concurrently in both the net global position and the spot position, the higher charge will apply.
Charges not paid on time will incur an interest penalty during the non-compliance period, calculated at a rate 50% higher than the one applied to the excesses.
In addition to the above-mentioned charge, sanctions set forth in section 41 of the Financial Institutions Law shall apply (including: caution; warning; fine; temporary or permanent disqualification to dispose of a banking current account; temporary or permanent disqualification to act as promoters, founders, directors, administrators, members of surveillance committees, comptrollers, liquidators, managers, auditors, partner or shareholders; and license revocation).
Fixed Assets and Other Items
The Central Bank establishes that fixed assets and other items held by financial institutions must not exceed 100% of the institution’s RPC.
Such fixed assets and other items include:
• Shares of domestic companies;
• Various loans;
• Real estate, machinery, and equipment; and
• Other assets.
The calculation of these assets shall be based on month-end balances, net of impairments, accumulated amortization, and provisions for uncollectibility.
Failure to comply with this ratio shall result in an increase in the minimum capital requirements equivalent to 100% of the excess over the established limit.
Credit Ratings
As of November 28, 2014, the Central Bank’s Communication “A” 5671 — as supplemented and amended — replaced all prior regulatory provisions regarding credit rating requirements issued by local credit rating agencies. Under the updated rules on “Credit Assessments,” the previously applicable requirements tied to local credit ratings are no longer in effect. Where regulations still call for a minimum international credit rating, the new criteria under the Credit Assessments framework will apply on a complementary basis.
The provisions of Communication “A” 5671 are basic guidelines to properly assess the credit risk that financial institutions must observe when implementing Central Bank Rules including the requirement of a particular rating and do not replace the credit assessment that each financial institution must make to their counterparts. International credit ratings that refer to these provisions shall be issued by rating agencies that have a code of conduct based on the “Principles of the Code of Conduct for Agents Rate Risk” issued by the International Organization of Securities Commissions.
Annex II of Communication “A” 5671 provides a table regarding the new qualification requirements for financial institutions. This table classifies the credit ratings requirements for different transactions.
Debt Classification and Loan Loss Provisions for Regulatory Purposes
Unless otherwise indicated, the regulations explained in this section should be applied to financial information of the banks calculated in accordance with Central Bank Rules. IFRS differs in certain aspects from Central Bank Rules.
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Credit Portfolio
The regulations on debt classification are designed pursuant to Central Bank Rules, which differ from IFRS to establish clear guidelines for identifying and classifying the quality of assets, as well as evaluating the actual or potential risk of a lender sustaining losses on principal or interest, in order to determine (taking into account any loan security) whether the provisions against such contingencies are adequate. Banks must classify their loan portfolios into two different categories:
(1) Commercial portfolio. Includes all financing, except for consumer or housing loans.
Loans exceeding Ps.1,198,966,000, linked to the client’s business or productive activity, are classified as commercial. At the entity’s discretion, commercial loans up to Ps.1,198,966,000 may be grouped with consumer or housing loans, treated as such. Consumer loans are combined with commercial ones to determine classification, with collateral-backed loans weighted at 50%.
This option must apply to the entire portfolio and be outlined in the “Classification and Provision Procedures Manual,” with six months’ notice to the Superintendency for changes.
(2) Consumer or housing portfolio. Includes:
(a) Consumer loans (personal, family, professional, for consumer goods, credit card financing).
(b) Housing loans (purchase, construction, refurbishment).
(c) Microcredit loans – up to Ps.239,793,200, and microenterprise loans.
(d) Commercial loans up to Ps.1,198,966,000, with or without preferred collateral, if opted by the entity.
Under the current debt classification system, each customer, as well as the customer’s outstanding debts, are included within sub-categories. The debt classification criteria applied to the consumer loan portfolio are primarily based on objective factors related to customers’ performance of their obligations or their legal standing, while the key criterion for classifying the commercial loan portfolio is each borrower’s paying ability based on their future cash flow.
Clients with no previous credit history with the entity, who later receive financing that does not exceed the amount derived from applying the percentage in section 2.2.5 of the “Minimum Provisions for Uncollectible Risk” regulations to their debt balance, may be classified based only on a projected cash flow analysis.
To ensure compliance with obligations without requiring new financing or refinancing, additional credit facilities will not be considered refinancings if they do not exceed 10% of the limit assigned during the last credit assessment, and if they are in line with normal business operations and the client can meet their other financial obligations. New financings and refinancings related to increased investment due to business expansion are also excluded, provided the projected cash flow supports full repayment of obligations.
Refinancings granted to agricultural producers under the Agricultural Emergency Law will not count as refinancing for classification purposes. However, the projected cash flow at the end of the emergency period must be considered, and the classification cannot improve based on the client’s pre-emergency situation, nor extend beyond the emergency period.
Commercial loans—Regulatory Classification
The principal criterion used to evaluate a loan pertaining to the commercial portfolio is its borrower’s ability to repay it, whose ability is mainly measured by such borrower’s future cash flow. Pursuant to Central Bank Rules, commercial loans are classified as follows:
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Classification Criteria
Normal Situation Borrowers that demonstrate their ability to comply with their payment obligations. High repayment capacity.
Subject to special Monitoring/Under observation Borrowers that, among other criteria, are up to 90 days past due and, although considered to be able to meet all their financial obligations, are sensitive to changes that could compromise their ability to honor debts absent timely corrective measures.
Subject to special Monitoring / Under negotiation or refinancing agreement Borrowers who are unable to comply with their obligations as agreed with the bank and, therefore, formally state, within 60 calendar days after the maturity date, their intention to refinance such debts. The borrower must enter into a refinancing agreement with the bank within 90 calendar days (if up to two lenders are involved) or 180 calendar days (if more than two lenders are involved) after the payment default date. If no agreement has been reached within the established deadline, the borrower must be reclassified to the next category according to the indicators established for each level.
Subject to special Monitoring / Special Treatment For refinancings granted for the first time within the calendar year, once the first installment is paid, the client may be reclassified to this category only once. After this refinancing, only the overdue obligations will be considered for classification purposes. Subsequent refinancings will be treated under the general provisions outlined in these regulations.
Troubled Borrowers with difficulties honoring their financial obligations under the loan on a regular basis, which, if uncorrected, may result in losses to the bank.
With high risk of insolvency The client’s cash flow analysis indicates that it is highly unlikely they will be able to meet all of their financial obligations.
Irrecoverable The debts of clients in this category are considered uncollectible. Although these assets may have some recovery value under certain future circumstances, their uncollectibility is evident at the time of analysis. The borrower will not meet its financial obligations with the financial institution.
: Indicators of Uncollectibility (A) The client has a poor financial situation, with suspended payments, bankruptcy, or filing for bankruptcy, and is forced to sell significant assets at a loss. The cash flow does not cover production costs. (B) The client has been overdue for more than a year, with capital and interest refinanced, and financed operational losses. Refinancing will not interrupt the delinquency period unless overdue obligations are fully settled. If at least 15% of refinanced obligations and all accrued interest are paid, the debtor may be reclassified to a higher category. (C) The client has incompetent and/or dishonest management, or has the potential for fraudulent acts, with no internal control. (D) The client has inadequate information systems, making it impossible to accurately assess their financial situation, with unreliable and outdated information. (E) The client operates in an industry in decline or requiring widespread restructuring. (F) The client is in the lowest segment of their industry, unable to compete, and has outdated, unprofitable technology. (G) Clients with overdue obligations over 180 days, according to the Central Bank’s “List of Irregular Debtors,” including liquidated entities and certain financial institutions.
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(H) Foreign financial institutions or non-resident borrowers failing to meet the “Credit Evaluation” criteria must have an international risk rating of “investment grade.” (I) Private sector clients whose debt exceeds 2.5% of the entity’s computed equity or Ps.599.483.000, and who have not submitted an affidavit regarding their relationship with the intermediary financial institution. This also applies to clients not evaluated regularly, unless exempted under specific circumstances (e.g., ongoing bankruptcy proceedings).
Consumer or housing loans—Regulatory Classification
The principal criterion applied to loans in the consumer and housing portfolio is the length of period for which such loans remain overdue. Under Central Bank Rules, consumer and housing borrowers are classified as follows:
Classification Criteria
Normal Situation If all payments on loans are current or less than 31 calendar days overdue and, in the case of checking account overdrafts, less than 61 calendar days overdue.
Low Risk / Under observation Loans upon which payment obligations are overdue for a period of more than 31 and up to 90 calendar days.
Low Risk / Special treatment For refinancings granted for the first time within the calendar year, once the first installment is paid, the client may be reclassified to this category only once. After this refinancing, only overdue obligations will be considered for classification purposes. Subsequent refinancings will be subject to the general treatment outlined in these provisions.
Medium Risk Loans upon which payment obligations are overdue for a period of more than 90 and up to 180 calendar days.
High Risk Loans in respect of which a legal action seeking collection has been filed or loans having payment obligations overdue for more than 180 calendar days, but less than 365 calendar days.
Irrecoverable This category includes clients who are insolvent or in bankruptcy with little or no chance of credit recovery, or who have overdue payments exceeding one year. It also includes clients undergoing judicial management, or those who have requested preventive bankruptcy or extrajudicial preventive agreements, even if there is a chance of credit recovery, once more than 540 days of overdue payments have passed. Clients whose debts have been refinanced through periodic payment obligations (monthly or bimonthly) may be reclassified to the next higher level if they have made timely payments or have arrears not exceeding 31 days for three consecutive installments, or, in the case of lump-sum payments, bimonthly or irregular payments, if at least 15% of their refinanced obligations (principal) have been paid. A refinanced debtor who meets the above conditions may be reclassified to the next higher level if, additionally, the rest of their debts meet at least the requirements for that level. If a debtor classified in this category has refinanced their debt—regardless of whether they have paid the required installments or percentage—and has received additional credit as outlined in point Section.2.5 of the “Minimum Provisions for Uncollectibility Risk” guidelines, and if such additional financing remains unpaid, they must remain in this category for at least 180 days from the date the additional credit was granted or the refinancing agreement was made.
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This category also includes clients who meet the conditions outlined below: (a) Clients with overdue obligations over 180 days, according to the Central Bank’s “List of Irregular Debtors,” including liquidated entities and certain financial institutions. (b) Foreign financial institutions or non-resident borrowers failing to meet the “Credit Evaluation” criteria must have an international risk rating of “investment grade.” (c) Private sector clients whose debt exceeds 2.5% of the entity’s computed equity or the reference amount in section 3.7., and who have not submitted a sworn statement regarding their relationship with the intermediary financial institution. This also applies to clients not evaluated regularly, unless exempted under specific circumstances (e.g., ongoing bankruptcy proceedings).
Minimum Credit Provisions
Unless otherwise indicated, the financial regulations described in this section have been prepared in accordance with Central Bank Rules. IFRS differs in certain aspects from Central Bank Rules.
The following minimum credit provisions are required to be made by Argentine banks in relation to the credit portfolio category:
Category With Preferred Guarantees Without Preferred Guarantees
1. Normal situation 1 % 1 %
2. With special monitoring / Low risk
Under observation 3 % 5 %
Under negotiation or refinancing agreement 6 % 12 %
Special treatment 8 % 16 %
3. With problems / Medium Risk 12 % 25 %
4. With high risk of insolvency / High Risk 25 % 50 %
5. Irrecoverable 50 % 100 %
The Superintendency may require additional provisioning if it determines that the current level is inadequate.
In accordance with Central Bank Rules financial institutions are required to develop procedures for the analysis of the credit facilities assuring an appropriate evaluation of a debtor’s financial situation and a periodic revision of its situation concerning objective and subjective conditions of all the risks taken. The procedures established have to be detailed in a manual called “Manual of Procedures for Classification and Allowances” which shall be permanently available for the Superintendency. The frequency of the review of existing classifications must answer to the importance considering all facilities. The classification analysis shall be duly documented.
In the case of commercial loans, applicable regulations require a minimum frequency of review. Such review must take place:
(i) On a quarterly basis, with respect to individually considered clients whose financing at any point is equivalent to 5% or more of the RPC or the financial trust assets for the month preceding the end of the respective period, depending on whether the client is an entity or a financial trust. For these purposes, the group of connected counterparties shall be treated as a single client;
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(ii) On a semi-annual basis, with respect to individually considered clients whose financing at any point is between 1% (or the equivalent of Ps.1,198,966,000, whichever is lower) and less than 5% of the RPC or the financial trust assets for the month preceding the end of the respective period, depending on whether the client is an entity or a financial trust. For these purposes, the group of connected counterparties shall be treated as a single client.
At the close of the first calendar semester, the review must cover at least 50% of the total commercial portfolio, including clients referred to in section 6.3.1. Therefore, to meet this percentage, the review must also include clients whose financing is below 1% of the mentioned RPC or financial trust assets (or the equivalent of Ps.1,198,966,000), proceeding in decreasing order based on the magnitude of their financing.
(iii) During the fiscal year, in other cases, the review must cover the entire commercial portfolio by the end of the period.
In addition to the minimum frequency outlined above, the classification must be reviewed – with a reasoned record of the decision made in the client’s file – and, if necessary, amended whenever any of the following circumstances occur:
(1) Modification of any of the objective classification criteria arising from these regulations (e.g., terms of delinquency, legal status of the client or their debts, compliance with refinancings, and requests for refinancing of obligations).
(2) A negative change in the client’s classification in the “Central de Deudores del Sistema Financiero,” downgrading it to a lower degree than the one assigned by the entity, by at least another financial entity or trust whose claims represent at least 10% of the total reported by all creditors.
(3) Notification of the Superintendency’s final determination regarding the adjustment of provisions, as indicated by inspection activities.
When there is a discrepancy of more than one level between the classification given by the financial entity and those assigned by at least two other entities or financial trusts in categories lower than the one assigned by the entity, with their combined claims representing at least 20%, but less than 40%, of the total reported by all creditors, according to the latest available information from the “Central de Deudores del Sistema Financiero.”
The reassessment must be immediate for clients whose covered financing equals or exceeds 1% of the entity’s computable net worth or the trust’s assets, from the month prior to the occurrence of any of the circumstances mentioned, or the equivalent of Ps.599,483,000, whichever is lower, and within three months for all other included clients.
Allowances for loan losses
The Central Bank Rules establishes minimum requirements for allowances for loan losses, in accordance with the category assigned to the client and the type of guarantee. Entities may have allowances for amounts higher than the minimum requirements, as deemed reasonable. Allowances are designed pursuant to the Central Bank Rules which differ from IFRS. See “Item 5B. Critical accounting policies” and note 9 to our audited consolidated financial statements as of December 31, 2024 and 2023.
Increases in the allowance are based on the level of growth of the loan portfolio, as well as on the deterioration of the quality of existing loans, while decreases in the allowance are based on regulations requiring the write-off of non-performing loans classified as irrecoverable after a certain period of time and on decisions of the management to write off non-performing loans evidencing a very low probability of recovery.
