Two new special Public Offering regimes for Corporate notes in Argentina

To expand access to capital markets and promote economic development in Argentina, the Argentine Securities and Exchange Commission ("CNV"), by means of General Resolution No. 1047/2025, introduced two automatic public offering regimes for low and medium impact issuances. These regimes do not require prior authorization from the CNV and partially or fully exempt issuers from the disclosure obligations required under the general regime.

Both regimes are applicable to all types of issuers residing in the country and restrict primary placement and secondary trading exclusively to qualified investors.

Automatic Public Offering for Low-Impact Issuances

Issuances qualifying as low-impact must not exceed a maximum amount of one million Acquisition Value Units ("UVAs"), increasing to ten million UVAs for issuers also registered under the "PYME CNV Garantizada" regime. The maximum amount includes all placements made under this regime within the previous twelve months.

Public offering authorization is automatic if the issuance complies with regulatory guidelines. No prospectus nor supplements are required to be filed. Issuers only need to notify the CNV via the remote filing system (TAD) and publish the notice required under Article 10 of Law No. 23,576 before the start of the offering period.

Regarding information disclosure, issuers under this regime are exempt from filing periodic financial statements, among other obligations.

Issuers registered under the "PYME CNV Garantizada" or "PYME CNV" regimes may simultaneously opt into this low-impact issuance regime.

Automatic Public Offering for Medium-Impact Issuances

Issuances qualifying as medium-impact must not exceed a maximum amount of seven million UVAs . As in the low impact regime, the amount is calculated based on the total placements made in the previous twelve months.

Issuers seeking to access this medium-impact regime must complete a simplified admission procedure: while the publication of a simplified prospectus is required for informational purposes, prior review and approval by the CNV are not required.

Issuers must publish annual financial statements in accordance with Argentine Professional Accounting Standards and adhere to a limited regime for disclosing material events.

Unlike the low-impact regime, the medium-impact regime excludes simultaneous registration under the "PYME CNV Garantizada" regime. However, issuers registered under the "PYME CNV" regime remain eligible to adhere to this medium-impact regime.

Authors: Alejandro Noblía and Federico Vieyra

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