TERMS & CONDITIONS OF SERVICE

Effective Date: 1 January 2026 Document Version: 1.0

IMPORTANT LEGAL NOTICE — READ CAREFULLY BEFORE USING THE PLATFORM

These Terms and Conditions (“Terms”) constitute a legally binding agreement between you (the “User,” “Client,” or “Subscriber”) and TicTac Cyber Security & Data Recovery Services S.A. (Ελληνική Επωνυμία: ΤΙΚ ΤΑΚ ΥΠΗΡΕΣΙΕΣ ΚΥΒΕΡΝΟΑΣΦΑΛΕΙΑΣ ΚΑΙ ΑΝΑΚΤΗΣΗΣ ΔΕΔΟΜΕΝΩΝ Α.Ε.), a company duly incorporated under the laws of Greece, with its registered office at 9 Tripoleos str., 17237, Ymittos – Athens, Greece, VAT No. (ΑΦΜ) 800782394, GEMI No. (ΓΕΜΗ) 140756708000, operating the compliance platform accessible at www.startcomply.com (the “Platform”).

By accessing, registering for, or using the Platform or any part of the Services, you unconditionally acknowledge that you have read, understood, and agree to be legally bound by these Terms in their entirety.

If you do not agree with any part of these Terms, you must immediately cease all access to and use of the Platform.

These Terms apply to all visitors, registered users, subscribers, and any person accessing the Platform on behalf of a legal entity.

1. DEFINITIONS

“StartComply” means TicTac Cyber Security & Data Recovery Services S.A., its successors, affiliates, officers, employees, agents, and authorized contractors, operating the StartComply.com platform.

“Platform” means the StartComply.com software-as-a-service (SaaS) application, including all modules, dashboards, tools, APIs, automation features, documentation frameworks, and associated services.

“Services” means everything made available through or in connection with the Platform, including compliance workflow tools, assessment templates, policy management systems, advisory resources, automation modules, and any related operational support.

“User” / “Client” / “Subscriber” means the legal entity and its authorized representatives who access or use the Platform under a registered account.

“Authorized User” means any individual to whom the Client grants access credentials within the Platform.

“Content” means all data, files, documents, policies, information, and materials submitted, uploaded, or generated through the Platform by the User.

“Credits” means the usage units allocated to the Subscriber’s account as part of a Subscription plan, governing the extent of Platform usage.

“Subscription” means the paid access plan selected by the Subscriber, governing the duration, scope, and Credit allocation of Platform usage.

“Confidential Information” means non-public technical, financial, legal, or commercial information disclosed by either party in connection with these Terms.

“DPO” means the designated Data Protection Officer of TicTac Cyber Security & Data Recovery Services S.A., currently Panagiotis Pierros.

2. ELIGIBILITY AND AUTHORITY

The Platform is designed and intended exclusively for business entities and their duly authorized professional representatives.

By using the Platform, you represent and warrant that:

You are a legal entity or acting as an authorized representative of one;

You have full legal authority to enter into and be bound by these Terms on behalf of that entity;

You are at least 18 years of age if acting as an individual representative;

All information you provide is accurate, current, and complete;

Your use of the Platform complies with all applicable local, national, and EU laws and regulations;

You are not subject to any sanction, prohibition, or restriction that would preclude use of the Services.

StartComply reserves the right to refuse, suspend, or terminate access to any User or entity that does not satisfy these eligibility requirements, without prior notice and without liability.

3. DESCRIPTION OF SERVICES

StartComply.com provides a compliance technology platform designed to assist organizations in structuring, automating, and managing internal compliance processes, including but not limited to those relevant to EU regulatory frameworks such as NIS2, DORA, GDPR, ISO standards, and related frameworks.

The Services include compliance workflow management tools, automated compliance assessment and gap analysis modules, documentation and policy generation frameworks, risk assessment and scoring systems, template libraries and advisory resource repositories, credit-based usage mechanisms, and reporting and audit trail features.

3.1 Express Exclusions

The Platform does not and shall not be construed to:

Issue, grant, or represent any regulatory certification or official compliance status;

Constitute legal advice, regulatory advice, or professional advisory services of any kind;

Guarantee that any output, documentation, or process satisfies the requirements of any regulatory body, supervisory authority, or auditor;

Replace the need for qualified legal counsel, compliance officers, or accredited certification bodies;

Represent or act on behalf of the User before any authority.