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Priority rights of depositors
Under section 49 of the Financial Institutions Law, in the event of judicial liquidation or bankruptcy of a bank all depositors, irrespective of the type, amount or currency of their deposits, will be senior to the other remaining creditors (such as shareholders of the bank), with exceptions made for certain labor liens (section 53 paragraphs (a) and (b)) and for those creditors backed by a pledge or mortgage, in the following order of priority: (a) deposits of up to Ps.50,000 per person (including all amounts such person deposited in one financial entity), or its equivalent in foreign currency, (b) all deposits of an amount higher than Ps.50,000 or its equivalent in foreign currency, and (c) the liabilities originated in commercial lines granted to the financial institution and which directly affect international commerce. Furthermore, pursuant to section 53 of the Financial Institutions Law, as amended, Central Bank claims have absolute priority over other claims, except for pledged or mortgaged claims, certain labor claims, the depositors’ claims pursuant to section 49, paragraph e), items i) and ii), debt granted under section 17, paragraphs (b), (c) and (f) of the Central Bank’s Charter (including discounts granted by financial entities due to a temporary lack of liquidity, advances to financial entities with security interest, assignment of rights, pledges or special assignment of certain assets) and debt granted by the Banking Liquidity Fund backed by a pledge or mortgage.
The amendment to section 35 bis of the Financial Institutions Law by Law No. 25,780 sets forth that if a bank is in a situation where the Central Bank may revoke its authorization to operate and become subject to dissolution or liquidation by judicial resolution, the Central Bank’s Board of Directors may take certain actions. Among these actions, in the case of excluding the transfer of assets and liabilities to financial trusts or other financial entities, the Central Bank may totally or partially exclude the liabilities mentioned in section 49, paragraph (e), as well as debt defined in section 53, giving effect to the order of priority among creditors. Regarding the partial exclusion, the order of priority of paragraph (e), section 49 must be followed without treating liabilities of the same grade differently.
Mandatory deposit insurance system
Law No. 24,485, passed on April 12, 1995, as amended, created a Deposit Insurance System, or “SSGD,” which is mandatory for bank deposits, and delegated the responsibility for organizing and implementing the system to the Central Bank. The SSGD is a supplemental protection to the privilege granted to depositors by means of section 49 of the Financial Institutions Law, as mentioned above.
The SSGD has been implemented through the establishment of a Deposit Guarantee Fund, or “FGD,” managed by a private-sector corporation called Seguro de Depósitos Sociedad Anónima, (Deposit Insurance Corporation, or “SEDESA”). According to Decree No. 1292/96, the shareholders of SEDESA are the government through the Central Bank and a trust set up by the participating financial institutions. These institutions must pay into the FGD a monthly contribution determined by Central Bank Rules. The SSGD is financed through regular and additional contributions made my financial entities, with the additional contribution differentiated based on factors such as the rating assigned by the Superintendency, the ratio of excess computable equity responsibility relative to the minimum capital requirement, and the quality of the active portfolio, with the additional contribution not exceeding the normal contribution.
Financial entities must make regular monthly contributions to the FGD equivalent to 0.015% of their monthly average daily balances of the deposits listed in the following paragraph, recorded in the second month prior to the contribution. The Central Bank may require an advance contribution of up to the equivalent of 24 minimum normal contributions, with a notice period of no less than 30 calendar days, to cover the FGD’s resource needs. The first contribution was made on May 24, 1995.
The Central Bank may also require financial institutions to advance the payment of up to the equivalent of two years of monthly contributions and debit the past due contributions from funds of the financial institutions deposited with the Central Bank. The Central Bank may require additional contributions by certain institutions, depending on its evaluation of the financial condition of those institutions, as described above.
The SSGD’s coverage applies to deposits in Pesos and foreign currency made in participating entities in the form of: current accounts, demand accounts opened in Cooperative Credit Unions, savings accounts, fixed-term deposits, salary/social security accounts, basic, universal free, and special accounts, term investments, and immobilized balances derived from the above concepts.
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The SSGD does not cover: (i) deposits and term investments in transferable paper acquired through endorsement, even if the last endorsee is the original depositor; (ii) demand deposits with interest rates exceeding the reference rate, and term deposits or investments exceeding 1.3 times the reference rate or the reference rate plus 5 percentage points, as well as those influenced by additional incentives; (iii) deposits from financial entities in other intermediaries, including those acquired through secondary market transactions; (iv) deposits made by related parties to the entity, as defined in the “Large Credit Risk Exposures” regulations; (v) fixed-term deposits in securities, acceptances, or guarantees; (vi) immobilized balances from excluded deposits or transactions; (vii) term deposits and investments structured through Electronic Certificates for Deposits and Term Investments (CEDIP) transmitted after the issuing financial entity falls under the conditions outlined in Section 49 of the Central Bank’s Organic Charter or Section 35 bis of the Financial Institutions Law.
The guarantee will cover the return of the deposited capital, interest, adjustments (based on the Reference Stabilization Coefficient, “CER,” for UVA deposits and the Construction Cost Index, “ICC,” for UVI deposits), and exchange rate differences, up to a limit of Ps.50,000,000, accrued until the date of revocation of the authorization or suspension of the entity under Article 49 of the Central Bank’s Organic Charter. For accounts held by two or more individuals, the guarantee limit will be $50,000,000, distributed proportionally among the account holders. The total guarantee for any individual, including accumulated accounts and deposits covered by this scheme, will not exceed the $50,000,000 limit.
Effective payment on this guaranty will be made within 30 business days after revocation of the license of the financial institution in which the funds are held; such payments are subject to the exercise of the depositor’s priority rights described above.
In view of the circumstances affecting the financial system, Decree No. 214/2002 provided that SEDESA may issue registered securities for the purpose of offering them to depositors in payment of the guarantee in the event it should not have sufficient funds available.
When the contributions to the FGD reach the greater of Ps.2 billion or 5.0% of the total deposits of the financial system, whichever is greater, the Central Bank may suspend or reduce the obligation to make contributions to the FGD, reinstating the obligation in whole or in part when the contributions subsequently fall below that level.
Restrictions
Pursuant to the Financial Institutions Law, financial institutions cannot create any kind of liens over their assets without the Central Bank’s authorization.
Furthermore, in accordance with section 72 of Capital Markets Law, publicly offered companies are forbidden to enter into transactions with their directors, officers or affiliates in terms more favorable than arms-length transactions.
Capital Markets
Commercial banks are authorized to subscribe for and sell shares and debt securities. At present, there are no statutory limitations as to the amount of securities for which a bank may undertake to subscribe. However, under Central Bank Rules, underwriting of debt securities by a bank would be treated as “financial assistance” and, accordingly, until the securities are sold to third parties, such underwriting would be subject to limitations.
On September 9, 2013, the CNV published Resolution No. 622/2013 (the “CNV Rules”) supplementing the Capital Markets Law. On May 9, 2018, the Argentine Congress approved the Argentine Productive Financing Law No. 27,440, which modernized and completed the legal framework of the Argentine capital markets. Law No. 27,440 amended the legal framework of the capital markets (Law No. 26,831), mutual funds (Law No. 24,083), notes (Law No. 23,576), the Argentine Civil and Commercial Code (Law No. 26,994, as amended from time to time), financing of housing and construction (Law No. 24,441), the subjects obliged to report on concealing and asset laundering of criminal origin in the capital market framework (Law No. 25,246), and the tax relief regime for the purchase of private securities (Law No. 20,643).
Financial institutions with economic difficulties
The Financial Institutions Law provides that any financial institution, including a commercial bank, (i) with its solvency or liquidity affected, in the opinion of the Central Bank; (ii) recording deficiencies on the minimum cash reserve requirement during the periods established by the Central Bank; (iii) recording repeated failures to comply with the various limits or technical relations established; or (iv) that could not maintain the minimum asset liability required for its particular class, location or characteristics, must (upon request from the Central Bank and in order to avoid the revocation of its license) prepare a restructuring plan or a remediation and regularization plan. The plan must be submitted to the Central Bank on a specified date, no later than 30 calendar days from the date on which a request to that effect is made by the Central Bank. If the institution fails to submit, secure regulatory approval of, or comply with, a restructuring plan, the Central Bank will be empowered to revoke the institution’s license to operate as such, without prejudice to the application of the penalties provided for in the aforementioned law.
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The Central Bank may appoint overseers with veto power, require the provision of guarantees and limit or forbid the distribution or remittance of profits, temporarily admit exceptions to the relevant limits and technical relations; exempt or defer the payment of charges and/or fines as provided by the Financial Institutions Law.
The Central Bank’s charter authorizes the Superintendency to fully or partially suspend, exclusively subject to the approval of the President of the Central Bank, the operations of a financial institution for a term of 30 days if the liquidity or solvency thereof is adversely affected. Such term could be renewed for up to 90 additional days, with the approval of the Central Bank’s Board of Directors. During such suspension term an automatic stay of claims, enforcement actions and precautionary measures is triggered, any commitment increasing the financial institution’s obligations shall be null and void, and debt acceleration and interest accrual shall be suspended.
Institution restructuring to safeguard credit and bank deposits
If a financial institution meets the Central Bank’s criteria and is found to be in any of the situations foreseen by Section 44 of the Financial Institutions Law, the Central Bank may authorize the restructuring of the financial institution in defense of depositors, prior to revocation of the authorization to operate. The restructuring plan may consist of certain steps, including, among others:
(i) adoption of a list of measures to capitalize or increase the capital of the financial institution;
(ii) revoke the approval granted to the shareholders of the financial institution to hold interests therein;
(iii) exclusion or transfer assets and liabilities;
(iv) judicial intervention of the institution, displacing the statutory administrative authorities, and determine the capabilities needed to comply with the assigned function.
Revocation of the license to operate as a financial institution
The Central Bank may revoke the license to operate as a financial institution (a) as a request of the legal or statutory authorities of the institution; (b) in the cases contemplated by the Argentine Civil and Commercial Code or in the laws governing its existence as a legal entity; (c) when, as opinion of the Central Bank, the affections to the solvency and/or liquidity of the institution cannot be solved through a regularization and sanitation program; (d) in other cases provided by the Financial Institutions Law.
Liquidation of financial institutions
As provided in the Financial Institutions Law, the Central Bank must notify the revocation decision to a competent court, which will then determine who will liquidate the entity: the corporate authorities (extrajudicial liquidation) or an independent liquidator appointed by the court for that purpose (judicial liquidation). The court’s decision will be based on whether there are sufficient assurances that the corporate authorities are capable of carrying out such liquidation properly, prior authorization of the Central Bank and in the cases provided by subsections a) and b) of section 44 of the aforementioned law.
Bankruptcy of financial institutions
According to the Financial Institutions Law, financial institutions are not allowed to file their own bankruptcy petitions. In addition, the bankruptcy shall not be adjudged until the license to operate as a financial institution has been revoked.
Once the license to operate as a financial institution has been revoked, a court of competent jurisdiction may adjudge the former financial institution in bankruptcy, or a petition in bankruptcy may be filed by the Central Bank or by any creditor of the bank, in this case after a period of 60 calendar days has elapsed since the license was revoked.
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Once the bankruptcy has been adjudged, provisions of the Argentine Bankruptcy Law No. 24,522 (the “Bankruptcy Law”) and the Financial Institutions Law shall be applicable. In certain cases, specific provisions of the Financial Institutions Law shall supersede the provisions of the Bankruptcy Law (i.e., priority rights of depositors).
Merger and transfer of goodwill
Merger and transfer of goodwill may be arranged between entities of the same or different type and will be subject to the prior approval of the Central Bank. The new entity or the buyer must submit a financial-economic structure profile supporting the project in order to obtain authorization from the Central Bank.
Holding Companies
On June 28, 2019, the Central Bank ruled, through Communication “A” 6723, with effect from January 1, 2020, that Group “A” financial institutions which are controlled by non-financial institutions (as in our case in relation with the Bank) shall comply with the Minimum Capital Regulations (please see “Argentine Banking Regulation—Liquidity and Solvency Requirements—Minimum Capital Requirements”), the Major Exposure to Credit Risk regulations (please see “Argentine Banking Regulation—Credit Risk Regulation—Large Exposures”), the Liquidity Coverage Ratio (please see “Argentine Banking Regulation—Liquidity Coverage Ratios”) and the Net Stable Funding Ratio (please see “Argentine Banking Regulation—Liquidity Parameters—Net Stable Funding Ratio”) on a consolidated basis comprising the non-financial holding and all its subsidiaries (excluding insurance companies and non-financial subsidiaries).
Additionally, Group “A” financial institutions may not grant direct or indirect financial assistance of any kind to its holding company whenever it is a non-financial institution.
Financial system restructuring unit
The Financial System Restructuring Unit was created to oversee the implementation of a new approach towards those banks that benefit from assistance provided by the Central Bank. This unit is in charge of rescheduling maturities, determining restructuring strategies and action plans, approving transformation plans, and accelerating repayment of the facilities granted by the Central Bank.
Fintech regulations
The Central Bank issued Communication “A” 6885 (as amended from time to time, regulations on “Payment Service Providers”), by means of which it regulates certain aspects of fintech operations. Through these communications, PSPs as defined as legal entities that, although not classified as financial institutions, perform at least one function within a retail payment system, as part of the broader framework of the national payment system.
By means of these rules, PSPs operations are regulated and a specific registry for them was created. Entities that are not eligible to operate as PSPs include legal entities that are not regularly incorporated in the country, or those that, while incorporated abroad as private legal entities, have failed to meet the requirements outlined in the General Companies Law No. 19,550 and its amendments, specifically regarding the regular exercise of activities within their corporate purpose in Argentina. Additionally, entities recognized by the CNV as markets, clearinghouses, or any other type of agents are excluded from operating as PSPs.Furthermore, legal entities whose shareholders, voting rights, or governing and supervisory bodies involve individuals who fall under the provisions of sections a), b), d), e), or f) of Article 10 of the Financial Entities Law, or who have been convicted of crimes such as property offenses, public administration crimes, economic and financial offenses, or offenses against public faith, including violations of privacy or association crimes, are also disqualified. However, this does not apply to shareholdings acquired in securities markets that do not exceed 20% of the capital or voting rights.
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Regarding the registry, regulations on “Payment Service Providers” stipulate that PSPs performing the functions outlined below are required to register in the ‘Payment Service Providers Registry’ managed by the Superintendency:
(1) Virtual Account Provision: provision of virtual accounts for performing debits and credits within a payment scheme. The accounts offered by PSPs are referred to as payment accounts; these are freely available accounts in Pesos that allow for the ordering and receiving of payments. PSPCPs may allow for these accounts to have more than one holder.
(2) QR Management: Managing payments within travel schemes using QR codes (VQR).
(3) Acceptance: Enroll merchants into payment schemes with transfers. This includes, among other tasks, facilitating the mechanisms to initiate payments, transmitting payment order information to the administrator or other participants of the scheme, and, if authorized, confirming the operations.
(4) Initiation (registration is required only if they provide digital wallet services): Send a valid payment instruction at the request of a payer to the provider of a payment account (or a sight account) or to the issuer of the payment instrument.
(5) ATM Networks: Manage transactions ordered through ATMs.
(6) Electronic Funds Transfer Networks (processing or operation): Transmit electronic instructions for fund movements between financial entities and, where applicable, notify the PSP providing payment accounts of the credits to their sight accounts so that it can proceed with the fulfillment of the transfer function.
(7) Acquiring: Enroll merchants into payment schemes with cards. This includes, among other tasks, facilitating the mechanisms to initiate payments, transmitting payment order information to the administrator or other participants of the scheme, and, if authorized, confirming the operations.
(8) Aggregation or Sub-acquiring: Provide merchants with access to payment schemes that the aggregator has contracted with one or more acquirers, using the aggregator’s or sub-acquirer’s merchant identifier (ID), which acts as the receiving customer of the funds from the settlement of various payment schemes.
