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

), and Ttse for electrification activities ) by traffic types (freight or passenger and per line classes (A, B, C and D). The modalities of determining the costs specific to each stage are explained in the chapters below. CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 7 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România Figure No. 1 shows the diagram of the relations between the cost types from a) to d) CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 8 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România 4. MODALITY OF DETERMINING AND ALLOCATING THE COSTS This chapter shall present the modality of determining the costs related to the main stages indicated in the previous chapter. 4.1 Determination of the Total Operating Expenses The total operating expenses shall be CFR’s gross operating costs related to the provision of the railway infrastructure. These expenses shall mainly include the following items: - the operational cost of the functioning of the network (maintenance, repair, traffic management, and other operational costs, and other overheads); - the capital cost; - total subsidies related to the provision of the MAP; - subsidies related to the capital cost and the operational cost. The total operating expenses shall be recorded at the level of a calendar year on the basis of the form “Annex 2 Budget”, which is established in accordance with the requirements of the Order of the Minister of Public Finances No. 3818/2019 on approving the format and structure of the income and expense budget of the economic operators, as well as its substantiating annexes. As a supporting element, for a detailed breakdown of staff costs only, there shall also be used a breakdown of the costs of all CFR staff. For collecting this data, CFR developed two data templates, as follows: - a template with the recording of the expenses related to the CFR staff, which includes both the details on nine expense items (on the rows in the table), and their breakdown (on the columns in the table) per the main activities (Lines, Installations, Traffic, Electrification, other activities) for: basic units of the Regional Railway Branches, central unit of the Regional Railway Branches, and the CFR Headquarters, hereinafter referred to as Annex 1 (Annex for staff expenses). At the end of the table is presented the summary for: (i) the staff costs for the IAC, (ii) the administrative expenses for the staff, (iii) the fixed staff costs, and (iv) other non-eligible staff costs for the IAC. This data shall be later used for the distribution of the staff expenses related to Annex 2 but also for determining the direct costs of the CFR staff. - a complex template with the recording of the operating expense indicator, which is in accordance with the form “Annex 2 Budget” set down in the Order of the Minister of Public Finances No. 3818/2019, but also includes the additional details of some expense chapters to allow a clearer record of some common costs. This annex shall be hereinafter referred to as Annex 2 (Annex on the operating expenses), and include the details of the operating expenses per over 150 sub-chapters (on the rows in the table), and their breakdown (on the columns in the table) per main activities (Lines, Installations, Traffic, Electrification, Operation Buildings and Other Activities). There shall also be recorded in Annex 2 the amounts related to the Gross Eligible Cost for the IAC (GEC_IAC). Annex 1 and Annex 2 shall be filled in with the data required in the form both at the level of each of the 8 CFR Regional Railway Branches (RRBs 1-8) and at the level of the CFR Headquarters, whereas the supplied data shall be then centralized (summed in a matrix) in order to obtain the costs at the overall level of CFR. The total operating expenses shall be calculated as the sum of the expense chapters from A to D in Annex 2. CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 9 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România 4.2 Determination of the Total Gross Cost for the MAP This cost shall be obtained by deducting from the Total Operating Expenses the expenses that are not part of the supply of the MAP, and represent: - the cost of the services related to the additional services - ASC (which are not included in the MAP) provided by CFR upon the request of the RU (ASC-related costs) - the costs for other services besides the ASC, such as, e.g., the charge for driving the traffic on non- interoperable sections, and the service charge for the industrial railway lines; - the administrative costs related to the ASC and other charges besides the ASC. 4.3 Determination of the Gross Eligible Cost for the IAC This cost may be obtained by using two methods: a) the method indicated at Article. 