StartComply may, at its sole discretion and without incurring liability, modify, suspend, replace, limit, or permanently discontinue any feature, module, or aspect of the Services at any time.

4. ACCOUNT REGISTRATION AND SECURITY

Access to the Platform requires account registration. You agree to:

Provide and maintain accurate, truthful, and current registration information;

Keep all access credentials (usernames, passwords, API keys) strictly confidential;

Restrict access to Authorized Users only and ensure their compliance with these Terms;

Immediately notify StartComply at info@startcomply.com upon discovery of any unauthorized access, suspected breach, or misuse of your account.

You are solely and fully responsible for all activity conducted through your account, including any acts or omissions by your employees, contractors, agents, or third parties to whom you grant access. StartComply shall not be liable for any loss, damage, or consequence arising from unauthorized use of your account where such use was facilitated by your failure to secure credentials or limit access.

5. SUBSCRIPTIONS, CREDITS, BILLING, AND RENEWALS

5.1 Subscription Model

Access to paid Services is governed by the Subscription plan selected at the time of registration or upgrade. Subscriptions are:

Billed in advance on an annual basis;

Subject to the Credit allocation specified in the applicable plan;

Non-refundable once activated, except where expressly agreed in writing by StartComply.

5.2 Credit System

Credits are allocated at the start of each Subscription term;

Credits are non-transferable and expire at the end of the applicable Subscription term regardless of usage;

Additional Credits may be purchased and are subject to the same expiry date as the existing Subscription cycle;

Unused Credits carry no monetary value and shall not be refunded or rolled over.

5.3 Pricing and Modifications

StartComply reserves the right to modify pricing, plan structures, and Credit allocations. Modifications will be communicated with reasonable prior notice and shall apply from the next renewal period unless otherwise stated.

5.4 Non-Payment

Failure to meet payment obligations may result in:

Immediate suspension of access without prior notice;

Termination of the Subscription;

Referral to collection or legal proceedings for outstanding amounts.

6. USER RESPONSIBILITIES AND REGULATORY OBLIGATIONS

The User bears sole and exclusive responsibility for:

The accuracy, legality, and completeness of all data uploaded or generated on the Platform;

Ensuring that all Content complies with applicable laws, including data protection and privacy regulations;

Implementing and maintaining adequate internal governance, oversight, and compliance management processes;

The conduct of all Authorized Users;

Regulatory filings, declarations, audits, certifications, and dealings with supervisory authorities;

Retaining qualified legal, compliance, and technical advisors as necessary;

Applying appropriate cybersecurity measures, including encryption of sensitive or regulated data prior to upload where legally required.

StartComply acts exclusively as a technology service provider and does not act as a Data Controller, compliance officer, or regulatory representative of the User in any capacity.

7. DATA PROTECTION AND SECURITY DISCLAIMER

7.1 Technical Safeguards

TicTac Cyber Security & Data Recovery Services S.A. implements commercially reasonable technical and organizational security measures designed to protect data hosted on the Platform, including access controls, encryption in transit, audit logs, and infrastructure monitoring.

7.2 Absolute Disclaimer of Security Guarantee

No digital system can guarantee absolute security. StartComply expressly disclaims any warranty of uninterrupted, error-free, or breach-proof operation of the Platform.

The User acknowledges and accepts that:

Cyber threats, including unauthorized access, ransomware, data exfiltration, and denial-of-service attacks, are inherent risks of any online platform;

StartComply cannot guarantee the prevention of all security incidents;

The User assumes all risk associated with uploading and storing data on the Platform;

Where applicable law or internal policy requires encryption of sensitive data, the User is solely responsible for applying such encryption prior to upload.

7.3 Liability for Security Incidents

StartComply shall not be liable for any loss, damage, unauthorized access, data breach, or cyber incident except where directly and exclusively caused by StartComply’s own proven gross negligence or willful misconduct. The burden of proving gross negligence or willful misconduct rests entirely with the User.

7.4 GDPR and Data Processing

To the extent that the Platform processes personal data on behalf of the User, such processing shall be governed by a separate Data Processing Agreement (DPA). The User, as Data Controller, remains solely responsible for the lawfulness of all personal data submitted to the Platform.