(9) Non-Banking Collection Companies for Taxes and/or Services: Provide payment and/or collection services for taxes and/or services on behalf of third parties through agent networks, using cash and/or payment instruments.
PSP regulations establish that all funds credited to payment accounts offered by PSPCPs shall be (i) available at all times, for an amount at least equivalent to the one credited in the payment account; (ii) deposited in Pesos, in on-sight accounts in Argentine financial entities; and (iii) on an independent on-sight account from the one used for trading for own account (e.g.: creditor or salary payments).
Any breach of the rules as set on the abovementioned communication is submitted to the sanctions of the Financial Institutions Law.
By means of Communication “A” 7156 (as amended and supplemented from time to time), the Central Bank extended the application of the provisions of the Financial Institutions Law to “Other non- financial credit providers” covered by the rules on “Non-financial credit providers,” and among other measures, it provided that as from February 1, 2021, other non-financial credit providers and non-financial companies issuing credit and/or purchase cards will be subject to the provisions set forth in the rules on “Protection of financial services users,” for the financing they grant.
On February 24, 2022, the Central Bank issued Communication “A” 7462 (as amended from time to time) providing for the creation of the “Register of interoperable digital wallets” and establishing that any PSP wishing to provide a digital wallet service that allows making transfer payments initiated by reading QR codes must be registered therein. In addition, it defines a “digital wallet” service as the service offered by a financial institution or payment service provider (PSP) through an application on a mobile device or web browser that must allow making payments with transfer (PCT) and/or with other payment instruments.
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Pursuant to Communication “A” 7593, the Central Bank amended the rules on “Protection of Financial Services Users” to include Payment Service Providers that offer payment accounts and Payment Service Providers that perform the function of initiation and provide the digital wallet service among the obligated parties.
On the other hand, as regards the rules on “Payment Service Providers,” it establishes that they must submit a compliance report prepared by professionals or associations of licensed professionals, which must be prepared in accordance with the model to be established from time to time, and verify compliance with the rules issued by the Central Bank that are applicable according to the type of provider in question and submitted to the Superintendency on an annual basis.
By means of Communication “A” 7783, the Central Bank approved the rules on “Minimum requirements for the management and control of technology and information security risks associated with digital financial services” applicable to both PSPCP and financial entities.
Gender Parity Requirements
On September 3, 2020, by means of Communication “A” 7100 (as amended from time to time), the Central Bank amended the rules on “Guidelines for Corporate Governance in Financial Institutions” (Lineamientos para el gobierno societario en entidades financieras) to include a requirement of gender parity.
By virtue of such Communication, the Central Bank suggested to financial institutions to consider the progressive incorporation of women on new appointments and/or renewals, until gender parity is achieved. In this regard, the Central Bank defined gender parity as the guideline that aims at equalizing the participation of men and women in labor decision-making spaces, ensuring the right to equal opportunities and non-discrimination on the bases of gender.
Anti-Money Laundering, Terrorism Financing and Proliferation of Weapons of Mass Destruction Financing Regime
The concept of Money Laundering (“ML”) is generally used to denote transactions aimed at introducing funds from illicit activities into the institutional system and thus transform gains from illegal activities into assets of a seemingly legitimate source.
Terrorist financing (“TF”) consists of providing funds for terrorist activities. This may involve funds raised from legitimate sources, such as personal donations and profits from businesses and charitable organizations, as well as from criminal sources, such as drug trade, weapons and other goods smuggling, fraud, kidnapping and extortion.
Proliferation of Weapons of Mass Destruction Financing (“PF”) consists of providing financial support or resources to assist in the development, manufacture, acquisition, or spread of nuclear, chemical, or biological weapons and their delivery systems, in contravention of national laws or, where applicable, international obligations.
On April 13, 2000, the National Congress passed Law No. 25,246, (subsequently amended and complemented, the “AML/CTF/CPF Law”), which created at the national level the Anti- Money Laundering, Counter- Terrorist Financing and the Financing of Proliferation of Weapons of Mass Destruction Regime (“AML/CTF/CPF Regime”), criminalizing money laundering, creating and designating the Financial Information Unit (“UIF,” for its acronym in Spanish) as the enforcement authority of the regime, while also imposing legal obligations on certain public and private sector entities and professionals (the “Reporting Entities”) to report and cooperate with the UIF.
The UIF is a decentralized agency that operates with autonomy and financial independency under the Argentine Ministry of Justice, and its mission is to prevent and deter the crimes of ML/TF/PF.
The following are certain provisions relating to the Argentine Criminal Code, the AML/CTF/CPF Regime established by the AML/CTF/CPF Law, including regulations issued by the UIF, the CNV and the Central Bank. It is recommended that holders consult their own legal advisors and read the AML/CTF/CPF Law and its complementary regulations.
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Money Laundering, Terrorist Financing and Proliferation of Weapons of Mass Destruction in the Argentine Criminal Code
(a) Money laundering
Section 303 of the Argentine Criminal Code (the “ACC”) defines money laundering as a crime committed whenever a person converts, transfers, manages, sells, encumbers, acquires, conceals or in any other way puts into circulation in the market, property derived from an unlawful act, with the possible consequence that the origin of the original property or the subordinate property acquires the appearance of a lawful origin. Section 303 of the ACC establishes the following penalties:
(i) If the amount of the transaction exceeds the sum of 150 Minimum, Vital, and Mobile Wages at the time of the events (as of the date of this annual report, this equals Ps.50,220,000), either in a single act or by the repetition of various acts linked to each other, the penalty shall be imprisonment for a term of three to ten years and fines of two to ten times the amount of the illicit transaction. This penalty may be increased by one third of the maximum and half of the minimum, when the perpetrator of the crime:
(a) regularly commits such crimes or participates in organizations or associations specially designed for committing such crimes;
(b) is a public official who committed the act in the exercise or occasion of their duties. In this case, he/she shall also be subject to a penalty of special disqualification of three to ten years. The same penalty shall be imposed to anyone who has acted in the exercise of a profession or occupation requiring special qualification.
(ii) Anyone who receives money or other property from a criminal offense for the purpose of applying them in an operation as described above, which gives them the possible appearance of a lawful origin, shall be punished with imprisonment for a term of six months to three years.
(iii) If the value of the goods does not exceed 150 minimum wages, the penalty shall be a fine of five to 20 times the amount of the illicit transaction.
These provisions shall apply even if the preceding criminal offence was committed outside the scope of applicability of the Argentine Criminal Code, insofar as the criminal offence was also punishable in the place where it was committed.
(b) Penalties for legal persons
Furthermore, Section 304 of the ACC provides that when the criminal acts have been committed in the name of, or with the intervention of, or for the benefit of a legal person, the following sanctions shall be imposed to the entity jointly or alternatively:
(i) fine of two to ten times the value of the property subject to the offense;
(ii) total or partial suspension of activities, which in no case shall exceed ten years;
(iii) debarment for public tenders or bidding processes or any other State-related activities, which in no case shall exceed ten years;
(iv) dissolution and liquidation of the legal person when it was created for the sole purpose of committing the offense, or such acts constitute the main activity of the entity;
(v) loss or suspension of any State benefit that it may have;
(vi) publication of an extract of the condemnatory sentence at the expense of the legal entity.
In order to calibrate these sanctions, the Court will take into account the failure to comply with internal rules and procedures, the omission of vigilance over the activity of the authors and participants; the extent of the damage caused, the amount of money involved in the commission of the offense, the size, nature and economic capacity of the legal entity. In the cases in which it is essential to maintain the operational continuity of the entity, or of a public work, or particular service, the sanctions of suspension of activities or dissolution and liquidation of the legal person shall not be applicable.
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(c) Terrorist Financing and Proliferation of Weapons of Mass Destruction Financing
Section 306 of the ACC criminalizes the financing of terrorism and the proliferation of weapons of mass destruction. This offense is committed by any person who directly or indirectly collects or provides property or money, with the intention of it being used, or in the knowledge that it will be used, in full or in part to:
(i) To finance the commission of acts which have the aim of terrorizing the population or compelling national public authorities or foreign governments, or agents of an international organization to perform or refrain from performing an act (according to section 41.5 of the ACC);
(ii) by an organization committing or attempting to commit crimes for the purpose set out in (i);
(iii) by an individual who commits, attempts to commit or participates in any way in the commission of offenses for the purpose set out in (i);
(iv) to finance, for themselves or for third parties, the travel or logistics of individuals and/or things to a State other than that of their residence or nationality, or within the same national territory for the purpose of perpetrating, planning, preparing or participating in the purpose set out in (i);
(v) to finance, for themselves or for third parties, the provision or receipt of training for the commission of offenses for the purpose ser out in (i);
(vi) to finance the acquisition, production, development, possession, supply, exportation, importation, storage, transportation, transfer, or in any way the use of weapons of mass destruction, of the nuclear, chemical, biological type, their delivery systems, means of delivery and their related materials, including dual-use technologies and goods to commit any of the crimes provided for the ACC or in international regulations.
The penalty for this offense is imprisonment for a term of five to 15 years and a fine of two to ten times the amount of the illicit transaction. Likewise, the same penalties shall apply to legal persons as described for the crime of money laundering.
The same penalty of imprisonment and fine shall apply to anyone who produces, manufactures, develops, possesses, supplies, exports, imports, stores, transports, transfers, employs, or in any way proliferates, increases, reproduces or multiplies the weapons of mass destruction referred to in (vi) above, their means of delivery and related materials intended for their preparation.
The penalties described above will be applied regardless of the occurrence of the crime for which the financing was intended and, if the latter is committed, regardless of whether the goods or money were used for its commission.
These provisions shall apply even if the offense financed or intended to be financed is committed outside the territorial scope of application of the ACC, or, in the cases described in (ii) and (iii), if the organization or individual is located outside Argentine territory, provided that the conduct is also punishable in the relevant jurisdiction.
Reporting Subjects obliged to Inform and Collaborate with the UIF
The AML/CTF/CPF Regime, in line with international AML/CTF/CPF standards, not only designates the UIF as the agency in charge of preventing ML/TF/PF. It also imposes obligations on various public and private sector entities and individuals, designated as Reporting Subjects (“Sujetos Obligados”), to report and cooperate with the UIF.
Pursuant to Section 20 of the AML/CTF/CPF Law, the following, among others, are Reporting Entities before the UIF:
(i) banks, financial entities and insurance companies;
(ii) exchange agencies and natural and legal persons authorized by the Central Bank to intervene in the purchase and sale of foreign currency with funds in cash or checks issued in foreign currency or through the use of debit or credit cards or in the transfer of funds within or outside the national territory;
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(iii) virtual asset service providers, non-financial credit providers, issuers, operators and/or providers of collection and/or payment services, central securities depository agents and corporate and trust service providers;
(iv) settlement and clearing agents, trading agents; natural and/or legal persons registered with the CNV acting in the placement of investment funds or other collective investment products authorized by such agency; crowdfunding companies, global investment advisors and the legal persons acting as financial trustees whose trust securities are authorized for public offering by the CNV, and the agents registered by the above mentioned controlling agency that intervene in the placement of negotiable securities issued within the framework of the above mentioned financial trusts;
(v) government organizations such as the Central Bank, the Customs Collection and Enforcement Agency (“ARCA,” as per its acronym in Spanish), the Superintendence of Insurance of the Nation (“SSN,” as per its acronym in Spanish), the CNV and the IGJ; and
(vi) professionals in economic sciences, lawyers and notaries public, when they are involved in certain transactions.
Pursuant to Section 21 of the AML Law, Reporting Entities have the following duties::
(i) obtaining documents that indisputably prove the identity, legal status, domicile and other relevant information, about their clients’ operations (“know your customer” policy);
(ii) reporting any suspicious events or transactions. For the purposes of the AML/CTF/CPF Law, suspicious transactions are those that, appear unusual, lack economic or legal justification, or are unusually or unjustifiably complex, whether conducted once or repeatedly (regardless of their amount);
(iii) refraining from disclosing to customers or third parties any actions taken in compliance with the AML/CTF/CPF Law;
(iv) registering before the UIF;
(v) documenting procedures for the prevention of ML/TF/PF establishing internal manuals that reflect the tasks to be developed with a risk based approach;
(vi) appointing compliance officers within the governing body who shall be responsible before the UIF (in case the obliged entity is an individual, such individual will be considered the compliance officer);
(vii) obtaining information and determining the purpose and nature of the relationship with the client;
(viii) determining the risk of money laundering, terrorism financing and financing of proliferation of weapons of mass destruction associated to clients and transactions;
(ix) carrying out due diligence procedures to (i) determine the risk of money laundering, terrorism financing and financing of proliferation of weapons of mass destruction associated to clients and transactions, and (ii) review transactions during the course of the relationship with the client;
(x) performing ongoing client due diligence procedures to review transactions throughout the course of the relationship;
(xi) identifying the individuals who exercise functions of management and representation of the client and those who have powers of disposition;
(xii) adopting specific measures to mitigate the risk of money laundering, terrorism financing and financing of proliferation of weapons of mass destruction;
(xiii) having appropriate risk management systems in place to determine whether the client or final beneficial owner is a politically exposed person;
(xiv) determining the source and legality of funds; and
(xv) keeping, for ten years, all necessary records of transactions, client files and business communications.
These obligations are supplemented by sector-specific UIF resolutions that establish more detailed and targeted requirements depending on the activity performed by each Reporting Entity. By way of example, Reporting Entities operating in the financial sector are subject to UIF Resolution No. 14/2023 as amended by Resolution 199/2024, while those operating in the capital markets are subject to UIF Resolution No. 78/2023, which set forth more granular rules on matters such as customer due diligence, ongoing monitoring, internal controls and risk mitigation measures. Resolution 14/2023, which sets out specific rules for the financial sector, inter alia, prohibits the maintenance of anonymous accounts or accounts under fictitious names, emphasizes the need to apply enhanced due diligence measures to clients commensurate with the risks identified, and provides for the possibility for financial institutions to rely on third parties to carry out certain due diligence measures.
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In addition, the UIF has issued resolutions of general application addressing specific risk factors applicable across all sectors. For example, UIF Resolution No. 35/2023 establishes obligations for reporting entities in relation to politically exposed persons (“PEPs”), while UIF Resolution No. 112/2021 sets forth rules for the identification and verification of beneficial owners. Overall, this framework follows a risk-based approach aligned with FATF recommendations, requiring reporting entities to identify, assess and mitigate their ML/TF/PF risks through proportionate measures.
With respect to PEPs, Resolution No. 35/2023 requires Reporting Entities to assess the level of risk at the time of initiating or continuing a contractual relationship and to apply enhanced, proportionate due diligence measures where appropriate. These measures include, among others: (i) obtaining approval from the Compliance Officer to initiate or continue relationships with foreign PEPs or domestic PEPs classified as high risk; (ii) adopting reasonable procedures to determine whether a client and/or beneficial owner qualifies as a PEP, both at onboarding and on an ongoing basis; (iii) requiring clients to submit sworn statements regarding their PEP status, including updates in the event of any change; and (iv) identifying and documenting the PEP status of beneficial owners, where applicable. The Resolution also regulates the duration of PEP status, establishing a two-year maintenance period, after which Reporting Entities must reassess the risk level based on factors such as the relevance of the public function performed, decision-making authority over funds, and seniority. The same duration applies to persons classified as PEPs due to kinship or close association.
