What changed in this filing

/stocks — the workspaceLOADING

Item 1. Business

2024-02-23 compared with 2023-02-24 · 177 added, 131 removed, 323 unchanged (49% of the section changed)

20 unchanged sentences

Our digital payments solution enables any Mercado Libre registered user to securely and easily send and receive digital payments and to pay for purchases made on any of Mercado Libre’s Marketplaces.

Currently, Mercado Pago processes and settles all transactions on our Marketplaces in Argentina, Brazil, Mexico, Chile, Colombia, Uruguay and Peru, and is available to process and settle transactions on our Marketplace in Ecuador.

Currently, Mercado Pago processes and settles all transactions on our Marketplaces in Argentina, Brazil, Mexico, Colombia, Chile, Uruguay, Peru and Ecuador.

Beyond facilitating Marketplace transactions, over the years we have expanded our array of Mercado Pago services to third parties outside Mercado Libre’s Marketplace.

7 unchanged sentences

■ In-store physical payments by selling mobile point of sale (“MPOS”) devices and through quick response (“QR”) payment codes;

• Digital payment solutions for utilities, mobile phone top up, peer-to-peer payments and more through our mobile wallet;

• Pre-paid cards and debit cards for users to spend and withdraw their account balances from their Mercado Pago wallet;

■ Digital payment solutions for utilities, mobile phone top up, peer-to-peer payments and more through our digital account;

■ Pre-paid cards and debit cards for users to spend and withdraw their account balances from their Mercado Pago digital account;

■ Merchant and consumer credits, both on and off the Mercado Libre Marketplace, and credit cards;

■ Insurance products such as extended warranties, theft and damage policies, among others;

5 | MercadoLibre, Inc.

■ Savings and investment products to invest balances stored on Mercado Pago accounts;

• A cryptocurrency buy, hold and sell feature of our wallet in Brazil and Mexico, for users to buy, hold and sell selected global cryptocurrencies and stablecoins.

■ A cryptocurrency buy, hold and sell feature of our wallet in Brazil, Mexico and Chile, for users to buy, hold and sell selected global cryptocurrencies and stablecoins.

Mercado Credito, our credit solution available in Argentina, Brazil, Mexico and Chile, leverages our user base, which is loyal and engaged, and in part has also been historically underserved or overlooked by financial institutions and suffers from a lack of access to needed credit.

4 unchanged sentences

Consumers can access credit lines through us once we score and approve them through our proprietary models.

Loans can be used for a purchase on the Mercado Libre Marketplace, or for any other usage.

Since 2019, we also extend personal loans to recurring consumer credit borrowers, allowing them to buy products and services outside of our platform.

In 2021, we launched our first Mercado Pago credit card in Brazil, which is free, internationally accepted, digitally managed and can be used on- and off-platform.

An advantage of the credit card is that it allows users to pay in additional installments for purchases on the Mercado Libre Marketplace and accrue additional points to our user loyalty program.

Our credits business was initially impacted by the COVID-19 pandemic, particularly in the early stages of the pandemic when we slowed our pace of originations to manage our exposure to credit risk.

As 2020 progressed and transaction levels improved across our platforms, we began to collect more data in our proprietary credit models, which helped us gain a better understanding of users.

This understanding enabled us to more accurately predict their behavior and continue increasing the pace of originations while maintaining levels of uncollectible debt in an acceptable level from a business perspective in 2021 and 2022.

In mid-2022 we slowed our originations once more to contain the risks associated with a weaker lending environment, particularly in Brazil, which enabled us to maintain stable levels of early non-performing loans ("NPLs").

Our asset management product, which is available in Argentina, Brazil and Mexico, is a critical pillar to build our alternative two-sided network vision.

Loans can be used for a purchase on the Mercado Libre Marketplace, or on third party sites that use our payments processing technology.

Since 2019, we also extend personal loans to recurring consumer credit borrowers, allowing them to buy products and services outside of our platform via the Mercado Pago digital account.

In 2021, we launched our first Mercado Pago credit card in Brazil, followed by Mexico in 2023, which is free, internationally accepted, digitally managed and can be used on- and off-platform.

An advantage of the Mercado Pago credit card is that it allows users to pay in additional installments for purchases on the Mercado Libre Marketplace and accrue additional points to our user loyalty program.

We collect data in our proprietary credit models, which helps us better understand and more accurately predict the behavior of our users, and continue increasing the pace of originations while maintaining levels of uncollectible debt at an acceptable level from a business perspective.

Our asset management product, which is available in Argentina, Brazil, Mexico and Chile, is a critical pillar to build our alternative two-sided network vision.

It incentivizes our users to begin to fund their digital wallets with cash as opposed to credit or debit cards given that the return our product offers is greater than traditional checking accounts.

With a seamless onboarding, this product allows users to withdraw and use the value stored in their digital wallets at any given time through QR code in-store payments, pre-paid cards, or cash withdrawn from an ATM, without requiring that their funds be trapped in a money market fund or a certificate of deposit to obtain an equivalent return.

With a seamless onboarding, this product allows users to withdraw and use the value stored in their digital wallets at any given time through QR code in-store payments, pre-paid and debit cards, or cash withdrawn from an ATM, without requiring that their funds be trapped in a money market fund or a certificate of deposit to obtain an equivalent return.

This product is another way in which we continue to innovate, leveraging the rising trust in third-party e-commerce platforms and low levels of formal sector financial inclusion, which generate a unique opportunity for investment products aimed at users in Latin America who are unbanked or underbanked.

As an extension of our asset management and savings solutions for users, we launched a digital assets feature as part of the Mercado Pago wallet in Brazil in 2021 and in Mexico in 2022.

This service allows our millions of users to purchase, hold and sell selected digital assets through our interface without leaving the Mercado Pago application, while a partner acts as the custodian and exchange and offers the blockchain infrastructure platform.

As an extension of our asset management and savings solutions for users, we launched a digital assets feature as part of the Mercado Pago wallet in Brazil, Mexico and Chile, in 2021, 2022 and 2023, respectively.

This feature is available for all users through their Mercado Pago wallet.

1 unchanged sentence

In partnership with a third party, we also launched three investment fund options in Brazil, which enable our users to diversify their investment portfolio in an accessible way and with options for quick withdrawal.

Our advertising platform, Mercado Ads, enables businesses to promote their products and services on the internet.

Through our advertising platform, brands and sellers are able to display ads on our webpages through product searches, banner ads or suggested products.

Our advertising platform, Mercado Ads, enables businesses to promote their products and services on the Mercado Libre Marketplace and Mercado Pago Fintech platform.

Through our advertising platform, brands and sellers are able to display ads on our pages through product searches, banner ads or suggested products.

Our advertising platform enables merchants and brands to access the millions of consumers that are on our Marketplaces at any given time with the intent to purchase, which increases the likelihood of conversion.

