Argentina

O'Farrell advised John Deere Credit Compañia Financiera S.A. and EGFA Abogados advised Banco de Galicia y Buenos Aires S.A., Banco Santander Argentina S.A., Banco BBVA Argentina S.A., Balanz Capital Valores S.A.U., Banco Patagonia S.A., Macro Securities S.A.U., Puente Hnos S.A., Banco Comafi S.A., Allaria S.A., Cocos Capital S.A. and First Capital Markets .S.A as organizers and placement agents in the offering and issuance of Series XX Notes denominated and payable in US dollars at a fixed annual nominal rate of 6.50% and maturing in 2028 for a total amount of US$80,000,000. The issuance of the Series XX Notes was carried out on June 8, 2026, under the Frequent Issuer Regime established in Section VI, Chapter V, Title II of the CNV Regulations. The Series XX Notes have been authorized for listing on Bolsas y Mercados Buenos Aires S.A. (BYMA) through the Bolsa de Comercio de Buenos Aires S.A. (BCBA) and for trading on the A3 Mercados S.A. (A3). Legal advice to John Deere Credit Compañía Financiera S.A. O'Farrell: Partner Sebastián Luegmayer, Senior Consultant Nicolás Fernández Madero and associates Irupé Martínez and Lucas Rodríguez Castelli Legal advice to the Placement Agents EGFA Abogados: Partner Carolina Curzi and associates María Constanza Martella, Agustina Weil and Marina Galíndez.

On June 1, 2026, Executive Order No. 407/2026 (Order) was published in Argentina’s Official Gazette, implementing regulations for various provisions of the Employment Contract Law No. 20,744 (LCT), as amended by the Labor Modernization Act No. 27,802, in addition to regulations governing collective bargaining (Law No. 14,250), trade union organizations (Law No. 23,551), temporary staffing agencies (TSA), and construction industry registration (Law No. 22,250). The Order took effect on the date of its publication. Below, we offer a summary of the Order and highlight its key provisions. LCT Section 52: Employment registration The registration obligation required by the Order is fulfilled exclusively through enrollment and termination in the Customs Collection and Control Agency’s (ARCA) systems. Such registration is sufficient for all legal purposes. The obligation to maintain employment books – whether in physical or digital form – is eliminated; no administrative authority may impose additional requirements. LCT Section 140: Pay slip The pay slip must be structured in four clearly differentiated sections that identify: 1) data of the employer and the employee; 2) employer contributions and payroll charges; 3) gross remuneration and deductions; and 4) net remuneration. The document must include a summary of total labor cost sorted into the following categories: union fees, social security, health coverage (obra social), National Institute of Social Services for Retirees and Pensioners (INSSJP), Workers’ Compensation Insurance (ART), employer chamber contributions, and other items. Each line item must specify the computation base, unit of measurement, and resulting amount. LCT Sections 103 bis and 105: Fringe benefits and in-kind compensation Employer-provided meal benefits (Section 103 bis, para. (a)) must be furnished or directly funded by the employer and may not be substituted for or commuted into cash. The monthly cap is 40 percent of the prevailing Minimum Living Wage (SMVM). For in-kind compensation (Section 105, para. (b)), the applicable maximum is set at five percent of the employee's annual gross remuneration. LCT Section 210: Illness monitoring and medical certificates Medical prescriptions indicating rest leave must be issued electronically through platforms registered with the National Register of Electronic Prescriptions (ReNaPDiS) and signed by professionals enrolled in the Register of Health Professionals (REFEPS). Paper-based certificates with handwritten signatures are permitted only where lack of digital connectivity is demonstrated. Where an irreconcilable discrepancy exists between the initial diagnosis and the employer's medical review, the parties may resort to (a) an official medical panel in jurisdictions that have established such a mechanism or (b) an opinion from institutions registered with the Federal Registry of Healthcare Facilities (Ministry of Health Resolution No. 1,070/2009) with at least five continuous years of standing. LCT Sections 240 and 241: Resignation and mutual termination Concerning resignation (Section 240), the Secretariat of Labor, Employment, and Social Security (STEySS) will issue complementary regulations to implement the procedure for formalizing resignations before the labor administrative authority, including registration and verified notice to the employer. For mutual termination (Section 241), termination agreements submitted to the administrative authority may be ratified pursuant to Section 15 of the LCT, following verification of legality, absence of consent defects, and adequate accommodation of the parties' interests. LCT Section 252: Retirement notification The National Social Security Administration (ANSES) must implement an electronic notification system to inform both employers and agents of the National Health Insurance System of the commencement and completion of retirement proceedings, enabling timely awareness of the grant of the retirement benefit