Within their respective regulatory frameworks, the relevant sectoral authorities, such as the CNV and the Central Bank of Argentina, also issue rules applicable to their regulated entities that reflect and operationalize AML/CFT/CPF requirements established by the UIF. In this context, the CNV regulations stipulate, among other provisions, that the Reporting Subjects under its control shall only perform the operations provided for under the public offering system when these operations are performed or ordered by persons constituted, domiciled or resident in countries, domains, jurisdictions, territories or associated states not considered to be non-cooperative or high risk by the FATF. Similarly, they establish payment modalities and control procedures for the reception and delivery of funds from and to clients.
Asset Freezing Regime and Terrorism Financing/Proliferation Financing Reporting Regime
Executive Decree No. 918/2012, as amended, establishes the legal framework and procedures for the reporting of transactions linked to TF/PF, as well as for the freezing of assets related to such activities.
In this context, UIF Resolution No. 207/2025 and 3/2026, regulate the implementation of Executive Decree No. 918/2012 and establish, among other matters: (i) the obligation for Reporting Entities to verify clients are not listed in TF/PF associated lists, including designated by the United Nations Security Council pursuant to Resolution No. 1267 (1999), 1718 (2006), 1737 (2006) or linked to criminal actions under Section 306 of the Argentine Criminal Code; (ii) the procedures for reporting suspicious transactions of TF/PF; and (ii) the administrative procedures applicable to the freezing of assets of natural or legal persons or entities related to TF/PF.
For purposes of facilitating compliance with these obligations, Executive Decree No. 489/2019 created the Public Registry of Persons and Entities Linked to Acts of Terrorism and Its Financing (Registro Público de Personas y Entidades vinculadas a actos de Terrorismo y su Financiamiento – “RePET”), a national public registry that consolidates the relevant United Nations Security Council designations and persons or entities linked to terrorism-related offenses under Argentine law. As of January 2026, this registry does not include designations or lists specifically related to the PF.
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Supervision and Administrative Enforcement
The UIF is vested with supervisory and enforcement powers over Reporting Entities and may monitor compliance with AML/CFT/CPF obligations, conduct inspections and request information. In sectors subject to specific regulatory oversight, the UIF carries out its supervisory functions with the assistance of the relevant specific control authorities (“órganos de contralor específico”). In particular, the Central Bank of Argentina assists the UIF with respect to reporting entities in the financial sector, and the National Securities Commission (CNV) assists the UIF with respect to reporting entities operating in the capital markets.
Reporting Entities are subject to administrative sanctions under the AML/CFT/CPF Law for failures to comply with applicable obligations. The UIF is empowered, following administrative proceedings, to impose the following sanctions:
(i) a fine ranging from one to ten times the total value of the assets involved in the transaction in cases of failure to report a suspicious transaction or of reporting it outside the prescribed timeframes and formal requirements; in the case of other infringements consisting of formal non-compliance, a fine ranging from 15 to 2,500 units, updated annually (currently set at ARS 54,140);
(ii) a warning;
(iii) a warning with the obligation to publish the operative part of the resolution; and
(iv) for compliance officers, disqualification for up to five years from performing such functions.
Administrative liability extends both to the reporting entity and to the members of its management body and is subject to a statute of limitations of five years.
Politically Exposed Persons
Resolution No. 35/2023 (lastly amended by Resolution No. 192/2024), establishes the rules that Reporting Subjects must follow regarding clients that are Politically Exposed Persons (“PEP”).
Following the aforementioned RBA, Resolution 35/2023 establishes that Reporting Subjects must determine the level of risk at the time of beginning or continuing the contractual relationship with a PEP, and must take due diligence measures, adequate and proportional to the associated risk and the operation or operations involved.
This Resolution establishes (i) the measures that the Reporting Subjects must take with respect to foreign PEPs or domestic PEPs that have been classified as high risk by the Reporting Party, for example, having the approval of the compliance officer to initiate or continue commercial relations with them; (ii) each Reporting Subject must take reasonable measures to determine whether a customer and/or beneficial owner is a PEP, at the time of initiating or continuing the commercial relationship with them; (iii) the Reporting Subject must require their clients to sign a sworn statement in which they state whether or not they are a PEP, not only at the beginning of the contractual relationship, but also in the event that their status as a PEP is modified (whether they become or cease to be a PEP); (iv) the clients must inform the PEP status of the beneficial owners, if applicable; and (v) the maintenance period of the PEP status is expressly regulated, being set at two years. Once this term has expired, the Reporting Subject shall evaluate the level of risk of the client or beneficial owner, taking into consideration the relevance of the function performed, the power of disposition and/or administration of funds, and the seniority in the public function exercised, among other relevant factors, for the analysis of the level of risk. PEPs due to kinship or closeness will maintain their status for the same time as that of the person with whom they have or have had the relationship.
FOR A MORE SPECIFIC ANALYSIS OF THE REGIME, HOLDERS SHOULD CONSULT THEIR LEGAL COUNSEL AND/OR READ THE APPLICABLE LAWS BY VISITING THE WEBSITE OF THE FINANCIAL INFORMATION UNIT HTTPS://WWW.ARGENTINA.GOB.AR/UIF). HOLDERS ARE RECOMMENDED TO CONSULT THEIR LEGAL ADVISERS AND READ THE ABOVE-MENTIONED LAWS AND THEIR REGULATORY DECREES.
CNV Regulations
The CNV Rules stipulate, among other provisions, that the Reporting Subjects under its control shall only perform the operations provided for under the public offering system when these operations are performed or ordered by persons constituted, domiciled or resident in countries, domains, jurisdictions, territories or associated states not considered to be non-cooperative or high risk by the FATF.
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Similarly, they establish the payment modalities and control procedures for the reception and delivery of funds from and to clients.
Central Bank Regulations
Pursuant to Central Bank Communication “A” 6399, as amended and supplemented, including without limitation, by Communication “A” 6709, Reporting Subjects must keep—for a period of ten years—written records of the procedure applied in each case for the discontinuation of a client’s operations. Among these records, they shall keep a copy of any notification sent to the customer requesting further information and/or documentation, the corresponding notices of receipt and the documents identifying the officials who took part in the decision, in accordance with the respective procedural manuals.
Our Anti-Money Laundering and Prevention of Terrorist Financing Program
One of the most significant operational risks that is monitored by Banco Macro is that of the activities of “Anti-Money Laundering and Prevention of Terrorist Financing.” There is a program designed to safeguard us against any unintentional involvement or participation in criminal or illicit activities or terrorist financing, and to reaffirm the policy of fully cooperating with the strict application of law and cooperation with the authorities and regulatory bodies.
In order to ensure that the financial system is not used as a channel of funds from criminal activities, employees must determine the true identity of all customers and final beneficiaries of the contracted products and services.
Roles and responsibilities of the program
All employees have roles and responsibilities in the implementation of the Anti-Money Laundering Program. These roles and responsibilities vary depending on the employee’s business line or business area.
Elements of the Anti-Money Laundering Program
We adopt specific procedures for our various operational and commercial areas as applicable.
The following are the most important components of our Anti-Money Laundering Program:
(1) Prevention: We carry out different tasks in order to mitigate the risk of money laundering:
(a) Generation of policies and procedures;
(b) Reliable identification of customers and knowledge of their activities (“Know Your Customer” process);
(c) Specific risk analysis in the product and process approval process;
(d) Training and ongoing communication to update all relevant staff;
(e) Existence of a responsible Officer and a Committee for Money Laundering and Terrorist Financing Prevention;
(2) Monitoring: We monitor the activity of clients, suppliers, etc., by setting parameters and alerts to be able to identify cases that must be reported to the appropriate authorities.
(3) Relationship with regulatory agencies or industry: We maintain relations with the Central Bank/UIF/CNV by carrying out all necessary actions in order to collect and maintain adequate identification of clients and transaction records, in accordance with regulatory requirements. Likewise, we respond to the information requirements of the mentioned entities.
(4) Audits and Reviews: this program will be periodically reviewed through by its own assurance program and different types of audits (internal, external, comptroller) to identify opportunities for improvement.
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(5) Training and Communication: All our staff (including executive staff) who have a relationship with clients or handle their transactions must receive training in anti-money laundering. This training is institutional and mandatory.
(6) Know Your Client (KYC): Similar to our efforts to prevent money laundering, and terrorist financing begins with an appropriate “Know Your Customer” process.
(a) Customer awareness allows financial institutions to determine if certain customers are included on terrorist lists issued by governments and regulatory agencies. This process also allows us to establish whether we are facing high-risk clients (e.g., Politically Exposed Persons) in order to carry out an Enhanced Due Diligence process).
(b) \We will not enter into any relationship with any individual or entity who cannot prove their true identity.
(7) Recognition and reporting of unusual or suspicious activities: When employees receive indications that make them assume that clients’ funds come from criminal activities, they should report this to the Money Laundering and Terrorist Financing Committee for evaluation in accordance with established procedure.
For a thorough analysis of money laundering regulations in effect as of the date of this document, please consult with your own legal counsel and read Title XIII, Second Book of the ACC and any regulations issued by the UIF, the CNV and the Central Bank in their entirety. For this purpose, interested parties may visit the websites of the Argentine Ministry of Economy, www.argentina.gob.ar/economia, the UIF, www.argentina.gob.ar/uif, the CNV, www.argentina.gob.ar/cnv or the Central Bank, www.bcra.gob.ar none of which websites are incorporated by reference herein.
Corporate Criminal Liability Law
The Corporate Criminal Liability Law No. 27,401 sets forth a criminal liability regime applicable to legal entities involved in certain corruption offenses directly or indirectly committed in their name, on their behalf or in their interest and from which a benefit may arise. The individual offenders may be employees or third parties — even unauthorized third parties, provided that the company ratified the act, even tacitly.
In accordance with such law, the Board of Directors has approved a Corruption and Anti-Bribery Policy that sets forth the ethical and compliance standards regarding officer corruption practices, under the scope of the Corporate Criminal Liability Law and the applicable international laws. The Board of Directors expressly prohibits this kind of practices and applies the same criterion in similar cases where private sector individual acts as counterparty.
In turn, the Board of Directors has implemented a Code of Conduct applicable to all employees, contractors, suppliers and agents, with the prohibitions, restrictions and conditions imposed upon them under the Integrity Program approved by us, which was previously discussed by the Appointment and Corporate Government Committee.
For an extensive analysis of the AML/CTF/CPF Regime and Anti-Bribery and Anti-Corruption Regime in effect as of the date of this annual report, investors should consult legal counsel and read Title XIII, Book 2 of the Argentine Criminal Code and any regulations issued by the UIF, the CNV and the Central Bank in their entirety. For such purposes, interested parties may visit the websites of the Argentine Ministry of Economy, (www.argentina.gob.ar/economia), the Argentine Ministry of Justice (https://www.argentina.gob.ar/justicia), the UIF (www.argentina.gob.ar/uif), the CNV (www.argentina.gob.ar/cnv), or the Central Bank (www.bcra.gov.ar). The information found on such websites is not a part of this annual report.
Alterations to Argentine Regulatory Framework
During 2025, the Argentine government enacted several regulations amending the regulatory framework for financial institutions. These regulations include:
• Communication “A” 8277 which established the financial institutions may, within certain limits, carry forward to the following month the excess minimum cash integration in Pesos generated between July and October 2025;
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• Communications “A” 8281 and 8289, which increased the minimum cash requirement applicable to demand deposits, term investments with early termination options, repos and passive stock market guarantees in Pesos by 10 percentage points, and reduced by 4 percentage points the portion of the demand deposit requirement in Pesos that can be covered with government securities, effective as of August 1, 2025;
• Communication “A” 8302, which established that (i) compliance with reserve requirements in Pesos was measured daily instead of on an average monthly basis, effective as of August 18, 2025, (ii) the charge applicable to reserve requirement shortfalls increased from 1.5x the Argentine wholesale rate (Tasa Mayorista de Argentina or “TAMAR”) to 3x TAMAR, (iii) certain situations triggering the need for the submission of an adequation plan are eliminated, (iv) the minimum cash requirement applicable to certain deposits in Pesos, term investments with early termination options, repos and passive stock market guarantees in Pesos, be increased in 5 percentage points, from August 19, 2025, to November 28, 2025 (subsequently extended until March 31, 2025 by Communication “A” 8355), and (v) financial institutions may allocate up to 3 percentage points of their reserve requirements on demand deposits to public securities in Pesos issued by the Argentine Treasury in primary offerings, effective as of August 19, 2025;
• Communication “A” 8306 which established (i) as of September 1, 2025, an additional 3.5 percentage point reserve requirement on all Peso-denominated liabilities subject to fractional reserve requirements, and (ii) that financial institutions increase by 2 percentage points the allocation of their reserve requirements on certain demand liabilities denominated in Pesos (current accounts, savings accounts, demand accounts, and unused balances of advances) to public securities with a minimum maturity of 60 days issued by the Argentine Treasury in primary offerings;
• Communication “A” 8350 which established, effective November 1, 2025, an amendment to the method for calculating compliance with the minimum cash requirement in Pesos—moving to a measurement based on the monthly average of the daily balances of eligible items recorded during the applicable period—and further provided that, as from such date, financial institutions must comply with a daily minimum cash requirement in Pesos, determined as the sum of the balances of eligible items recorded at each day’s close, which may not be lower than 95% of the total minimum cash requirement for the period; and
• Communication “A” 8355, which: (i) as of December 1, 2025, removes the additional 3.5 percentage point reserve requirement on certain demand deposits and investments (including money market mutual funds, reverse repos, and securities lending) previously imposed by Communication “A” 8306; (ii) increases for the liabilities in Pesos, from the same date, the possibility of meeting up to 3.5 percentage points of the minimum cash requirement with government securities issued by the National Treasury (acquired through primary subscription as of August 25, 2025, and with a minimum term of 60 days); (iii) reduces the daily minimum integration of the Peso cash requirement from 95% to 75%, effective December 1, 2025; and (iv) extends until March 31, 2026, the additional 5 percentage point requirement, imposed by Communication “A” 8302, for Group A entities and certain G-SIB branches/subsidiaries, which applies to certain demand deposits and other specified instruments (this requirement may also be met with the aforementioned government securities).
• Communication “A” 8410, dated March 19, 2026, which provides that, until December 31, 2026, financial institutions holding prior authorization from the Central Bank may distribute profits in three equal, non-cumulative monthly installments, beginning on the third business day of May 2026 and of each month in which a payment is made; establishes that the total distributable amount may not exceed 60% of the net income for fiscal year 2025, net of the amounts corresponding to the legal and statutory reserves — recorded as of the same date — whose constitution is required; and further requires that any such distribution be consistent with the information reported under the “Business Plan and Projections and Capital Self-Assessment Report” reporting regime.
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C. Organizational Structure
Subsidiaries and controlled entities
We have eight subsidiaries and controlled entities: (i) Macro Securities, which is a member of the BYMA, and through which we provide investment research, securities trading and custodial services to our customers; (ii) Macro Fiducia, a subsidiary that acts as trustee and provides financial advisory and analysis services; (iii) Macro Fondos, an asset management subsidiary,;(iv) Macro Bank Limited, our subsidiary in the Bahamas through which we primarily provide private banking services; (v) Macro Agro S.A.U., which facilitates access to credit for SMEs by granting guarantees; (vi) Argenpay S.A.U., through which we provide electronic payment services ; (vii) Fintech S.G.R., which facilitates access to credit for micro, small and medium-sized enterprises; and (viii) Alianza S.G.R., which grants guarantees.
