What changed in this filing

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Item 1. Business

2026-02-25 compared with 2025-02-21 · 200 added, 212 removed, 318 unchanged (56% of the section changed)

MercadoLibre, Inc.

(together with its subsidiaries “us”, “we”, “our” or the “Company”) is the leading online commerce and fintech ecosystem in Latin America.

(together with its subsidiaries “us,” “we,” “our,” "MercadoLibre," or the “Company”) is the leading online commerce and fintech ecosystem in Latin America.

Our e-commerce platform is the leader in the region based on gross merchandise volume (“GMV”), and our fintech platform is the leader in monthly active users (“MAUs”) among fintech companies in Argentina, Chile and Mexico, and the second largest in Brazil.

Mercado Libre's e-commerce platform is present in 18 countries (Argentina, Brazil, Mexico, Chile, Colombia, Peru, Uruguay, Venezuela, Bolivia, Costa Rica, Dominican Republic, Ecuador, Guatemala, Honduras, Nicaragua, Panama, Paraguay and El Salvador) and our fintech platform, Mercado Pago, is present in 8 countries (Argentina, Brazil, Mexico, Chile, Colombia, Peru, Uruguay and Ecuador).

Mercado Libre's e-commerce platform is present in 18 countries (Argentina, Brazil, Mexico, Chile, Colombia, Peru, Uruguay, Venezuela (deconsolidated since December 2017), Bolivia, Costa Rica, Dominican Republic, Ecuador, Guatemala, Honduras, Nicaragua, Panama, Paraguay and El Salvador) and our fintech platform, Mercado Pago, is present in 8 countries (Argentina, Brazil, Mexico, Chile, Colombia, Peru, Uruguay and Ecuador).

Our ecosystem provides consumers and merchants with a complete portfolio of services to enable buying and selling online, and the processing of payments online and offline, as well as offering a wide array of simple day-to-day financial services.

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the Mercado Libre Marketplace, the Mercado Pago fintech platform, the Mercado Envios logistics service, the Mercado Ads solution and the Mercado Libre Classifieds service.

Our e-commerce platform provides buyers and sellers with a robust and safe environment that fosters the development of a large e-commerce community in Latin America, a region with a population of over 650 million people where penetration of e-commerce over total retail significantly lags benchmarks such as the United States of America ("U.S."), the U.K.

We believe that we offer world-class technological and commercial solutions that address the distinctive cultural and geographic challenges of operating a digital commerce platform in Latin America.

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Our advertising platform, Mercado Ads, is another value-added service that we offer to sellers on our platform and brands both on- and off-platform.

The platform enables sellers and brands to access the millions of consumers that browse and purchase on our Marketplace, as well as the first-party data that all of these engagements generate.

The platform enables sellers and brands to access the millions of consumers who browse and purchase on our Marketplace, as well as the first-party data that all of these engagements generate.

This enables advertisers to target highly granular audiences.

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In January 2025, we announced the migration of Mercado Shops to “Mi Página,” which offers similar functionalities but is fully embedded within our Marketplace (without an external storefront).

Mercado Shops will be discontinued as of December 31, 2025.

Mercado Shops was discontinued as of December 31, 2025.

Mercado Pago was initially designed to facilitate transactions on Mercado Libre’s Marketplace by providing a mechanism that allowed our users to securely, easily and promptly send and receive payments.

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T able of Contents

In our main markets, we currently offer the following solutions:

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

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

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

Our lending solution is available in Argentina, Brazil, Mexico and Chile.

We offer credits mostly to merchants and consumers that already form part of our user base, many of whom have historically been underserved or overlooked by financial institutions and therefore suffer from a lack of access to credit.

We offer loans mostly to merchants and consumers that already form part of our user base, many of whom have historically been underserved or overlooked by financial institutions and therefore suffer from a lack of access to credit.

Facilitating credit is a key service overlay that enables us to further strengthen the engagement and lock-in rate of our users, while also generating additional touchpoints and incentives to use Mercado Pago as an end-to-end financial solution.

Our distribution capabilities and in-depth understanding of our customers’ behavior and merchants’ sales on the Mercado Libre Marketplace combined with machine learning ("ML") and artificial intelligence ("AI") algorithms have allowed us to develop our own proprietary credit risk models with unique data that differentiate our scoring from traditional financial institutions.

Our distribution capabilities and in-depth understanding of our customers’ behavior and merchants’ sales on the Mercado Libre Marketplace combined with machine learning (“ML”) (pillar of artificial intelligence (“AI”)) algorithms have allowed us to develop our own proprietary credit risk models with unique data that differentiate our scoring from traditional financial institutions.

These models enable us to understand and better predict the behavior of our user and originate loans while maintaining acceptable levels of uncollectible debts.

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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 the Mercado Pago credit card in Brazil, and this was followed by Mexico in 2023.

In 2021, we launched the Mercado Pago credit card in Brazil, and this was followed by Mexico in 2023 and Argentina in 2025.

It is free, internationally accepted, digitally managed and can be used on- and off-platform.

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

In 2024, in Brazil and Mexico we launched "Meli Dólar", a stablecoin that is pegged to the US dollar.

In 2024 and 2025 we launched “Meli Dólar,” a stablecoin that is pegged to the US dollar, in Brazil, Mexico and Chile.

Members of our loyalty program receive their cashback in Meli Dólar and all Mercado Pago users can buy, hold and sell the stablecoin without any fees.

In 2024, we launched the latest iteration of the Meli+ loyalty program in Brazil and Mexico.

The relaunch added new benefits to complement the additional free shipping threshold for loyalty members.

The new benefits include cashback and extra installments on Marketplace purchases as well as new fintech benefits designed to drive principality, such as cashback on purchases made with the Mercado Pago credit card and an extra yield on deposits in the Mercado Pago digital account.

The relaunch also introduced two subscription options for our users to be able to choose the benefits package that best suits them.

The Meli+ Essencial option offers all of the previously mentioned ecosystemic benefits.

The Meli+ Total option includes all of our ecosystemic benefits, plus free access to content from Disney+ and Deezer and discounts on other streaming services such as Max, Paramount+ and Vix.

