DLA Piper Argentina

Written by:Alberto RubioMaría Florencia Labarile 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.   Leer este artículo en español.

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. Related professionals:Josh KaufmanMarcelo EtchebarneAlejandro NoblíaNicolas TeijeiroDaiana SukFederico VieyraIgnacio ComparatoEugenio Rattagan

Written by:Marcelo EtchebarneMartín MittelmanJoaquín Eppens EchagüeAugusto Nicolás MancinelliRichard Chesley The Milei Administration recently submitted to Congress a bill titled Ley de Régimen de Incentivo para Grandes Inversiones en Nuevas Industrias (Súper RIGI), which aims to promote investments exceeding USD1 billion. The Súper RIGI expands on existing, similar legislation (RIGI), increasing investment size from USD200 million to USD1 billion, and granting tax, labor, foreign exchange (FX), and other benefits to both foreign and domestic investors. This alert provides a snapshot of the original RIGI pipeline – approved projects, projects pending approval, and major investments announced but not yet formally filed – and a summary of key terms from the Súper RIGI. Original RIGI: Pipeline status as of May 2026 The original RIGI (Law No. 27,742; regulated August 2024) offers a minimum USD200 million-investment threshold across strategic sectors with a 30-year tax, customs, and FX stability. The adhesion window was extended by Decree 105/2026 to July 8, 2027. As of May 2026, 16 projects have been approved (approximately USD30 billion) and 22 projects are pending approval (approximately USD68 billion), for a total formal pipeline of approximately USD95 billion. Net FX inflows through March 2026 totaled USD762 million – a fraction of committed amounts, reflecting the long construction timelines. Minister Luis Caputo's oft-cited figure of USD140 billion includes the formal pipeline plus major projects announced but not yet filed, principally YPF's LNG project with ENI and XRG and Chevron's Vaca Muerta expansion. Approved projects: Sixteen projects totaling USD30 billion YPF Luz – El Quemado Solar Park (USD211 million; Mendoza). Photovoltaic park with 305 MW installed capacity.   Vaca Muerta Oleoducto Sur (VMOS) (USD2.4–2.9 billion; Neuquén, Río Negro). Oil pipeline consortium: YPF, PAE, Vista, Pampa, Pluspetrol, Chevron, Shell. Capacity of up to 700,000 barrels per day.   Southern Energy – GNL Pampa del Castillo (USD6.8–15.1 billion over 20 years, Río Negro). Floating LNG-export facility; PAE, Golar LNG, YPF, Pampa Energía, and Harbour Energy. First export is expected by 2027.   Salar de Rincón (USD2.7–2.74 billion; Salta). Río Tinto lithium project, estimated to produce 60,000 metric tons per year of battery-grade lithium.   Sidersa – Steel Plant (USD286 million; San Nicolás, Buenos Aires). Estimated to produce 360,000 metric tons per year of green long steel products.   Parque Eólico Olavarría (USD276 million; Buenos Aires). PCR/ArcelorMittal Acindar.   Hombre Muerto Oeste (HMW) (USD292 million; Catamarca). Galán Lithium.   Los Azules (USD2.3 billion; San Juan). McEwen Copper; large-scale copper mining.   Agua Rica (MARA) (USD3.8–6.7 billion; Catamarca). Glencore; copper and gold mining.   Carbonatos Profundos (DCP) (USD519 million; San Juan). MASA-SD; gold and silver mining.   Terminal Multipropósito Timbúes (USD277 million; Santa Fe). Port infrastructure expansion.   PSJ Cobre Mendocino (USD891 million; Mendoza). First copper export from Mendoza province.   Veladero Expansion (USD380 million; San Juan). Barrick/Shandong Gold.   Diablillos (USD760 million; Salta). AbraSilver; gold and silver.   Cauchari-Olaroz Expansion (USD1.2 billion; Jujuy). Lithium Americas/JEMSE. Projects pending approval: Twenty-two projects totaling USD68 billion The following projects have been formally filed and are currently under evaluation by the enforcement authority. Where investment figures have been publicly disclosed, they are included. Mining Proyecto Vicuña (USD9.7 billion; San Juan). BHP/Lundin; integrates the Josemaría and Filo del Sol copper deposits. 25-year mine lifespan.   El Pachón (USD11.6 billion; San Juan). Glencore; copper. Projected to create 12,000 jobs.   Plata Grande/Bajo del Choique–La Invernada (USD12.2 billion; Neuquén). Pluspetrol; oil production of up to 100,000 barrels per day plateau.   Pozuelos Pastos Grandes (USD4.2 billion; Salta). Lithea; lithium.   Sal de Oro II (USD845 million; Salta/Catamarca). Posco Argentina; lithium carbonate, hydroxide, and phosphate plant. Projected to create 2,335 jobs.   Sal de Vida (USD1.3 billion; Catamarca). Río Tinto (second project); lithium. Expected to create 1,404 jobs.   Cauchari-Olaroz Expansion II (USD1.2 billion; Jujuy). Minera Exar.   