Banco Macro’s direct and indirect interest
Subsidiary / controlled entity Percentage of Capital Stock Percentage of possible votes
Macro Securities S.A.U.(1) 100.000 % 100.000 %
Macro Fiducia S.A.U.(1) 100.000 % 100.000 %
Macro Fondos S.G.F.C.I. S.A.(1) 100.000 % 100.000 %
Macro Bank Limited(2) 100.000 % 100.000 %
Macro Agro S.A.U.(1) 100.000 % 100.000 %
Argenpay S.A.U.(1) 100.000 % 100.000 %
Fintech S.G.R.(1)(3) 24.999 % 24.999 %
Alianza S.G.R.(1) 24.998 % 24.998 %
Notes:-
(1) Jurisdiction of incorporation: Argentina
(2) Jurisdiction of incorporation: The Bahamas
(3) Structured entity.
D. Property, plants and equipment
Property
Our headquarters consist of 54,971 square meters of office area that we own at Avenida Eduardo Madero 1172, Alem 1110 1st floor, and Juana Manso 555, 1A, 8B, and 9B, in the City of Buenos Aires, and are used by our management, accounting, technology, and administrative personnel. As of December 31, 2025, we have a branch network that consists of 444 branches in Argentina, of which 145 are leased properties.
Our corporate headquarters were designed to take full advantage of natural light and maximize energy efficiency, while also using materials that do not adversely affect the environment, and were built in compliance with the LEED International Sustainability Standards of the “U.S. Green Building Council.” The building has its own environmental policy and an intelligent energy system; it has a state-of-the-art architectural design that prioritizes energy efficiency in accordance with the standards of the LEED sustainable building certification system. In addition to energy efficiency, the tower has a construction mechanism that manages to reduce water consumption through the reuse and controlled use of inputs, thus being considered a building with sustainable criteria and optimization of the use of resources.
Thanks to the process initiated in previous years, during 2022 Banco Macro received the LEED certification for the “Banco Macro Corporate Headquarters,” achieving the LEED GOLD certificate with 64 points.
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With the objective of advancing towards new international certifications, we engaged specialized consultants to assess the feasibility of obtaining WELL certification. To this end, the technical team conducted a Performance Test (June 2025) and a Feasibility Study (October 2025), the results of which confirmed that Torre Macro has a concrete likelihood of meeting the required credits to obtain such certification. Implementation of the certification process is subject to approval during the 2026 fiscal year.
Selected Statistical Information
The following information is included for analytical purposes and should be read in conjunction with our audited consolidated financial statements as well as Item 5 “Operating and Financial Review and Prospects.” This information has been extracted from our internal documentation that supports our financial records.
Average balance sheets, interest earned on interest-earning assets and interest paid on interest-bearing liabilities.
The following tables show average balances, interest amounts and nominal and real rates for our interest-earning assets and interest-bearing liabilities for the years ended December 31, 2025, 2024, and 2023 based on results adjusted for inflation as of December 31, 2025, as explained in our audited consolidated financial statement.
The nominal interest rate has been calculated by dividing the amount of interest gain or loss during the period by the related average balance, both amounts not restated. The nominal rates calculated for each period have been converted into real rates using the following formulas:
Where:
Rp = real average rate for Peso-denominated assets and liabilities (in Ps.) for the period;
Rd = real average rate for foreign currency denominated assets and liabilities for the period;
Np = nominal average rate for Peso-denominated assets and liabilities for the period;
Nd = nominal average rate for foreign currency denominated assets and liabilities for the period;
D = devaluation rate of the Peso to the U.S. dollar for the period; and
I = inflation rate in Argentina for the period based on the variation of the Consumer Price Index.
2025 2024(1) 2023(1)
Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate
(In thousands of Pesos)
ASSETS
Interest-earning assets
Cash and Deposits in Banks
Pesos — — 0.00 % 0.00 % — — 0.00 % 0.00 % — — 0.00 % 0.00 %
Foreign currency 601,403,361 17,042,902 7.18 % 2.83 % 612,014,165 21,225,033 -24.34 % 3.47 % 658,829,851 19,615,682 50.94 % 2.98 %
Total 601,403,361 17,042,902 7.18 % 2.83 % 612,014,165 21,225,033 -24.34 % 3.47 % 658,829,851 19,615,682 50.94 % 2.98 %
Loans and other financing Non-financial Public Sector
Pesos 121,813,508 52,261,142 -38.29 % 42.90 % 38,555,410 17,572,206 -53.25 % 45.58 % 60,293,002 54,802,878 -38.70 % 90.89 %
Foreign currency 0 0 0.00 % 0.00 % 13 0 0.00 % 0.00 % 0 0 0.00 % 0.00 %
Total 121,813,508 52,261,142 -38.29 % 42.90 % 38,555,423 17,572,206 -53.25 % 45.58 % 60,293,002 54,802,878 -38.70 % 90.89 %
Other Financial Entities
Pesos 97,057,229 28,683,654 -44.05 % 29.55 % 45,430,566 10,175,844 -60.69 % 22.40 % 26,150,362 9,309,342 -56.46 % 35.60 %
Foreign currency 1,886,740 164,134 13.30 % 8.70 % 1,659,960 126,929 -21.28 % 7.65 % 3,977,471 92,256 49.97 % 2.32 %
Total 98,943,969 28,847,788 -42.96 % 29.16 % 47,090,526 10,302,773 -59.30 % 21.88 % 30,127,833 9,401,598 -42.41 % 31.21 %
Non-financial Private Sector and Foreign Residents
Pesos 7,182,363,920 3,380,568,923 -36.48 % 47.07 % 4,370,966,661 2,635,930,253 -48.52 % 60.31 % 5,282,622,310 3,173,474,435 -48.60 % 60.07 %
Foreign currency 2,204,827,644 149,134,204 11.28 % 6.76 % 991,323,176 104,657,050 -19.16 % 10.56 % 411,887,501 11,698,747 50.74 % 2.84 %
Total 9,387,191,564 3,529,703,127 -25.26 % 37.60 % 5,362,289,837 2,740,587,303 -43.09 % 51.11 % 5,694,509,811 3,185,173,182 -41.41 % 55.93 %
Other Debt Securities
Pesos 3,988,169,370 1,359,811,434 -42.09 % 34.10 % 2,308,604,513 1,447,935,608 -47.75 % 62.72 % 3,882,764,606 3,147,716,101 -41.85 % 81.07 %
Foreign currency 107,490,392 5,057,820 9.14 % 4.71 % 110,661,777 8,180,198 -21.47 % 7.39 % 373,302,099 27,083,171 57.21 % 7.26 %
Total 4,095,659,762 1,364,869,254 -40.75 % 33.32 % 2,419,266,290 1,456,115,806 -46.55 % 60.19 % 4,256,066,705 3,174,799,272 -33.16 % 74.59 %
Repo Transactions
Pesos 27,530,346 12,781,269 -36.76 % 46.43 % 485,472,150 391,599,824 -41.99 % 80.66 % 799,135,530 564,096,983 -45.22 % 70.59 %
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2025 2024(1) 2023(1)
Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate
(In thousands of Pesos)
Foreign currency — — 0.00 % 0.00 % — — 0.00 % 0.00 % 3,108,802 6,142 46.87 % 0.20 %
Total 27,530,346 12,781,269 -36.76 % 46.43 % 485,472,150 391,599,824 -41.99 % 80.66 % 802,244,332 564,103,125 -44.86 % 70.32 %
Total interest-earning assets
Pesos 11,416,934,373 4,834,106,422 -38.53 % 42.34 % 7,249,029,300 4,503,213,735 -47.94 % 62.12 % 10,050,965,810 6,949,399,739 -45.69 % 69.14 %
Foreign currency 2,915,608,137 171,399,060 10.36 % 5.88 % 1,715,659,091 134,189,210 -21.16 % 7.82 % 1,451,105,724 58,495,998 52.48 % 4.03 %
Total 14,332,542,510 5,005,505,482 -28.58 % 34.92 % 8,964,688,391 4,637,402,945 -42.81 % 51.73 % 11,502,071,534 7,007,895,737 -33.30 % 60.93 %
Total non interest-earning assets
Pesos 4,082,207,143 — — — 6,170,267,877 — — — 2,654,914,878 — — —
Foreign currency 2,087,831,654 — — — 2,657,917,714 — — — 5,258,349,888 — — —
Total 6,170,038,797 — — — 8,828,185,591 — — — 7,913,264,766 — — —
TOTAL ASSETS
Pesos 15,499,141,516 — — — 13,419,297,177 — — — 12,705,880,688 — — —
Foreign currency 5,003,439,791 — — — 4,373,576,805 — — — 6,709,455,612 — — —
Total 20,502,581,307 — — — 17,792,873,982 — — — 19,415,336,300 — — —
LIABILITIES
Interest-bearing liabilities
Deposits
Non financial Public Sector
Pesos 411,514,662 138,042,556 -42.33 % 33.54 % 489,155,643 258,936,076 -50.89 % 52.94 % 450,880,526 354,540,807 -42.64 % 78.63 %
Foreign currency 98,967,999 2,742,266 7.12 % 2.77 % 27,362,240 385,898 -25.85 % 1.41 % 32,085,039 25,177 46.69 % 0.08 %
Total 510,482,661 140,784,822 -32.74 % 27.58 % 516,517,883 259,321,974 -49.56 % 50.21 % 482,965,565 354,565,984 -36.71 % 73.41 %
Non financial Private Sector and Foreign Residents
Pesos 6,050,874,243 1,660,898,520 -44.96 % 27.45 % 4,966,075,589 2,152,183,620 -53.97 % 43.34 % 6,999,901,609 4,177,914,869 -48.72 % 59.69 %
Foreign currency 2,853,574,471 26,072,841 5.18 % 0.91 % 1,744,100,837 2,382,086 -26.78 % 0.14 % 1,352,645,217 385,903 46.62 % 0.03 %
Total 8,904,448,714 1,686,971,361 -28.89 % 18.95 % 6,710,176,426 2,154,565,706 -46.90 % 32.11 % 8,352,546,826 4,178,300,772 -33.28 % 50.02 %
Financing received from the BCRA and other financial institutions
Pesos 2,154,925 3,071,649 4.75 % 142.54 % 10,417,850 21,665,786 -1.10 % 207.97 % 16,036,081 24,582,547 -18.66 % 153.30 %
Foreign currency 95,491,991 4,806,104 9.47 % 5.03 % 36,173,251 2,064,447 -22.70 % 5.71 % 48,259,987 1,912,554 52.38 % 3.96 %
Total 97,646,916 7,877,753 9.37 % 8.07 % 46,591,101 23,730,233 -17.87 % 50.93 % 64,296,068 26,495,101 34.66 % 41.21 %
Issued Corporate Bonds
Pesos 12,169,526 4,557,335 -40.64 % 37.45 % 17,432,785 17,473,885 -35.70 % 100.24 % 16,095,846 3,325,701 -61.25 % 20.66 %
Foreign currency 384,830,545 32,497,975 13.03 % 8.44 % 75,491,011 3,979,142 -23.02 % 5.27 % 35,012,354 1,407,212 52.47 % 4.02 %
Total 397,000,071 37,055,310 11.38 % 9.33 % 92,923,796 21,453,027 -25.40 % 23.09 % 51,108,200 4,732,913 16.66 % 9.26 %
Subordinated Corporate Bonds
Pesos — — — — — — — — — — — —
Foreign currency 568,417,904 36,261,152 10.88 % 6.38 % 608,348,995 38,713,239 -22.23 % 6.36 % 613,177,097 40,622,398 56.28 % 6.62 %
Total 568,417,904 36,261,152 10.88 % 6.38 % 608,348,995 38,713,239 -22.23 % 6.36 % 613,177,097 40,622,398 56.28 % 6.62 %
Repo Transactions ,
Pesos 32,216,147 21,508,859 -27.98 % 66.76 % 15,280,475 10,876,608 -45.03 % 71.18 % 36,023,634 39,743,187 -32.46 % 110.33 %
Foreign currency — — — — — — — — — — — —
Total 32,216,147 21,508,859 -27.98 % 66.76 % 15,280,475 10,876,608 -45.03 % 71.18 % 36,023,634 39,743,187 -32.46 % 110.33 %
Total interest-bearing liabilities
Pesos 6,508,929,503 1,828,078,919 -44.68 % 28.09 % 5,498,362,342 2,461,135,975 -53.51 % 44.76 % 7,518,937,696 4,600,107,111 -48.24 % 61.18 %
Foreign currency 4,001,282,910 102,380,338 6.90 % 2.56 % 2,491,476,334 47,524,812 -25.48 % 1.91 % 2,081,179,694 44,353,244 49.69 % 2.13 %
Total 10,510,212,413 1,930,459,257 -25.04 % 18.37 % 7,989,838,676 2,508,660,787 -44.77 % 31.40 % 9,600,117,390 4,644,460,355 -27.01 % 48.38 %
Total non–interest bearing liabilities and shareholders’ equity
Pesos 8,854,169,564 8,662,267,107 8,783,867,929
Foreign currency 1,138,199,330 1,140,768,199 1,031,350,981
Total 9,992,368,894 9,803,035,306 9,815,218,910
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2025 2024(1) 2023(1)
Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate Average Balance Interest Earned / (Paid) Average Real Rate Average Nominal Rate
(In thousands of Pesos)
TOTAL LIABILITIES AND SHAREHOLDERS’ EQUITY
Pesos 15,363,099,067 — — — 14,160,629,449 — — — 16,302,805,625 — — —
Foreign currency 5,139,482,240 — — — 3,632,244,533 — — — 3,112,530,675 — — —
Total 20,502,581,307 — — — 17,792,873,982 — — — 19,415,336,300 — — —
Note:-
(1) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial information.”
Changes in interest income and interest expense; volume and rate analysis
The following tables allocate, by currency of denomination, changes in our interest income and interest expense segregated for each major category of interest-earning assets and interest-bearing liabilities into amounts attributable to changes in their average volume and their respective nominal interest rates for fiscal year ended December 31, 2025 compared to the fiscal year ended December 31, 2024 and to the fiscal year ended December 31, 2023, all based on information adjusted for inflation as of December 31, 2025.
