CHALLENGER LIMITED — Transaction in Own Shares 2011

May 4, 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 entity Challenger 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 2 Date Appendix 3C was given to ASX	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

3 Number of shares bought back or if buy-back is an equal access scheme, in relation to which acceptances have been received 4 Total consideration paid or payable for the shares	Before previous day	Previous day
	5,689,212	200,000
	$27,178,065.48	$938,340.00

• 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: $5.05 date: 1 March 2011 lowest price paid:$4.45 date: 17 March 2011	highest price paid: $4.75 lowest price paid: $4.66 highest price allowed under rule 7.33: $5.0463

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 44,376,111 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: 5 May 2011 Company Secretary Print name: Suzie Koeppenkastrop == == == == ==

• See chapter 19 for defined terms.

Appendix 3E Page 2

30/9/2001