Structural Digital Database

Date:21-10-2026 To, To, TheGeneralManager, NationalStockExchangeofIndiaLimited BSELimited ListingDepartment, PhirozeJeejeebhoyTowers, ExchangePlaza,Plotno.C/1, DalalStreet, GBlock,Bandra-KurlaComplex, Mumbai-400001 Bandra(E),Mumbai-400051 ScripCode532788 SYMBOL:XLENERGY Subject:StructuredDigitalDatabase(SDD)ComplianceCertificateforthequarterended 30thSeptember,2026. DearSir/Madam, In terms of Regulation 3(5) and 3(6) of Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015 ("PIT Regulations"), please find attached herewith the Structured Digital Database (SDD) Compliance Certificate issued by R. Bhandari & Co, PractisingCompanySecretaries(PCS),fortheQuarterended30thSeptember,2026. We would like to inform you that the Company is presently undergoing implementation of an NCLT-approved Resolution Plan under the Insolvency and Bankruptcy Code, 2016, and was earlier delisted and subsequently placed under suspension. During the transition phase, compliances are being undertaken in line with regulatory applicability and operational feasibility, subject to regulatory approvals and the outcome of the pending appeal filed by NSE beforetheHon’bleNCLAT. TheSDDcompliance statushasbeenreviewedand certifiedbasedontherecordsmaintained by theCompanyduringtherelevantperiod. Kindlytakethissubmissioninyourrecords. ThankingYou. Yoursfaithfully, FORXLENERGYLIMITED NareshJain Director (DIN:00291963) XLENERGYLIMITED CINNo:U31300TG1985PLC005844 Office318,3rdFloor,MittalChambers,2-2-51,M.G.Road,Secunderabad,Hyderabad, Telangana,India,500003,Tel–040-27710751 Corpaddress:OfficeNo.2,1stFloor,7HomjiStreet,RahimtoolaHouse, Fort,Mumbai–400001. E-mail:xlenergy85@gmail.com Phone:+91 7666540600 ..*=:= .''i-= i .-eB. R. Bhondori & Co. Company Secretaries * lnsolvency Professional * Trademark Attorney STRUCTI]RDD DIGITAL DATABASE (SDD) COMPLIAITCE CERTIFICATE, FOR TIIE QUARTER ENDED - SEPTEMBER,2026 (Pursuant to Securities and Exchange Board oflndia (Prohibition oflnsider Trading) Regulations,20l5) We, R. Bhandari & Co, Practising Company Secretaries (PCS) appointed by XL Energy Limited am aware of the compliance requirement of Structured Digital Database (SDD) pursuant to provisions ofRegulation 3(5) and 3(6) ofSecurities and Exchange Board oflndia (Prohibition of Insider Trading) Regulations, 2015 (PIT Regulations) and I certiry that I =the€empany has a Struetured Digital Daebase in plaee r, eentrel exists a (SDD has not let in plemenled, as lhe Company was under suspension / lransition pu$uanl to an NclT-approved Resolulion Plan. Further, the ,rutter relating lo reJisting is sub judice pursuant to the appeol Jiled by NSE before NCLAT and there is pending clarity on the outcome of the said appeal) - QYot Applicable as the Con pan! was under suspension / lransition pursudnt to an NCLT: approved Reso I uli on P I an) ime - (IYol opplicable, due to n o n-imp I emenlatio n of S D D) 5. the daebase has beer maintaired intemall., and an audit tra:l is mainta:ned _ /No, applicable, as lhe q)stem has not yet been operutionalised-) (Not opplicable since SDD has nol been implemenled) (Relevant points from I to 6 can be striked off in the case of non-compliance) I also confirm that the company was required to capture NIL number of events during the quarter e+snaneiallea+ ended and has captured NIL number ofthe said required events. I would Iike to report that the forlowing noncompliance(s) was observed in the previous quarter er*naneiat+eer+neee and the remedial action(s) taken along with timelines in this regard: Non-compliances: Non-implementation of Structured Digital Database, due to: The Company being earlier delisted and presently suspended from B. B Office No.4O2, 4th floor, A- Wing, Pushp Vinod No.2, S.V. Road, Borivali W, a4509 4372s I 70214 00558 Mu mbai-400092. I csrbhanda ri@gma il.com www.csrutrandari.com Change in management pursuant to IBC-CIRP proceedings; Absence of active trading and non-applicability of routine UPSI events during the period. Ongoing implementation of resolution plan, subject to regulatory approvals and the outcome ofthe pending appeal filed by NSE before Hon'ble NCLAL Remedial Action & Timeline: The Company has undertaken to implement and operationalise a fully compliant SDD in accordance with Regulation 3(5) and 3(6) of the PIT Regulations upon completion of restructuring and normalization ofoperations, subject to regulatory approvals and outcome of appeal filed by NSE before NCLAT. This certificate is issued for the purpose of submission to the Slock Exchanges and is based on information made available to me. For M/s. R. Bh Company S oe;.t Raghunath Proprietor FCS No.: 8048 COP: 15381 Date:21-10-2026 Place: Mumbai UDIN: F008048H00 I 9s871 I Disclaimer This certilicare is exclusively issued upon rhe request made by the Company and is issued solely based on the information, reprcsentation and documents ptovided. It is grounded entirely o:n factual data, interpretation, and imprication of Reguration 3(5) and i(6) of the securitiei and Exchange Board oflndia (Prohibition oflnsider Trading) Reguratiow, 20 t 5 (pIT Regurations), and is subject to our prcfessionar opinion. The obligation lies with the Manage."rttco^pory to en/orce the stipulations outrined in Reguration 3(5) and 3(6) of the securities and Exchange Board of India (Pruhibition of Insider Trading) Regulations, 2015 (pIT Regurations). Tik includes rhe maintenance ofrecords and the estabrishmenr of apprcpriate systems to guarantee adhercnce to said pmvisions. Furthermore, it is incumbent upon the Managemenr/company to