Please find attached herewith, Statement of Deviation or Variation for the half year ended September 30, 2026.

ACE ALPHA TECH LIMITED Regd. Office: A-28, First Floor, Jhilmil Industrial Area Shahdara, East Delhi- 110095 CIN: L62099DL2012PLC243246 Tele. No.: +91-1149854818 E-Mail: compliance@acealphatech.in website: www.acealphatech.in October 30, 2026 BSE Limited SCRIP CODE: 544431 Sub: Statement of Deviation or Variation in Utilization of Initial Public Offer (IPO) Proceeds of the Company for the half year ended September 30, 2026 Pursuant to Regulation 32 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, read with SEBI Master Circular No. SEBI/ HO/49/14/14(7)2025-CFD-POD2/I/3762/2026 dated January 30, 2026, we hereby confirm that there is no deviation or variation in the utilization of proceeds from the objects stated in the Prospectus for Initial Public Offer (IPO) of the Company for the half year ended September 30, 2026 except as disclosed in Annexure I. Further, please note that pursuant to Regulation 32(3) of SEBI (LODR) Regulations, 2015, the said Statement was placed before the Audit Committee for its review at the Audit Committee Meeting held today, i.e., on October 30, 2026. Kindly take the same on record. Thanking you, For Ace Alpha Tech Limited Priyanka Company Secretary & Compliance Officer M. No.: ACS 72473 Encl: As above Corporate Office: A-25, 1st Floor, Sector 64, Noida , Gautam Buddha Nagar, Uttar Pradesh -201301 ACE ALPHA TECH LIMITED Regd. Office: A-28, First Floor, Jhilmil Industrial Area Shahdara, East Delhi- 110095 CIN: L62099DL2012PLC243246 Tele. No.: +91-1149854818 E-Mail: compliance@acealphatech.in website: www.acealphatech.in STATEMENT OF DEVIATION/ VARIATION IN UTILIZATION OF FUNDS RAISED Name of the Listed Ace Alpha Tech Limited Entity Mode of Fund Raising Public Issue-Initial Public Offer (IPO) Date of Raising Funds July 01, 2025 Amount Raised Rs. 32,22,30,000 (Rupees Thirty-Two Crore Twenty-Two Lakh Thirty Thousand Only) out of which Rs. 24,48,12,000 (Rupees Twenty-Four Crore Forty-Eight Lakh Twelve Thousand Only) raised through Fresh Issue and Rs. 7,74,18,000 (Rupees Seven Crore Seventy-Four Lakh Eighteen Thousand Only) through Offer for sale. Report filed for the half- September 30, 2026 year ended Monitoring Agency The Company has voluntarily appointed a monitoring agency vide agreement and consent dated May 23, 2025, for monitoring the utilisation of the Net Proceeds from the Fresh Issue. Monitoring Agency CARE Ratings Limited Name, if applicable Is there a Deviation/ Yes Variation in the use of funds raised If yes, whether the same Yes is pursuant to change in terms of a contract or objects, which was approved by the shareholders If yes, date of June 21, 2026 shareholders’ approval Explanation for the As disclosed under the chapter “Objects of the Issue” in the Prospectus, Deviation/ Variation the total estimated public issue expenses were Rs. 3,86,48,000, out of which Rs. 3,46,37,100 was to be borne by the Company from the fresh issue proceeds and Rs. 40,10,900 was to be borne by the Selling Shareholders towards the Offer for Sale (OFS) portion. However, due to an inadvertent presentation error in the Prospectus, the OFS portion of Rs. 40,10,900 was also included under the “Fresh Issue – Issue Expenses” head, resulting in duplication of this amount and leaving it unearmarked. To rectify this, it was decided to earmark the said amount (i.e. Rs. 40,10,900/-) to “Capital Expenditure – Human Resources Head”. This Corporate Office: A-25, 1st Floor, Sector 64, Noida , Gautam Buddha Nagar, Uttar Pradesh -201301 ACE ALPHA TECH LIMITED Regd. Office: A-28, First Floor, Jhilmil Industrial Area Shahdara, East Delhi- 110095 CIN: L62099DL2012PLC243246 Tele. No.: +91-1149854818 E-Mail: compliance@acealphatech.in website: www.acealphatech.in was in line with the flexibility provided in the Prospectus for utilisation of funds across the stated objects, subject to applicable laws and approvals. Additionally, the implementation timelines disclosed in the Prospectus