CHALLENGER LIMITED — Transaction in Own Shares 2011

May 15, 2011

Appendix 3E Daily share buy-back notice

Rule 3.8A

Appendix 3E

Daily share buy-back notice ( except minimum holding buy-back and selective buy-back)

Information and documents given to ASX become ASX’s property and may be made public.

Introduced 1/9/99. Origin: rule 3.6, Appendix 7C. Amended 30/9/2001.

Name of entityChallenger Limited	ABN
Challenger Limited	85 106 842 371

We (the entity) give ASX the following information.

Information about buy-back

1 Type of buy-back On-market 2 Date Appendix 3C was given to ASX 23 November 2010

Total of all shares bought back, or in relation to which acceptances have been received, before, and on, previous day

			Before previous day	Previous day
	3Number of sharesif buy-back is anscheme, in relatacceptances have b	bought back orequal accession to whicheen received	6,208,089	50,000
	4Totalconsiderati	onpaidor
payable for the shar	payable for the shar	es	$29,620,968.58	$236,965.00

• See chapter 19 for defined terms.

Appendix 3E Page 1

30/9/2001

Appendix 3E Daily share buy-back notice

5If buy-back is an on-market buy-back	Before previous day	Previous day
	highest price paid: $5.05date: 1 March 2011lowest price paid:$4.45date: 17 March 2011	highest price paid: $4.78lowest price paid: $4.70highest price allowedunder rule 7.33:$4.9875

Participation by directors

• 6 Deleted 30/9/2001.

How many shares may still be bought back?

7 If the company has disclosed an intention to buy back a maximum 44,007,234 number of shares - the remaining number of shares to be bought back

Compliance statement

1. The company is in compliance with all Corporations Act requirements relevant to this buy-back.

2. There is no information that the listing rules require to be disclosed that has not already been disclosed, or is not contained in, or attached to, this form.

==> picture [388 x 118] intentionally omitted <==

----- Start of picture text ----- Sign here:………………………………………. Date: 16 May 2011Company SecretaryPrint name: Suzie Koeppenkastrop== == == == ==----- End of picture text -----

• See chapter 19 for defined terms.

Appendix 3E Page 2

30/9/2001