and allowing each party to make the relevant decisions regarding the employment relationship and health coverage. Law No. 14,250 and Executive Order No. 199/88: Collective bargaining Concerning employer representation (new Section 2), employer associations and business chambers are entitled to participate in collective bargaining provided that they demonstrate representation of at least ten percent of workers within the relevant scope. In multi-jurisdictional agreements, up to two additional employer-side representations may be admitted. Condominium-owner associations may be represented by the grouping associations to which they belong. For obligatory clauses and the Section 9 cap (new Sections 6 and 6 bis), the concept of an obligatory clause encompasses all contributions, dues, withholdings, funds, or economic charges benefiting the signatory parties or affiliated entities, regardless of denomination. The Section 9 cap is computed globally across all charges, and the computation base is the applicable conventional basic wage for the relevant job category. Agreements currently in force that exceed the cap must be restructured; those exceeding it as of the Order's effective date will discharge the obligor up to that limit. Agreements exceeding the cap will not be ratified or registered, while contributions within the cap are mandatory only for companies affiliated with the signatory entities (pursuant to Executive Order No. 149/2025). For the purposes of Section 137 of Law No. 27,802, collective bargaining agreements whose stated term has expired (Section 4) are deemed to have lapsed. Those lacking an express expiration date will be treated as expiring on December 31, 2026. STEySS is required to initiate the renegotiation convocation procedure within 30 days of the Order's effective date. Law No. 23,551 and Executive Order No. 467/88: Trade union organizations The Order mandates that the size of governing bodies must bear reasonable proportion to the number of dues-paying members. In addition to the membership register, an association may demonstrate dues-paying membership through union fee invoices, pay slips showing union dues withheld, or employer-issued certifications. The Competent Authority will cross-check the membership list against Integrated Argentinian Pension System (SIPA) records; material discrepancies will preclude satisfaction of the legal requirement. To replace an existing registered union, the Order requires the petitioning association to exceed the incumbent's dues-paying membership by at least five percent. The administrative authority must issue a decision within 45 days. Union time-off credits must be exercised upon 48-hour advance notice in a manner compatible with the establishment's operational continuity and without affecting critical sectors; credits may not be accumulated or transferred. In addition, the protection afforded under Section 50 of the Trade Union Act is enforceable against the employer only from the moment the association formally notifies the candidacy; protection ceases upon failure to officially list the candidate or if the candidate receives fewer than five percent of valid votes cast. An employer may seek judicial suspension of the protected employee's work activity where a potential hazard exists to persons, assets, or the effective operation of the business. Loss of coverage under the union's registration does not affect the personal protection afforded under Section 48, third paragraph of the Trade Union Act. Annex II: Temporary staffing agencies The Order revokes Executive Order No. 1,694/06 and enacts a new regulatory framework setting regulations for TSAs. A TSA is a legal entity whose exclusive purpose is to supply personnel to client companies for any economic activity. Under the Order, employment agreements with non-continuous workers must expressly identify the staffing modality. Workers deployed to client companies are engaged under a permanent non-continuous contract; those performing services at the TSA's own premises are engaged under a permanent continuous contract. Gap periods between assignments may not exceed 45 consecutive calendar days (extendable to 60 by agreement) or 90 alternating days per anniversary year. An employee is not required to accept a posting located more than 30 km away from their place of residence (or 50 km away by agreement at commencement of the relationship). Minimum remuneration must be no less than the applicable statutory and/or collectively agreed minimums, nor less than the compensation paid to permanent employees of the client company in the same job category and seniority. The Order authorizes the use of a TSA in the event of an absence of permanent staff, a statutory or collectively agreed leave or suspensions, an increase in extraordinary activity (including technology adoptions), urgent accident-prevention or repair work, and, generally, extraordinary or transient needs outside the company's ordinary course of business. In addition, the Order limits the ratio of temporary to permanent staff. Registration for authorization to use a TSA can be made electronically and at no cost with STEySS. If there are no objections, authorization becomes effective after 15 business days. Successful registration guarantees 1) a