Advertisers are able to leverage our first-party data to create and target highly particularized audiences.

Through Mercado Libre Classifieds, our online classified listing service, our users can also list and purchase motor vehicles, real estate and services in the countries where we operate.

4 unchanged sentences

Users can create a store at no cost, and can access additional functionalities and value added services on commission.

Our loyalty program offers various benefits to users based on a point-generation system that quantifies the user’s spending on the Mercado Libre Marketplace and Mercado Pago.

Level 6, the highest level of the six tier program, offers the most benefits, which includes discounts on shipping for purchases that fall below the free shipping threshold, free and subsidized access to third-party video content and higher rates of interest on some of our savings and investment account products, among other benefits.

We also enable users to subscribe to Level 6 for a monthly fee, giving them access to the full suite of benefits without having to reach the number of points required to be eligible for Level 6 organically, through the point-generation system.

Finally, we also offer our users subscriptions to video content from certain third-party content providers for a monthly fee.

In 2023, we relaunched our loyalty program in Brazil and Mexico, simplifying the experience with the elimination of the prior levels system and offering a brand new paid subscription, Meli+, which includes free shipping on more products, free Disney+ and Star+, as well as Deezer Music Premium free for the first 12 months.

The subscription also includes video content discounts for certain third-party content providers such as HBO Max, Paramount+ and Vix.

In Argentina, Chile and Colombia we still have the original Level 6 subscription.

In addition, in 2023 we launched Mercado Play, a streaming service available to all users in Argentina, Brazil, Mexico, Colombia, Chile, Peru and Uruguay.

The platform offers users access to content from various national and international content studios at no cost.

6 | MercadoLibre, Inc.

The following table shows the main services currently available in each country where we operate:

Country Marketplace Mercado

Pago Mercado Envios Mercado Credito

Country Marketplace Mercado Pago Mercado Envios Mercado Credito

Argentina ü ü ü ü

10 unchanged sentences

Services and Product Sales.

Our Services revenue stream is mainly generated from Marketplace fees that include final value fees and flat fees for transactions below a certain merchandise value, related shipping fees net of third-party carrier costs (when we act as an agent), classifieds fees, ad sales up-front fees, and fees from other ancillary businesses.

Our Services revenue stream is mainly generated from Marketplace fees that include final value fees and flat fees for transactions below a certain merchandise value, related shipping fees net of third-party carrier costs (when we act as an agent) and storage fees, classifieds fees, advertising sales fees, and fees from other ancillary businesses.

Our Product Sales revenue stream entails selling merchandise on a first-party basis from our own inventory and related shipping fees.

17 unchanged sentences

We believe that a significant portion of our growth will be derived from these new or expanded product and service launches within our ecosystem in the future.

7 | MercadoLibre, Inc.

■ Continue to improve the shopping experience for our users .

15 unchanged sentences

Our marketing strategy is designed to grow our platform by promoting the Mercado Libre and Mercado Pago brands, attracting new users, generating more frequent trading by our existing users and cross-selling services among our existing user base within our entire ecosystem of commerce and fintech.

To this end, we employ various means of advertising, including placement in leading online channels across Latin America, paid and organic positioning in leading search engines, email and push notification marketing, onsite marketing, presence in offline media and live-streaming events, and use of targeted promotional discount coupons.

During 2022, we strengthened our demand generation efforts in Mercado Libre with multiple initiatives.

We also accelerated our digital financial services positioning for Mercado Pago.

To this end, we employ various means of advertising, including placement in leading online channels across Latin America, paid and organic positioning in leading search engines, email and push notification marketing, onsite marketing, presence in offline media, sponsorship of large events, and use of targeted promotional discount coupons.

During 2023, we strengthened our buyers acquisition and demand generation efforts in Mercado Libre with multiple initiatives that helped us drive total gross merchandise volume (“TGMV”) while gaining efficiency in our budget investments.

We also relaunched our loyalty program (Meli+) to increase users engagement and accelerated our digital financial services positioning for Mercado Pago.

These campaigns were rolled out across public TV, cable TV, radio, billboards and online media.

We continued carrying out a complete coverage of promotional campaigns on commercial dates such as Children’s Day, Mother’s Day, Father’s Day, Christmas and dates specific to the e-commerce industry, such as Hot Sale, CyberMonday and Black Friday, leveraging our unique ecosystem of solutions within advertising, Mercado Credito, Mercado Shops and Mercado Envios.

We continued carrying out a complete coverage of promotional campaigns on commercial dates such as Children’s Day, Mother’s Day, Father’s Day, Christmas and dates specific to the e-commerce industry, such as Hot Sale, CyberMonday, Black Friday and Buen Fin, leveraging our unique ecosystem of solutions within advertising, Mercado Credito, Mercado Shops and Mercado Envios.

Product Development and Technology

On December 31, 2022, we had 13,856 employees on our information technology and product development staff, an increase from 9,471 employees on December 31, 2021, due to new hires and as a consequence of improvements in our ecosystem products, which increased our information technology and product development staff.

On December 31, 2023, we had 15,638 employees on our information technology and product development staff, an increase of 13% from 13,856 employees on December 31, 2022, due to new hires and as a consequence of improvements in our ecosystem products, which increased our information technology and product development staff.

We continually work to improve both our Mercado Libre Marketplace and Mercado Pago mobile apps and websites so that they better serve our users’ needs and function more efficiently.

12 unchanged sentences

We also rely on certain technologies that we license from third parties, suppliers of key database technology, operating systems and specific hardware components for our services.

8 | MercadoLibre, Inc.

In the past, we started a deep technology overhaul to switch from a closed and monolithic system to an open and decoupled one.

9 unchanged sentences

Like most retail businesses, we experience the effects of seasonality in all of the countries in which we operate throughout the calendar year.

Although much of our seasonality is due to the year-end promotional campaigns and the Christmas holiday season, the geographic diversity of our operations helps mitigate the seasonality attributed to summer vacation time (i.e.

southern and northern hemispheres) and national holidays.

Typically, the fourth quarter of the year is the strongest in every country where we operate due to the significant increase in transactions before the holiday season.

Although much of our seasonality is due to the year-end promotional campaigns and the Christmas holiday season, the geographic diversity of our operations (i.e.

southern and northern hemispheres) helps mitigate the seasonality attributed to summer vacation time and national holidays.

Typically, the fourth quarter of the year is the strongest in terms of revenue in every country where we operate due to the significant increase in transactions before the holiday season.

The first quarter of the year is generally our slowest period.

2 unchanged sentences

This first quarter seasonality is partially mitigated by our operations in the countries located in the northern hemisphere, such as Colombia and Mexico, the slowest months for which are the summer months of July, August and September.

Lastly, commercial campaigns like Hot Sale, Black Friday and Cyber Monday generate an increase in transactions.

Lastly, commercial campaigns like Hot Sale, CyberMonday, Black Friday and Buen Fin generate an increase in transactions.

