Modality of allocating the direct costs taken into account for the calculation of the IAC at CFR 

CFR NETWORK STATEMENT - 2026 ANNEX 25.c MODALITY OF ALLOCATING THE DIRECT COSTS TAKEN INTO ACCOUNT FOR THE CALCULATION OF THE IAC AT CFR Validity: 01.03.2024 – 14.12.2026 Version: 15.1.0 Update: 15.01.2026  Compania Naţională de Căi Ferate “CFR” S.A. România Modality of Allocating the Direct Costs Taken into Account for the Calculation of the IAC at CFR starting with 01.03.2024 1. GENERAL PRINCIPLES REGARDING THE IAC CALCULATION MODALITY For the traffic of a train on the railway infrastructure managed by CFR between two points (stations) of the network, without shunting or (re)fuelling services, CFR shall calculate and levy an Infrastructure Access Charge (IAC). IAC shall apply in a non-discriminatory way to all the RUs under similar conditions of transport. TUI shall be calculated by the CFR for the services supplied within the minimum access package defined in point 1 of Annex II to Law No. 202/2016 on the integration of the Romanian railway system into the Single European Railway Area, hereinafter referred to as the MAP, with its further amendments and supplements, hereinafter referred to as Law 202/2016. In accordance with the provisions of Article 31(3) of Law No. 202/2016 on the integration of Romania into the Single European Railway Area, with its further amendments and supplements (hereinafter referred to as Law No. 202/2016), which is the transposition of UE Directive No. 2014/34, „…. the charges for the minimum access package and for access to infrastructure connecting service facilities shall be set at the cost that is directly incurred as a result of operating the train service, in accordance with the measures adopted by the European Commission, by means of implementing acts, setting out the modalities for the calculation of the costs that are directly incurred as a result of operating a train.” The implementing act is Implementing Regulation (EU) 2015/909 on the modalities for the calculation of the cost that is directly incurred as a result of operating the train service (hereinafter referred to as EU Regulation 2015/909). In order to explain the principles regarding the modality of allocating the IAC-related direct costs (the direct cost that is directly incurred as a result of operating the train service), we present in the following some general aspects regarding the IAC calculation modality As shown in Article 5.3.2 of the NS, the IAC shall be calculated on the basis of the “Methodology for Charging the Use of the Railway Infrastructure", approved, in accordance with the law, by means of the Activity and Performance Contract of Compania Națională de Căi Ferate "C.F.R." - SA, a methodology which is presented in Annex 25.a to the NS. This methodology sets down that the IAC shall be calculated, for each train running on the railway infrastructure managed by CFR SA, on the basis of a formula including values of the basic charging elements according to the category of the line on which the train runs. For determining the value of the basic charging elements, the traffic lines of the railway infrastructure shall be classified according to the maximum allowed line speed, per line categories from A (lines with a maximum speed of over 121 km/h) to D (lines with a maximum speed up to 50 km/h (Table No. 1). CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 2 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România Table No. 1 – Line Categories Speed Regime (km/h) Line Category from Up to A 121 160 B 91 120 C 51 90 D 0 50 The line categories and the modality of sharing the line categories into sections for the IAC calculation shall be presented in Article 6 and Article 7 of the methodology, and the list of line categories for the IAC sections shall be approved, in accordance with the law, by means of the Activity and Performance Contract of Compania Națională de Căi Ferate "C.F.R." - SA. The list of the sections for the IAC calculation classified per line categories can be found in Annex 25.b to the NS. The basic charging element shall be determined at the level of the direct cost related to the activity of the charging element, for each line category. Thus, the basic charging elements shall represent the direct cost related to the charging element incurred for running one kilometre on the relevant line category. The direct costs shall mainly include the costs of line maintenance and repair, those for the traffic activities (traffic management, signalling equipment, etc.), as well as those for supplying the traction current (for electrification). The basic charging elements applicable for determining the IAC shall be structured in accordance with Table No. 2, for each freight or passenger traffic type: Table No. 2 – Basic Charging Elements Name of the charging element Basic charging elements Charging elements according to the train Charge per train-km according to the tonnage tonnage (RON/train-km) Category of line A B C D Traffic lines Ttsn Ttsn Ttsn Ttsn Minimum tonnage Tmin Tmin Tmin Tmin Tonnage factor Ft Ft Ft Ft Charging