In 2024 we continued to scale Mercado Play, an AVOD streaming service first launched in 2023 and available to all users in Argentina, Brazil, Mexico, Colombia, Chile, Peru and Uruguay.

In 2025, we launched the latest iteration of the Meli+ loyalty program in Argentina, Chile and Colombia, following its launch in Brazil and Mexico in 2024.

The latest iteration introduces a tiered structure designed to provide users with a choice of benefits, which differ depending on the country.

The Meli+ Essential tier includes ecosystem-wide benefits such as enhanced shipping options, cashback and additional installments on Marketplace purchases.

The Meli+ Total tier includes all such benefits and also provides free access to Disney+, as well as discounts on other streaming platforms, such as HBO Max and Paramount+.

In Brazil, we introduced a new subscription tier, Meli+ Mega, which consolidates multiple entertainment services into a unique single-subscription bundle, offering access to streaming platforms such as Netflix, Disney+, HBO Max and Apple TV+.

We continue to scale Mercado Play, an advertising-based video on demand (“AVOD”) streaming service first launched in 2023 and available to all users in Argentina, Brazil, Mexico, Colombia, Chile, Peru and Uruguay.

In 2025, Mercado Play previously available only through our apps, was made available on connected TVs for the first time.

Mercado Play serves as a tool to drive user engagement on Mercado Libre and is a new platform to serve video advertising, complementing the portfolio of ads formats available through Mercado Ads.

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T able of Contents

We have two distinctive revenue streams in our business:

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Services and Product Sales.

Our Services revenue stream is mainly generated from Marketplace fees that include final value fees, which include the use of the payment solution, and flat fees for certain 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.

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These new transactional offerings include, but are not limited to:

(a) offering additional product categories in our Marketplace, (b) bringing new brands to our Marketplace, (c) complementing our 3P selection with 1P goods in selected categories where we can enhance price competitiveness and assortment, (d) expanding our presence in vehicle, real estate and services classifieds and (e) offering enterprise software solutions to our online commerce business users.

(a) offering additional product categories in our Marketplace, (b) bringing new brands to our Marketplace, (c) complementing our 3P selection with 1P goods in selected categories where we can enhance price competitiveness and assortment and (d) expanding our presence in vehicle, real estate and services classifieds.

■ Continue to improve the shopping experience for our users .

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Value-added services that we intend to continue to scale include, but are not limited to:

(a) maximizing utilization of Mercado Envios, particularly our fulfillment services, (b) expanding our advertising offerings, both on- and off-platform, (c) maximizing the use of Mercado Pago as a means of payment in our Marketplace, and (d) scaling our loyalty scheme, MELI+.

We are committed to continue investing in the development of new tools and technologies that facilitate web and mobile commerce on our platform.

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We will continue to focus on improving the functionality of our websites and apps to deliver a more efficient and safe shopping experience and providing our users with the help of a dedicated customer support department.

We will continue to focus on increasing purchase frequency and transaction volumes from our existing users.

We will continue to focus on increasing purchase frequency and transaction volumes from our existing users, as well as attracting new buyers to our platform.

We believe that a significant portion of our growth will be derived from the development of these tools and technologies in the future.

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We believe this strategy will help us maximize the utilization of Mercado Pago on our Marketplace and the value of Mercado Pago as a day-to-day financial services partner.

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T able of Contents

■ Overlay value-added services onto our payments processing products .

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(b) offering credit products to help merchants to scale their businesses, and (c) offering enterprise software solutions that help merchants to manage their businesses.

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■ Continue to grow our business and maintain market leadership .

We focus on growing our business, achieving scale-related competitive advantages and strengthening our position as a preferred commerce and fintech platform in each of the markets in which we operate.

We also intend to grow our business and maintain our leadership by taking advantage of the expanding potential user base that has resulted from the growth of e-commerce penetration in Latin America.

We also intend to grow our business and maintain our leadership by expanding our user base as we reduce the frictions of buying online in Latin America.

We intend to achieve these goals through organic growth, by introducing our services in new countries and entering new category segments, by launching new transactional business lines, and through potential strategic acquisitions of key businesses and assets.

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We believe in local relevance to create a unique positioning in our top markets and promote a clear, differentiated brand voice.

During 2024, we strengthened our buyer acquisition and demand generation efforts with multiple initiatives that helped us to increase GMV.

We focused not only on peak season (Hot Sale, Black Friday) and gifting events (such as Christmas, Mother's Day), but also on creating new shopping occasions during periods of quieter demand.

During 2025, we strengthened our buyer acquisition and demand generation efforts with multiple initiatives that helped us to increase the usage of our ecosystem.

We focused not only on peak season (Hot Sale, Black Friday) and gifting events (such as Christmas, Mother's Day), but also on creating new shopping occasions during low season by promoting new seasonal dates called “double dates.”

Product Development and Technology

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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.

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T able of Contents

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

We split our teams into many decoupled and autonomous “cells”.

A cell is a functional unit with its own team, hardware, data and source code.

We split our teams into many decoupled and autonomous “cells.” A cell is a functional unit with its own team, hardware, data and source code.

Cells interact with each other using Application Programming Interfaces (“APIs”).

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Since then, we have seen significant adoption of our platform and entire companies built on and around our APIs and services, all of them focused on adding even more value to our users.

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During this overhaul, we built a proprietary Platform as a Service (“PAAS”) product used daily by our development team.

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Our PAAS is a constant area of investment which we have expanded from microservices to simplifying the building of mobile applications, software development kits (“SDKs”) and building, testing, training, deploying and monitoring predictive Machine Learning models, all with the purpose of increasing the rate of development and, by extension, the pace and cadence with which all our teams add value to our users.

Generative AI (“GenAI”) adoption at MercadoLibre has continued to expand across the organization.

Approximately 95% of our employees have adopted GenAI tools in their work.

Internal measurements show that about 30% of the code that reaches production is written with the use of AI.

This blended figure reflects differences across our portfolio, where mature, large-scale systems and newer environments show varying levels of AI-generated code.