The online commerce market is rapidly evolving and is highly competitive.

2 unchanged sentences

Over the past few years, we have seen competition intensify not only as local players grow their e-commerce businesses, but also as international players expand, mainly in Brazil and Mexico.

That said, over the last 12 months, we have seen signs of some local and international players retrenching.

The financial services market is also becoming increasingly competitive with the growth of several fintechs established in Latin America.

5 unchanged sentences

Intellectual Property Rights

Our intellectual property rights (“IPRs”) are critical to our future success and rely on a combination of copyright, trademark, patent designs, trade secret laws and contractual restrictions.

Our intellectual property rights are critical to our future success and rely on a combination of copyright, trademark, patent designs, trade secret laws and contractual restrictions.

We pursue the registration of our intangible assets in each country where we operate.

2 unchanged sentences

Risk factors—Intellectual Property Risks—We could face legal and financial liability upon the sale of items that infringe intellectual property rights of third parties and for information and material disseminated through our platforms”, which describes these risks as well as our Brand Protection Program, which we make available to IPR holders to enable them to enforce their rights against listings on our sites that allegedly infringe upon their rights.

We have entered into confidentiality and intellectual property (“IP”) assignment agreements with our employees and certain contractors.

We have entered into confidentiality and intellectual property assignment agreements with our employees and certain contractors.

To prevent disclosure of our proprietary information to unauthorized parties, we have also entered into non-disclosure agreements with our employees, strategic partners and suppliers.

4 unchanged sentences

We could potentially face claims alleging that our technologies infringe the property rights of others.

9 | MercadoLibre, Inc.

Human Capital

2 unchanged sentences

Country Number of Employees

Argentina 10,130

Brazil 22,791

Mexico 16,195

Argentina 10,663

Colombia 4,419

3 unchanged sentences

Our employees in Brazil are represented by different labor unions:

i) Fetramag ( “Federação dos Trabalhadores na Movimentação de Mercadorias em Geral de Goiás, Bahia e Piauí” ) in the States of Goias, Bahia and Piauí, ii) Fetrammergs ( “Federação dos Trabalhadores na Movimentação de Mercadorias em Geral, Comércio Armazenador e Auxiliares de Administração de Armazéns Gerais do Estado do Rio Grande do Sul” ) in the State of Rio Grande do Sul, iii) Sindiesp ( “Sindicato dos Trabalhadores nas Empresas de Internet Manutenção e Cursos de Informática do Estado de São Paulo” ) in the State of São Paulo, iv) Fetramov ( “Federação dos Trabalhadores na Movimentação de Mercadorias em Geral e Operações de Logística do Estado de Minas Gerais” ) in the State of Minas Gerais, v) Sintracamp ( “Sindicato da Categoria Profissional dos Trabalhadores Empregados e Avulsos, na Movimentação e Ensacamento de Mercadorias e de Cargas e Descargas em Geral de Campinas e Região” ) in the city of Louveira, State of São Paulo, vi) Sintrammgep ( “Sindicato dos Trabalhadores em Movimentação de Mercadorias em Geral de Paulínia e Região” ) in the city of Cajamar, State of São Paulo, vii) Fetrammasc ( “Federação dos Trabalhadores na Movimentação de Mercadorias em Geral e Auxiliar de Administração em Gerais, Similares, Conexos” ) in the State of Santa Catarina, viii) Sintramoju ( “Sindicato dos Trabalhadores na Movimentação de Mercadorias em Geral e Logistica de Jundiaí e Região” ) in the city of Franco da Rocha, State of São Paulo, ix) Sintrammsp ( “Sindicato dos Trabalhadores, na Movimentação de Mercadorias em Geral e Auxiliar na Administração em Geral de São Paulo” ) in the City of Perus, State of São Paulo, and x) Sindlog ( “Sindicato dos Empregados em Escritórios de Empresas de Transportes Rodoviários de Cargas Secas e Molhadas, Cargas Pesadas e Logísticas em Transportes de São Paulo e Itapecerica de Serra” ), in the cities of São Paulo e Itapecerica da Serra, State of São Paulo.

i) Fetramag (“Federação dos Trabalhadores na Movimentação de Mercadorias em Geral de Goiás, Bahia e Piauí”) in the States of Goias, Bahia and Piauí, ii) Fetrammergs (“Federação dos Trabalhadores na Movimentação de Mercadorias em Geral, Comércio Armazenador e Auxiliares de Administração de Armazéns Gerais do Estado do Rio Grande do Sul”) in the State of Rio Grande do Sul, iii) Sindiesp (“Sindicato dos Trabalhadores nas Empresas e Cursos de Informática do Estado de São Paulo”) in the State of São Paulo, iv) Fetramov (“Federação dos Trabalhadores na Movimentação de Mercadorias em Geral e Operações de Logística do Estado de Minas Gerais”) in the State of Minas Gerais, v) Sintracamp (“Sindicato da Categoria Profissional dos Trabalhadores Empregados e Avulsos, na Movimentação e Ensacamento de Mercadorias e de Cargas e Descargas em Geral de Campinas e Região”) in the city of Louveira, State of São Paulo, vi) Sintrammgep (“Sindicato dos Trabalhadores em Movimentação de Mercadorias em Geral de Paulínia e Região”) in the city of Cajamar, State of São Paulo, vii) Fetrammasc (“Federação dos Trabalhadores na Movimentação de Mercadorias em Geral e Auxiliar de Administração em Gerais, Similares, Conexos”) in the State of Santa Catarina, viii) Sintramoju (“Sindicato dos Trabalhadores na Movimentação de Mercadorias em Geral e Logistica de Jundiaí e Região”) in the city of Franco da Rocha, State of São Paulo, ix) Sintrammsp (“Sindicato dos Trabalhadores, na Movimentação de Mercadorias em Geral e Auxiliar na Administração em Geral de São Paulo”) in the city of Perus, State of São Paulo, x) Sindpd SC (“Sindicato dos Empregados em Empresas de Processamento de Dados de Santa Catarina”) in the State of Santa Catarina, and xi) Sinetrosv (“Sindicato dos Empregados em Escritório de Empresas de Transporte Rodoviário de Osasco, Sorocaba e Vale do Ribeira”) in the cities of Osasco, Sorocaba and Vale do Ribeira, State of São Paulo.

Also, some of our employees in Argentina are represented by the Commercial Labor Union (“Sindicato de Empleados de Comercio”) and our fulfillment employees in Argentina are represented by “Sindicato de Carga y Descarga” and some of our employees in Uruguay are represented by the Commercial Labor Union (“Federación Uruguaya de Empleados de Comercio y Servicios”).

In Mexico some of our fulfillment employees are represented by the Mexican Commercial Labor Union (“Federación Obrera Sindical de la República Mexicana”).

Unions or local regulations in other countries could also require that employees be represented.

