Annex A: Operational Transition Plan and Contractual Adaptation — MiCA Regulation (European Economic Area)

Supplement to the General Terms and Conditions of Use of the BNKA Platform.

This Annex sets out the formal procedure for the discontinuation, liquidation, and orderly safeguarding of the platform's digital asset services vertical within the European Economic Area (EEA), in strict compliance with Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA).

1. Definitive Suspension of Digital Asset Operations

Effective as of 1 July 2026, the platform will permanently cease all active crypto-asset-related operations for EEA users, including, without limitation, the purchase, exchange (inbound swap), receipt, and deposit of new digital funds. Any inbound transfer executed after this date will be rejected by network nodes, and the platform disclaims all liability for asset losses on disabled channels.

2. Preferential Liquidation Window

A grace period is established, ending irrevocably on 30 July 2026 (the "Liquidation Deadline"). During this period, users with crypto-asset balances greater than zero (>0) will have restricted access in "Withdrawal-Only" mode to exclusively carry out:

• Ordinary Conversion: final sale of their crypto-assets with direct crediting to their fiat balances in Euros (EUR), which remain fully operational.
• External (On-Chain) Withdrawal: transfer of their assets to external addresses under their own control, operating through the compatible blockchain networks indicated in the user interface.

3. Verification of Ownership and AML Control on Fiat Withdrawals

In strict accordance with applicable Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) regulations, any withdrawal of Euro (EUR) funds resulting from the liquidation of digital assets will be processed solely and exclusively to bank accounts (IBAN) whose ownership matches exactly and precisely the User's identity data previously verified through BNKA's Know Your Customer (KYC) process. The processing of outbound transfers to third-party accounts is strictly prohibited and blocked.

4. Regime for Blocked Remaining Balances and Inactive Custody Fee

Once the Liquidation Deadline has elapsed, the platform will proceed to close the autonomous digital asset operational interfaces. Crypto-asset balances (including remaining, residual balances or those below the technical minimum transaction thresholds) that have not been claimed or withdrawn will be moved outside the app's ordinary environment to segregated, contingency technical custody accounts, and the user will lose the ability to dispose of them automatically.

In order to cover the extraordinary costs of technical security, segregated infrastructure, specific private key control, and regulatory compliance for orphaned balances, starting on day sixty (60) after the Liquidation Deadline, BNKA will apply an Administrative Fee for Custody of Inactive Balances of up to the equivalent of EUR 10.00 per month.

This fee will be deducted automatically and directly from the user's remaining balance until the accounting balance reaches zero (0). The legitimate holder may only request the manual withdrawal of their remaining funds by formally arranging it through the official channel compliance@bnka.com, and such release will be conditional on strict, enhanced, and up-to-date verification of their identity (KYC) and the source of the funds (AML).

5. Consent, Contractual Precedence, and Fiduciary Continuity

The exercise of the transition options within the interface, continued access to the platform, or the maintenance of custodied balances after notification of this document constitutes the User's express and unequivocal consent to the terms of this Annex. The provisions contained herein represent a legitimate contractual amendment made for regulatory reasons and shall take precedence, with a higher hierarchical rank, over any clause of the General Terms and Conditions of Use that may be contradictory.

It is reiterated that ordinary payment accounts, EUR balances, and vIBANs are not affected in any way and remain fully in force.