CHALLENGER LIMITED — Transaction in Own Shares 2011

May 8, 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	Name of entityChallenger Limited	Name of entityChallenger Limited	ABN
Challenger Limited			85 106 842 371

We (the entity) give ASX the following information.

Information about buy-back

	ck	ck	ck
1Type of buy-back2Date Appendix 3C was given toASX		On-market
		23 November 2010

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

3Number of shares bought back orif buy-back is an equal accessscheme, in relation to whichacceptances have been received4Totalconsiderationpaidorpayable for the shares	Before previous day	Previous day
	5,958,089	20,000
	$28,440,912.58	$94,000.00

• See chapter 19 for defined terms.

Appendix 3E Page 1

30/9/2001

Appendix 3E Daily share buy-back notice

• 5 If buy-back is an on-market buyback

Before previous day	Previous day
highest price paid: $5.05date: 1 March 2011lowest price paid:$4.45date: 17 March 2011	highest price paid: $4.70lowest price paid: $4.70highest price allowedunder rule 7.33:$4.9959

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 44,287,234 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.

Sign here: ………………………………………. Date: 9 May 2011 Company Secretary Print name: Suzie Koeppenkastrop == == == == ==

• See chapter 19 for defined terms.

Appendix 3E Page 2

30/9/2001