2025 2024(1) 2023(1) December 2025/ December 2024 Increase (Decrease) Due to Changes in December 2024 / December 2023 Increase (Decrease) Due to Changes in
Interest Earned / (Paid) Volume Rate Net Change Volume Rate Net Change
(in thousand of Pesos)
ASSETS
Interest-earning assets
Cash and Deposits in Banks
Pesos — — — — — — — — —
Foreign currency 17,042,902 21,225,033 19,615,682 (356,336 ) (3,825,795 ) (4,182,131 ) (1,377,660 ) 2,987,011 1,609,351
Total 17,042,902 21,225,033 19,615,682 (356,336 ) (3,825,795 ) (4,182,131 ) (1,377,660 ) 2,987,011 1,609,351
Loans and other financing Non-financial Public Sector
Pesos 52,261,142 17,572,206 54,802,878 37,950,391 (3,261,455 ) 34,688,936 (19,759,866 ) (17,470,806 ) (37,230,672 )
Foreign currency — — — — — — — — —
Total 52,261,142 17,572,206 54,802,878 37,950,391 (3,261,455 ) 34,688,936 (19,759,866 ) (17,470,806 ) (37,230,672 )
Other Financial Entities
Pesos 28,683,654 10,175,844 9,309,342 11,564,975 6,942,835 18,507,810 6,863,939 (5,997,437 ) 866,502
Foreign currency 164,134 126,929 92,256 17,407 19,798 37,205 (53,745 ) 88,418 34,673
Total 28,847,788 10,302,773 9,401,598 11,582,382 6,962,633 18.545.015 6,810,194 (5,909,019 ) 901,175
Non-financial Private Sector and Foreign Residents
Pesos 3,380,568,923 2,635,930,253 3,173,474,435 1,695,753,427 (951,114,757 ) 744,638,670 (547,834,762 ) 10,290,580 (537,544,182 )
Foreign currency 149,134,204 104,657,050 11,698,747 128,172,749 (83,695,595 ) 44,477,154 16,454,831 76,503,472 92,958,303
Total 3,529,703,127 2,740,587,303 3,185,173,182 1,823,926,176 (1,034,810,352 ) 789,115,824 (531,379,931 ) 86,794,052 (444,585,879 )
Other Debt Securities
Pesos 1,359,811,434 1,447,935,608 3,147,716,101 1,053,444,221 (1,141,568,395 ) (88,124,174 ) (1,276,130,422 ) (423,650,071 ) (1,699,780,493 )
Foreign currency 5,057,820 8,180,198 27,083,171 (236,658 ) (2,885,720 ) (3,122,378 ) (19,049,126 ) 146,153 (18,902,973 )
Total 1,364,869,254 1,456,115,806 3,174,799,272 1,053,207,563 (1,144,454,115 ) (91,246,552 ) (1,295,179,548 ) (423,503,918 ) (1,718,683,466 )
Repo Transactions
Pesos 12,781,269 391,599,824 564,096,983 (369,393,847 ) (9,424,708 ) (378,818,555 ) (221,402,192 ) 48,905,033 (172,497,159 )
Foreign currency — — 6,142 — — — (6,142 ) — (6,142 )
Total 12,781,269 391,599,824 564,103,125 (369,393,847 ) (9,424,708 ) (378,818,555 ) (221,408,334 ) 48,905,033 (172,503,301 )
Total interest-earning assets
Pesos 4,834,106,422 4,503,213,735 6,949,399,739 2,429,319,167 (2,098,426,480 ) 30,892,687 (2,058,263,303 ) (387,922,701 ) (2,446,186,004 )
Foreign currency 171,399,060 134,189,210 58,495,998 127,597,162 (90,387,312 ) 37,209,850 (4,031,842 ) 79,725,054 75,693,212
Total 5,005,505,482 4,637,402,945 7,007,895,737 2,556,916,329 (2,188,813,792 ) 368,102,537 (2,062,295,145 ) (308,197,647 ) (2,370,492,792 )
LIABILITIES
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2025 2024(1) 2023(1) December 2025/ December 2024 Increase (Decrease) Due to Changes in December 2024 / December 2023 Increase (Decrease) Due to Changes in
Interest Earned / (Paid) Volume Rate Net Change Volume Rate Net Change
(in thousand of Pesos)
Interest-bearing liabilities
Deposits
Non financial Public Sector
Pesos 138,042,556 258,936,076 354,540,807 (41,080,214 ) (79,813,306 ) (120,893,520 ) 30,082,275 (125,687,006 ) (95,604,731 )
Foreign currency 2,742,266 385,898 25,177 1,009,551 1,346,817 2,356,368 (3,287 ) 364,008 360,721
Total 140,784,822 259,321,974 354,565,984 (40,070,663 ) (78,466,489 ) (118,537,152 ) 30,078,988 (125,322,998 ) (95,244,010 )
Non financial Private Sector and Foreign Residents
Pesos 1,660,898,520 2,152,183,620 4,177,914,869 470,265,277 (961,550,377 ) (491,285,100 ) (1,213,664,350 ) (812,066,899 ) (2,025,731,249 )
Foreign currency 26,072,841 2,382,086 385,903 1,612,918 22,077,837 23,690,755 137,327 1,858,856 1,996,183
Total 1,686,971,361 2,154,565,706 4,178,300,772 471,878,195 (939,472,540 ) (467,594,345 ) (1,213,527,023 ) (810,208,043 ) (2,023,735,066 )
Financing received from the Central Bank of Argentina and other financial institutions — — —
Pesos 3,071,649 21,665,786 24,582,547 (17,184,188 ) (1,409,949 ) (18,594,137 ) (8,611,983 ) 5,695,222 (2,916,761 )
Foreign currency 4,806,104 2,064,447 1,912,554 3,388,146 (646,489 ) 2,741,657 (480,093 ) 631,986 151,893
Total 7,877,753 23,730,233 26,495,101 (13,796,042 ) (2,056,438 ) (15,852,480 ) (9,092,076 ) 6,327,208 (2,764,868 )
Issued Corporate Bonds
Pesos 4,557,335 17,473,885 3,325,701 (5,275,152 ) (7,641,398 ) (12,916,550 ) 275,912 13,872,272 14,148,184
Foreign currency 32,497,975 3,979,142 1,407,212 16,301,428 12,217,405 28,518,833 1,627,527 944,403 2,571,930
Total 37,055,310 21,453,027 4,732,913 11,026,276 4,576,007 15,602,283 1,903,439 14,816,675 16,720,114
Subordinated Corporate Bonds
Pesos — — — — — — — — —
Foreign currency 36,261,152 38,713,239 40,622,398 (2,561,860 ) 109,773 (2,452,087 ) (349,695 ) (1,559,464 ) (1,909,159 )
Total 36,261,152 38,713,239 40,622,398 (2,561,860 ) 109,773 (2,452,087 ) (349,695 ) (1,559,464 ) (1,909,159 )
Repo Transactions
Pesos 21,508,859 10,876,608 39,743,187 12,054,845 (1,422,594 ) 10,632,251 (22,884,239 ) (5,982,340 ) (28,866,579 )
Foreign currency — — — — — — — — —
Total 21,508,859 10,876,608 39,743,187 12,054,845 (1,422,594 ) 10,632,251 (22,884,239 ) (5,982,340 ) (28,866,579 )
Total interest-bearing liabilities
Pesos 1,828,078,919 2,461,135,975 4,600,107,111 418,780,568 (1,051,837,624 ) (633,057,056 ) (1,214,802,385 ) (924,168,751 ) (2,138,971,136 )
Foreign currency 102,380,338 47,524,812 44,353,244 19,750,183 35,105,343 54,855,526 931,779 2,239,789 3,171,768
Total 1,930,459,257 2,508,660,787 4,644,460,355 438,530,751 (1,016,732,281 ) (578,201,530 ) (1,213,870,606 ) (921,928,962 ) (2,135,799,568 )
Note:-
(1) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial information.”
Interest-earning assets: net interest margin and spread
The following table analyzes, by currency of denomination, the levels of our average interest-earning assets and net interest income and illustrates the comparative margins and spreads for each of the years indicated all based on information adjusted for inflation as of December 31, 2025.
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Year Ended December 31,
2025 2024(1) 2023(1)
(in thousands of Pesos, except percentages)
Average interest-earning assets
Pesos 11,416,934,373 7,249,029,300 10,050,965,810
Foreign currency 2,915,608,137 1,715,659,091 1,451,105,724
Total 14,332,542,510 8,964,688,391 11,502,071,534
Net interest income(2)
Pesos 3,006,027,503 2,042,077,760 2,349,292,628
Foreign currency 69,018,722 86,664,398 14,142,754
Total 3,075,046,225 2,128,742,158 2,363,435,382
Net interest margin(3)
Pesos (59.43 %) (58.84 %) (36.66 %)
Foreign currency (25.15 %) (23.18 %) (10.64 %)
Weighted average rate (52.46 %) (52.02 %) (33.38 %)
Yield spread real basis(4)
Pesos 6.15 % 5.57 % 2.55 %
Foreign currency 3.46 % 4.32 % 2.79 %
Weighted average rate (3.54 %) 1.95 % (6.29 %)
Notes:-
(1) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial information.”
(2) Defined as interest earned less interest paid.
(3) Calculated by dividing the amount of net interest income/(loss) by the interest-earning assets. The nominal rates calculated for each period have been converted into real rates using the formulas disclosed in “Item 4. Selected Statistical Information—Average balance sheet, interest earned on interest-earning assets and interest paid on interest-bearing liabilities.”
(4) Defined as the difference between the average real rate on interest-earning assets and the average real rate on interest-bearing liabilities.
Remaining maturity of government and private securities
We own, manage and trade a portfolio of securities issued by the Argentine and other governments and private issuers. The following table analyzes the remaining maturities of our investment portfolio as of December 31, 2025 in accordance with issuance terms (before allowances). For further information, see “Item 3—Risk Factors—Argentina’s ability to obtain financing from international markets may be limited or costly, which may impair its ability to implement reforms and public policies and foster economic growth.”
Maturity date Maturing within 1 year Maturing after 1 year but within 5 years Maturing after 5 year but within 10 years Maturing after 10 years Without due date Total
Book Value (in thousands of Pesos, except percentages)
DEBT SECURITIES AT FAIR VALUE THROUGH PROFIT OR LOSS
Local
Government securities:
Argentine Treasury Bonds in Pesos at dual rate 09/15/2026 175,222,819 — — — — 175,222,819
Argentine Treasury Bonds in Pesos at dual rate 06/30/2026 145,650,166 — — — — 145,650,166
Argentine Treasury Bonds in Pesos at dual rate 12/15/2026 125,991,253 — — — — 125,991,253
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Maturity date Maturing within 1 year Maturing after 1 year but within 5 years Maturing after 5 year but within 10 years Maturing after 10 years Without due date Total
Book Value (in thousands of Pesos, except percentages)
Argentine Treasury Bonds in Pesos at dual rate 03/16/2026 122,427,407 — — — — 122,427,407
Argentine Treasury Bills in Pesos TAMAR 08/31/2026 39,074,708 — — — — 39,074,708
Argentine Treasury Bonds capitalizable in Pesos 02/13/2026 37,398,950 — — — — 37,398,950
Argentine Treasury Bills in Pesos TAMAR 04/30/2026 27,196,354 — — — — 27,196,354
Argentine Treasury Bonds at a discount in Pesos adjusted by CER 12/15/2026 24,787,126 — — — — 24,787,126
Argentine Treasury Bonds at a discount in Pesos adjusted by CER 12/15/2027 — 24,546,500 — — — 24,546,500
Argentine Treasury Bonds at a discount in Pesos adjusted by CER 03/31/2026 22,213,684 — — — — 22,213,684
Others 93,888,345 41,381,391 19,003,198 5,998,385 — 160,271,319
Subtotal local government securities 813,850,812 65,927,891 19,003,198 5,998,385 — 904,780,286
Private securities:
Corporate Bonds YPF SA C043 02/16/2032 — 2,542,777 5,162,610 — — 7,705,387
Corporate Bonds PSA Finance Argentina C034 12/19/2027 — 6,312,268 — — — 6,312,268
Corporate Bonds John Deere Credit Cía. Financiera SA C013 01/04/2026 5,573,667 — — — — 5,573,667
Corporate Bonds Tecpetrol SA C012 11/03/2030 — 4,824,917 — — — 4,824,917
Corporate Bonds Vista Energy Argentina SAU C29 06/10/2033 — — 4,341,029 — — 4,341,029
Corporate Bonds Transportadora de Gas del Sur SA C003 07/24/2031 — — 3,706,794 — — 3,706,794
Corporate Bonds YPF SA C030 07/01/2026 3,526,047 — — — — 3,526,047
Corporate Bonds Cresud S24 C38 03/03/2026 3,434,367 — — — — 3,434,367
Corporate Bonds Vista Energy Argentina SAU C29 Additional 06/10/2033 — — 2,984,714 — — 2,984,714
Corporate Bonds Genneia SA C049 12/02/2033 — — 2,924,954 — — 2,924,954
Others 16,710,192 11,913,154 11,821,943 516,786 — 40,962,075
Subtotal local private securities 29,244,273 25,593,116 30,942,044 516,786 — 86,296,219
TOTAL DEBT SECURITIES AT FAIR VALUE THROUGH PROFIT OR LOSS(1) 843,095,085 91,521,007 49,945,242 6,515,171 — 991,076,505
OTHER DEBT SECURITIES
MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME
Local:
Government securities
Argentine Bonds US dollar Step-up 07/09/2030 9,760 39,048 — — — 48,808
Subtotal local government securities(2) 9,760 39,048 — — — 48,808
Foreign:
Government securities
US Treasury bills 01/06/2026 65,648,357 — — — — 65,648,357
US Treasury bills 01/13/2026 30,614,694 — — — — 30,614,694
US Treasury bills 01/15/2026 14,575,405 — — — — 14,575,405
US Treasury bills 01/27/2026 7,279,120 — — — — 7,279,120
Subtotal foreign government securities 118,117,576 — — — — 118,117,576
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Maturity date Maturing within 1 year Maturing after 1 year but within 5 years Maturing after 5 year but within 10 years Maturing after 10 years Without due date Total
Book Value (in thousands of Pesos, except percentages)
TOTAL OTHER DEBT SECURITIES MEASURED AT FAIR VALUE THROUGH OTHER COMPREHENSIVE INCOME 118,127,336 39,048 — — — 118,166,384
Weighted average rate 2.73 % 9.63 % —
MEASURED AT AMORTIZED COST
Local
Government securities:
Argentine Treasury Bonds at a discount in pesos adjusted by CER 06/30/2027 — 3,242,092,349 — — — 3,242,092,349
Argentine Treasury Bills in Pesos TAMAR 01/16/2026 437,664,436 — — — — 437,664,436
Argentine Treasury Bills in Pesos TAMAR 08/31/2026 290,547,385 — — — — 290,547,385
Argentine Treasury Bills in Pesos TAMAR 04/30/2026 257,995,575 — — — — 257,995,575
Argentine Treasury Bonds in Pesos 05/23/2026 10,662,191 10,662,190 — — — 21,324,381
Province of Buenos Aires Debt Securities variable rate 12/05/2027 11,014,718 — — — — 11,014,718
Province of Córdoba Debt Securities in Pesos C04 12/05/2027 — 9,447,631 — — — 9,447,631
Discount Bonds in Pesos 5.83% 12/31/2033 866,163 3,464,636 2,598,477 — — 6,929,276
Argentine Treasury Bonds in Pesos BADLAR x0.7 11/23/2027 3,080,001 3,080,002 — — — 6,160,003
Municipality of Córdoba Government Securities S51 02/13/2027 5,101,631 — — — 5,101,631
Others 2,810,384 3,754,808 — — — 6,565,192
Subtotal local government securities(3) 1,014,640,853 3,277,603,247 2,598,477 — — 4,294,842,577
Private securities
Corporate Bonds Newsan SA C022 05/15/2026 2,173,930 — — — — 2,173,930
Fiduciary Debt Securities Megabond Financial Trust S316 CL.A 03/01/2027 — 390,781 — — — 390,781
Fiduciary Debt Securities Secubono Financial Trust S243 CL.A 04/28/2026 238,642 — — — — 238,642
Fiduciary Debt Securities Secubono Financial Trust S242 CL.A 03/30/2026 15,629 — — — — 15,629
Subtotal local Private securities 2,428,201 390,781 — — — 2,818,982
TOTAL OTHER DEBT SECURITIES MEASURED AT AMORTIZED COST(3) 1,017,069,054 3,277,994,028 2,598,477 — — 4,297,661,559
Weighted average rate 3.57 % 7.09 % 8.26 % — — —
EQUITY INSTRUMENTS MEASURED AT FAIR VALUE THROUGH PROFIT OR LOSS
Local
A3 Mercados SA (former Mercado Abierto Electrónico SA) — — — — 25,827,906 25,827,906
C.O.E.L.S.A. — — — — 3,083,093 3,083,093
Sedesa — — — — 317,923 317,923
AC Inversora SA — — — — 207,724 207,724
Rofex Inversora SA — — — — 239,127 239,127
Pampa Energía SA — — — — 8,621 8,621
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Maturity date Maturing within 1 year Maturing after 1 year but within 5 years Maturing after 5 year but within 10 years Maturing after 10 years Without due date Total
Book Value (in thousands of Pesos, except percentages)
Bolsas y Mercados Argentinos — — — — 5,815 5,815
Tienda Campo Simple SA — — — — 5,382 5,382
Argencontrol SA — — — — 4,388 4,388
Others — — — — 447 447
Subtotal local — — — — 29,700,426 29,700,426
Foreign
Banco Latinoamericano de Comercio Exterior SA — — — — 475,385 475,385
Sociedad de Telecomunicaciones Financieras Interbancarias Mundiales — — — — 59,780 59,780
Subtotal foreign — — — — 535,165 535,165
TOTAL EQUITY INSTRUMENTS AT FAIR VALUE THROUGH PROFIT OR LOSS — — — — 30,235,591 30,235,591
Notes:-
(1) In August 2024, we entered into voluntary debt exchange under the terms of section 11, Presidential Decree No. 331/2022 issued by the Ministry of Economy. The securities involved in such exchange transactions were as follows:
• Argentine Treasury bonds in Pesos adjusted by CER 4.25%—Maturity 02-14-2025 (T2X5) for a face value of Ps. 2,000,000,000.