All code written with AI is incorporated through our established development, review, and release processes.

During the year, we also observed an approximately 40% increase in merged contributions, which we believe reflects improvements in development velocity and ongoing enhancements to our development processes.

We also use autonomous AI agents to support portions of our engineering work.

These agents perform defined tasks such as contributing to code reviews, assisting with documentation, reviewing incidents, and handling certain migration and update activities across parts of our codebase.

They operate as part of our broader development workflow and complement the work of our engineering teams.

In addition, the use of internal workflow-automation tools has expanded across the Company.

These tools help coordinate recurring operational processes, streamline multi-step tasks, and reduce manual work across business units.

Adoption of such tools has continued to grow as our teams incorporate automation into a wider range of day-to-day responsibilities, supporting greater efficiency and consistency in routine operations.

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

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Barriers-to-entry for large, well-established technology companies are relatively low, and current and new competitors can launch new sites at a relatively low cost using commercially available software.

While we are currently a market leader in a number of the markets in which we operate, we currently or potentially could compete with marketplace operators, businesses that offer business-to-consumer online e-commerce services or others with a focus on specific vertical categories, as well as brick and mortar retailers that have launched online offerings.

While we are currently the market leader in a number of the markets in which we operate, we currently or potentially could compete with marketplace operators, businesses that offer business-to-consumer online e-commerce services or others with a focus on specific vertical categories, as well as brick and mortar retailers that have launched online offerings.

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.

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Other large companies with strong brand recognition and experience in e-commerce, such as large newspapers or media companies, also compete in the online listing market in Latin America.

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T able of Contents

Intellectual Property Rights

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See “Item 1A.

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 IP rights 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 assignment agreements with our employees and certain contractors.

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

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

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Available Information

Our Internet address is www.mercadolibre.com.

Our investor relations website is investor.mercadolibre.com.

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

Our country-specific Impact Reports for Brazil, Mexico and Argentina 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:

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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.

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T able of Contents

Human Capital

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The following table shows the number of our employees by country as of December 31, 2025:

Country Number of Employees

Number of Employees

Brazil 61,139

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We manage operations in the remaining countries in which we have operations remotely.

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 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) Sintrammgep (Sindicato dos Trabalhadores em Movimentação de Mercadorias em Geral de Paulínia e Região) in the city of Cajamar, State of São Paulo, (vi) Fetrammasc (Federação dos Trabalhadores na Movimentação de Mercadorias em Geral e Auxiliar de Administração em Gerais, Similares, Conexos) in the State of Santa Catarina, (vii) 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, (viii) 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, (ix) Sindpd SC (Sindicato dos Empregados em Empresas de Processamento de Dados de Santa Catarina) in the State of Santa Catarina, (x) Sintramov (Sindicato dos Trabalhadores na Movimentação de Mercadorias em Geral de Contagem, Betim e Região in the State of Minas Gerais) 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.

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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, some of our employees in Uruguay are represented by the Commercial Labor Union (Federación Uruguaya de Empleados de Comercio y Servicios), and some of our employees in Chile are represented by the Mercado Libre Chile Employees’ Union.

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.

Some of our employees located in Brazil, Argentina, Mexico, Uruguay and Chile are represented by different labor unions.

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.

Culture and Development

Our entrepreneurial culture is the most significant attribute that makes Mercado Libre a unique place to work.

Our entrepreneurial culture is the most significant attribute that makes MercadoLibre a unique place to work.

This characteristic, which dates back to our early days in a garage in Buenos Aires, continues to thrive among the more than 123,000 talented individuals who comprise our exceptional team across Latin America.

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a relentless commitment to creating value for our users through risk-taking and innovation, all while delivering excellence as a collective.

2024 marked our 25th anniversary, and we celebrate how far we have come, achieving extraordinary and sustainable results.

Throughout the years, our culture has been instrumental in shaping our Company’s dynamic and successful journey, serving as a competitive advantage and a crucial differentiator.

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In the past year, we have trained over 3,150 leaders to serve as multipliers of our DNA.

This initiative included more than 140 training sessions focused on enhancing the impact of our leaders, emphasizing the importance of overcoming challenges, embodying a proactive attitude and delivering effective feedback.

This initiative included 120 training sessions focused on enhancing the impact of our leaders, emphasizing the importance of overcoming challenges, embodying a proactive attitude and delivering effective feedback.

We are thrilled with the positive outcomes this initiative has generated, not only for the participants and their teams but also for the overall business results.

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This milestone is particularly significant as we recognize that managing team engagement is an indispensable responsibility of our leaders.

In addition, our “Leading Operations” program trained more than 3,775 leaders to strengthen management within our logistics operations.

In addition, during 2025 our “Leading Operations” program trained more than 2,600 leaders to strengthen management within our logistics operations.

This initiative has boosted productivity and supported our goal of expanding our logistics network to every home in Latin America.

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Every action we take as a company is anchored in this purpose, with our culture guiding and inspiring each decision we make and every initiative we launch.

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T able of Contents

Generation of quality employment opportunities

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In 2025 alone, we welcomed more than 39,000 new team members throughout the region, particularly within our Technology, Product, and Logistics divisions.

We have shown consistent expansion, nearly quintupling our workforce from 15,546 to 84,207 employees in the last four years, which means a 30 times growth over the last decade.

We have shown consistent expansion, almost quadrupling our workforce from 29,957 to 123,670 employees in the last four years, resulting in 37 times the workforce we had a decade ago.

This substantial growth distinguishes us as a leader in creating genuine employment in the region while maintaining our unique culture.

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Multiple perspectives, common purpose

We believe in effort and the value of meritocracy, and we know that the inclusion of diverse experiences drives innovation and allows us to anticipate the needs and expectations of those who choose Mercado Libre.

To achieve this, we work on two complementary pillars:

inclusion, through processes and actions that ensure equal opportunities within a culture that fundamentally values the meritocracy;

and representativeness, promoting the inclusion of different profiles and experiences, thus reflecting the diversity of our user community.

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Today, 93% of our employees perceive their leaders as inclusive, and this perception is held by employees across diverse groups.