We consider our relations with our employees to be good and we implement a variety of human resources practices, programs and policies that are designed to hire, develop, compensate and retain our employees.

Talent, Culture and Development

Culture and Development

If we want to shed light on the most significant attribute that makes MercadoLibre a unique place to work at, we need to point to our entrepreneurial culture.

This attribute, visible since our early garage days in Buenos Aires, continues to live in the more than 58,000 people that create our great team across Latin America.

MercadoLibre’s DNA, our culture, is best represented by a protagonist attitude, a relentless mandate to create value for our clients, to take risks and innovate, while delivering excellence as a team.

MercadoLibre’s DNA, our culture, is best represented by a protagonist attitude, a relentless mandate to create value for our users to take risks and innovate, while delivering excellence as a team.

Integrity nurtures our DNA and defines our identity, beliefs and conduct.

For 24 years, our culture has played a major role in our Company’s exciting and successful story, becoming a competitive advantage and a major differentiating factor.

Our leadership team takes a central role in modeling our culture.

One of our cultural principles is “Lead by example”.

Our leaders are expected to be the first to give their best, to spread enthusiasm and, above all, to inspire the Company’s culture and DNA with their actions.

Over the past year, we have trained over 1,500 leaders to become multipliers of our DNA.

This included over 70 training sessions focused on maximizing the impact of our leaders, with an emphasis on overcoming challenges, embodying MercadoLibre's culture through a protagonist attitude, and the importance of effective feedback.

We are excited about the positive impact these trainings have generated, not only on the participants and their teams but, consequently, on the business results.

In 2024, we expect to reach a total of more than 1,800 leaders.

In 2023, our “Leading Ops” program trained over 3,400 leaders to strengthen management in our logistics operation, which has enhanced productivity and has helped us continue with our expansion goal of our logistics network reaching every home in Latin America.

10 | MercadoLibre, Inc.

Leading the business in every market where we operate requires attracting, engaging and developing the best talent.

1 unchanged sentence

In a fast-paced, dynamic, joyful and collaborative environment, we offer people the opportunity to develop through complex challenges, pursuing excellence and achieving outstanding results while working as a team.

Over the last two years, as our business thrived, MercadoLibre more than doubled its headcount without losing our distinct culture.

We remain committed to preserve the singular qualities that our DNA brings, scaling excellence and being agile to turn challenges into opportunities.

Loyal to our agile and entrepreneurial culture, at MercadoLibre we seek to develop an environment that offers maximum flexibility, that connects people, and at the same time, inspires them to give their best.

We are driven by the purpose of democratizing commerce and financial services to transform the lives of millions of people across Latin America.

Everything we do as a company begins and ends with this purpose in mind, and our culture guides and inspires every decision that we make and every initiative that we launch.

Recruitment and Hiring

Talent, Recruitment and Hiring

Our recruitment and hiring strategy is an example of our commitment to serve as a growth engine for Latin America in response to the challenges presented in the last years.

In 2022, we continued to generate quality employment.

Our 2022 Hiring Plan, which created more than 10,000 jobs at the regional level, impacted our business and the development of Latin America.

In 2022, we started with a team of 29,957 people and ended with 40,548 employees.

It is a privilege and source of pride to continue generating quality employment in Latin America.

This year, we achieved a new milestone, surpassing 58,000 employees at MercadoLibre.

This year, we welcomed over 17,500 employees across the region, with significant growth in our Technology, Product, and Logistics teams.

We have been consistently expanding over the last 10 years, and in the last three years, we have almost quadrupled our workforce (from 15,546 to 58,313 employees), without losing our distinct culture.

We remain committed to preserving the singular qualities that our DNA brings, scaling excellence and being agile to turn challenges into opportunities.

This ongoing evolution solidifies us year after year as leaders in job creation with a distinctive value proposition.

The growth in direct employment, coupled with the development of our business, has a significant impact in terms of indirect employment, by multiplying opportunities and jobs throughout the value chain and among the hundreds of thousands of MSMEs that trust our ecosystem today.

This growth allowed us to continue to expand the shipping network and strengthen the technology team that develops our commerce and fintech solutions throughout the region.

4 unchanged sentences

With this perspective in mind, we work on the comprehensive nature of well-being, which includes physical and emotional health, social connection, and financial well-being.

Around these four pillars, we deploy our well-being proposal that includes activities, talks with specialists, learning opportunities, and meetings that aim at social connection and fun (which is also part of our culture, because at MercadoLibre we strive for our best and work intensively while enjoying what we do).

Our well-being initiatives during the pandemic reflect the impact we seek to have on our teams' health.

In partnership with the Ineco Foundation and Humanize Consulting, we launched a mental health mapping tool to assess our people's emotional state and develop a data-based well-being strategy that could support each individual according to their individual needs.

This tool allowed us to identify people who were showing high symptoms of depression and/or anxiety, and to provide them professional, personalized and confidential support.

In 2023, we organized the second edition of the Wellbeing Summit, a regional virtual event available to all our employees to discuss, alongside distinguished speakers, the comprehensive nature of well-being, as well as habits and routines to boost productivity and performance.

Diversity and Inclusion

3 unchanged sentences

Our mission regarding diversity and inclusion is focused on three dimensions:

○ The construction of diverse teams, seeking complementary profiles.

To include all perspectives and accelerate the change in mindset of the organization, in 2022 we set out to advance diversity especially in the following four pillars:

■ The construction of diverse teams that reflect the diversity of our users, by increasing representation and inclusion of different profiles and experiences.

To include all perspectives and accelerate the change in mindset of the organization, we set out to advance diversity especially in the following four pillars:

ethnicity, gender, sexual orientation and expression, and disability.

3 unchanged sentences

■ The promotion of an inclusive society, fostering equal opportunities for all with products, services, and initiatives.

11 | MercadoLibre, Inc.

We prioritize the inclusion and development of women in our sector.

3 unchanged sentences

At MercadoLibre, we are constantly progressing by promoting increasingly inclusive teams and environments, and also evolving accessible technologies for providers and users.

The percentage of our employees with disabilities doubled in 2021, and now there are almost 700 people with disabilities who give their maximum every day.

The percentage of our employees with disabilities doubled in 2021, and now there are more than 1,000 people with disabilities who give their maximum every day (more than 280 of whom joined MercadoLibre during 2023).

In addition, our commitment to the promotion of an increasingly inclusive society impacts our business.

1 unchanged sentence

For example, all the main streams are developed so that they can be interpreted and converted to audio by any read application of the operating systems.

We have a team dedicated to educating and raising awareness among all of our development and UX teams to build accessible solutions for everyone.

We have a team dedicated to educating and raising awareness among all of our development and user experience (“UX”) teams to build accessible solutions for everyone.

Developing policies that accompany our employees in their family planning is key at MercadoLibre.