principal guarantee of 14,000 UVA units, applicable to all TSAs; and 2) a scaled supplemental guarantee of 100 UVA units per each additional worker between 31 and 100 employees, and 75 UVA units per worker when there are more than 100 employees. The Order designates the following permitted instruments: UVA-indexed cash deposit, government securities, real property security interest, bank guarantee, or surety bond. Annual adjustments are made based on UVA value and a sworn statement of headcount. Law No. 22,250: Construction industry registration Enrollment, termination, and modification of employment data for construction-industry workers must be filed with ARCA pursuant to the procedures and technological means it establishes. The Order establishes ARCA’s record as the authoritative record of registration, thereby excluding the Institute of Statistics and Registry of the Construction Industry’s (IERIC) registration competence. ARCA has 120 days to adapt its systems and implement the information exchange with the IERIC; the IERIC will act as a transitional relay channel until full implementation. Other amendments and repeals Concerning digital-platform workers (Section 3), the Secretariat of Transport of the Ministry of Economy is designated as the Competent Authority for the Mobility and Delivery Services Regime (Title XII, Law No. 27,802), while STEySS retains jurisdiction over collective bargaining agreements in the sector. Family allowances for agricultural workers covered by Sections 16 and 17 of the Agricultural Labor Act No. 26,727 are unified with the general framework under Section 1(a) of Law No. 24,714. The following are repealed: Sections 9 and 12 of Executive Order No. 199/88; Sections 6, 7, 8, and 11 of Executive Order No. 301/13 (Regulation of Law No. 26,727); and Executive Order No. 1,694/06 (TSA regulations). For more information, please contact the authors.

DLA Piper advised Empresa Distribuidora y Comercializadora Norte S.A. (Edenor), Argentina’s largest electricity distributor, on its issuance of US$550 million Class 10 Notes, as well as a concurrent repurchase offer for its outstanding Class 7 Notes – key steps in the company’s broader strategy to manage maturities and strengthen its financial structure. The debt securities were issued on April 28, 2026, under Edenor’s global notes issuance program of up to US$1.25 billion (or its equivalent in other currencies), as approved by the Argentine Securities Commission. The Notes were issued through two series with differing settlement mechanisms. Series I was settled in cash through the transfer of US dollars held in Argentina and abroad, while Series II was settled in kind through the delivery of the company's outstanding Class 3 and Class 5 Notes. The DLA Piper team consisted of Partners Joshua Kaufman (New York), Marcelo Etchebarne, and Alejandro Noblía; Of Counsel Nicolás Teijeiro; and Associates Daiana Suk, Federico Vieyra, Ignacio Comparato, and Eugenio Rattagan (all Buenos Aires). DLA Piper in Latin America’s team offers full-service business legal counsel to domestic and multinational companies with interests in and operations throughout the region. Our integrated approach to serving clients combines local knowledge with the resources of the DLA Piper global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, in addition to our US-based cross-border attorneys, our teams frequently work with our professionals throughout the LatAm region, Iberian Peninsula, and around the globe. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve all our clients’ legal and business needs, whether they are based in Latin America or wish to do business there. For more information, visit Latin America | DLA Piper.

Regional Spanish CNMC hosts annual meeting of Ibero-American Association of Energy Regulatory Authorities and adopts Madrid Declaration. In May 2026, the Spanish Competition Authority (CNMC), which is also the energy regulator in Spain, hosted the annual meeting of the Ibero-American Association of Energy Regulatory Authorities (Asociación Iberoamericana de Entidades Reguladoras de la Energía, or ARIAE). Regulators from Ibero-American countries – along with Portuguese-speaking African regulators – discussed opportunities to enhance regulatory frameworks for integrating renewable energy into the electricity, natural gas, and liquid fuels sectors.  Participants also adopted the Madrid Declaration, which is a document that encourages the independence of energy regulators and promotes a stable regulatory framework. The Declaration also highlights the importance of international cooperation and the need to strengthen technical training, digitalization, and cybersecurity in order to improve market functioning, boost energy efficiency, and protect vulnerable consumers. Argentina Argentina moves toward a suspensory merger control regime. Argentina is set to transition to a suspensory merger control regime, as Article 9 of the Argentine Competition Law will become fully effective on November 17, 2026 – one year after the appointment of the President and other members of the Argentine Competition Authority. Under this framework, mergers and acquisitions (M&A) will be subject to approval by the Argentine Competition Authority before closing. With this