We also ensure pay equity by examining all groups, and there is no representative gap in any talent management processes, such as performance evaluations, promotions, and internal rotations.

inclusion, through processes and actions that ensure equal opportunities within a culture that fundamentally values meritocracy;

and representation, promoting the inclusion of different profiles and experiences, thus reflecting the diversity of our user community.

We ensure pay equity by conducting annual company-wide analyses, and there is no representative gap in any talent management processes, such as performance evaluations, promotions, internal rotations and employee engagement.

Our priority is to guarantee an inclusive and respectful environment.

In 2024, we created the Inclusion Insights Team, an intersectional team whose mission is to ensure that our initiatives and processes are inclusive and incorporate a multiplicity of perspectives and experiences, enabling a great place to work for all people.

The group is led by the Inclusion team and consists of 13 representatives from different groups (women, men, employees over 40, people with disabilities, different ethnicities, LGBTQI+, etc.), ensuring a balance across countries, tenure, seniority, and considering performance and cultural alignment.

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AI-Driven Innovation at MercadoLibre

At MercadoLibre, we continuously seek to innovate in all our processes.

We are currently exploring alternatives in AI to gain efficiency and scalability in our People processes, like using generative IT for employee services, such as our People Chat, which we are converting into a conversational chat formating using GenAI.

This way, the interaction between the employee and the bot is much simpler, more natural, and fluid, which allows us to better detect intentions, accelerating response times and simplifying user management.

We are also using AI for talent detection, candidate matching and content management, for example.

We expect this will allow us to optimize our resources and enhance talent management, generating greater effectiveness in our operations.

Additionally, we are committed to enriching the training and development experiences of our teams.

By integrating AI solutions, we aim to offer more personalized and effective training programs that will enhance the professional growth of each member of our organization, thereby increasing the scalability of our training initiatives.

We firmly believe that the combination of technology and a human-centered approach will enable us to adapt quickly to change and continue growing in an ever-evolving environment.

Through these initiatives, we reaffirm our dedication to innovation and continuous learning at MercadoLibre.

Furthermore, our goal is to train as many people as possible in the use of AI by 2025 to improve their efficiency, ensuring that our team is empowered to embrace the future.

MercadoLibre is experiencing a new phase in its evolution where the transformative power of technology, specifically AI, challenges the Company to evolve its ways of working.

To be prepared, MercadoLibre chooses to learn constantly, remaining in continuous beta, test, and iterate.

Based on MercadoLibre's DNA, the Company chooses not to simply “adapt,” but to anticipate and lead the transformation.

The capacity and speed of learning are key at the Company.

Our vision for GenAI is that everyone at the Company can use it to boost their productivity and accelerate business impact.

To solve the various challenges in our operations, MercadoLibre has numerous proprietary AI solutions, and our teams are much more efficient today.

We are using AI to assist our employees in the production of TV commercials, handling of customer service cases, and response to legal demands.

Beyond these specific applications, MercadoLibre is transforming its ways of working by incorporating AI into daily operations.

MercadoLibre has made world-class GenAI tools available to the entire team, accelerating tasks across all roles through content creation assistants (like Gemini) and coding assistants (like GitHub Copilot), as well as proprietary decision automation agents (Verdi).

To drive usage, the Company has trained over 23,000 people, including leaders and developers, on solving business challenges with AI tools, prompting, and coding.

MercadoLibre also reinforces the importance of GenAI use through leadership messaging and internal “GenAI Weeks“ across business units to share practical applications.

Approximately 95% of the Company’s employees have adopted AI tools in their work.

This metric is more than 50% above industry benchmarks.

Moreover, AI is also used as a co-pilot in the Human Capital area, specifically being used for talent identification, evaluation and engagement.

In Talent Acquisition, the Company has long used AI to assist with efficient candidate-position matching and ranking.

MercadoLibre is now experimenting internally with autonomous agents for initial candidate phone-screening while ensuring that human interviews remain central to the hiring process.

For Employee Support, a proprietary GenAI conversational bot handles over 1.4 million annual inquiries, increasing the self-service rate from 70% to 93%.

Furthermore, in Talent Evaluation, AI assists leaders by summarizing 360° feedback and helping to prepare performance reviews.

Also, in the engagement annual survey, the Company uses models like Humor Sense to automatically analyze survey content and provides leaders with an intelligent assistant that integrates results, highlights key insights, and offers recommendations for action plans.

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T able of Contents

Government Regulation

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Due to these areas of legal uncertainty, and the user’s adoption of the Internet and other online services, it is possible that new laws and regulations will be adopted with respect to the Internet or other online services.

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.

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 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.

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

13,709 (“LGPD”) in Brazil, Law No.

13,709 in Brazil, Law No.

25,326 in Argentina, Federal Law on the Protection of Personal Data on Private Sector Possession in Mexico, Laws No.

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18,331 in Uruguay, Organic Law on Personal Data Protection in Ecuador, Law No.

29,733 in Peru, Personal Information Protection Law in China and some privacy and data protection state laws in the U.S.).

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.

29,733 in Peru, Personal Information Protection Law in China as well as various state-level privacy laws in the United States.

These laws broadly govern the collection, use, processing, storage and transfer of personal data across both digital and physical environments.

We have implemented a data protection program designed to incorporate applicable requirements into our business processes, compliance infrastructure and IT systems.

Further, many jurisdictions continue to review, amend or propose additional obligations, which may require further operational or technical adjustments.

Failure, or perceived failure, to comply with these evolving laws could result in regulatory investigations, fines, litigation, reputational harm, or operational restrictions.

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

Mercado Pago’s activities are subject to a number of laws and regulations that relate to payment schemes and payment institutions, including Law No.

12,865/2013, which established the first set of rules regulating the electronic payments industry within the Brazilian Payment System (the Sistema de Pagamentos Brasileiro, or “SPB”) and created the concepts of payment schemes and payment institutions.

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In addition, Law No.

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.

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

A payment arrangement is a set of rules and procedures that regulate the provision of a certain payment service to the public accepted by more than one payee, through direct access by paying and receiving end users.

