External Assets and Liabilities Survey Regime Updated

On August 19, 2025, the Argentine Central Bank (BCRA) issued Communication “A” 8304, introducing changes to the External Assets and Liabilities Survey (EALS) regime, originally established through Communication “A” 6401 and its supplements.

This measure updates the guidelines that individuals and legal entities must comply with for submitting information on assets and liabilities abroad, to specify the deadlines and procedures for filing returns.

• 2017–2019 statements: sampling criteria

Firstly, the regulation replaces point 2 of the Annex to Communication “A” 6401 regarding the declarations for financial years 2017–2019 inclusive. Here, the different sampling levels are maintained according to the magnitude of the flows and balances of external assets and liabilities:

1. Main sample: composed of subjects whose annual balances or flows reached or exceeded USD 50 million, who must make quarterly advance payments and submit an annual statement consolidating and rectifying the submitted information.

2. Secondary sample: consisting of those with values between USD 10–50 million, who are only required to file an annual return.

3. Supplementary sample: those who register between USD 1–10 million, also with an annual declaration, but using a simplified form.

Communication “A” 8304 requires that those who are not included in the previous sections but had debts with non-residents at the end of 2018 or 2019 file returns in simplified format.

• 2020-2025 statements: expanded obligations

Regarding the submission of data for the period from the 1^st quarter of 2020 to the 4^th quarter of 2025 inclusive, the BCRA establishes that all individuals or legal entities that record external liabilities at the end of a calendar quarter, or that have settled them during that period, must submit the EALS declaration. Likewise, those that accumulate balances equal to or greater than USD 50 million at the end of each year must also file an annual report (which will allow them to supplement, ratify, and/or rectify the quarterly filed reports). This is in addition to the quarterly reports, which may be filed optionally by any legal or natural person.

• EALS guidelines based on data for the first quarter of 2026

Main sample. This will include all entities with external assets and liabilities equal to or greater than USD 10 million at the end of any quarter. In this case, the reports must be filed quarterly and, in addition, a simplified annual statement will be required, reporting only the forms relating to investors, income statement, changes in net equity, and balance sheet.

If the reporter ceases to record external liabilities, they must still submit the declaration corresponding to the quarter in which this situation occurs, to reflect the cancellation of said liabilities.

Secondary sample. This will include those who maintain balances of less than USD 10 million in all quarters of the year. These reporters will only be required to submit an annual affidavit. If the threshold is exceeded in any quarter, the reporter will be included in the main sample for the rest of the period. To be eligible as part of the secondary sample, the reporter must not have debts equal to or greater than the threshold in other associated BCRA surveys. The Communication clarifies that entities may not charge fees for reporting circumstances that imply a reduction in such debts without access to the foreign exchange market.

If the reporter ceases to have external liabilities, they must still submit the annual declaration for the year in which this situation occurs, to reflect they paid said liabilities.

• Expiration dates

Finally, Communication “A” 8304 modifies the deadlines for filing returns. For the periods between 2020 and 2025, it sets a maximum of 45 calendar days from the end of the quarter for quarterly returns. And it maintains the 180 calendar days from the end of the year for annual returns.

Based on data from the first quarter of 2026, the deadlines for submitting reports will be:

1. Main sample: 45 calendar days from the end of the reference calendar quarter for quarterly filings and 180 calendar days from the end of the calendar year for annual filings.

2. Secondary sample: 90 calendar days from the end of the reference calendar year for annual submissions.