elements according to the run Charge per train-km according to the distance distance ( RON/train-km ) Category of line A B C D Traffic Tc Tc Tc Tc Electrification Ttse Ttse Ttse Ttse The basic charging elements shall have the following meaning: Ttsn - represents the charge according to the tonnage for each km of line category; CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 3 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România Tmin – represents the gross tonnage of the train starting from which the tonnage factor shall be applied; for trains with a tonnage lower than Tmin, Ttsn related to Tmin shall be applied. Ft – the tonnage factor represents a correction coefficient to be applied to the gross train tonnage; Tc - represents the traffic charge according to the distance for every km of line category. Ttse – represents the charge for the use of electrification equipment for each km of category of electrified line, and does not include the value of traction current; The direct costs shall mainly include: - for Ttsn - the line maintenance and repair costs according to the train tonnage; - for Tc - the costs of the traffic activities (traffic management, signalling equipment, etc.); - for Ttse - the costs for supplying the traction current (for electrification). (2) The IAC value for a train running on a traffic route shall be calculated as the sum of the charges for each distance run on a IAC section (section IAC), according to its category, by using the following formula: TUI =  section IAC where: section IAC = tonnage IAC + traffic IAC + electrification IAC and: tonnage IAC - represents the railway infrastructure access charge for a IAC section category according to the run distance, as well as the tonnage of the train, and shall be calculated by using the following formula: tonnage IAC = Km x Ttsn [1 + (Gross tonnage – Tmin) x Ft] where: Km = the number of km run on the IAC section; Ft = 0 for the trains with a gross tonnage below Tmin; Gross tonnage = the gross tonnage of the train according to the form „Wagon Display”, including the locomotives in action or the tonnage of the locomotives or self-propelled units for the traffic without hauled rolling stock. traffic IAC - represents the charge for the traffic management according to the distance run, and shall be calculated by using the following formula: traffic IAC = Km x Tc where: Km = the number of kms run on the IAC section; electrification IAC - represents the charge for the use of electrification equipment for each category of electrified line, only for trains with electric traction, according to the distance run, and shall be calculated by using the following formula: electrification IAC = Km x Ttse where: Km = the number of kms run on the IAC section with electric traction; CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 4 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România By using the values of these charging elements specific to the line categories related to the traffic route of a train in the formula set down in the methodology, it results the IAC value for the relevant train. The values of the basic charging elements for the calculation of the IAC for each IAC category and per type of freight or passenger traffic as mentioned in the methodology shall be determined by CFR SA, in accordance with the provisions of the Activity and Performance Contract of CFR SA for the period of time 2021-2025. As a result, it is the basic charging elements that actually determine the IAC value for a run train. The values of the basic charging elements for the IAC calculation valid for the period of the timetable in force are presented in Annex in paragraph 1.2 of Annex 26.a. CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 5 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România 2. MODALITIES OF APPROACHING THE DETERMINATION OF THE DIRECT COSTS FOR THE IAC As we shown before, the IAC value shall be the value of the basic charging elements determined at the level of the direct costs, according to the category of the line used. In a first stage, starting from the total operating expenses, there shall be determined the total value of the net direct costs related to the IAC (or the MAP) to be allocated to the specific basic activities. In the second stage, by allocating them according to the line categories set down in the IAC calculation methodology, there shall be obtained the values of the basic elements used in the IAC calculation formula. Taking into account the provisions of Article 3(5) of Regulation 2015/909, there can be in principle two ways of approaching the determination of the direct costs related to the supply of the MAP: a) according to the forecast costs This modality shall include the determination of the forecast direct costs related to the supply of the MAP estimated for the calendar year following the timetable in force (forecast cost - as shown in Article 5, last paragraph of EU Regulation 2015/909) to be calculated according to the forecast direct costs eligible for the MAP for the next reference period. In this case, there shall be