Litio Ángeles Argentina (USD726 million; Salta). Potasio y Litio de Argentina S.A.   Salterra Lithium (USD710 million; Catamarca). LIEX S.A.   Jama Solaroz (USD1.1 billion; Jujuy). CNGR Advanced Material; lithium.   San Jorge (USD630 billion; Mendoza). Minera San Jorge; copper.   Arenas de Cercanías (USD233 million; Río Negro). Minera del Mojotoro/Minera Orosmayo. Projected to create 2,050 jobs. Hydrocarbons and energy YPF LLL Oil – Vaca Muerta (USD25 billion; Neuquén). Filed May 15, 2026 and announced simultaneously by YPF CEO Horacio Marín. The project includes 1,152 wells; 240,000 barrels per day plateau by 2032; USD6 billion per year in exports; USD100 billion in exports over the project’s lifespan. The largest RIGI filing to date.   Proyecto RDA (USD4.5 billion; Neuquén). Pampa Energía; oil and gas development.   PAE – GNL Dedicated Pipeline (USD1.3 billion; Río Negro/Neuquén). Pan American Energy; dedicated gas export pipeline.   Los Toldos (USD6.3 billion; Neuquén). Tecpetrol; upstream oil and gas development.   Duplicar Norte + MEGA Expansion (jointly, USD740 million). Oldelval/MEGA; midstream.   Gasoducto Perito Moreno Expansion (USD550 million). Transportadora de Gas del Sur. Infrastructure and industry Pampa Fértil (USD2.4 billion; Bahía Blanca). Pampa Energía; largest fertilizer plant in Latin America. Gas industrialization project highlighted by Minister Caputo.   Parque Eólico La Rinconada (USD219 million; Buenos Aires). Tenaris; wind energy to supply the SIDERCA steel plant. Projected to create 809 jobs.   NCA Railway Expansion (USD200 million; multiple provinces). Nueva Central Argentino; freight rail infrastructure. This list reflects projects publicly identified as pending as of mid-May 2026. Several additional projects may be in the pipeline but have not been individually named in official or press sources. The USD68 billion aggregate figure is according to official Ministry of Economy data. Announced but not formally filed Argentina GNL (YPF / ENI / XRG) (approximately USD20 billion). YPF has stated it plans to file a RIGI application for the Argentina GNL project in partnership with Italian ENI and Abu Dhabi's XRG (formerly ADNOC) in the coming weeks. The project involves USD20 billion in infrastructure investment and USD10 billion in upstream well development, estimated to create up to 50,000 jobs at peak.   Chevron – Vaca Muerta Expansion (over USD10 billion; Neuquén). Announced at the Milken Conference meeting with President Javier Milei and Minister Caputo (May 7, 2026). Formal RIGI filing is expected imminently. These two projects account for the bulk of the difference between the formal USD95-billion pipeline and Minister Caputo's projection of USD140 billion in total committed RIGI investment. The Súper RIGI: Key Terms The Súper RIGI is a separate, complementary regime – not a replacement for the original RIGI – designed exclusively for projects in industries that do not currently exist in Argentina or exist only at a pilot or experimental scale. The bill (Mensaje No. 181/2026, signed by President Milei, Minister Caputo, and Chief of Staff Manuel Adorni) was sent to Congress on May 23, 2026. Eligible activities Projects must involve new industrial, technological, or strategic digital/technological infrastructure activities that are not currently developed or produced in Argentina. Target sectors include artificial intelligence, semiconductors, copper refining, lithium batteries, electric vehicles, data centers, solar and wind manufacturing, uranium processing, fertilizers, and advanced biotechnology. Expansions or modernizations of existing facilities are expressly excluded from the scope of the Súper RIGI. Eligible vehicles Projects must be structured through a Single Project Vehicle (VPU) with exclusive object and ring-fenced assets. Permitted structures include local stock corporations and limited liability companies (S.A.; S.A.U.; and S.R.L.), foreign branches registered locally under Art. 118 of the General Companies Law, joint ventures (UTEs), and other partnership agreements. Minimum investment and commitment schedule The minimum investment is USD1 billion minimum per project (compared to USD200 million under the original RIGI). At least 20 percent of the minimum must be invested within the first two years from the adhesion date (compared to 40 percent under the original RIGI). The application window is five years from regulation, extendable once by one year. Income tax VPUs pay a flat rate income tax of 15% (compared to 25% under the original RIGI and the 35-percent standard rate). Accelerated depreciation is available and includes movable assets in a minimum of two annual