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

(i) “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 (ii) “Open Loop Payment Arrangement”:

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

Payment institutions are classified into (i) issuers of electronic currency, who manage a prepaid payment account, make available a payment transaction based on the electronic currency deposited in that account, convert such funds into physical or scriptural currency, or vice versa, can also enable its acceptance with settlement in a payment account it manages;

(ii) issuers of post-paid payment instruments, who manage post-paid payment accounts that enable users to make payments on a post-paid basis;

(iii) acquirer, who without managing payment accounts, enables payees for the acceptance of payment instruments issued by a payment or financial institution and participates in the settlement process of payment transactions as a creditor vis-à-vis the issuer, pursuant to the rules of the payment arrangement;

and (iv) payment initiator, who initiates a payment upon a request of a client but it does not touch the money and does not keep passwords to execute payments on behalf of users.

In November 2018, Mercado Pago obtained approval from the BACEN to become a payment institution in the modality of an issuer of electronic currency, pursuant to which Mercado Pago carries out payment processing functions and offers payment accounts to its customers.

The funds held in a payment account:

(i) constitute segregated assets in relation to the Mercado Pago’s assets;

(ii) are not directly or indirectly available to settle any obligations of Mercado Pago;

(iii) cannot be subject to attachment, sequestration, search and seizure on account of the Mercado Pago’s debts;

(iv) are not part of Mercado Pago’s assets for bankruptcy or liquidation purposes;

(v) cannot be given as guarantee for debts assumed by Mercado Pago;

and (vi) are subject to the possibility of total redemption of the balance by the user at any time.

These are very important concepts introduced by the law that ensures more reliability to customers of services provided by payment institutions, which offer payment accounts to its users.

According to the BACEN’s regulation, Mercado Pago is required to maintain funds in an amount equal to the value of the balance of funds held in a payment account and in transit between payment accounts at the same payment institution in:

(i) a specific account in the BACEN (Correspondent Account for Electronic Currency) or (ii) federal government bonds, registered at the Special Settlement and Custody System (“SELIC”).

Mercado Pago is also a payment scheme owner of a closed-loop payment scheme, which is not part of the SPB and therefore does not require the BACEN’s authorization to operate as such, relating to peer-to-peer transfers between accounts opened by our users within the Mercado Pago payment account.

Pursuant to the BACEN’s regulations, we are required to report certain operational information regarding this scheme to the BACEN on an annual basis, such as the number of users and the annual cash value of our peer-to-peer transfer transactions.

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

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.

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.

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 to Mercado Pago and its lending products.

Data Protection Law:

In August 2018, Brazil approved its first comprehensive data protection law, the LGPD, which became applicable to our business in Brazil in August 2020.

In December 2018, the president of Brazil issued Provisional Measure No.

869/2018 which amended the LGPD and created Brazil’s national data protection authority (the “ANPDP”).

We have created a program to implement the relevant changes to our business processes, compliance infrastructures and IT systems to reflect the new requirements and comply with the LGPD.

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.

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.

Internet activities in Brazil are regulated by Law No.

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.

Mercado Pago's activities in Brazil operate under a regulatory framework consolidated by Law No.

12,865/2013, which defines the concepts of payment arrangements and payment institutions and vested the Brazilian Central Bank ("BACEN"), following guidelines set by the National Monetary Council ("CMN"), with authority to regulate and supervise the sector.

Based on that law, the BACEN Resolution 80/2021 governs the formation, operation, authorization, governance, and prudential requirements of payment institutions ("PIs") in the following modalities:

electronic money issuer, postpaid instrument issuer, acquirer (merchant acquirer), and payment transaction initiator.

As an authorized electronic money issuer since 2018, Mercado Pago Instituição de Pagamento Ltda.

offers payment accounts with client funds segregated from its own assets and fully backed by federal government securities in the Special Settlement and Custody System ("SELIC"), ensuring redemption at any time and ring-fencing against the institution’s obligations (BACEN Resolution 80/2021).

On March 11, 2020, the BACEN also approved its activities as an acquirer (merchant acquirer) and postpaid instrument issuer (credit cards), and subsequently as a payment transaction initiator, expanding the scope of services.

At the arrangement level, the BACEN Resolution 150/2021 establishes the regulatory regime applicable to payment arrangements that are part of the Brazilian Payments System ("SPB") and defines when an arrangement is not part of the SPB.

Mercado Pago participates in regulated arrangements such as Pix (the Brazilian instant payments system), card network arrangements, and maintains its own payment arrangement, complying with the applicable reporting obligations (BACEN Resolution 150/2021).

We have also been part of Open Finance since 2021, sharing data with the account holder’s consent, in accordance with the BACEN’s timeline and technical standards.

During March 2022, the BACEN announced new rules for PIs 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, extended the application of the rule regarding proportionality of regulatory requirements (currently applicable to conglomerates of financial institutions) to financial conglomerates led by PIs.

The rules required a gradual increase between 2023 and 2025 in the regulatory capital requirements applicable to our regulated Brazilian entities which from January 2025 onwards is 10.50%.

In September 2024, the Brazilian Mercado Pago's entities received the BACEN authorization to establish its own Distribuidora de Títulos e Valores Mobiliários ("DTVM"), which became operational in 2025, strengthening the investment's offering.

Credit operations within the ecosystem are conducted by Mercado Crédito Sociedade de Crédito, Financiamento e Investimento S.A., a financial institution authorized by the BACEN since 2020.

On cross-cutting matters, the Brazilian Mercado Pago's entities comply with:

(i) the anti–money laundering and counter–terrorism financing regime (Law No.

9,613/1998, amended by Law No.

12,683/2012, and the BACEN regulations);

(ii) the centralized receivables registry;

(iii) cybersecurity and cloud outsourcing policies and controls applicable to PIs;

(iv) the General Data Protection Law ("LGPD") and acts of the National Data Protection Authority ("ANPD");

and (v) rules for sharing data on indications of fraud among authorized institutions, pursuant to Joint Resolution 6/2023 and the BACEN Resolution 343/2023 (electronic registry, timelines, and security requirements).

13 | MercadoLibre, Inc.