change, Argentina will align more closely with international practice requiring approval for regulated M&A transactions. Chile TDLC rejects abuse of dominance claim against Metrogas and Agesa in gas distribution case. On January 28, 2026, Chile’s Competition Tribunal (Tribunal de Defensa de la Libre Competencia, or TDLC) issued Judgment No. 208/2026, rejecting a consumer claim alleging that the 2016 corporate division of Metrogas – which created Agesa – and a subsequent gas supply agreement constituted a scheme to circumvent Metrogas's profitability cap and enabled exploitative abuse through excessive pricing. The TDLC found that the corporate division was carried out transparently and was addressed by the law itself, dismissing both the fraud and excessive pricing allegations. TDLC approves settlement between FNE, Delivery Hero, and Glovo in cross-border market allocation case. On February 5, 2026, the TDLC approved a settlement agreement between the Fiscalía Nacional Económica (FNE), Delivery Hero SE (parent of PedidosYa), and Glovoapp23 SA (parent of Glovo) in a case concerning an international market allocation agreement. The FNE alleged that the companies entered into asset-transfer agreements in 2019 (Project Green) that included non-compete clauses allocating territories across Chile, Egypt, Peru, and Ecuador, resulting in Glovo's exit from Chile. The settlement imposes a fine of approximately USD31.5 million payable to the Treasury and requires Delivery Hero to implement annual competition law training for PedidosYa executives for five years. For additional background, see “FNE pursues Delivery Hero and Glovo for alleged market allocation” in the November 2025 issue of Juntos. TDLC rejects SumUp's abuse of dominance claim against Transbank in payment processing case. On February 3, 2026, the TDLC issued Judgment No. 209/2026, rejecting SumUp's claim against Transbank SA alleging that Transbank’s 2022 increase in acquirer margin fees breached a 2022 Supreme Court ruling and constituted a margin squeeze amounting to abuse of dominance. The TDLC dismissed both claims, finding that alternative providers were available and that SumUp failed to demonstrate that Transbank acted contrary to the Supreme Court's decision or that its margins had become negative. Supreme Court overturns TDLC rulings in interlocking cases. On March 2, 2026, Chile's Supreme Court overturned two TDLC judgments (2025) that sanctioned several entities for violating rules regarding interlocking directorates – which occur when an individual serves on the boards of competing companies simultaneously. In the first case, Juan Hurtado Vicuña served simultaneously as director of Consorcio and Larraín Vial; in the second, Hernán Büchi served on the boards of Banco de Chile, Consorcio, and Falabella. The Supreme Court held that 1) the interlocking prohibition applies only to individuals, not to the companies in which they participate, and 2) parent companies cannot be deemed “competing enterprises” merely because their subsidiaries operate in overlapping markets. The ruling nullified fines totaling approximately CLP7.5 billion but did not affect prior settlement agreements with Hernán Büchi and Falabella. TDLC approves settlement with Booking.com eliminating price parity clauses in digital lodging market. On March 23, 2026, the TDLC approved a settlement between the FNE and Booking.com BV, concluding an investigation into the company’s use of most favored nation, or price parity, clauses that restricted accommodation providers from offering lower prices on competing channels. Booking.com committed to eliminating such clauses, refraining from reintroducing them, removing external pricing criteria from its loyalty programs, and paying USD6 million to the Treasury. The obligations will remain in effect for a minimum of three years, after which Booking.com may seek review. FNE files complaint against PedidosYa for alleged breach of 2023 settlement banning price parity clauses in food delivery. On March 11, 2026, the FNE filed a complaint before the TDLC against Delivery Hero E-Commerce Chile SpA (PedidosYa) alleging a breach of the extrajudicial settlement approved by the TDLC in December 2023, which prohibited PedidosYa from implementing most favored nation, or price parity, clauses with its partner restaurants. The FNE alleges that PedidosYa used a banner labeled “Mismo precio que en local” (“Same price as in-store”) that effectively restricted restaurants from offering lower prices through their own channels or competing platforms. The FNE has requested a fine of approximately USD3.8 million. Mexico Mexico’s CNA sanctions companies for exclusivity clauses in medical oxygen supply contracts. On March 19, 2026, Mexico’s National Antitrust Commission (Comisión Nacional Antimonopolio, or CNA) imposed sanctions on two companies for engaging in anticompetitive practices related to the use of exclusivity clauses in medicinal oxygen supply contracts. According to the CNA, the sanctioned companies included exclusivity provisions in their supply agreements that prevented private clinics and hospitals from purchasing medicinal oxygen from alternative suppliers. The contracts also contained automatic renewal clauses and early termination penalties that applied to