installments and infrastructure at 60 percent in the commissioning year, plus 40 percent over two subsequent years. Net operating losses may be carried forward indefinitely and transferred to third parties after 5 years. All tax losses and adjustments are indexed to CPI. Debit and credit tax 100% of bank debit and credit tax is creditable against a VPU’s income tax. Dividend withholding tax The dividend withholding tax is 7% during the first four years from adhesion; 3.5% from year four onwards (compared to year seven under the original RIGI). Social security New employment relationships from the adhesion date are subject to a flat employer contribution rate of 10% (vs. 20.4%–26.4% standard). This benefit is not available under the original RIGI. Value-added tax Value-added tax on computable asset purchases is offset through Tax Credit Certificates (Certificados de Crédito Fiscal), freely transferable if the Customs Collection and Control Agency (ARCA) fails to process refunds within 3 months. Customs duties There is full exemption from import duties; statistics tax; and all national, provincial, and municipal levies on plan-of-investment assets (including components physically integrated into fixed assets). In addition, there is full exemption from export duties on project products. A VPU may import and export freely without quotas, prior authorizations, or price measures. FX: Export proceeds 20% of foreign currency generated by VPU’s exports freely available from year 1; 40% from year 2; 100% from year 3 (vs. 100% from year 4 under the original RIGI). Capital contributions, external financings, and service payments are exempt from settlement requirements from the beginning. Legal stability Thirty years from the adhesion date in tax, customs, social security, and FX matters. Taxes in force at adhesion are frozen; future increases do not apply. Future decreases in the general regime apply. The burden of proving that a new measure does not increase the investor's tax burden falls on ARCA, not the investor. Guarantees The national government guarantees full availability of project outputs without mandatory domestic commercialization (under other local regimes guaranteeing supply to domestic market was mandatory; for example, gas exports), protection against confiscation or expropriation, uninterrupted project operation (absent prior judicial order with due process), and unrestricted access to justice. Provincial adherence National incentives only apply to projects in provinces (and municipalities) that expressly adhere. Adhering jurisdictions must 1) cap gross turnover tax (ingresos brutos) at 0.50%  (the single most distortive local tax is up to 5% of gross sales, not including income and applicable at each stage of the local supply chain), 2) exempt all VPU transactions from stamp tax (sellos), 3) waive all royalties and administrative canons, and 4) waive the pay-to-play requirement for VPU legal challenges. Once a province adheres, subsequent withdrawal does not affect previously approved VPUs. Arbitration Similar to the original RIGI, disputes are subject to a 60-day amicable negotiation period, after which the VPU may elect the Permanent Court of Arbitration, the International Chamber of Commerce (no abbreviated procedure), or International Centre for Settlement of Investment Disputes/Additional Facility arbitration. The seat must be outside Argentina in a country that is party to the New York Convention. Proceedings require three-member tribunals, none of which can be nationals of Argentina or of a VPU-controlling shareholder. No exhaustion of administrative remedies is required and there are no limitation periods on arbitral claims. Project rights are treated as protected investments under applicable bilateral investment treaties. Mutual exclusion with the original RIGI A VPU may not adhere to the Súper RIGI if it, or a controlled-group entity, has already filed under the original RIGI with a substantially overlapping project. Overlap is defined as sharing 50%  or more of capital expenditure, principal physical assets, or projected production capacity, or having the same value chain or final product. Importantly, the bill provides that corporate reorganizations, spin-offs, transfers, or other restructurings cannot be used to circumvent this exclusion; the enforcement authority may look through any such transaction and apply the overlap test to the economic reality of the project. OECD Pillar Two Art. 45 contains a self-limiting clause by which income tax incentives will not apply to the extent that their use would result in a transfer of Argentine fiscal revenues to foreign governments through any global minimum tax mechanism, including GloBE Income Inclusion Rules, Undertaxed Profits Rule, or analogues implementing Organisation for Economic Co-operation and Development (OECD)/G-20 Pillar Two. In practice, this means investors whose parent entities are subject to Pillar Two top-up taxes in their home jurisdiction will not receive the full economic benefit of the 15-percent rate – the Argentine incentive will simply be clawed back abroad. Each investor will need to model the net after-Pillar Two benefit of the Súper RIGI based on its specific global tax profile.   