BEFOREPAY GROUP LIMITED — Major Shareholding Notification 2025

May 19, 2025

		Form 603 Corporations Act 2001 Section 671B Notice of initial substantial holder	Form 603 Corporations Act 2001 Section 671B Notice of initial substantial holder	Form 603 Corporations Act 2001 Section 671B Notice of initial substantial holder	Form 603 Corporations Act 2001 Section 671B Notice of initial substantial holder	Form 603 Corporations Act 2001 Section 671B Notice of initial substantial holder
To Company Name/Scheme BeforepayGroup Ltd(B4P) ACN/ARSN 633 925 505 1. Details of substantial holder (1) Name Regal Funds Management PtyLtd and its associates(see Annexure 1) ACN/ARSN (if applicable) - The holder became a substantial holder on 16/05/2025 2. Details of voting power The % substantial is based on the shares on issue of 48,228,136 as disclosed by the Company on 19-03-2025. 3. Details of relevant interests 4. Details of present registered holders* The persons registered as holders of the securities referred to in paragraph 3 above are as follows: The total number of votes attached to all the voting shares in the company or voting interests in the scheme that the substantial holder or an associate (2) had a relevant interest (3) in on the date the substantial holder became a substantial holder are as follows: Voting power (6) Person's votes (5) Number of securities Class of securities (4) ORDINARY The nature of the relevant interest the substantial holder or an associate had in the following voting securities on the date the substantial holder became a substantial holder are as follows: Class and number of securities 2,965,743 ORDINARY Holder of relevant interest 6.15% 2,965,743 2,965,743 REGAL FUNDS MANAGEMENT PTY LIMITED Nature of relevant interest (7) REGAL FUNDS MANAGEMENT PTY LIMITED HAS A RELEVANT INTEREST IN ITS CAPACITY AS INVESTMENT MANAGER AND/OR TRUSTEE REGAL PARTNERS LIMITED CONTROLLER OF REGAL FUNDS MANAGEMENT PTY LIMITED 2,965,743 ORDINARY		BeforepayGroup Ltd(B4P)
		633 925 505
		Regal Funds Management PtyLtd and its associates(see Annexure 1)
		-
Holder of relevant interest	Registered holder of securities		Person entitled to be registered as holder (8)	Nature of relevant interest (6)	Class and number of securities	Person's votes
Regal Funds Management Pty Ltd and its associates	UBS NOMINEES PTY LTD		UBS AG, AUSTRALIA BRANCH	Power to control the exercise of a power to dispose of securities	1,723,687 ORDINARY	1,723,687
Regal Funds Management Pty Ltd and its associates	MERRILL LYNCH (AUS) NOMINEES PTY LTD		MERRILL LYNCH INTERNATIONAL LIMITED	Power to control the exercise of a power to dispose of securities	271,376 ORDINARY	271,376

Class of securities (4)	Number of securities	Person's votes (5)	Voting power (6)
ORDINARY	2,965,743	2,965,743	6.15%

Holder of relevant interest	Nature of relevant interest (7)	Class and number of securities
REGAL FUNDS MANAGEMENT PTY LIMITED	REGAL FUNDS MANAGEMENT PTY LIMITED HAS A RELEVANT INTEREST IN ITS CAPACITY AS INVESTMENT MANAGER AND/OR TRUSTEE	2,965,743 ORDINARY
REGAL PARTNERS LIMITED	CONTROLLER OF REGAL FUNDS MANAGEMENT PTY LIMITED	2,965,743 ORDINARY

Holder of relevant interest	Registered holder of securities	Person entitled to be registered as holder (8)	Nature of relevant interest (6)	Class and number of securities	Person's votes
			Power to control
Regal Funds Management Pty Ltd and its associates	UBS NOMINEES PTY LTD	UBS AG, AUSTRALIA BRANCH	the exercise of a power to dispose	1,723,687 ORDINARY	1,723,687
			of securities
			Power to control
Regal Funds Management Pty Ltd and its associates	MERRILL LYNCH (AUS) NOMINEES PTY LTD	MERRILL LYNCH INTERNATIONAL LIMITED	the exercise of a power to dispose	271,376 ORDINARY	271,376
			of securities