clients’ existing and future medical facilities. The CNA determined that these contractual provisions restricted competition, hindered entry and expansion by other suppliers, and limited the ability of clinics and hospitals to obtain alternative supply conditions for medicinal oxygen. The conduct was found to have affected medical facilities and patients requiring oxygen as part of their treatment. The CNA imposed fines of approximately MXN800 million. In addition, the CNA ordered the companies to 1) cease enforcing exclusivity clauses in existing contracts, 2) refrain from including exclusivity and automatic renewal provisions in future contracts, and 3) appoint a compliance officer and an independent auditor to oversee implementation of the corrective measures and ensure compliance with competition laws. The CNA files a class action to seek compensation for consumers affected by collusion in the LP gas market On April 23, 2026, the CNA announced the filing of a class action lawsuit against 53 liquefied petroleum (LP) gas companies, seeking compensation for consumers affected by a long-running collusive scheme in the distribution of LP gas in Mexico. The case arises from a prior investigation in which the authority identified and sanctioned an illegal agreement among major gas distributors, who allegedly coordinated to manipulate prices and allocate customers across regions such as Mexico City, the State of Mexico, and various localities in Colima, Tamaulipas, and Sinaloa. The CNA reports these practices resulted in overcharges that caused harm to consumers exceeding MXN13 billion. In addition to the administrative fines previously imposed, the CNA is seeking judicial remedies aimed at achieving direct compensation for affected consumers. In particular, the lawsuit requests that the companies be ordered to grant discounts on LP gas prices in the affecting regions. Peru INDECOPI sanctions an electricity sector company for failure to provide complete information in merger control review. On January 19, 2026, Peru’s National Institute for the Defense of Competition and Protection of Intellectual Property (INDECOPI) sanctioned an electricity sector company with a fine of 1,000 Tax Units (approximately PEN5.5 million) for failing to provide complete, accurate, and truthful information to the authority during the evaluation of a merger control filing. In 2023, the company notified INDECOPI of the proposed acquisition of solar power generation plants. INDECOPI requested documents related to the company’s investment plans or projects in the Peruvian energy sector for the following five years, which the company claimed did not exist. However, INDECOPI later identified internal documents indicating undisclosed investment plans. The decision represents the first sanction imposed for infringements under the current merger control regime. The first administrative resolution has been appealed and is currently pending at the appellate level. United States FTC secures USD10 million settlement with StubHub for deceptive ticket pricing. On April 9, 2026, the Federal Trade Commission (FTC) announced a settlement with StubHub for violating the FTC Act and the Rule on Unfair or Deceptive Fees. The FTC alleged that StubHub deceptively advertised ticket prices across the first three pricing displays on its website without clearly and conspicuously disclosing the total price, including all mandatory fees. State enforcers push for parallel remedies proceedings after jury verdict against Live Nation. On April 15, 2026, the jury in United States et al. v. Live Nation Entertainment, Inc. et al., found that Live Nation and its Ticketmaster unit monopolized ticketing services for large music venues and unlawfully tied venue access to its concert promotion services. This development follows Live Nation entering a mid-trial settlement with the US Department of Justice (DOJ) on March 9, 2026, which allowed Live Nation to retain Ticketmaster subject to certain conditions (as reported in our April 2026 issue of Inside Competition). However, state enforcers have deemed the DOJ settlement insufficient and have reportedly indicated their intent to seek a forced sale. State enforcers requested that the court proceed with remedies discovery in parallel with the Tunney Act review. Federal court blocks Nexstar-Tegna merger pending resolution of antitrust suit. On April 17, 2026, US District Court Chief Judge Troy L. Nunley extended an emergency order blocking Nexstar Media Group’s proposed USD6.2 billion acquisition of Tegna while an antitrust lawsuit brought by eight states and DIRECTV proceeds. Although the transaction had received approval from the Federal Communications Commission and DOJ, the merger would result in Nexstar owning 265 television stations across 44 states and the District of Columbia, including two or three “Big Four” local network affiliates in 31 markets. The court concluded that the plaintiffs were likely to succeed on the merits, finding that the transaction could lead to increased consumer prices, reduced programming quality and access, and diminished local journalism. Nexstar has announced its intent to appeal the ruling, stating that the transaction has received the required regulatory approvals and would expand local journalism.