III. Key issues to monitor "New activity" definition. New activity will be determined by additional regulations and requires a sworn declaration, in addition to an independent technical report. How the enforcement authority treats sectors where some domestic capacity already exists – such as partial battery assembly or small-scale copper processing – is to be determined. Investors in those sectors are encouraged to monitor for future updates.   Provincial adherence. Unlike mining and hydrocarbon projects (where geology determines location), AI, data center, semiconductor, and advanced manufacturing projects are flexible in terms of their location. Competition among provinces to attract Súper RIGI projects by offering adherence and complementary local incentives will play a role that is not present under the implementation of the original RIGI.   Mutual exclusion overlap analysis. Companies with existing RIGI filings or controlled-group projects in related sectors must complete the 50% overlap test before filing under the Súper RIGI. As noted above, the test is designed to survive restructurings, therefore, investors should analyze the economic substance of their projects rather than relying on legal form.   OECD Pillar Two impact. As explained above, the 15% rate benefit may be partially or fully offset by Pillar Two top-up taxes for investors whose parent entities are in GloBE-implementing jurisdictions. This requires case-by-case modeling before adhesion.   Investment realization gap. Commitment figures significantly exceed actual disbursements. Net FX inflows through March 2026 were USD762 million against a total committed pipeline of around USD30 billion. The gap reflects long construction timelines, for example, the GNL Pampa del Castillo project's first export is not expected until 2027, and LLL Oil's production plateau is targeted for 2032.   Congressional approval. The bill requires passage through both chambers. Final terms – including the minimum investment threshold, eligible sectors, and provincial adherence conditions – may be modified during legislative debate. The government lacks a majority but has demonstrated the ability to build sufficient coalitions on an ad hoc basis with the Ley de Bases in 2024, the Labor Reform Act and the 2026 Budget, and by significantly increasing its congressional representation. Following the October 2025 midterms – in which La Libertad Avanza (Liberty Advances, or LLA) obtained over 40% of the national vote – LLA now holds approximately 88–92 seats in the Chamber of Deputies, the largest single bloc in the lower chamber, with the Propuesta Republicana (Republican Proposal, or PRO) contributing an additional 14. To pass legislation, 129 votes are required for a quorum majority; to sustain a presidential veto, 86 are required – a threshold LLA now clears on its own for the first time. In the Senate, Peronism has fallen to just 25 senators following a series of defections in early 2026, its smallest caucus since the return of democracy in 1983. LLA itself holds 20 Senate seats, up from seven before the midterm elections. The majority threshold in the Senate is 37 votes, which the government cannot reach on its own, making the provincial governors the decisive players; these include the Unión Cívica Radical (9 senators), PRO (6 senators), and Provincias Unidas (3 senators) blocs – most aligned with non-Peronist provincial administrations – which voted with the current administration on recent laws. Given that the Súper RIGI's provincial adherence mechanism directly channels large-scale investment projects to the governors who sign on, the political incentives for a negotiated approval are substantial. For more information on conducting business in Argentina, including the RIGI framework or the Súper RIGI bill, please contact Marcelo Etchebarne, Argentina's Managing Partner; Martin Mittleman, Deputy Managing Partner and leader of the Corporate practice; Joaquin Eppens Echagüe, Deputy Managing Partner and leader of the M&A practice; Augusto Mancinelli, leader of the Tax practice; or Richard Chesley, Co-Global Managing Partner.  