For all data protection matters, the designated Data Protection Officer of TicTac Cyber Security & Data Recovery Services S.A. is:

Panagiotis Pierros Email: info@startcomply.com Address: 9 Tripoleos str., 17237, Ymittos – Athens, Greece

8. LIMITATION OF LIABILITY

8.1 General Exclusion of Liability

To the fullest extent permitted by applicable law, TicTac Cyber Security & Data Recovery Services S.A., its shareholders, directors, officers, employees, agents, affiliates, successors, and authorized contractors shall not be liable — whether in contract, tort (including negligence), statute, or otherwise — for any of the following, however caused:

Regulatory fines, administrative penalties, or supervisory sanctions;

Audit failures or adverse audit findings;

Loss of business, revenue, profit, or anticipated savings;

Reputational damage or brand harm;

Loss, corruption, or unauthorized disclosure of data;

Failure to achieve or maintain compliance with any regulation or standard;

Claims brought by third parties;

Business interruption or operational disruption;

Indirect, incidental, special, consequential, exemplary, or punitive damages.

8.2 Aggregate Liability Cap

In all cases where StartComply is found liable despite the above exclusions, total aggregate liability shall not exceed the total Subscription fees paid by the User to StartComply in the twelve (12) calendar months immediately preceding the event giving rise to the claim.

8.3 Essential Basis of Agreement

The User acknowledges that the limitations and exclusions of liability in this Section 8 form an essential basis of the agreement between the parties and that StartComply would not offer the Services at the current pricing without these protections.

9. DISCLAIMER OF WARRANTIES

The Services are provided strictly “AS IS” and “AS AVAILABLE” without warranty of any kind.

To the maximum extent permitted by law, StartComply expressly disclaims all warranties, whether express, implied, statutory, or otherwise, including but not limited to:

Fitness for a particular purpose;

Merchantability or satisfactory quality;

Non-infringement of third-party rights;

Achievement of regulatory compliance or certification;

Continuous, uninterrupted, or error-free availability;

Accuracy or completeness of outputs generated by the Platform;

Compatibility with the User’s systems or infrastructure.

The User assumes full and exclusive responsibility for evaluating and validating all outputs, documents, and assessments generated through the Platform before relying on them for any regulatory, legal, or business purpose.

10. INDEMNIFICATION

The User agrees to indemnify, defend, and hold harmless TicTac Cyber Security & Data Recovery Services S.A. and its affiliates, directors, officers, employees, and agents from and against any and all claims, actions, proceedings, damages, liabilities, losses, costs, and expenses (including reasonable legal fees) arising from or relating to:

Use or misuse of the Platform or Services;

Breach of these Terms;

The User’s regulatory non-compliance or failure to maintain adequate internal governance;

Any misrepresentation of compliance status to a third party or authority;

Violation of applicable laws or regulations;

Data protection breaches resulting from the User’s actions, omissions, or failures;

Claims by Authorized Users, employees, contractors, or third parties resulting from the User’s use of the Platform.

11. INTELLECTUAL PROPERTY

All intellectual property rights in and to the Platform, including source code, algorithms, designs, trademarks, logos, documentation, templates, and all related materials, are and shall remain the exclusive property of TicTac Cyber Security & Data Recovery Services S.A. or its licensors.

The User is granted a limited, personal, non-exclusive, non-transferable, revocable license to access and use the Platform solely for internal business compliance management purposes during the active Subscription term.

The User shall not:

Reverse engineer, decompile, or disassemble any part of the Platform;

Copy, reproduce, or extract source code or proprietary algorithms;

Sublicense, resell, or make available the Services or outputs to third parties for commercial gain;

Create derivative works based on the Platform or its outputs;

Use the Platform to build a competitive product or service;

Remove or alter any proprietary notices or branding.

Any feedback, suggestions, or improvement ideas submitted by the User may be used by StartComply without restriction or compensation.

12. CONFIDENTIALITY

Each party agrees to maintain the confidentiality of the other party’s Confidential Information using at least the same degree of care it applies to its own confidential information, and no less than reasonable care.

Confidentiality obligations do not apply to information that is or becomes publicly available through no fault of the receiving party; was already known prior to disclosure; is independently developed without reference to the disclosing party’s information; or must be disclosed by law or court order, provided prompt prior notice is given where legally permissible.