3(1) of EU Regulation 2015/909 For this purpose, in principle there shall be deducted from the Total Gross Cost (Art. 3.2), in a first stage, a part of the non-eligible costs for the direct cost mentioned at Article 4 of the same Regulation: - fixed cost related to the administrative cost of all the staff (from Annex 1); - fixed cost of the used staff irrelevant of the traffic volume (from Annex 1); - other non-eligible staff costs (from Annex 1); - other non-eligible costs recorded in Annex 2; - subsidies (budget allocations) for the costs related to the CFR staff not involved in the activities related to the MAP (the IAC); - subsidies (budget allocations) for the investment activities. b) the method of using the data from Annex 2, from which only the gross eligible costs related to the MAP and registered in Annex 2 are recorded and taken into account. In principle, the amount of these costs collected from the data supplied by the RRBs 1-8 and the CFR Headquarters should be concurrent with the amount of the costs determined by using the method a). The gross eligible cost for the IAC shall be then recorded per the main activities of CFR (Lines, Installations, Traffic, Electrification). In order to facilitate the determination of the gross eligible cost for the IAC, there are highlighted (for example by marking on a green background) on each of the two annexes from Chapter 4.1. (Determination of the total operating expenses) the cells containing the data related to the gross eligible cost for the IAC. 4.4 Determination of the IAC-Related Direct Cost This cost shall be obtained by deducting from the Gross Eligible Cost for the MAP the second stage of non-eligible cost for the direct cost mentioned at Article 4 of EU Regulation 2015/909: - total budget amounts for the railway infrastructure maintenance, repair and operation; CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 10 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România - amounts from the budget for the social security for the traffic operating staff; - salary cost for the ASC + other charges besides the ASC; - fixed cost related to the staff on sections without traffic (from Annex 1) - amounts from the budget for non-eligible costs for electrification; - VAT amounts from the budget. In order to obtain the IAC-related direct cost per the main activities, there shall be deducted from the gross eligible cost for the IAC recorded per the main activities (mentioned at the end of Chapter 4.3) the costs shown above, also distributed per the main activities. The result shall be the IAC-related direct cost for Lines, Traffic (Traffic + Installations) and Electrification, a cost that is used in the next stage to determine the basic charging coefficients: Ttsn (Lines), Tc (Traffic + Installations + other activities) and Ttse (Electrification)). The weight of the values of the IAC-related direct cost applicable in 2024, distributed per types of activities, is presented in Table No. 3 Table No. 3 – The Weight of the IAC-Related Costs per Types of Activities Applicable in 2023 Lines Traffic Electrification 21,14% 75,81% 3,05% Table No. 4 shows the weight of the value of each type of cost from the stages of determining the IAC-related direct cost (presented in Chapters 4.2-4.4) relative to the value of the total operating expenses (Chapter 4.1). These weights are valid for the data applicable in 2024. Table No. 4 - The Weight of the Types of Costs Relative to the Total Operating Expenses Ctotal gross Cgross eligible Cdirect IAC MAP IAC 98,07% 55,91% 16,15% 4.5 Determination of the Value of the Basic Charging Elements The values of the basic charging elements (coefficients) used in the IAC calculation formula (Ttsn, Tc and Ttse) shall be unit values of the related direct costs (RON/km) distributed per line categories and traffic types (freight and passenger). These unit values shall be obtained by relating the value of the IAC-related direct costs per types of activity (shown in Chapter 4.4) to the volume of traffic in the period under analysis (according on the modalities of approaching the determination of the direct costs presented in Chapter 2 letter (a) and (b) , using the combined weight of the costs and the traffic volume per line categories per types of transport (freight and passenger). The values of the basic charging elements (coefficients) used in the IAC calculation formula, applicable in 2024, were determined based on the data from the Final Report developed within the project “Calculation of the Infrastructure Access Charges”, carried out by the consulting firm First Class Partnerships (FCP) Ltd. from England, by using the modality of approaching the determination of the direct costs presented in Chapter 2 letter (b). There shall be presented next the principles for determining the unit costs per charging elements (from a) to c)), and then (letter d) the modality of determining these costs for the basic charging elements (Ttsn, Tc, Ttse), as well as a comparative analysis between the new values and the old ones. CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 11 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România a) Unit costs for line activity (Ttsn) There are two standard ways of determining costs by line categories. One is based on UIC sheet 714, 