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

In November 2020, the BACEN approved the application filed by MercadoLibre, Inc.

for authorization to incorporate a financial institution in the modality of credit, financing and investment corporation (“SCFI”).

In light of the authorization granted by BACEN, we incorporated a new entity (Mercado Crédito Sociedade de Crédito, Financiamento e Investimento S.A.), which operates activities related to the granting of loans and obtains better funding alternatives for our business.

On March 11, 2020, Mercado Pago also obtained approval from the BACEN to operate the activities of acquiring (payment processor) and post-paid payment instruments (credit cards) issuer, enabling the strengthening and growth of the Mercado Pago’s operations.

However, according to regulation implemented by the BACEN, any payment institution that is already licensed in another modality may operate as acquirers, post-paid payment instrument issuers and/or payment transaction initiators, provided a 90-day prior notification is sent to the BACEN.

In 2020 the BACEN, within the Brazilian instant payment ecosystem, created Pix, the Brazilian instant payment scheme that enables its users — people, companies and governmental entities — to send or receive payment transfers in a few seconds at any time, including non-business days.

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 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.

and Mercado Crédito Sociedade de Crédito, Financiamento e Investimento S.A.

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 BACEN 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 required a gradual increase between 2023 and 2025 in the regulatory capital requirements applicable to our regulated Brazilian entities based on the following schedule:

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

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.

On January 2, 2024, article 28 of Law 14,690 came into force, which caps the total amount that may be charged to a credit card holder in the form of interest and financial charges at the value of the original debt.

The BACEN also adopted rules in Resolution CMN N° 5,112 that provide guidance and define criteria for calculating the original value of the debt in card revolving and invoice financing operations.

To comply with the new regulation, we reduced the duration of the credit card invoice financing plans beginning in January 2024.

On June 28, 2024, Law No.

14,905 was enacted, modifying Decree No.

22,626, known as the "Lei da Usura".

The law came into force on August 28, 2024, resulting in operations undertaken with institutions authorized by the BACEN, such as Mercado Pago Instituição de Pagamento Ltda., no longer being subject to the previously imposed interest rate cap.

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For postpaid credit, since January 2, 2024, a cap has been in force for credit card revolving balances and invoice installment plans:

interest and financial charges may not exceed 100% of the original debt amount, pursuant to Article 28 of Law No.

14,690/2023 and the CMN Resolution 5,112/2023, which details the calculation of the “original amount,” invoice disclosures, and balance portability.

In 2024, Law No.

14,905 (the updated “Usury Law”) amended the Civil Code and Decree No.

22,626/1933 to (a) standardize monetary restatement and the legal interest rate;

and (b) exclude the application of the old interest cap to transactions contracted with institutions authorized by the BACEN (among other hypotheses), so that such transactions are not subject to the limit previously imposed by the 1933 Decree, without prejudice to other legal and consumer protection safeguards.

On November 3, 2025, the CMN and the BACEN issued Joint Resolution 14/2025 and the BACEN Resolution 517/2025, which overhaul the calculation of minimum paid-in capital and net equity required of authorized institutions, including PIs, Direct Credit Societies ("SCDs"), and Credit, Financing and Investment Societies ("SCFIs").

The requirement is no longer “by type” and now reflects the activities actually undertaken, the use of intensive technological infrastructure, and the funding profile, with transition rules through 2028.

The Brazilian Mercado Pago's entities have been implementing the necessary adjustments, maintaining capital buffers and alignment with the prudential benchmarks applicable to PI-led conglomerates.

Additionally, since December 1, 2025, BACEN Resolution 518/2025 has been in force, broadening the grounds for compulsory closure of payment accounts to curb improper uses, detailing the characterization and closure of “contas-bolsão,” serious registration inconsistencies, and the movement of third-party funds through own accounts, and requiring formal identification criteria and documentation retention at the BACEN’s disposal.

Mercado Pago entities in Brazil remain under BACEN supervision, as well as that of the Securities and Exchange Commission of Brazil ("CVM") due to the DTVM license, and fully comply with regulatory obligations with the knowledge that noncompliance may result in measures ranging from warnings and administrative sanctions to the cancellation of authorizations.

In March 2018, Mexico enacted a new law that regulates both crowd-funders as well as providers of wallets and money transmittal services (the “Fintech Law”).

Under the Fintech Law, institutions that provided the aforementioned services prior to its enactment are required to submit an application to the Comisión Nacional Bancaria y de Valores (the Mexican National Banking and Securities Commission or the “CNBV”) to obtain a license, and may continue to provide those services while such license application is being processed.

On April 29, 2022, MercadoLibre, S.A.

Institución de Fondos de Pago Electrónico, a Mexican subsidiary, obtained the final approval by the CNBV to operate as an Electronic Payment Institution (Institución de Fondos de Pago Electrónico or “IFPE”, as referred to by the Financial Technology Institutions Act), which enables the entity to issue, manage, redeem 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.

MercadoLibre, S.A.

Institución de Fondos de Pago Electrónico became a regulated financial entity towards third parties, effective on May 11, 2022 duly published in the Official Gazette, and is subject to the supervision and jurisdiction of the relevant Mexican financial regulators, including but not limited to the National Commission for the Protection and Defense of Users of Financial Services, CNBV and the Central Bank of Mexico.

Amongst the regulatory obligations to which Electronic Payment Institutions are subject, the following are noteworthy:

a) maintain minimum capital requirements, b) maintain sufficient reserves in high-quality liquid assets (e.g.

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, and 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.

Additionally, in February 2022, the National Insurance and Bond Commission granted Mercado Insurtech, Agente de Seguros, S.A.

definitive authorization to operate as an Insurance Agent.

On September 11, 2024, MercadoLibre, S.A., de C.V., Institución de Fondos de Pago Electrónico submitted to the CNBV an authorization request to organize and operate as a multiple banking institution.

As of the date of this filing, the aforementioned authorization is still pending approval.

On March 27, 2025, MPFS, S.

submitted to the CNBV an authorization request to organize and operate as an investment funds management company through Mercado Pago Fondos, S.A.

de C.V., Sociedad Operadora de Fondos de Inversión (a new subsidiary to be legally formed when the authorization request is approved).