4 unchanged sentences

Also, we provide paid leave for women experiencing a miscarriage, to support the recovery path during this difficult moment in their lives.

Remote Work Environment

Loyal to our agile and entrepreneurial culture, at MercadoLibre we seek to develop an environment that offers maximum flexibility, that connects people, and, at the same time, inspires them to give their best.

Currently, of the more than 40,000 people who are part of this team, around 16,200 integrate Shipping operations with on-site work.

The remaining employees work 100% remotely with the option of going to the offices.

That is, each person can choose where to work from.

This hyper-flexibility model has multiple benefits:

on the one hand, it allows teams to integrate work with personal life, and on the other, it increases our ability to attract talent, since it opens up the possibility of hiring people who live in cities where we do not have offices.

In recent times, this new modality has challenged us more than ever and urged us to continue multiplying our culture in remote environments and redefining the "office" concept.

To do this, we have listened to our leaders and teams to understand what they value about on-site work and the activities that would add differential value to them in this work environment.

Based on their input, we have redefined the experience on our sites to promote what we call “in-person with purpose”, which is a format in which offices become one campus.

We seek to motivate people to choose face-to-face activities by offering high value-added activities that foster the in-person gathering:

staff meetings, town halls, after-offices, learning activities, etc.

In other words, by offering experiences that enhance connection and teamwork.

Government Regulation

We are subject to a variety of laws, decrees and regulations that affect companies conducting business on the Internet in some of the countries where we operate related to e-commerce, fintech, privacy, data protection, taxation (including value added taxes (“VAT”), or sales tax), obligations to provide information to certain authorities about transactions occurring on our platform or about our users, anti-money laundering regulations, transport regulations and other legislation which also applies to other companies conducting business in general.

We are subject to a variety of laws, decrees and regulations that affect companies conducting business on the Internet in some of the countries where we operate related to e-commerce, fintech, privacy, data protection, taxation, obligations to provide information to certain authorities about transactions occurring on our platform or about our users, anti-money laundering regulations, transport regulations and other legislation which also applies to other companies conducting business in general.

It is not clear how existing laws governing issues such as general commercial activities, property ownership, copyrights and other intellectual property issues, taxation, libel and defamation, obscenity, consumer protection, digital signatures and personal privacy apply to online businesses.

2 unchanged sentences

These regulations could cover a wide variety of issues, including, without limitation, online commerce, Internet service providers’ responsibility for third party content hosted in their servers, user privacy, fintech transactions, freedom of expression, pricing, content and quality of products and services, taxation (including VAT or sales tax collection obligations, obligation to provide certain information about transactions that occurred through our platform, or about our users), advertising, intellectual property rights, consumer protection and information security.

There are laws and regulations that address foreign currency and exchange rates in every country in which we operate.

In certain countries where we operate, we need governmental authorization to pay invoices to a foreign supplier or send money abroad due to foreign exchange restrictions.

See “Item 1A.

Risk factors—Risks related to doing business in Latin America—Local currencies used in the conduct of our business are subject to depreciation, volatility and exchange controls” for more information.

In addition, on June 10, 2019, the Argentine government enacted Law No.

27,506 (knowledge-based economy promotional regime), which established a regime that provides certain tax benefits for companies that meet specific criteria.

In August 2021, the Under Secretariat of Knowledge Economy issued the Disposition 316/2021 approving MercadoLibre S.R.L.’s application for eligibility under the knowledge-based economy promotional regime.

Tax benefits granted pursuant to the promotional regime to MercadoLibre S.R.L.

were retroactive to January 1, 2020.

See Item 8 of Part II, Financial Statements and Supplementary Data—Note 14 – Income taxes for further information.

We are also subject to significant general data protection and privacy-related regulations in many of the jurisdictions in which we operate (e.g.

Law 13,709 (LGPD) in Brazil, Law 25,326 in Argentina, Federal Law on the Protection of Personal Data on Private Sector Possession in Mexico, Laws No.

1581/2012 and 1266/2008 in Colombia, Law No.

19,628 in Chile, Law No.

18,331 in Uruguay and Law No.

29,733 in Peru).

Data protection laws establish rules for the collection, use, processing and storage of personal data and affect all economic sectors, including the relationship between customers and suppliers of goods and services, employees and employers and other relationships in which personal data is collected, whether in a digital or physical environment.

We have created a program to implement the relevant requirements to our business processes, compliance infrastructures and IT systems to comply with data protection laws.

Further, some jurisdictions in which we operate are considering imposing additional restrictions or regulations.

Our Mercado Pago service is subject to regulation in the countries in which we operate, as described below:

3 unchanged sentences

12,865/2013 gave the Brazilian Central Bank (“BACEN”), according to guidelines set out by the National Monetary Council (“CMN”) authority to regulate entities involved in the payments industry.

12 | MercadoLibre, Inc.

Pursuant to that authority, the CMN and the BACEN created a regulatory framework regulating the operation of payment schemes and payment institutions.

1 unchanged sentence

There are two types of payment arrangements, as defined by Resolution 150/21:

(a) “Closed Loop Payment Arrangement”:

payment arrangements whereby the payment services (account management, issuance and accreditation of payment instrument) are performed by only one legal entity, which also acts as the payment arranger (or is controlled/the controller of the payment arranger) and (b) “Open Loop Payment Arrangement”:

(i) “Closed Loop Payment Arrangement”:

any payment arrangements that do not fit into the concept of “Closed Loop Payment Arrangement”.

17 unchanged sentences

In addition, Mercado Pago as a payment institution in Brazil is subject to:

(i) Anti-Money Laundering Rules:

Anti-Money Laundering Rules:

Mercado Pago is subject to Brazilian laws and regulations relating to anti-money laundering, terrorism financing and other potentially illegal activities.

These rules require us to implement policies and internal procedures to manage, monitor, identify and, if applicable, report suspicious transactions to the relevant authorities to prevent the practice of crimes of “money laundering” or concealment of assets.

(ii) Register of Receivables from Payment:

Mercado Pago is also subject to rules regarding the register of credit card receivables and credit operations in a centralized system operated by an entity authorized by the BACEN.

These recent regulations aim to promote transparency in credit transactions, a broader credit offer and to allow merchants to offer their credit card receivables as collateral to receive better loan offers, improving competition and reducing the cost of credit.

(iii) Cybersecurity Policies:

Cybersecurity Policies:

In 2018 the BACEN published new rules setting forth cybersecurity policies and requirements for the contracting relevant data processing and storage services as well as cloud-based computing services, which are applicable both to Mercado Pago and Mercado Credito.

(iv) Data Protection Law:

Data Protection Law:

In August 2018, Brazil approved its first comprehensive data protection law (the “Lei Geral de Proteção de Dados Pessoais” or “LGPD”), which became applicable to our business in Brazil in August 2020.