StartComply does not assume fiduciary obligations or heightened confidentiality duties beyond those expressly stated herein, unless agreed separately in a signed written agreement.

13. THIRD-PARTY INTEGRATIONS AND EXTERNAL SERVICES

The Platform may offer integrations with third-party tools, APIs, platforms, or data sources. StartComply is not responsible for the availability, performance, or accuracy of third-party services; data inaccuracies, outages, or security failures of external providers; or changes to third-party APIs or services that affect Platform functionality.

Use of third-party integrations is subject to those providers’ own terms of service and privacy policies. The User assumes full responsibility for any third-party tools deployed in conjunction with the Platform.

14. SUSPENSION AND TERMINATION

14.1 Termination by StartComply

StartComply reserves the right to immediately suspend or permanently terminate the User’s access to the Platform without prior notice if:

The User violates any provision of these Terms;

Required by applicable law or regulatory order;

A security risk or threat is identified;

Payment obligations are not met;

StartComply reasonably determines continued access presents legal or reputational risk.

14.2 Termination by User

The User may terminate the Subscription by providing written notice to info@startcomply.com in accordance with the notice period specified in the applicable plan. Termination does not entitle the User to a refund of

Please continue generating the last response from where you left off.

claude-4.6-sonnet ai model’s icon

Claude Sonnet 4.6

1 minute ago

Continuing seamlessly from Section 14.2:

prepaid fees under any circumstances, unless expressly agreed in writing by an authorized officer of StartComply.

14.3 Effect of Termination

Upon termination or expiry of any Subscription:

Access to the Platform and all Services ceases immediately;

All outstanding payment obligations remain due and fully enforceable;

Provisions relating to liability, indemnification, confidentiality, intellectual property, data retention, and dispute resolution survive termination indefinitely.

15. DATA RETENTION AND DELETION

Upon expiry or termination of a Subscription for any reason:

The User’s access will be revoked immediately;

Data submitted by the User to the Platform will be retained by TicTac Cyber Security & Data Recovery Services S.A. for a period of ninety (90) calendar days following the date of termination or expiry, for legitimate legal, audit, and operational purposes;

After the 90-day retention period, all User data may be permanently and irreversibly deleted from StartComply’s systems without further notice to the User;

StartComply bears no responsibility whatsoever for the retrieval, recovery, or restoration of any data following permanent deletion.

Users are strongly advised to export and retain complete copies of all critical data prior to the termination or expiry of their Subscription. StartComply shall have no liability for any loss or damage resulting from a User’s failure to export data before the retention period expires.

16. FORCE MAJEURE

StartComply shall not be liable for any failure or delay in performance of its obligations under these Terms where such failure or delay results from circumstances beyond its reasonable control, including but not limited to:

Cyberattacks, distributed denial-of-service (DDoS) attacks, ransomware incidents, or infrastructure breaches by third parties;

Internet or telecommunications outages or failures;

Acts or omissions of government, regulatory, or judicial authorities;

Natural disasters, earthquakes, floods, fires, pandemics, or acts of God;

Failure of third-party cloud hosting, data centre, or infrastructure providers;

War, civil unrest, terrorism, strikes, or labor disputes outside StartComply’s control.

In such circumstances, StartComply will make commercially reasonable efforts to restore Services as promptly as possible and will endeavor to notify Users of significant disruptions where operationally feasible. No liability shall attach to StartComply for any duration of service unavailability attributable to force majeure events.

17. GOVERNING LAW AND JURISDICTION

These Terms shall be governed by and construed exclusively in accordance with the laws of the Hellenic Republic (Greece), without regard to its conflict of law principles.

The courts of Athens, Greece shall have exclusive jurisdiction over any dispute, claim, or controversy arising out of or relating to these Terms, the Platform, or the Services.

The United Nations Convention on Contracts for the International Sale of Goods (CISG) shall not apply to these Terms.

The parties expressly waive any right to object to the jurisdiction of the courts of Athens, Greece, on grounds of inconvenience or otherwise.

18. DISPUTE RESOLUTION

18.1 Good-Faith Negotiation

Before initiating any formal legal proceedings, the parties agree to attempt to resolve any dispute, claim, or controversy arising from or relating to these Terms or the Platform through good-faith direct negotiation. The disputing party must submit a written notice to the other party describing the nature of the dispute in reasonable detail. The parties shall have thirty (30) calendar days from receipt of such notice to reach a mutually acceptable resolution.