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.

DLA Piper advised the Province of Chubut on the issuance of series CXVIII Class 2 Treasury Notes for an aggregate principal amount of AR$45.5 billion in debt secured notes due 2026. The debt securities were issued on May 20, 2026 and were structured with a dual fixed-rate mechanism, accruing interest at the higher of (i) a 27.00% nominal annual fixed rate or (ii) the Private TAMAR Rate plus a fixed spread of 5.50% nominal annual. The debt securities will be fully amortized at maturity on September 21, 2026. The DLA Piper team was comprised of Partner Justo Segura and Associates Federico Vieyra, and Ignacio Comparato (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.

Argentina’s National Executive Branch has approved new regulations (Regulations) governing Title II of the Labor Modernization Act No. 27,802, establishing Labor Assistance Funds (FALs). The Regulations are designed to facilitate compliance with severance obligations under the Employment Contract Law and applicable professional statutes, with coverage limited to duly registered employees. They take effect on November 1, 2026. Below, we summarize the Regulations, their scope, and key provisions. Scope of application The Regulations cover all private-sector employers, with the exception of public-sector employment relationships (as defined under Section 8 of the Financial Administration Act No. 24,156) and relationships expressly exempted under the last paragraph of Section 58 of Law No. 27,802. Small- and medium-sized enterprises are defined pursuant to former Secretary of Small and Medium Enterprise (SEPyME) Resolution No. 220/2019. Non-profit entities meeting the parameters of this Resolution, as registered before the Customs Collection and Control Agency (ARCA), are likewise covered. Legal description and structure of FALs FALs are structured through collective investment vehicles authorized by the National Securities Commission (CNV), such as mutual funds (Section 1, first paragraph, Law No. 24,083) or financial trusts (Civil and Commercial Code, Chapter 30). In all cases, asset segregation and specific earmarking of resources are required. Such vehicles are subject to the regulatory, supervisory, and enforcement jurisdiction of the CNV. Employers are required to maintain an Individual Employer Account, which is a separate, independent, non-transferable, and non-attachable fund of a pooled nature (i.e., not attributable on a per employee basis) (Section 59, Law No. 27,802) administered by an Authorized Entity. Each account is assigned a unique identifier (FAL ID) that the employer must report to ARCA. Financial trusts must implement operational continuity mechanisms no later than 24 months before the trust's maturity date, providing for renewal or orderly asset migration. Key operational definitions The Regulations provide the following definitions related to the operation of FALs: Registered employee: An employee whose employment relationship has been enrolled and reported in compliance with applicable labor and social security law at least 12 months prior to termination (Section 58, Law No. 27,802). Waiting period: Six complete and consecutive monthly accrual and payment periods, counted from the calendar month in which ARCA records the actual payment of the first employer contribution (Section 15). Deficient registration: FAL coverage is limited to amounts computed on the basis of data actually registered, without prejudice to the employer's full liability for any resulting deficiency under applicable labor law (Section 13). Portability: The transfer by an employer of accumulated funds to another CNV-authorized collective investment vehicle, provided no payment obligations are outstanding, and ARCA is duly notified. The CNV will establish applicable timeframes and frequency (Section 14). Monthly contribution and employer relief The monthly contribution is included within the Unified Social Security Contribution (CUSS), with ARCA acting as the transfer agent for the Individual Account. Non-payment, unavailability, or insufficiency of funds will not give rise to any liability on the part of the National Government or ARCA. FAL contributions may not be offset against any tax, social security, or customs obligations of the employer. Employer contribution relief (Section 76, Law No. 27,802) applies exclusively to employment relationships covered by the FAL and not subject to the Labor Formalization Incentive Regime (RIFL), while the latter remains applicable. Relief is prorated in