3 unchanged sentences

The LGPD establishes detailed rules for the collection, use, processing and storage of personal data and affects all economic sectors, including the relationship between customers and suppliers of goods and services, employees and employers and other relationships in which personal data is collected, whether in a digital or physical environment.

(v) Secrecy rules:

Secrecy rules:

In addition to regulations affecting payment schemes, Mercado Pago is also subject to laws relating to internet activities and e-commerce, as well as banking secrecy laws, consumer protection laws, tax laws (and related obligations such as the rules governing the sharing of customer information with tax and financial authorities) and other regulations applicable to Brazilian companies generally.

1 unchanged sentence

12,965/2014, known as the Brazilian Civil Rights Framework for the internet, which embodies a substantial set of rights of internet users and obligations relating to internet service providers, including data protection.

13 | MercadoLibre, Inc.

12,865/2013 prohibits payment institutions from performing activities that are restricted to financial institutions, such as granting loans directly.

6 unchanged sentences

Mercado Pago has participated in the payment scheme of Pix since its beginning and is subject to the applicable regulation.

The BACEN implemented the Brazilian Open Banking environment, to enable the sharing of data, products and services between regulated entities — financial institutions, payment institutions and other entities licensed by the BACEN — at the customers' discretion, as far as their own data is concerned (individuals or legal entities).

The Open Banking implementation has been gradual, through incremental phases that take into account specific information/services to be shared, and Mercado Pago has been a participant of the Open Banking system since February 2021, when its phase 1 started.

The BACEN implemented the Brazilian Open Finance environment, to enable the sharing of data, products and services between regulated entities — financial institutions, payment institutions and other entities licensed by the BACEN — at the customers’ discretion, as far as their own data is concerned (individuals or legal entities).

The Brazilian Open Finance implementation has been gradual, through incremental phases that take into account specific information/services to be shared, and Mercado Pago has been a participant of the Brazilian Open Finance system since February 2021, when its phase 1 started.

Mercado Pago Instituição de Pagamento Ltda.

1 unchanged sentence

as regulated entities in Brazil are subject to the supervision of the BACEN and must fully comply with all the obligations established in the current regulation, or be subject to (i) formal warning establishing a deadline for the remediation of non-compliance activity, (ii) penalties for non-compliance, or (iii) shutting down our Mercado Pago business in Brazil for an indefinite period of time, which would be costly.

During March 2022, the Central Bank of Brazil announced new prudential rules for payment institutions based on their size and complexity and raising standards for required capital.

The new framework, which will be effective starting in July 2023 with full implementation by January 2025, will extend the application of the rule regarding proportionality of regulatory requirements (currently applicable to conglomerates of financial institutions) to financial conglomerates led by payment institutions.

We are assessing the effects that the new rules may have on its regulated Brazilian subsidiaries.

During March 2022, the Central Bank of Brazil announced new rules for payment institutions based on their size and complexity and raised standards for required capital.

The new framework, which was effective starting in July 2023 with full implementation by January 2025, will extend the application of the rule regarding proportionality of regulatory requirements (currently applicable to conglomerates of financial institutions) to financial conglomerates led by payment institutions.

The new rules require a gradual increase in regulatory capital requirements for the Company’s regulated Brazilian subsidiaries until 2025:

6.75% from July 2023, 8.75% from January 2024 and 10.50% from January 2025.

On May 23, 2023, the BACEN published Joint Resolution No.

6, providing requirements for financial institutions, payment institutions and other institutions authorized to operate by the BACEN with respect to the sharing of data and information pertaining to fraud.

According to this regulation, the listed institutions must share certain information related to fraud and interoperate with centralized bureaus, which may be elected by the institutions.

In October 2023, the BACEN published Resolution BCB nº 343, which details the information that must be shared, including information relating to fraud in account opening, account maintenance, provision of payment services and credit.

These requirements became effective on November 1, 2023, and Mercado Pago is fully compliant, electing CERC as its centralized bureau.

In January 2020, the Central Bank of Argentina (“CBA”) enacted regulations relating to payments service providers that apply to the Fintech institutions that are not financial institutions but nevertheless, provide payment services in at least one of the stages of the payment system.

3 unchanged sentences

(iii) allowing users to dispose immediately of the funds credited to their accounts;

and (iv) providing information to the CBA relating to the business of payments processing.

and (iv) providing information to the CBA relating to the business of payment processing.

On July 7, 2020, MercadoLibre S.R.L.

was registered with the CBA as a payment service provider in accordance with applicable regulations.

On December 30, 2021, the board of the CBA issued a regulation that established that financial institutions must set up a reserve of 100% of the funds deposited by payment service providers that offer payment accounts in which the customers’ funds are deposited.

According to this new regulation, from January 1, 2022, 100% of our customer funds that have not been invested by users in Mercado Fondo, have remained deposited at financial institutions, and such financial institutions deposited 100% of those funds at the CBA, and available for users.

On September 22, 2022, the CBA modified the aforementioned resolution and established that a percentage of the customer funds deposited in financial institutions by payment service providers that offer payment accounts may be invested in Argentinian treasury bonds and do not necessarily have to remain deposited at the CBA.

Under the amended regulation, financial institutions in which we deposit customer funds may invest up to 45% of funds that have not already been invested by users in Mercado Fondo in Argentinian, peso-denominated treasury bonds due May 23, 2027.

As a result of the amended regulation, we withdrew on September 5, 2022 the cases we had originally filed challenging the December 30, 2021 regulation.

As a non-financial loan provider, since March 1, 2021, we have been required to provide certain information on a monthly basis as part of a new reporting regime.

6 unchanged sentences

The rules regarding interest rates became effective on January 1, 2021, and the rules regarding the protection of users of financial services, methods of communication and access to information became effective on February 1, 2021.

On September 1, 2022, the CBA issued a regulation that extended the application of the rules for the protection of users of financial services to payment service providers (the regulation was already applicable to non-financial loan providers).

This regulation will enter into force on March 1, 2023.

On December 30, 2021, the board of the CBA issued a regulation by which financial institutions must set up a reserve of 100% of the customer funds deposited by payment service providers that offer payment accounts.

On September 22, 2022, the CBA modified the aforementioned resolution and established that financial institutions in which the Company deposits customer funds may invest up to 45% of funds that have not already been invested by users in Mercado Fondo in Argentine, peso-denominated treasury bonds due May 23, 2027.

As a result of the amended regulation, we withdrew on September 5, 2022 the cases we had originally filed challenging the December 30, 2021 regulation.

On August 24, 2023, the CBA issued a regulation (Communication “A” 7825), which states that payment service providers who offer payment accounts (“PSPOCP” according to its Spanish acronym) must allocate in full to their clients any compensation received from financial institutions for investing clients’ funds held in deposit accounts into Argentine treasury bonds.

Since August 25, 2023, MercadoLibre S.R.L.

is not receiving any compensation from financial institutions for clients’ funds held in deposit accounts.