were based on the projected business growth plans, anticipated operational expansion and estimated deployment requirements prevailing at the relevant time. Accordingly, in order to facilitate efficient, phased and need-based utilisation of the IPO proceeds earmarked towards “Capital Expenditure”, including the reallocated amount, it was decided to extend the timeline for utilisation of such proceeds up to the financial year 2027-28. Also, pursuant to a post-listing review, it had been noted that certified second-hand or refurbished hardware and server infrastructure, when sourced from established vendors with appropriate performance assurances, is a reliable and cost-efficient alternative. Accordingly, it was decided to modify the said restriction so as to permit procurement of such hardware and server/server infrastructure from the IPO proceeds allocated towards Capital Expenditure. The aforesaid variations did not involve any change in the original objects of the Issue or the overall utilisation of IPO proceeds. It was considered to be in the best interests of the Company and its stakeholders. Comments of the Audit As at September 30, 2026, the Company has utilised Rs. 2263.16 lakhs Committee after review out of the total fresh issue proceeds raised through its IPO. The Monitoring Agency’s report for the relevant period is awaited. The statement of deviation/variation in utilisation of IPO proceeds shall be considered by the Audit Committee and submitted to the Stock Exchange(s) in the prescribed format in accordance with Regulation 32 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, read with the applicable SEBI Master Circular. The comments/report of the Monitoring Agency shall be submitted to the Stock Exchange(s) within the prescribed timelines upon receipt, as applicable. Comments of Auditors, No Comments if any (Amt. in Rs. Lakhs) Objects for which funds have been raised and where there has been a deviation, in the following table: Sr. Original Modified Original Modified Funds Amount of Remarks, No. Object Object, if Allocation Allocation, Utilized Deviation/ if any any if any Variation Corporate Office: A-25, 1st Floor, Sector 64, Noida , Gautam Buddha Nagar, Uttar Pradesh -201301 ACE ALPHA TECH LIMITED Regd. Office: A-28, First Floor, Jhilmil Industrial Area Shahdara, East Delhi- 110095 CIN: L62099DL2012PLC243246 Tele. No.: +91-1149854818 E-Mail: compliance@acealphatech.in website: www.acealphatech.in for the quarter according to applicable object 1. Capital Refer Note Refer 1,250 1290.11* 1064.97 40.11* Expenditure ** Notes 2. Unidentified Not Acquisition Applicable and General 811.64 811.64 811.64 - - Corporate Purposes 4. Issue Not Refer Related Applicable 386.48 386.48 386.48 - Notes Expenses Notes *As disclosed under the chapter “Objects of the Issue” in the Prospectus, the total estimated public issue expenses were Rs. 3,86,48,000, out of which Rs. 3,46,37,100 was to be borne by the Company from the fresh issue proceeds and Rs. 40,10,900 was to be borne by the Selling Shareholders towards the Offer for Sale (OFS) portion. However, due to an inadvertent presentation error in the Prospectus, the OFS portion of Rs. 40,10,900 was also included under the “Fresh Issue – Issue Expenses” head, resulting in duplication of this amount and leaving it unearmarked. Up to the quarter ended March 31, 2026, the Company had fully utilised Rs. 3,46,37,100 towards issue expenses from the fresh Issue proceeds and Rs. 40,10,900 towards OFS proceeds as stated in the prospectus. Subsequently, the Company has earmarked Rs. 40,10,900 towards the “Capital Expenditure – Human Resources Head” object of the Issue, pursuant to approval by the shareholders through a Special Resolution passed via postal ballot, effective June 21, 2026. Accordingly, the revised allocation under the “Capital Expenditure – Human Resources” is as mentioned above. Consequent to the increase in capital expenditure, the total revised cost has also incr [Showing first 8,000 characters — download PDF for full document]