accordance with the distribution of employer contributions across social security sub-systems (Laws Nos. 19,032; 24,013; 24,241; and 24,714). It may not be carried forward across periods or generate offsetting credits. Tax treatment Employer contributions to the FAL are deductible for income tax purposes (Section 60, Law No. 27,802). Investment returns, interest, and other income generated by fund assets, including dividend-equivalent distributions, are exempt from income tax. Amounts received by employees as severance payments are accorded the same income tax treatment applicable to the indemnification payments that they replace. Accounts and transactions of the collective investment vehicles implementing FALs are exempt from the Tax on Banking Debits and Credits (Section 25, incorporated into Executive Order No. 380/2001). Fees charged by Authorized Entities are capped at a global maximum of one percent per year on total assets under management (Section 20). Validation and payment procedure Upon termination of the employment relationship, the employer must submit to the Authorized Entity an electronic sworn statement (declaración jurada) containing: The employer's tax identification number (CUIT) and registered address The employee's full name and labor identification number (CUIL) The employee's bank account details The date and grounds for termination, with a copy of the terminating act or agreement (including any Section 241 LCT mutual termination agreement executed with the required formalities) A detailed severance computation The amount to be transferred, and The case number, if applicable. The Authorized Entity's verification is limited to: Confirmation of the employee's bank account ownership Confirmation of the employee's registered status, and Completeness of the sworn statement. Once the requirements are satisfied, funds must be transferred within five business days of the complete and accurate submission. The accuracy of severance calculations is the exclusive responsibility of the employer. Enforcement and sanctions Enforcement authority is exercised concurrently, each within its respective jurisdiction, by the Secretariat of Labor, Employment, and Social Security (STEySS); ARCA; and the CNV. The administrative fine set forth in Section 75 of Law No. 27,802 is assessed by the STEySS pursuant to the procedural framework of Law No. 18,695, and enforced by ARCA through tax enforcement proceedings (Law No. 11,683). The three agencies will establish a joint information-sharing mechanism for the detection of noncompliance. Effective date and implementing regulations The Regulations take effect on November 1, 2026 (Section 27). STEySS, ARCA, the CNV, and the Secretariat of Finance of the Ministry of Economy are required to issue all necessary clarifying and implementing regulations within 45 business days from the publication of Executive Order No. 408/2026 in the Official Gazette. For more information, please contact the authors.

DLA Piper advised the Province of Buenos Aires, Argentina, in connection with its issuance of public debt securities in the aggregate principal amount of AR$113 billion (the “TAMAR Notes”), maturing in 2027, and CER-adjustable peso-denominated public debt securities maturing in 2028, in the aggregate principal amount of AR$203 billion (the “CER Notes”). The Province of Buenos Aires will use the net proceeds to finance public investment projects currently underway or expected to commence and to repay public debt obligations. The debt securities, which mature on April 30, 2027, will be repaid in full at maturity and will accrue interest at a rate equal to the TAMAR rate plus a fixed margin of 7 percent per annum. The DLA Piper team representing the Province of Buenos Aires included Partner Justo Segura and Associates Federico Vieyra and Ignacio Comparato, all based in Buenos Aires. DLA Piper’s Latin America team offers full-service business legal counsel to domestic and multinational companies with interests and operations throughout the region. Our integrated approach combines local knowledge with the resources of DLA Piper’s global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, together with our US-based cross-border attorneys, our teams frequently collaborate with colleagues across the Latin America region, the Iberian Peninsula, and around the world. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve clients’ legal and business needs, whether they are based in Latin America or seeking to do business there. For more information, visit Latin America | DLA Piper.