As a consequence, this regulation has no applicable effect for MercadoLibre S.R.L.

14 | MercadoLibre, Inc.

On September 1, 2022, the CBA issued a regulation that extended the application of the rules for the protection of users of financial services to PSPOCP.

The regulation was already applicable to non-financial loan providers.

This regulation came into effect on March 1, 2023.

On February 15, 2023, the CBA issued another regulation, which establishes that PSPOCP must submit the Information Regime on Claims, with the first submission deadline was on April 24, 2023, and the Information Regime on Transparency, Chapter II, with the first submission deadline for monthly information was on March 14, 2023.

On May 18, 2023, the CBA enacted a new regulation that established the creation of the new regulatory titles of “acceptor”, “acquirer” and “aggregator”, defining their respective functions and requiring their registration in the registry of payment service providers maintained by the CBA as of December 18, 2023.

As a result of this new regulation, Mercado Libre S.R.L.

started the registration as “aggregator” and “acceptor” and Mercado Pago Servicios de Procesamiento S.R.L.

started the registration as “acquirer”.

This regulation further sets forth that acquirers and aggregators who offer their clients the possibility of accepting payments with credit cards by reading a QR Code must allow another registered interoperable digital wallet to make payments with the associated credit cards in the event that the shop accepts them through the corresponding aggregator or acquirer.

In this way, the CBA established that QR Codes must be interoperable with credit card payments.

On September 14, 2023, the CBA issued Communication “A” 7861 establishing that starting on December 1, 2023, DEBIN (debit immediate), the main and simple funding source of Mercado Pago users’ accounts, will be suspended and replaced with a pull transfer method that requires the consent of the client outside of Mercado Pago’s environment before the first use.

After several extensions, on January 11, 2024, the CBA issued a new regulation establishing that the suspension of DEBIN must be effective starting on April 30, 2024.

As we continue to develop Mercado Pago and our peer-to-peer lending business, we may need to comply with regulations applicable to such payments and lending activities and/or anti-money laundering.

13 unchanged sentences

cash, treasury bills, etc.), so as to be able to redeem, on par, the funds held on behalf of the clients, c) comply with anti-money laundering and countering of terrorism financing regulations, d) develop and maintain sound cybersecurity and information security policies, including but not limited to the performance of recurrent vulnerability tests and the deployment of strict infrastructure controls.

On February 13, 2024, the Mexican antitrust authority (Comisión Federal de Competencia Económica or “COFECE”) notified MercadoLibre, S.A., de C.V., Institución de Fondos de Pago Electrónico of its preliminary findings, conclusions and recommendations regarding competition in the ecommerce sector in Mexico, including proposed corrective measures on marketplace operators that include Mercado Libre and that, if confirmed, could require us to change certain aspects of some of our business practices in Mexico.

This preliminary report is the result of a general market study on barriers to competition in the ecommerce market, launched by COFECE in 2022 and will now be taken to a subsequent stage of the process where MercadoLibre, S.A., de C.V., Institución de Fondos de Pago Electrónico and other affected entities may submit their views and additional evidence.

The preliminary report and additional submissions will be analyzed by COFECE’s full board of commissioners, in accordance with applicable laws and procedures, and the plenary will issue a final report.

We expect it will take several months until there is a final report issued by COFECE’s plenary.

The final report may be subject to a special constitutional appeal before a specialized Mexican court and subsequent judicial decisions may be further appealed and may reach the Mexican Supreme Court.

This additional judicial stage may take several years until a final decision is reached.

The outcome of these proceedings and the impact that any final corrective measures may have on certain aspects of some of our business practices, is uncertain.

We cannot assure you that they will not adversely affect our business, operation results and/or financial conditions.

See “Risk Factors—We are subject to extensive government regulation and oversight.

Failure to comply with existing and future rules and regulations in the jurisdictions in which we operate could adversely affect the operations of one or more of our businesses in those jurisdictions—Competition”.

15 | MercadoLibre, Inc.

In 2017 and 2018, Chile enacted regulations regarding the issuance and operation of payment cards, which could affect Mercado Pago’s operations, including authorization to operate, anti-money laundering obligations, capital requirements and reserve funds, operational and security safeguards, among others.

In November 2021, the Chilean Commission for the Financial Market (“CMF”) granted Mercado Pago, through its entities Mercado Pago Emisora S.A.

and MercadoPago S.A., a prepaid card issuer license and payment card operator license, respectively.

and Mercado Pago Operadora S.A.

(formerly know as MercadoPago S.A.), a prepaid card issuer license and payment card operator license, respectively.

These licenses transformed Mercado Pago Emisora S.A.

and MercadoPago S.A.

into regulated entities, supervised by the CMF and the Chilean Financial Analysis Unit (UAF, in charge of supervising anti-money laundering activities in Chile), and subject to other regulatory and financial requirements such as minimum capital requirements, liquidity reserves and know your client and anti-money laundering duties.

and Mercado Pago Operadora S.A.

into regulated entities, supervised by the CMF and the Chilean Financial Analysis Unit ("UAF", in charge of supervising anti-money laundering activities in Chile), and became obligated, among other things, to:

(i) deliver information on its financial and operational management on a regular basis;

(ii) maintain certain minimum capital required;

(iii) set up a determined liquidity reserve;

(iv) deposit and maintain users’ funds in specific banks’ accounts (only applicable to Mercado Pago Emisora S.A.);

and (v) perform know your client and anti-money laundering duties.

On October 12, 2022, the Chilean Congress approved the Fintech and Open-Banking Law Project, which was published on January 4, 2023, and came into effect on February 3, 2023.

2 unchanged sentences

(i) Alternative Transaction Systems, (ii) Crowdfunding Financing Platforms, (iii) Financial Instrument Intermediation, (iv) Order Routing, (v) Credit Advisory, and (vi) Investment Advisory.

Pursuant to this law, Mercado Pago Crypto S.A.

shall file a license request with the CMF in order to continue offering Order Routing services through the “buy, hold and sell” product launched in 2023 in collaboration with Ripio Chile SpAp.

The rules governing the specifics of this filing and the license that CMF must grant, were issued on January 12, 2024, giving Mercado Pago Crypto S.A.

until February 2025 to file the license request.

In addition, an Open Finance System is created to allow financial service providers to exchange customer financial information.

After the Fintech Law comes into effect, the CMF will have 18 months to issue secondary regulation.

Mercado Pago Emisora S.A.

will actively participate in the discussions and workshops at the CMF with the other players in the industry.

The CMF has until June 3, 2024 to issue secondary regulation.

On October 24, 2022, Mercado Pago Corredores de Seguros SpA was registered as an Insurance Broker in the Registry of Trade Assistants for Insurance of the CMF.

2 unchanged sentences

There are also regulations requiring payment processors such as Mercado Pago to comply with certain security, privacy and anti-money laundering standards.

As a result, Mercado Pago has started the process of incorporating a new company (“MercadoPago S.A.