Additionally, in January 2025, under the terms of section 2, Presidential Decree No. 846/2024 issued by the Ministry of Economy, we entered into voluntary debt exchange. The security involved in such exchange transaction was as follows:
• Argentine Treasury bonds in Pesos zero coupon adjusted by CER—Maturity 06-30-2025 (TZX25) for a face value of Ps. 201,356,504,100.
(2) In February 2025, under the terms of section 2, Presidential Decree No. 846/2024 issued by the Ministry of Economy, the Bank entered into voluntary debt exchange. The security involved in such exchange transaction was as follows:
• Argentine Treasury bonds in Pesos adjusted by CER 4.25%—Maturity 02-14-2025 (T2X5) for a face value of Ps. 28,282,779,133
(3) The holding at amortized cost includes Argentine Treasury bonds in Pesos adjusted by CER—Maturity 06-30-2027 acquired in the first quarter of 2024 through primary subscription. In the third quarter of 2024, as a consequence of a reassessment of its monetary position, the Banks’s Management resolved to reduce the position of inflation-adjustable securities through the exercise of put options with the BCRA and to maintain the residual portfolio of the aforementioned security until maturity. On June 11, 2025, all options were rescinded as part of the rescission offer published through Central Bank Comunication “B” 12997.
Loans and other financing portfolio
The following table analyzes our loans and other financing portfolio by type as of December 31, 2025, 2024 and 2023. Due to IFRS 9, as of December 31, 2025, 2024, and 2023, we calculate the allowances included in our financial statements under expected credit losses approach. For further information see note 3 “Loss allowance for expected credit losses on credit exposures not measured at fair value through profit or loss” to our audited consolidated financial statements as of December 31, 2025 and 2024.
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As of December 31,
2025 2024(1) 2023(1)
(in thousands of Pesos)
To the non-financial government sector 228,468,387 92,000,704 13,511,799
To the financial sector(2) 117,691,168 83,089,000 28,578,300
To the non-financial private sector and foreign residents
Overdrafts(3) 1,516,312,714 693,832,643 762,245,767
Documents(4) 1,709,320,666 1,300,935,776 858,293,985
Mortgages loans 503,010,717 264,856,599 169,893,220
Pledged loans(5) 286,660,226 157,966,045 76,353,149
Consumer loans(6) 4,089,470,285 3,271,172,985 2,024,726,689
Other loans 2,062,399,807 1,349,591,636 926,700,059
Accrued Interest, adjustments, foreign exchange and quoted price differences receivables 736,341,253 593,191,588 630,514,366
Other financing 29,385,240 34,472,259 48,805,685
Less: Unearned discounts (63,213,034 ) (46,824,887 ) (133,143,366 )
Less: Allowances (507,532,406 ) (162,271,441 ) (153,685,227 )
Total Loans and other financing 10,708,315,023 7,632,012,907 5,252,794,426
Notes:-
(1) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial and other information.”
(2) Includes loans to financial institutions, inter-financing (granted call) and other financing to Argentine financial institutions.
(3) Includes overdraft lines of credit resulting from checking accounts.
(4) Includes the face values of drafts, promissory notes and other bills transferred to us by endorsement for which the assignor is liable, whenever the latter is part of the non-financial private sector.
(5) Includes the principal amounts actually lent of automobile and other collateral granted, for which the obligor is part of the non-financial private sector and productive investment loans.
(6) Includes personal loans, credit card loans and other consumer loans. Overdrafts to individuals are included under “Overdrafts.”
Maturity composition of the loans and other financing portfolio
The following table analyzes our loans and other financing portfolio as of December 31, 2025, by type and by the time remaining to maturity. Loans are stated before deduction of the allowance for loan losses. We expect most loans to be repaid at maturity in cash or through refinancing at market terms.
Maturity
Amount as of December 31, 2025 Within 1 Year After 1 Year but Within 5 Years After 5 Years but Within 15 Years After 15 Years
(in thousands of Pesos, except percentages)
To the non-financial government sector 228,468,387 126,670,891 101,797,496 — —
To the financial sector(1) 117,691,168 101,870,730 15,820,438 — —
To the non-financial private sector and foreign residents — — — — —
Overdrafts(2) 1,555,171,290 1,555,171,290 — — —
Documents(3) 1,699,582,957 1,643,580,851 56,002,106 — —
Mortgages loans 924,454,417 119,802,178 186,434,320 440,043,188 178,174,731
Pledged loans(4) 285,211,086 91,394,307 181,654,973 12,161,806 —
Consumer loans(5) 4,194,310,353 2,767,213,693 1,395,932,526 31,164,134 —
Other loans 2,181,698,682 1,649,382,612 469,772,141 47,353,101 15,190,828
Other financings 29,259,089 21,652,442 7,606,647 — —
Total Loans and other financing 11,215,847,429 8,076,738,994 2,415,020,647 530,722,229 193,365,559
Percentage of total loans and other financing portfolio 100 % 72 % 22 % 5 % 2 %
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Notes:-
(1) Includes loans to financial institutions, interfinancing (granted call) and other financing to Argentine financial institutions.
(2) Includes overdrafts lines of credit resulting from checking accounts.
(3) Includes the face value of drafts, promissory notes and other bills transferred to us by endorsement for which the assignor is liable, whenever the latter is part of the non-financial private sector.
(4) Includes the principal amount actually lent of automobile and other collateral granted, for which the obligor is part of the non-financial private sector and productive investment loans.
(5) Includes personal loans, credit card loans and other consumer loans. Overdrafts to individuals are included under “Overdrafts.”
Interest rate sensitivity of outstanding loans and other financing
The following table presents the interest rate sensitivity of our outstanding loans and other financing with maturities over one year as of December 31, 2025:
As of December 31, 2025
(in thousands of Pesos)
Loans and other financing with maturities over one year:
Variable rate
To the non-financial government sector 101,797,496
To the financial sector 15,816,894
To the non-financial private sector and foreign residents 999,514,864
Total 1,117,129,254
Fixed rate
To the non-financial government sector
To the financial sector 3,544
To the non-financial private sector and foreign residents 2,021,975,637
Total 2,021,979,181
Total Loans and other financing with maturities over one year 3,139,108,435
Loans and other financing with maturities of less than one year:
To the non-financial government sector 126,670,891
To the financial sector 101,870,730
To the non-financial private sector and foreign residents 7,848,197,373
Total loans and other financing with maturities of less than one year 8,076,738,994
Total Loans and other financing 11,215,847,429
Analysis of the allowance for loan and other financing losses
The allowances for the year 2025, 2024 and 2023 were calculated based on the ECL according to IFRS.
The table below sets forth the activity in the allowances for loan losses for the years ended December 31, 2025, 2024 and 2023:
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Commercial portfolio Consumer portfolio Total
(in thousands of Pesos)
ECL as of January 1, 2025 19,073,672 143,197,769 162,271,441
Assets originated or purchased 23,838,211 245,241,032 269,079,243
Assets derecognized or repaid (17,099,673 ) (100,768,815 ) (117,868,488 )
Variations(1) 4,168,044 384,337,163 388,505,207
Amounts Written Off (49,342 ) (110,521,480 ) (110,570,822 )
Monetary effects (6,100,572 ) (77,783,603 ) (83,884,175 )
As of December 31, 2025 23,830,340 483,702,066 507,532,406
Commercial portfolio Consumer portfolio Total
(in thousands of Pesos)(2)
ECL as of January 1, 2024 68,170,268 85,514,959 153,685,227
Assets originated or purchased 12,234,719 98,679,302 110,914,021
Assets derecognized or repaid (19,406,900 ) (14,435,081 ) (33,841,981 )
Variations(1) (4,502,045 ) 31,040,820 26,538,775
Amounts Written Off (402,554 ) (6,889,131 ) (7,291,685 )
Monetary effects (37,019,816 ) (50,713,100 ) (87,732,916 )
As of December 31, 2024 19,073,672 143,197,769 162,271,441
Commercial portfolio Consumer portfolio Total
(in thousands of Pesos)(2)
ECL as of January 1, 2023 18,232,784 79,917,807 98,150,591
Assets originated or purchased 58,841,107 47,241,876 106,082,983
Assets derecognized or repaid (8,058,130 ) (11,679,251 ) (19,737,381 )
Variations(1) 29,798,734 71,445,145 101,243,879
Amounts Written Off (1,383,240 ) (9,648,195 ) (11,031,435 )
Monetary effects (29,260,987 ) (91,762,423 ) (121,023,410 )
As of December 31, 2023 68,170,268 85,514,959 153,685,227
Notes:-
(1) Represent changes (increases and decreases) to the expected credit loss (ECL) allowance relating to loans and other financing transactions that remained outstanding from the opening of the fiscal period to the end of such period.
(2) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial and other information.”
In 2025, changes in expected credit loss (ECL) allowance were mainly driven by higher delinquency levels in our consumer portfolio during the period. In 2024 and 2023, changes in expected credit loss (ECL) allowance were mainly driven by growth in our loan portfolio.
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The table below presents a reconciliation of the credit loss expense recongnized for 2025, 2024 and 2023 to the line items in the ECL roll forward.
(in thousands of Pesos)
Credit loss expense on financial assets for the year ended December 31, 2025 538,422,387
Credit loss (gain) related to debt securities 279,775
Credit loss expense related to loans and other financing 538,142,612
ECL as of January 1, 2025 162,271,441
Movements of ECL that impact credit loss expense
Credit loss expense related to Asset originated or purchased(1) 269,079,243
Credit loss expense related to Asset derecognized or repaid(2) (112,637,187 )
Credit loss expense related to Asset held during the fiscal year(3) 328,546,555
Subtotal I Credit loss expense 484,988,611
Other movements of ECL that do not impact credit loss expense
Other Movements 54,727,351
Amounts Written Off(4) (110,570,822 )
Monetary Effects for balances (83,884,175 )
ECL as of December 31, 2025 507,532,406
Other charges to Credit loss expense
IAS 29 restatement for results 50,774,969
Charged off Loans(5) 2,371,732
Other Movements 7,300
Subtotal II Credit loss expense 53,154,001
Total Credit loss expenses related to loans and other financing (Subtotal I + Subtotal II) 538,142,612
Credit loss expense on financial assets for the year ended December 31, 2024 142,213,553
Credit loss (gain) related to debt securities (1,692,324 )
Credit loss expense related to loans and other financing 143,905,878
ECL as of January 1, 2024 153,685,227
Movements of ECL that impact credit loss expense
Credit loss expense related to Asset originated or purchased(1) 110,914,021
Credit loss expense related to Asset derecognized or repaid(2) (30,982,192 )
Credit loss expense related to Asset held during the fiscal year(3) 31,761,623
Subtotal I Credit loss expense 111,693,452
Other movements of ECL that do not impact credit loss expense
Other Movements (8,082,637 )
Amounts Written Off(4) (7,291,685 )
Monetary Effects for balances (87,732,916 )
ECL as of December 31, 2024 162,271,441
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(in thousands of Pesos)
Other charges to Credit loss expense
IAS 29 restatement for results 31,581,809
Charged off Loans(5) 630,616
Subtotal II Credit loss expense 32,212,425
Total Credit loss expenses related to loans and other financing (Subtotal I + Subtotal II) 143,905,878
Credit loss expense on financial assets for the year ended December 31, 2023 131,684,527
Credit loss (gain) related to debt securities 48,514
Credit loss expense related to loans and other financing 131,636,013
ECL as of January 1, 2023 98,150,592
Movements of ECL that impact credit loss expense
Credit loss expense related to Asset originated or purchased(1) 24,734,821
Credit loss expense related to Asset derecognized or repaid(2) (18,615,385 )
Credit loss expense related to Asset held during the fiscal year(3) 90,352,321
Subtotal I Credit loss expense 96,471,757
Other movements of ECL that do not impact credit loss expense
Other Movements 9,769,562
Amounts Written Off(4) (11,031,436 )
ECL derived from acquired subsidiaries during the year 81,348,162
Monetary Effects for balances (121,023,410 )
ECL as of December 31, 2023 153,685,227
Other charges to Credit loss expense
IAS 29 restatement for results 34,767,749
Charged off Loans(5) 396,506
Subtotal II Credit loss expense 35,164,256
Total Credit loss expenses related to loans and other financing (Subtotal I + Subtotal II) 131,636,013
Notes:-
(1) It includes the movements in the ECL allowance for assets purchased or originated during the period, which are recognized within the credit loss expense.
(2) It includes the movements in the ECL allowance for assets derecognized or repaid during the period.
(3) It includes changes (increases and decreases) to the ECL allowance related to loans and other financing transactions that remained outstanding from the opening of the fiscal period to the end of such period.
(4) Amounts Written Off: this term refers to the amounts of loans and other financing that are settled in part or in full against the ECL allowance. Write-offs occur after the first month in which the Bank has no reasonable expectations of recovering the financial instrument or a portion thereof. The amounts written off are managed by the Bank through off balance sheet accounts.
(5) Charged-off Loans: this term refers, to the increase in the credit loss expense recognized in the income statement for the period that does not impact the Expected Credit Loss (ECL) allowance, but instead directly reduces the loans and other financing balance. These charges arise from specific customer circumstances.
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As of December 31, 2025, the “Other movements”, which amounted to Ps. 54,727,351 thousand corresponds to loan portfolio sales and foreign exchange effects. These items impact the ECL allowance balance without affecting the credit loss expense.
As of December 31, 2024, the “Other movements”, which amounted to Ps. (8,082,637) thousand corresponds to loan portfolio sales and foreign exchange effects. These items impact the ECL allowance balance without affecting the credit loss expense.