18.2 Mediation

If good-faith negotiation fails to produce a resolution within the thirty (30) day period, either party may refer the dispute to non-binding mediation to be conducted in Athens, Greece, under a mediator mutually agreed upon by both parties within fifteen (15) days of the referral. Costs of mediation shall be shared equally between the parties unless otherwise agreed in writing.

18.3 Litigation

If mediation does not produce a resolution within forty-five (45) calendar days of referral to mediation, either party may submit the dispute to the competent courts of Athens, Greece, in accordance with Section 17 above.

18.4 Interim and Injunctive Relief

Nothing in this Section 18 prevents either party from seeking urgent interim, provisional, or injunctive relief from a competent court at any time in order to protect its intellectual property rights, confidential information, or other rights where immediate judicial intervention is necessary to prevent irreparable harm.

18.5 Continued Performance

Both parties shall continue to perform their respective obligations under these Terms during the pendency of any dispute resolution process unless and until the agreement is lawfully terminated or a court orders otherwise.

19. AMENDMENTS AND MODIFICATIONS

StartComply reserves the right to amend, revise, or replace these Terms at any time and at its sole discretion.

Amendments will be communicated to Users via email notification to the registered account address and/or through a prominent notice within the Platform dashboard;

Changes will take effect fourteen (14) calendar days after notification, unless the changes are required immediately by applicable law or relate to new features, in which case they may take immediate effect with contemporaneous notice;

Continued use of the Platform following the effective date of any amended Terms constitutes the User’s unconditional acceptance of the revised Terms;

If the User does not accept the revised Terms, they must cease all use of the Platform and provide written notice to StartComply at info@startcomply.com prior to the effective date of the changes.

StartComply recommends that Users periodically review these Terms to remain informed of the current version. The most current version shall always be accessible at www.startcomply.com/terms.

20. ENTIRE AGREEMENT

These Terms, together with any applicable Subscription plan documentation, Data Processing Agreement (DPA), and any other addenda or schedules expressly incorporated by reference herein, constitute the entire and exclusive agreement between the parties with respect to the subject matter hereof.

These Terms supersede and replace all prior negotiations, representations, proposals, understandings, and agreements — whether written or oral — relating to the Platform and the Services.

No employee, agent, or representative of TicTac Cyber Security & Data Recovery Services S.A. has authority to make representations or commitments that are inconsistent with or supplementary to these Terms unless expressly set out in a separately executed written agreement signed by an authorized officer of the company.

21. NOTICES

21.1 Notices to StartComply

All formal legal notices to StartComply must be submitted in writing and delivered by:

Email: info@startcomply.com (with written confirmation of receipt requested); or

Registered post or courier to: TicTac Cyber Security & Data Recovery Services S.A., 9 Tripoleos str., 17237, Ymittos – Athens, Greece.

21.2 Notices to the User

StartComply may provide notices to the User via email to the registered account address, in-platform notification or dashboard announcement, or postal correspondence to the address provided during registration.

21.3 Effective Date of Notices

Notices sent by email shall be deemed received upon confirmation of delivery or within 24 hours of transmission, whichever is earlier, unless a delivery failure notification is received. Notices sent by registered post shall be deemed received within five (5) business days of dispatch.

22. SEVERABILITY

If any provision of these Terms is found to be invalid, unlawful, void, or unenforceable by a competent court or authority, that provision shall be deemed severed from these Terms to the minimum extent necessary. The remaining provisions shall continue in full force and effect and shall be interpreted to give maximum effect to the original intent of the parties as expressed herein.

23. NO WAIVER

No failure or delay by StartComply in exercising any right, power, or remedy under these Terms shall operate as a waiver of that right, power, or remedy. No single or partial exercise of any right or remedy shall preclude any other or further exercise of the same or any other right or remedy. Waivers must be expressly confirmed in writing by an authorized representative of TicTac Cyber Security & Data Recovery Services S.A. to be valid and effective.