used the forecast traffic data for the next calendar year, provided by the RU distributed per line categories according to the percentages recorded in the previous year. Although CFR requested several times the forecast traffic data from the RUs at least 6 months before the next year, these, for objective reasons (related to the predictability of the transport contracts), were unable to provide the requested data. In this case, there may be used the traffic data related to the previous period or the data updated by applying an index forecast by CFR in its capacity as the railway infrastructure manager based on the previous progress of the train-km indicator. Considering the fact that during the period of assessing the forecast costs for the next year (usually in the middle of the current year) the amounts related to the transfers from the state budget are not established yet (the CFR budget is approved later, usually only in the first part of the next year), these transfers are forecast according to the mechanism for establishing the budget transfers related to the last available period (e.g. the current year or the previous year). b) according to the (previous) outturn costs When the forecast data on the direct costs for the next year or those on the budget transfers are not available or cannot be forecast with sufficient accuracy for the next reference period (next year) there may be used the actual available direct costs related to the immediately previous period (outturn cost - as shown in Article 5, last paragraph of EU Regulation 2015/909), calculated according to the outturn direct costs eligible for the MAP for the previous reference period (budget year already completed). In this case, there shall be used the traffic data related to the previous period. Throughout this material, it shall be considered that the notion of “cost” is equivalent to that of “expenditure” and vice versa, and refers to the forecast cost or the outturn cost, depending on the approach adopted at letter (a) or (b) above. It should also be specified that the references to costs/expenditures in the following chapters refer only to CFR and the lines of the interoperable and non-interoperable railway infrastructure managed by CFR. CFR cannot take into account the cost incurred by the managers of the non-interoperable railway infrastructure for the infrastructure rented from CFR and managed by them. CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 6 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România 3. PRINCIPLES OF DETERMINING THE EXPENDITURES/DIRECT COSTS TAKEN INTO ACCOUNT FOR THE CALCULATION OF THE IAC The principles of allocating the direct costs for the calculation of the IAC are based on the provisions of Law 202/2016 and EU Regulation 2015/909. For the calculation of the direct costs at network level, CFR shall use the principle defined in Article 3(1) of Regulation (EU) 2015/909: “Article 3(1) Direct costs on a network-wide basis shall be calculated as the difference between, on the one hand, the costs for providing the services of the minimum access package and for the access to the infrastructure connecting service facilities and, on the other hand, the non-eligible costs referred to in Article 4.” The costs for providing the services of the minimum access package shall be the costs related to the services from item 1 of Annex II to Law 202/2016. We will use below the acronym MAP for the minimum access package. The costs for providing the services for the access to the infrastructure connecting service facilities shall be the costs related to the Charge for the Access of Shunting Convoys to/from the CFR Railway Infrastructure, a charge included in the category of additional services (ASC), which shall be determined at the level of the direct costs (without AGC and profit share), which is why in the following we will refer only to the Costs for providing the services in the MAP. The main stages for determining the direct costs for providing the IAC-related services shall be as follows: a) Determination of the total operating expenses (Ctotal operating) – these shall be obtained from the analysis of the CFR annual budget. b) Determination of the total gross cost for the MAP (Ctotal gross) Ctotal gross MAP = Ctotal eligible – Costs not attributable to the MAP c) Determination of the gross eligible cost for the IAC (Cgross eligble IAC) Cgross eligible IAC = Ctotal gross MAP – Non-eligible costs d) Determination of the IAC-related direct cost (Cd TUI) Cdirect IAC = Cgross eligible IAC – IAC non-eligible costs After determining the IAC-related direct cost, its value shall be distributed among the main activities (Lines, Installations, Traffic, Electrification) according to the direct costs incurred by each of these activities. e) Determination of the value of the basic charging elements This shall represent the final stage, and consist in determining the value of the basic charging elements from the IAC calculation methodology: Ttsn for line activity, Tc for installation, traffic and other activities (such as traffic- related telecommunications