Balurghat Technologies Limited has filed its Annual Secretarial Compliance Report for the financial year ended 31st March 2026 with the Bombay Stock Exchange, in accordance with Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The report was submitted on 16th May 2026 by Company Secretary and Compliance Officer Sushma Kumari Agarwal, and was prepared by CS Prity Bishwakarma of M/s. Prity Bishwakarma & Co., Practising Company Secretaries, Kolkata.

Scope of Secretarial Review

The secretarial review covered compliance with a broad range of applicable SEBI regulations and statutory provisions during the financial year ended 31st March 2026. The examination included verification of the company's books, papers, minutes books, forms and returns filed, and other records maintained by the listed entity. The following regulations were examined as part of the review:

• SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 — Applicable
• SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011 — Applicable
• SEBI (Prohibition of Insider Trading) Regulations, 2015 — Applicable
• SEBI (Registrar to an Issue and Share Transfer Agents) Regulations, 1993 — Applicable
• SEBI (Depositories and Participants) Regulations, 2018 — Applicable
• SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 — Not Applicable
• SEBI (Buyback of Securities) Regulations, 2018 — Not Applicable
• SEBI (Share Based Employee Benefits) Regulations, 2021 — Not Applicable
• SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021 — Not Applicable
• SEBI (Issue and Listing of Non-Convertible and Redeemable Preference Shares) Regulations, 2013 — Not Applicable

Key Compliance Findings

The secretarial auditor confirmed compliance across multiple regulatory and governance parameters for the review period. The table below summarises the compliance status across key areas:

The company was also confirmed to be in compliance with the requirements of the Structural Digital Database under the SEBI (Prohibition of Insider Trading) Regulations, 2015, including circulars issued by BSE Limited dated March 16, 2023. No actions were taken against the listed entity, its promoters, directors, or subsidiaries by SEBI or any stock exchange during the review period.

Auditor Resignation Compliance

With respect to the SEBI Circular CIR/CFD/CMD1/114/2019 dated 18th October 2019, the secretarial auditor confirmed that there was no resignation of the statutory auditor during the financial year ended 31st March 2026. Accordingly, all related compliance requirements pertaining to auditor resignation were reported as Not Applicable or as having no such event.

Notable Observations

The secretarial auditor highlighted two specific observations as part of the report:

• Paid-up Share Capital Discrepancy: A difference exists between the paid-up share capital as recorded on the MCA portal and as reflected in Stock Exchange records. As per the MCA portal, the paid-up share capital stands at ₹17,40,81,800, whereas Stock Exchange records reflect ₹1,82,00,000. The discrepancy is attributed to certain partly paid-up equity shares.
• Delayed Filing of MGT-15: The MGT-15 filing was delayed due to technical glitches on the MCA portal.

No deviations from applicable SEBI regulations were reported, and no prior-period observations required follow-up action. The report was signed by Prity Bishwakarma, Proprietor, ACS No. 63580, C. P. No. 27227, Peer Review No. 5738/2024, UDIN: A063580H000382096, dated 16th May 2026, from Kolkata.

Balurghat Technologies Limited has informed the Bombay Stock Exchange that it does not qualify as a Large Corporate under SEBI's regulatory framework, exempting it from specific disclosure requirements for the financial year 2026.

Regulatory Compliance Disclosure

The company submitted its formal disclosure on April 11, 2026, addressing the non-applicability of SEBI Circular No. SEBI/HO/DDHS/CIR/P/2018/144 dated November 26, 2018. This circular pertains to fund raising through issuance of debt securities by Large Corporate entities and their associated compliance obligations.

Large Corporate Classification

Balurghat Technologies Limited confirmed that it does not meet the criteria for Large Corporate classification as defined under para 2.2 of the SEBI framework. This classification determines whether companies are subject to enhanced disclosure requirements when raising funds through debt securities.

Exemption from Disclosure Requirements

Due to its non-Large Corporate status, the company is exempt from filing mandatory disclosures for FY26. The exempted requirements include:

• Initial disclosure as specified in Annexure A of the SEBI circular
• Annual disclosure as outlined in Annexure B1 of the framework
• Other compliance obligations applicable to Large Corporate entities

Official Communication

The disclosure was signed by Sushma Kumari Agarwal, Company Secretary and Compliance Officer, and submitted to the Department of Corporate Services at Bombay Stock Exchange. The communication formally requested the exchange to take the non-applicability information on record for regulatory compliance purposes.