24. SURVIVAL

The following Sections shall survive the expiry or termination of these Terms for any reason whatsoever and remain in full force and effect indefinitely:

Section 8 — Limitation of Liability

Section 9 — Disclaimer of Warranties

Section 10 — Indemnification

Section 11 — Intellectual Property

Section 12 — Confidentiality

Section 15 — Data Retention and Deletion

Section 17 — Governing Law and Jurisdiction

Section 18 — Dispute Resolution

Section 20 — Entire Agreement

Section 22 — Severability

Section 24 — Survival

25. ASSIGNMENT

The User may not assign, transfer, delegate, or sublicense any of its rights or obligations under these Terms — whether by operation of law, change of control, merger, acquisition, or otherwise — without the prior express written consent of StartComply.

TicTac Cyber Security & Data Recovery Services S.A. may freely assign, transfer, or novate its rights and obligations under these Terms to any affiliate, successor entity, or acquirer without the User’s prior consent, provided that the acquiring or successor entity assumes all obligations set forth herein. The User will be notified of any such assignment in a timely manner.

26. EXPORT CONTROLS AND SANCTIONS COMPLIANCE

The User represents and warrants that their use of the Platform shall at all times comply with all applicable export control laws and regulations, including those of the European Union and, where applicable, the United States. The User agrees not to use, export, or re-export the Platform, its outputs, or any associated Content in violation of any applicable export control law, trade embargo, or sanctions regime. StartComply assumes no responsibility for the User’s compliance with export control or sanctions obligations, and the User shall indemnify StartComply against any claim or penalty arising from the User’s breach of this Section.

27. ELECTRONIC COMMUNICATIONS AND ELECTRONIC SIGNATURES

The User expressly consents to receive communications from StartComply electronically, including via email, in-platform notifications, and dashboard messages. The User agrees that all agreements, notices, disclosures, and other communications delivered electronically satisfy any legal requirement for written form to the extent permitted by applicable law.

Where electronic acceptance mechanisms — such as “I Agree” checkboxes, digital signatures, or online form submissions — are used to accept these Terms, such mechanisms shall be considered legally binding and equivalent to a handwritten signature for all purposes under Greek law and Regulation (EU) No 910/2014 (eIDAS), to the extent applicable.

28. ANTI-CORRUPTION AND ETHICAL USE

The User agrees to comply with all applicable anti-bribery, anti-corruption, and ethical business conduct laws, including the applicable Greek legislative framework and all relevant EU directives and regulations. The User shall not use the Platform in any manner that facilitates, conceals, or enables fraudulent, corrupt, or unlawful conduct of any kind.

29. ACCESSIBILITY AND SERVICE AVAILABILITY

TicTac Cyber Security & Data Recovery Services S.A. will use commercially reasonable efforts to maintain Platform availability, but does not guarantee uninterrupted uptime or error-free operation. Scheduled maintenance, security updates, and infrastructure upgrades may require temporary suspension of Services. StartComply will endeavor to provide reasonable advance notice of planned downtime where feasible but is not obligated to do so in urgent or unforeseeable circumstances.

No service level agreement (SLA) is implied by these Terms unless expressly set forth in a separately executed and signed written agreement between the parties.

30. CONTACT INFORMATION AND LEGAL NOTICES

ACCEPTANCE AND BINDING EFFECT

By accessing, registering for, or using the StartComply.com Platform in any capacity, you confirm that:

You have read and fully understood these Terms in their entirety;

You have the full legal authority to bind the entity you represent to these Terms;

You unconditionally accept these Terms and agree to be legally bound by them as of the date of first access or registration;

You acknowledge that no compliance guarantee, certification, or professional advisory service of any kind is provided by the Platform;

You accept full and sole responsibility for your organization’s regulatory compliance obligations;

You acknowledge that TicTac Cyber Security & Data Recovery Services S.A. operates exclusively as a technology service provider and bears no liability for regulatory outcomes.

If you do not accept these Terms in full, you must not access or use the Platform.

© 2026 TicTac Cyber Security & Data Recovery Services S.A. — ΤΙΚ ΤΑΚ ΥΠΗΡΕΣΙΕΣ ΚΥΒΕΡΝΟΑΣΦΑΛΕΙΑΣ ΚΑΙ ΑΝΑΚΤΗΣΗΣ ΔΕΔΟΜΕΝΩΝ Α.Ε. All rights reserved. ΓΕΜΗ: 140756708000 | ΑΦΜ: 800782394 | 9 Tripoleos str., 17237 Ymittos, Athens, Greece These Terms were last reviewed and updated on: 1 January 2026