As of the date of this filing, this authorization is pending approval.

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.

The regulation sets forth certain specific rules related to (i) providing information to users;

(ii) depositing users’ funds in a freely available bank account;

(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 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.

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.

We have been registered as a “Proveedor No Financiero de Crédito” (non-financial loan provider) with the CBA since December 18, 2020.

The regulation also requires that we comply with certain rules established by the CBA regarding, among other things:

(i) interest rates in loan operations;

(ii) protection of users of financial services;

(iii) methods of communication with users of financial services;

and (iv) such users’ access to information concerning their contractual obligations.

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.

was registered with the CBA as a payment service provider in accordance with applicable regulations, and since December 18, 2020 has also been registered as a “Proveedor No Financiero de Crédito” (non-financial loan provider).

In September 2021, MercadoLibre S.R.L.

completed the registration process with the National Insurance Superintendent to operate as appointed agent for insurance companies (“agente institorio”), which allows MercadoLibre S.R.L.

to offer its users insurance policies sold by one or more insurance companies, as well as to manage certain aspects of such policies (payments, claims, etc.).

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 services providers who offer payment accounts (“PSPOCP” according to its Spanish acronym).

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 requiring PSPOCPs to comply with the Information Regime on Claims and the Information Regime on Transparency, Chapter II.

14 | MercadoLibre, Inc.

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On May 18, 2023 and May 30, 2023, the CBA enacted new regulations establishing that (i) QR codes must be interoperable with credit card payments, effective as from May 1, 2024;

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was registered as an Acquirer in the "Registry of Payment Service Providers" of the CBA on February 23, 2024.

On September 14, 2023, the CBA established 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 of the application of the rule, on April 30, 2024, the CBA approved a new method of pull transfer that no longer requires the consent of the client outside of Mercado Pago’s environment.

On June 6, 2024, the CBA established that payment service providers who offer payment accounts (“PSPOCP” according to its Spanish acronym) are no longer required to distribute the returns generated by their clients' funds.

However, financial institutions are still required to set up a reserve of 100% of the customer funds deposited by Mercado Pago and may invest up to 45% of those funds in Argentine bonds.

In September 2021, MercadoLibre S.R.L.

completed the registration process with the National Insurance Superintendent to operate as appointed agent for insurance companies (“agente institorio”), which allows MercadoLibre S.R.L.

to offer its users insurance policies sold by one or more insurance companies, as well as to manage certain aspects of such policies (payments, claims, etc.).

On June 4, 2024, Mercado Pago Inversiones S.R.L.

was established.

After its registration in the General Inspection of Justice on August 9, 2024, on September 2, 2024, this subsidiary requested a Comprehensive Settlement and Clearing Agent license from the Argentinian National Securities Commission, which was authorized on February 5, 2025.

In addition, the subsidiary initiated the registration as a Comprehensive Investment Fund Placement and Distribution Agent (“ACDI”), which is still pending approval.

On June 4, 2024, Mercado Pago Asset Management S.A.

was established.

After its registration in the General Inspection of Justice on August 5, 2024, on September 2, 2024, this subsidiary requested a Product Administration Agent of Collective Investment - Common Investment Funds license and requested the creation of a Money Market Mutual Fund ("Mercado Fondo Ahorro") from the Argentinian National Securities Commission.

Both authorizations were granted on February 5, 2025.

In addition, this subsidiary requested the replacement of INDUSTRIAL ASSET MANAGEMENT S.A.

as Management Agent of “Mercado Fondo”, which is still pending approval.

As of the date of this filing, the aforementioned subsidiaries have not yet begun their operations.

In March 2018, Mexico enacted a new law that regulates both crowd-funders as well as providers of wallets and money transmittal services (the “Fintech Law”).

Under the Fintech Law, institutions that provided the aforementioned services prior to its enactment are required to submit an application to the Comisión Nacional Bancaria y de Valores (the Mexican National Banking Commission or the “CNBV”) to obtain a license, and may continue to provide those services while such license application is being processed.

On April 29, 2022, MercadoLibre, S.A.

MercadoLibre, S.A.

Amongst the regulatory obligations to which Electronic Payment Institutions are subject, the following are noteworthy:

a) maintain minimum capital requirements, b) maintain sufficient reserves in high-quality liquid assets (e.g.

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.

Additionally, in February 2022, the National Insurance and Bond Commission granted Mercado Insurtech, Agente de Seguros, S.A.

definitive authorization to operate as an Insurance Agent.

On September 11, 2024, MercadoLibre, S.A., de C.V., Institución de Fondos de Pago Electrónico submitted to the National Banking and Securities Commission ("CNVB") an authorization request to organize and operate as a multiple banking institution.

As of the date of this filing, the aforementioned authorization is still pending approval.

("MPY") and Mercado Pago Asset Management S.A.

("MPA") were established.

After its registration in the General Inspection of Justice, these subsidiaries requested a Comprehensive Settlement and Clearing Agent license and a Product Administration Agent of Collective Investment - Common Investment Funds license, respectively, from the Argentinian National Securities Commission (“CNV” according to its Spanish acronym), which were authorized on February 5, 2025.

On February 25, 2025, the CNV approved the registration of MPY as a Comprehensive Investment Fund Placement and Distribution Agent (ACDI).

On the same day, the CNV approved the request made by MPA to replace Industrial Asset Management S.A.

as management agent of “Mercado Fondo.” As of December 31, 2025, the assets under administration of MPA related to mutual funds amount to 4,536 million.

In April 2025, Mercado Pago Servicios de Procesamiento S.R.L.

(“MPSP”) created a global program for the issuance of debt securities.

The maximum principal amount of the debt securities permitted to be outstanding at any one time under the program is $500 million (or its equivalent in other currencies and/or units of value or measure).

In July 2025, MPSP was authorized by the CNV to issue debt securities under Argentina's public offering regime, and as result, it is regulated by the CNV.