'Classification of lines for railway maintenance purposes (Fourth Edition, 2009)'. It uses theoretical traffic volumes based on a combination of gross tons circulated, speed and axle load for each railway station. The other method closely related to the first, is the use of "Instruction no. 300 for repair and maintenance of railway lines", which is the CFR standard for line maintenance and is very similar to the UIC Sheet 714. This method is more appropriate to the specifics of CFR. Thus, for the CFR activity, the determination of the costs related to the activity of lines by categories of traffic line is made according to the elements and conditionalities set out in the Annexes 5 and 10 of the Instruction no. 300: ▪ Annex 5 "Schedule of the cycles of periodic repair and current maintenance" highlights the frequency of types of repair and maintenance of the path: - overhauls, - burage maintenance work, - periodic repairs for maintaining parameters, - periodic repair with material replacements, and - current maintenance works The frequency and type of works actually determine the costs related to the maintenance/repair of the line which are also depending on the scale and density of the works and the length of the line path. ▪ Annex 10 "Coefficients for conversion into conventional km in terms of maintenance" The relative weights of the current maintenance effort on different types of lines are given in this Annex. Depending on the line speed category, the coefficients are set between 1.45 for the best category and 0.7 for the weakest category and intermediate coefficients of 1.15 and 0.95. Thus, the equivalence coefficient for the current line categories can be assimilated under reasonable conditions as shown in Table No. 5: Table No. 5 - Coefficients for the equivalence of the assimilated maintenance and repair activity in the Instruction 300 Line category A B C D 1,45 1,15 0,95 0,70 These coefficients shall be used for the weighting of line costs by line category. Depending on the cost structure resulting from the application of the Instruction 300, it appears that for an A category line, the costs should be approximately double that of a D category line (1.45 : 0.70 = 2.07). This weighting corresponds to an obvious reality: the costs for an A category line must be significantly higher than those for a D category line. In view of the above, in order to ensure a fair relationship between the cost of repair/maintenance of the line and the line categories, new Ttsn coefficients have been determined, corresponding to the reality. b) Unit costs for traffic activity CFR Network Statement - 2026 ANNEX 25.c Version:15.1.0 Update: 15.01.2026 Pag: 12 / 20  Compania Naţională de Căi Ferate “CFR” S.A. România In order to determine the direct costs related to the traffic activity (Tc), the expenses with the traffic activity, those with the activity of installations, as well as other expenses such as those with telecommunications related to the traffic activity were taken into account. c) Unit costs for electrification activity These costs are determined relatively simply because they do not depend on the line category on which the train runs or on the type of traffic (freight or passengers). As a result, they are obtained by relating the direct costs related to the electrification activity to the volume of the train km that circulated with electric traction. d) Determination of the value of basic charging elements (Ttsn, Tc and Ttse) and their comparative analysis In order to be able to determine the unit values of the charging elements, a computerized calculation model was developed with the help of which several simulation iterations were performed. The computer model had as input data(s) the following elements: - the costs of line, circulation and electrification activities; - coefficients for the equivalence of maintenance and repair activity by line categories; - the weight of the line lengths for each of the A to D category; - the volume of the freight traffic broken down by line category; - the volume of passenger traffic broken down by line category; - the tonnages of the freight trains and the tonnages of the passenger trains broken down by line categories - the tonnage factor. As a general principle, in order to obtain the unit values of the basic charging elements, the model reported the value of the direct costs related to the IAC for the activity of lines, circulation and electrification to the volume of traffic during the analyzed period, using the combined share of the above elements. The simulations carried out showed some variations in the coverage of direct costs by the type of activity, but the option that reached a 99.2% coverage of the costs was chosen. The values of the basic charging elements resulting from this variant are presented in Table no. 6 Table No. 6 - Values of the basic charging elements resulting from the simulation (RON/km) Traffic Line category Element Ttse Ft type A B C D Tsn 5 4,05 3,1 2,15 Passengers 0.00020 Tc 6,2 6,2 5,9 2,65 Tsn 5 4,05 3,1 2,15 1,11 Freight 0.00025 Tc