Regal Funds Management Pty Ltd and its associates	J.P. MORGAN PRIME NOMINEES LTD	J.P MORGAN SECURITIES PLC	Power to control the exercise of a power to dispose of securities	511,691 ORDINARY	511,691
Regal Funds Management Pty Ltd and its associates	CITICORP NOMINEES PTY LIMITED	CITIGROUP GLOBAL MARKETS LIMITED	Power to control the exercise of a power to dispose of securities	458,989 ORDINARY	458,989

5. Consideration
The consideration paid for each relevant interest referred to in paragraph 3 above, and acquired in the four months prior to the day								that the
substantial holder became a substantial holder is as follows:
Holder of relevant interest Date of acquisition			Consideration (9)			Class and number of securities
		See Annexure 2
6. Associates
The reasons	the persons named in paragraph 3 above are associates of the substantial holder are as follows:
	Name and ACN/ARSN (if applicable)		Nature		of association
		REGAL PARTNERS LIMITED	100% OWNER OF REGAL FUNDS MANAGEMENT PTY
				LIMITED
7. Addresses
The addresses		of persons named in this form are as follows:
		Name		Address
REGAL FUNDS MANAGEMENT PTY LIMITED			LEVEL 46, GATEWAY,	1	MACQUARIE PLACE, SYDNEY
				NSW		2000
		REGAL PARTNERS LIMITED	LEVEL 46, GATEWAY,	1	MACQUARIE PLACE, SYDNEY
				NSW		2000
Signature
		print name KennyHo				capacity	CompanySecretary
		sign here				date	20/05/2025
Annexure	1
Details of Substantial Holders
ACN		Name
107 576 821		REGAL FUNDS MANAGEMENT PTY LIMITED
129 188 450		REGAL PARTNERS LIMITED

Annexure 2

Changes in Relevant Interests

Annexure 2 Changes in Relevant Interests	Annexure 2 Changes in Relevant Interests	Annexure 2 Changes in Relevant Interests	Annexure 2 Changes in Relevant Interests	Annexure 2 Changes in Relevant Interests	Annexure 2 Changes in Relevant Interests	Annexure 2 Changes in Relevant Interests
Date	Person whose relevant interest changed	Nature of Change	Consideration given in relation to change	Number of securities affected	Class of securities	Persons votes affected
22/01/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	53639.54	41122	Ordinary	41122
29/01/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	63335.03	44250	Ordinary	44250
29/01/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	29523.85	18805	Ordinary	18805
30/01/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	23631.77	17027	Ordinary	17027
31/01/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	22608.37	16223	Ordinary	16223
5/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	33808.32	26208	Ordinary	26208
7/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	15859.27	12098	Ordinary	12098
10/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	3999.08	3028	Ordinary	3028
13/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	3195.95	2697	Ordinary	2697
14/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	22450.19	16918	Ordinary	16918
18/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	48216.32	35692	Ordinary	35692
25/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	9276.65	6941	Ordinary	6941
27/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	7392.72	5151	Ordinary	5151
28/02/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	3476.60	2418	Ordinary	2418
5/03/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	7719.37	6035	Ordinary	6035

3/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	1063972.69	994367	Ordinary	994367
4/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	4354.48	4187	Ordinary	4187
7/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	20130.54	19495	Ordinary	19495
8/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	19182.60	18311	Ordinary	18311
9/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	46185.23	42979	Ordinary	42979
10/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	901.74	798	Ordinary	798
11/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	98392.79	87189	Ordinary	87189
14/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	5346.67	4237	Ordinary	4237
14/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	161250.00	150000	Ordinary	150000
29/04/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	12165.61	9643	Ordinary	9643
1/05/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	2540.00	2000	Ordinary	2000
9/05/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	8970.00	7800	Ordinary	7800
13/05/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	21568.00	16000	Ordinary	16000
16/05/2025	Regal Funds Management Pty Limited (and Regal Partners Limited by virtue of control of Regal Funds Management Pty Limited)	Buy	666387.60	555323	Ordinary	555323