As of December 31, 2023, the “Other movements”, which amounted to Ps. 9,769,562 thousand corresponds to balances derived from acquired subsidiaries during the year, loan portfolio sales and foreign exchange effects. These items impact the ECL allowance balance without affecting the credit loss expense.
The “Monetary Effects for balances” line item in the ECL rollforward presented above includes the impact of changes in the general price level on the ECL allowance balance, measured from the revaluation date to the closing date of each reporting period. This adjustment is calculated by applying a general price index to ensure that the comparative financial statements are presented in terms of the measuring unit current at the end of each reporting period, in accordance with IAS 29.
Ratio of net write-offs
The following table presents the ratio of net write-offs to average loans and other financing by category for the fiscal years ended December 31, 2025, 2024 and 2023.
As of December 31,
2025 2024 2023
Overdrafts 0.19 % 0.03 % 0.02 %
Documents 0.21 % 0.02 % 0.00 %
Mortgage loans 0.08 % 0.00 % 0.00 %
Pledged loans 0.04 % 0.00 % 0.02 %
Consumer Loans 2.61 % 1.09 % 0.91 %
Other loans 0.65 % 0.17 % 0.23 %
Other financings 6.02 % 1.16 % 0.85 %
Allocation of the allowances for loans and other financing losses
The following table allocates the allowance for loans and other financing losses by each category of financing and sets forth the percentage distribution of the total allowance for each of the fiscal years ended December 31, 2025, 2024 and 2023.
As of December 31,
2025 2024(1) 2023(1)
(in thousands of Pesos, except percentages)
Overdrafts 38,560,169 7.60 % 15,982,684 9.85 % 10,292,729 6.70 %
Documents 15,841,879 3.12 % 7,312,060 4.51 % 9,458,972 6.15 %
Mortgage loans 21,599,024 4.26 % 11,510,540 7.09 % 13,563,814 8.83 %
Pledged loans 5,393,600 1.06 % 2,238,218 1.38 % 1,001,892 0.65 %
Consumer Loans 362,592,370 71.44 % 101,858,385 62.77 % 59,204,029 38.52 %
Other loans 63,052,434 12.42 % 22,320,791 13.76 % 59,542,385 38.74 %
Other financings 492,930 0.10 % 1,048,763 0.65 % 621,406 0.40 %
Total Allowances 507,532,406 100.00 % 162,271,441 100.00 % 153,685,227 100.00 %
Note:-
(1) Figures stated in thousands of Pesos adjusted for inflation as of December 31, 2025. See “Presentation of certain financial and other information.”
Deposits
The following table sets out the composition of each category of deposits that exceeded 10% of average total deposits in each of the years ended December 31, 2025, 2024 and 2023.
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Year Ended December 31,
2025 2024(1) 2023(1)
(in thousands of Pesos, except percentages)
Deposits in Domestic Bank Offices
Non-interest bearing Demand Deposits(2)
Average
Pesos 1,434,871,087 1,424,831,481 1,520,392,461
Foreign currency 81,338,489 65,066,482 37,934,438
Total 1,516,209,576 1,489,897,963 1,558,326,899
Non-interest bearing Other Deposits
Average
Pesos 109,251,820 87,858,803 124,847,949
Foreign currency 641,663,290 659,508,212 628,449,940
Total 750,915,110 747,367,015 753,297,889
Savings Accounts
Average
Pesos 1,569,691,881 1,561,773,434 2,024,234,839
Foreign currency 1,515,456,929 1,003,710,755 928,074,617
Total 3,085,148,810 2,565,484,189 2,952,309,456
Average real rate
Pesos (54.40 %) (62.31 %) (62.01 %)
Foreign currency 4.26 % (26.87 %) 46.59 %
Total (25.59 %) (48.44 %) (27.87 %)
Time Deposits
Average
Pesos 4,892,697,024 3,893,457,798 5,426,547,296
Foreign currency 1,432,994,134 767,122,115 450,784,897
Total 6,325,691,158 4,660,579,913 5,877,332,193
Average real rate
Pesos (41.71 %) (50.24 %) (43.26 %)
Foreign currency 6.23 % (26.65 %) 46.68 %
Total (30.85 %) (46.36 %) (36.36 %)
Deposits in Foreign Bank Offices
Non-interest bearing Demand Deposits
Average
Pesos 389,700 — 132
Foreign currency 33,554,189 31,080,623 40,675,405
Total 33,943,889 31,080,623 40,675,537
Non-interest bearing Other Deposits
Average
Pesos — — —
Foreign currency 98,869,058 101,042,536 82,851,412
Total 98,869,058 101,042,536 82,851,412
Savings Accounts
Average
Pesos — — —
Foreign currency — — —
Total — — —
Time Deposits
Average
Pesos — — —
Foreign currency 4,091,407 679,002 5,870,741
Total 4,091,407 679,002 5,870,741
Average real rate
Pesos 0.00 % 0.00 % 0.00 %
Foreign currency 25.63 % (1.19 %) 46.94 %
Total 25.63 % (1.19 %) 46.94 %
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Notes:-
(1) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial and other information.”
(2) Non-interest-bearing demand deposits consist of checking accounts.
Deposits by Type of Guarantee
The following table sets forth information regarding deposits by type of guarantee as of December 31, 2025, 2024 and 2023.
2025 2024(1) 2023(1)
(in thousands of Pesos)
With guarantee Without guarantee Total With guarantee Without guarantee Total With guarantee Without guarantee Total
Checking accounts 523,174,471 1,126,878,336 1,650,052,807 544,610,541 1,406,102,173 1,950,712,714 369,939,139 1,481,057,650 1,850,996,789
Savings accounts 2,523,854,646 1,940,751,094 4,464,605,740 2,475,573,193 1,960,966,248 4,436,539,441 1,602,426,974 2,392,535,231 3,994,962,205
Time deposits 1,881,504,023 5,221,639,469 7,103,143,492 1,460,438,901 1,465,319,111 2,925,758,012 1,567,364,956 1,564,663,060 3,132,028,016
Investment accounts 1,413,472 23,007,952 24,421,424 53,826 855,261,433 855,315,259 17,789,991 507,524,992 525,314,983
Other 119,519,259 328,895,052 448,414,311 257,834,939 653,804,835 911,639,774 75,087,276 76,182,383 151,269,659
Total deposits 5,049,465,871 8,641,171,903 13,690,637,774 4,738,511,400 6,341,453,800 11,079,965,200 3,632,608,336 6,021,963,316 9,654,571,652
Note:-
(1) Figures stated in thousands of Pesos adjusted for inflation as of December 31, 2025. See “Presentation of certain financial and other information.”
All deposits in Pesos and foreign currency placed in participating entities in the form of checking accounts, savings accounts, certificates of deposits or other forms of deposit that the Central Bank may determine from time to time shall be subject to the Deposit Guarantee Insurance System up to the amount of Ps.25,000,000 as of December 31, 2025 and 2024 and Ps.6,000,000 as of December 31, 2023 (in all cases, per depositor), which must meet the requirements provided for in Presidential Decree 540/1995 and other requirements that the regulatory authority may determine from time to time. On the other hand, the Central Bank provided from the exclusion of the guarantee system, among others, of any deposits made by other financial entities, deposits made by persons related to us and securities deposits.
Maturity of Deposits Without Guarantee
The following table sets forth information regarding our deposits without guarantee as of December 31, 2025.
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Total Within 3 Months Maturing After 3 but Within 6 Months After 6, but Within 12 Months After 12 Months
(in thousands of Pesos)
Checking accounts
That exceed the guarantee 767,049,396 767,049,396 — — —
Without guarantee 359,828,940 359,828,940 — — —
Savings accounts
That exceed the guarantee 1,305,426,605 1,305,426,605 — — —
Without guarantee 635,324,489 635,324,489 — — —
Time deposits
That exceed the guarantee 2,427,448,340 2,170,488,824 128,933,522 125,847,904 2,178,090
Without guarantee 2,794,191,129 2,702,428,280 80,401,181 9,133,121 2,228,547
Investment accounts
That exceed the guarantee 6,095,866 6,029,213 54,555 12,098 —
Without guarantee 16,912,086 16,822,905 89,111 70 —
Other
That exceed the guarantee 250,174,111 250,174,110 — 1 —
Without guarantee 78,720,941 78,720,872 68 1 —
Total Deposits without guarantee 8,641,171,903 8,292,293,634 209,478,437 134,993,195 4,406,637
Return on equity and assets
The following table presents certain selected financial information and ratios for the years indicated.
Year Ended December 31,
2025 2024(1) 2023(1)(2)
(in thousands of Pesos, except percentages)
Net income for the fiscal year attributable to controlling interests 289,494,680 428,193,992 1,667,326,227
Average total assets 20,502,581,307 17,792,873,982 19,415,336,300
Average shareholders’ equity 5,220,133,149 5,334,906,673 5,109,508,815
Shareholders’ equity at the end of the fiscal year 5,234,546,354 5,328,662,213 5,840,268,867
Average shareholders’ equity as a percentage of Average total assets 25.46 % 29.98 % 26.32 %
Net income as a percentage of:
Average total assets 1.41 % 2.41 % 8.59 %
Average shareholders’ equity 5.55 % 8.03 % 32.63 %
Declared nominal dividends(3) 138,956,468 300,000,000 294,130,168
Dividend payout ratio(4) 47.80 % 92.27 % 50.05 %
Notes:-
(1) Figures adjusted for inflation as of December 31, 2025. See “Presentation of certain financial and other information.”
(2) Figures recast due to the recognition of a prior period adjustment related to the business combination. See note 14.2. to our audited consolidated financial statements as of December 31, 2025 and 2024.
(3) Figures not restated
(4) Declared nominal cash dividends stated as percentage of net income calculated under Central Bank Rules. Net income in nominal value calculated under Central Bank Rules as of December 31, 2023, of Ps. 587,654,845 thousand, as of December 31, 2024, of Ps. 325,132,181 thousand and as of December 31, 2025 of Ps. 290,703,797 thousand.
Interest rate sensitivity
The following table shows the interest rate sensitivity of our interest-earning assets and interest-bearing liabilities based on contractual maturities all based on information adjusted for inflation as of December 31, 2025. Variations in interest rate sensitivity may also arise within the repricing periods presented.
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Remaining Maturity at December 31, 2025
0-1 Year 1-5 Years 5-10 Years Over 10 years Without due date Total
(in thousands of Pesos)
Interest-earning assets:
Loans and other financing to non-financial Public Sector 126,822,566 101,603,958 — — — 228,426,524
Loans and other financing to other Financial Entities 7,539,125,614 2,146,615,806 165,209,797 511,294,708 — 10,362,245,925
Loans and other financing to non-financial Private Sector and Foreign Residents 101,777,324 15,865,250 — — — 117,642,574
Other Debt Securities 1,135,196,390 3,278,033,076 2,598,477 — — 4,415,827,943
Repo Transactions 181,151,259 — — — — 181,151,259
Total Interest-Earning Assets 9,084,073,153 5,542,118,090 167,808,274 511,294,708 — 15,305,294,225
Interest-bearing liabilities:
Non-financial Public Sector deposits 410,786,972 — — — — 410,786,972
Non-financial Private Sector and Foreign Residents deposits 10,654,736,196 5,285,183 — — — 10,660,021,379
Financing received from the BCRA and other financial institutions 152,996,678 246,476 — — — 153,243,154
Issued Corporate Bonds 1,360,618 756,223,959 — — — 757,584,577
Subordinated Corporate Bonds 588,032,164 — — — — 588,032,164
Repo Transactions — — — — — —
Total Interest-Bearing Liabilities 11,807,912,628 761,755,618 — — — 12,569,668,246
Asset (Liability) Gap (2,723,839,475 ) 4,780,362,472 167,808,274 511,294,708 — 2,735,625,979
Cumulative Asset/Liability Gap (2,723,839,475 ) 2,056,522,997 2,224,331,271 2,735,625,979 2,735,625,979
Cumulative sensitivity gap as a percentage of total interest-earning assets (17.80 %) 13.44 % 14.53 % 17.87 % 17.87 %
Interest-earning assets in Pesos
Loans and other financing to non-financial Public Sector 126,822,566 101,603,958 — — — 228,426,524
Loans and other financing to other Financial Entities 5,519,461,089 1,838,336,439 161,435,902 501,417,388 — 8,020,650,818
Loans and other financing to non-financial Private Sector and Foreign Residents 101,645,508 15,865,250 — — — 117,510,758
Other Debt Securities 1,017,069,054 3,277,994,028 2,598,477 — — 4,297,661,559
Repo Transactions 181,151,259 — — — — 181,151,259
Total Interest-Earning Assets in Pesos 6,946,149,476 5,233,799,675 164,034,379 501,417,388 — 12,845,400,918
Interest-bearing liabilities in Pesos
Non-financial Public Sector deposits 317,686,566 — — — — 317,686,566
Non-financial Private Sector and Foreign Residents deposits 6,865,774,689 67,968 — — — 6,865,842,657
Financing received from the BCRA and other financial institutions 17,786,069 — — — — 17,786,069
Issued Corporate Bonds — — — — — —
Subordinated Corporate Bonds — — — — — —
Repo Transactions — — — — — —
Total Interest-Bearing Liabilities in Pesos 7,201,247,324 67,968 — — — 7,201,315,292
Asset (Liability) Gap (255,097,848 ) 5,233,731,707 164,034,379 501,417,388 — 5,644,085,626
Cumulative Asset/Liability Gap (255,097,848 ) 4,978,633,859 5,142,668,238 5,644,085,626 5,644,085,626
Cumulative sensitivity gap as a percentage of total interest-earning assets (1.99 %) 38.76 % 40.04 % 43.94 % 43.94 %
151
Table of Contents
Remaining Maturity at December 31, 2025
0-1 Year 1-5 Years 5-10 Years Over 10 years Without due date Total
(in thousands of Pesos)
Interest-earning assets in foreign currency
Loans to non-financial Public Sector — — — — — —
Loans to other Financial Entities 2,019,664,525 308,279,367 3,773,895 9,877,320 — 2,341,595,107
Loans and other financing to non-financial Private Sector and Foreign Residents 131,816 — — — — 131,816
Other Debt Securities 118,127,336 39,048 — — — 118,166,384
Repo Transactions — — — — — —
Total Interest-Earning Assets 2,137,923,677 308,318,415 3,773,895 9,877,320 — 2,459,893,307
Interest-bearing liabilities in foreign currency
Non-financial Public Sector deposits 93,100,406 — — — — 93,100,406
Non-financial Private Sector and Foreign Residents deposits 3,788,961,507 5,217,215 — — — 3,794,178,722
Financing received from the BCRA and other financial institutions 135,210,609 246,476 — — — 135,457,085
Issued Corporate Bonds 1,360,618 756,223,959 — — — 757,584,577
Subordinated Corporate Bonds 588,032,164 — — — — 588,032,164
Repo Transactions — — — — — —
Total Interest-Bearing Liabilities 4,606,665,304 761,687,650 — — — 5,368,352,954
Asset (Liability) Gap (2,468,741,627 ) (453,369,235 ) 3,773,895 9,877,320 — (2,908,459,647 )
Cumulative Asset/Liability Gap (2,468,741,627 ) (2,922,110,862 ) (2,918,336,967 ) (2,908,459,647 ) (2,908,459,647 )
Cumulative sensitivity gap as a percentage of total interest-earning assets (100.36 %) (118.79 %) (118.64 %) (118.24 %) (118.24 %)
ITEM 4.A. UNRESOLVED STAFF COMMENTS
None.