Compañía de Financiamiento”) and requesting a license to act as a financial institution, and will therefore be able to offer credits, digital accounts, investments and prepaid cards without any limitation upon obtaining such license.

We expect this new company to be operational by the second half of 2023.

Uruguay and Peru

Uruguay and Peru have also enacted regulations that cover a wide variety of issues related to electronic payments or e-money, including, among other things, rules related to the requirement to obtain authorization from the relevant authority to operate, offer or provide certain payment services.

As a result, in June 2023, MercadoPago S.A.

Compañía de Financiamiento obtained a license to operate as a financial institution in Colombia, and therefore is able to offer credits, digital accounts, investments and prepaid cards.

We expect this new company to be operational by the first quarter of 2024 and be subject to minimum capital, reporting, consumer protection and risk management requirements.

Uruguay has implemented comprehensive regulations governing electronic payments.

In September 2016, we obtained the registration of our Uruguayan subsidiary Deremate.com de Uruguay S.R.L.

from the Central Bank of Uruguay as an entity entitled to provide services of payments and collections (“PSPC”).

from the Central Bank of Uruguay (“BCU”) as an entity entitled to provide services of payments and collections (“PSPC”).

Thus, on November 1, 2016, Mercado Pago was launched in Uruguay.

Likewise, on August 26, 2021, we filed a license application before the Central Bank of Uruguay for our new company MercadoPago Uruguay S.R.L.

to operate as an e-money institution.

The product offer planned for this operation includes the products currently offered by Mercado Pago in Uruguay under the PSPC registration, plus the launch of new products enabled by new license.

In January 2023, we obtained the approval by the Central Bank of Uruguay to operate as an Electronic Money Issuing Institution (“IEDE”) which enables that entity to issue, manage, and make electronic transfers of money on behalf of its clients, through computer applications, interfaces, web sites or any other means of electronic or digital communication.

However, a final approval is needed to start operations.

In July 2023, MercadoPago Uruguay S.R.L.

obtained the approval by the BCU to operate as an Electronic Money Issuing Institution (“IEDE”) facilitating electronic money transfers.

On October 1, 2023, MercadoPago Uruguay S.R.L.

started operations, and since then, must adhere to regulations regarding the placement of user funds, including the obligation to deposit and maintain these funds in designated local bank accounts to guarantee the availability of balances in each user’s digital account.

In October 2023, MercadoPago Uruguay S.R.L.

was authorized by the BCU, subject to the terms of the regulations, to invest its user funds in short-term investments, including “overnight” bank deposits, leveraging results and assuming associated risks.

In July 2023, Communication No.

2023/147, superseded by Communication No.

2024/018 on February 1, 2024, established regulations for reporting security incidents.

In October 2023, Communication No.

2023/196 mandated bi-monthly reports on administered fund compositions, and significant modifications addressing fast payment systems and regulatory rules were made to the payment system rules.

On November 10, 2022, the Central Reserve Bank of Peru (“BCRP”) enacted regulations related to the card payment processing system that applies to issuers, acquirers and payment facilitators.

On January 27, 2023, MercadoPago Perú S.R.L.

was registered by the BCRP as a payment facilitator entity, allowed to (a) affiliate merchants to the card payment system, (b) offer POS, and (c) transmit or process card payment orders and /or participate in the process of settlement to the merchants affiliated.

There are laws and regulations that address foreign currency and exchange rates in every country in which we operate.

In certain countries where we operate, we need governmental authorization to pay invoices to a foreign supplier or send money abroad due to foreign exchange restrictions.

See “Item 1A.

On June 10, 2019, the Argentine government enacted Law No.

27,506 (knowledge-based economy promotional regime), which established a regime that provides certain tax benefits for companies that meet specific criteria, such as companies that derive at least 70% of their revenues from certain specified activities related to the knowledge-based economy.

Based on this regulations, companies that meet the specified criteria shall be entitled to:

i) a reduction of the income tax burden (60% for micro and small enterprises, 40% for medium-sized enterprises and 20% for large enterprises) over the promoted activities for each fiscal year, applicable to both Argentine source income and foreign source income, ii) stability of the benefits established by the knowledge-based economy promotional regime (as long as the beneficiary is registered and in good standing), and iii) a non-transferable tax credit bond amounting to 70% (which can be up to 80% in certain specific cases) of the Company’s contribution to the social security regime of every employee whose job is related to the promoted activities (caps on the number of employees are applicable).

Such bonds can be used within 24 months from their issue date (this period can be extended for an additional 12 months in certain cases) to offset certain federal taxes, such as value-added tax, but cannot be used to offset income tax.

Tax benefits granted pursuant to the promotional regime to MercadoLibre S.R.L.

were retroactive to January 1, 2020.

See Item 8 of Part II, “Financial Statements and Supplementary Data-Note 14-Income taxes” for further information.

We are also subject to significant general data protection and privacy-related regulations in many of the jurisdictions in which we operate (e.g.

Law 25.326 in Argentina, Federal Law on the Protection of Personal Data on Private Sector Possession in Mexico, Laws No.

1581/2012 and 1266/2008 in Colombia, Law No.

19,628, Law No.

18.331 in Uruguay and Law No.

29.733 in Peru).

We have created a program to implement the relevant requirements to our business processes, compliance infrastructures and IT systems to comply with data protection laws.

Further, some jurisdictions in which we operate are considering imposing additional restrictions or regulations.

was registered by the BCRP as a payment facilitator entity, allowing it to (a) affiliate merchants to the card payment system, (b) offer POS, and (c) transmit or process card payment orders and /or participate in the process of settlement to the merchants affiliated.

We are a Delaware corporation incorporated on October 15, 1999.

Our registered office is located at 874 Walker Road, Suite C, Dover, Delaware.

Our registered office is located at 800 North State Street, Suite 304, Kent County, Dover, Delaware, 19901.

Our principal executive offices are located at Dr.

1 unchanged sentence

1733, Tower II, Montevideo, Uruguay, 11300.

16 | MercadoLibre, Inc.

Available Information

5 unchanged sentences

The SEC maintains an internet site that contains reports, proxy and information statements, and other information regarding issuers that file electronically with the SEC at www.sec.gov.

Our Annual Impact report, the Sustainability Bond report and the Task Force on Climate-Related Disclosures are available on our investor relations website.

Our Annual Integrated Impact report and the Sustainability Bond report are available on our investor relations website.

Our Corporate Governance Guidelines, Code of Ethics, and the charters of the Audit Committee, the Compensation and the Nominating and Corporate Governance Committee are also available on our website and are available in print to any stockholder upon request in writing to MercadoLibre, Inc., Attention:

3 unchanged sentences

Information on or connected to our website is neither part of nor incorporated into this report on Form 10-K or any other SEC filings we make from time to time.

17 | MercadoLibre, Inc.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1. Business