On June 17, 2025, we filed an application with the CBA to obtain a banking license in Argentina for a new entity to be incorporated, which will be controlled by the subsidiaries Meli Participaciones, S.L.

and Marketplace Investments, LLC.

As of the date of this filing, the application is currently under review.

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.

15 | MercadoLibre, Inc.

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

and Mercado Pago Operadora S.A.

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

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

These licenses transformed Mercado Pago Emisora S.A.

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submitted the license application to the CMF within the legal deadline for its ruling, which is still pending approval.

On April 8, 2024, the Chilean Congress published the Cybersecurity Law.

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.

The main objective of the Company is the remunerated intermediation of general and life insurance contracts with any insurer based in Chile.

On April 8, 2024, the Chilean Congress created de National Cybersecurity Agency ("ANCI") which act as the competent authority for critical and essential service providers in Chile and also published the Cybersecurity Law.

Although Mercado Pago Chilean entities already comply with the law’s main obligations as a result of being regulated entities, pursuant to this new law, such entities will be subject to a new regulator and must comply with certain reporting requirements for cybersecurity incidents.

We expect that the Mercado Pago Chilean entities will be required to comply with these new reporting requirements sometime during 2025 or 2026.

On May 30, 2024, the Chilean Congress passed Law 21,673, amending Law 20,009, which, effective as of June 1, 2024, establishes a limited liability regime for users of prepaid cards in case of loss, theft, or fraud.

However, in this context, in June 2025, Mercado Pago Operadora S.A.

and Mercado Pago Emisora S.A.

submitted their filings before the ANCI to be registered as "essential service providers", as required under the new regulatory framework, which were admitted.

In December 2025, the ANCI published the entities that were classified as Operators of Vital Importance (“OIV”), and only Mercado Pago Operadora S.A.

has been included in that list.

Such classification impose Mercado Pago Operadora S.A.

specific obligations regarding cybersecurity governance, technical and organizational security measures, incident reporting protocols, business continuity standards and oversight by the ANCI.

Mercado Pago’s Chilean entities are preparing to meet all applicable obligations once secondary regulation is enacted.

On May 30, 2024, the Chilean Congress passed Law 21,673, which establishes a limited liability regime for users of prepaid cards in case of loss, theft, or fraud.

Pursuant to Law 21,673, there may be instances in which an issuer may suspend a refund in the event of fraud or serious fault on behalf of the user claiming such refund on account of allegedly fraudulent charges.

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completed the implementation of these measures for its compliance.

In December 2024, Law No.

21,719 was approved by the National Congress of Chile to regulate the processing and protection of individuals' personal data.

The law establishes the creation of a Data Protection Agency, which will serve as a technical and autonomous entity responsible for supervising and ensuring the data protection rights of individuals in Chile.

This agency will have various powers, including the authority to oversee and sanction data controllers who do not comply with the regulations.

The modifications will enter into force 24 months after their publication, while the necessary regulations must be issued within a period of six months.

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.

The main objective of the Company is the remunerated intermediation of general and life insurance contracts with any insurer based in Chile.

Colombian regulations establish specific requirements to open accounts and provide certain financial services, as well as policies for cash and risk management.

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

In June 2025, Mercado Pago Operadora S.A.

submitted an application to the CMF for registration to execute cross-border transactions.

As of the date of this filing, this application is pending approval by the CMF.

15 | MercadoLibre, Inc.

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On August 6, 2025, Mercado Pago Operadora S.A.

submitted an additional request to the CMF for approval of the enhancement of the existing Prepaid Card Issuer License.

The proposed upgrade entails the conversion of the current license into a consolidated Prepaid Card and Credit Card Issuer License.

As of the date of this filing, this additional request is pending approval.

Colombia has regulatory frameworks for establishing clear guidelines to open accounts and delivering financial services.

These include comprehensive policies for cash and risk management, with a particular focus on liquidity risk.

Additionally, payment processors like Mercado Pago must adhere to high standards regarding security, privacy, and anti-money laundering compliance.

In June 2023, MercadoPago S.A.

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On April 22, 2024, MercadoPago S.A.

Compañía de Financiamiento started operations initially offering only the “Ordinary Deposit” product.

In accordance with regulations, customers' funds are now subject to regulatory liquidity, reserve, and solvency requirements to ensure their protection.

Compañía de Financiamiento started operations, currently offering only the “Ordinary Deposit” product.

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 (“BCU”) as an entity entitled to provide services of payments and collections (“PSPC”).

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

In 2016, Mercado Pago was launched in Uruguay and registered in Central Bank of Uruguay ("BCU") to provide services of payments and collections ("PSPC").

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

13 unchanged sentences

received authorization from the BCU to offer payment with transfers acquiring services.

16 | MercadoLibre, Inc.

On April 17, 2024, MercadoPago Uruguay S.R.L.

4 unchanged sentences

In September 2024, the BCU announced that they approved the release of the interoperable QR transfer payment feature of the payment system.

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, 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.

On February 20, 2024, the Register of Entities with Payments by Card agreement form was completed, in accordance with BCRP requirements.

In August 2025, MercadoPago Uruguay S.R.L.

filed an application with the CBU to offer interest-bearing accounts, through a partner.

MercadoPago Uruguay S.R.L.

has provided all requested information but the authorization is still pending approval by the CBU.

On July 17, 2025, the Bermuda Monetary Authority (“BMA”) granted Meli ISAC Ltd.

and Meli ISA Ltd., two Bermudian subsidiaries of the Company, a Digital Asset Business license application to issue and operate the Company’s stablecoin, Meli Dólar, which was conditional upon satisfying certain pre-commencement requirements that were completed in August 2025.

Therefore, on August 18, 2025, the BMA issued the corresponding Class M Digital Asset Business licenses, thus authorizing Meli ISAC Ltd.

to issue, sell or redeem digital assets, and authorizing Meli ISA Ltd.

to operate as a digital assets service vendor.

On September 22, 2025, the migration of the Meli Dólar business from Uruguay to Bermuda was successfully completed under the Class M Digital Asset Business licenses and operations under this new regulatory framework commenced.

16 | MercadoLibre, Inc.

T able of Contents

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