DLA Piper advised the Province of Chubut on the issuance of US$650 million in international debt securities due 2036, as well as on a cash tender offer for the outstanding US dollar-denominated secured notes due 2030. The Debt Securities were issued on April 29, 2026 and bear interest at a 9.450% nominal annual rate. The Province plans to use the proceeds to buy back some of the BOCADE Public Securities maturing in 2030 and to fund infrastructure projects and public works. This includes optimizing the Lago Musters–Comodoro Rivadavia, Rada Tilly, and Caleta Olivia Regional Aqueduct, as well as supporting related projects and purchasing equipment and instruments needed to open the High Complexity Hospital of Trelew “María Humphreys.” The DLA Piper team comprised of Partners Joshua Kaufman (New York), Marcelo Etchebarne, Justo Segura, Of Counsel Nicolás Teijeiro, and Associates Daiana Suk, Federico Vieyra, Ignacio Comparato and Martina Miret (all Buenos Aires). DLA Piper’s Latin America team offers full-service business legal counsel to domestic and multinational companies with interests and operations throughout the region. Our integrated approach combines local knowledge with the resources of DLA Piper’s global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, together with our US-based cross-border attorneys, our teams frequently collaborate with colleagues across the Latin America region, the Iberian Peninsula, and around the world. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve clients’ legal and business needs, whether they are based in Latin America or seeking to do business there. For more information, visit Latin America | DLA Piper.

DLA Piper advised the Province of Mendoza on the issuance of Class 1 CER debt securities in an aggregate amount of approximately AR$296 billion, maturing on April 10, 2028, and Class 2 CER debt securities in an aggregate amount of approximately AR$149 billion, maturing on April 10, 2029. The DLA Piper team was led by Partner Justo Segura and included Associates Federico Vieyra and Ignacio Comparato, all based in Buenos Aires. DLA Piper’s Latin America team offers full-service business legal counsel to domestic and multinational companies with interests and operations throughout the region. Our integrated approach combines local knowledge with the resources of DLA Piper’s global platform. With more than 400 lawyers practicing throughout Argentina, Brazil, Chile, Mexico, Peru, and Puerto Rico, together with our US-based cross-border attorneys, our teams frequently collaborate with colleagues across the Latin America region, the Iberian Peninsula, and around the world. DLA Piper’s global platform of 90+ offices in more than 40 countries enables us to serve clients’ legal and business needs, whether they are based in Latin America or seeking to do business there. For more information, visit Latin America | DLA Piper.

DLA Piper advised leading Argentine private energy company Central Puerto on its acquisition of 100 percent of the share capital of Patagonia Energy S.A. The transaction marks Central Puerto’s entry into the oil and gas sector. The DLA Piper team was composed of Partners Antonio Arias and Augusto Mancinelli and included Associates Ignacio Bard, Carmen del Pino, Martina Miret, and Milagros Padilla (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.

DLA Piper advised Banco de la Ciudad de Buenos Aires (Banco Ciudad) on the public bank’s issuance of Class 23 and Class 24 UVA-denominated debt securities, totaling 55,231,066 UVAs, to support housing finance and infrastructure investment in Argentina. Net proceeds may be used to expand housing finance and mortgage lending and to fund infrastructure projects across Argentina, including energy, urban development, real estate, culture, and services initiatives, as well as other projects that advance economic and social development. The debt securities have been authorized for listing and trading on Bolsas y Mercados Argentinos S.A. and A3 Mercados S.A., respectively. The DLA Piper deal team in Argentina was led by Partner Alejandro Noblía with support from Associate Federico Vieyra (both 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.