Orla Mining Ltd. — Capital/Financing Update 2025

Sep 15, 2025

ORLA MINING

September 15, 2025

TO: British Columbia Securities, as Principal Regulator

AND TO: Alberta Securities Commission
Financial and Consumer Affairs Authority of Saskatchewan
The Manitoba Securities Commission
Ontario Securities Commission
Autorité des marchés financiers
Financial and Consumer Services Commission, New Brunswick
Nova Scotia Securities Commission
Office of the Superintendent of Securities, Prince Edward Island
Office of the Superintendent of Securities Service Newfoundland and Labrador
Office of the Superintendent of Securities Northwest Territories
Office of the Yukon Superintendent of Securities
Office of the Superintendent of Securities, Nunavut

Dear Sirs/Mesdames:

Re: Orla Mining Ltd. (the "Corporation")
Base Shelf Prospectus dated September 15, 2025 (the "Base Shelf Prospectus")

In connection with the filing of the Base Shelf Prospectus, the Corporation advises that it is relying on BC Instrument 44-503 - Exemption from Certain Prospectus Requirements for Canadian Well-known Seasoned Issuers as well as equivalent orders or instruments in each of the other provinces and territories of Canada as described in or contemplated by CSA Staff Notice 44-306 Blanket Orders Exempting Well-known Seasoned Issuers from Certain Prospectus Requirements (collectively, the "Blanket Order").

The Corporation satisfies the definition of "well-known seasoned issuer" or "WKSI" in the Blanket Order by virtue of the fact that, as of September 15, 2025, the Corporation's public float (as defined in the Blanket Order) of outstanding listed equity securities was $5,390,009,831.28.

The Corporation is eligible to file a short form prospectus in reliance on section 2.2 of National Instrument 44-101 - Short Form Prospectus Distributions ("NI 44-101").

For and on behalf of the Corporation, and without personal liability, the undersigned certifies that:

a) the Corporation meets the definition of a WKSI (as defined in the Blanket Order) as of a date within 60 days preceding the date hereof;

ORLA MINING LTD. #1010-1075 West Georgia St. Vancouver BC V6E 3C9

TSX: OLA | www.orlamining.com

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b) the Corporation is and has been a reporting issuer in at least one jurisdiction of Canada for 12 months;

c) the Corporation is eligible to file a short form prospectus and has satisfied the criteria of section 2.2 of NI 44-101;

d) the Corporation has satisfied the requirements to be qualified to file a short form prospectus under section 2.8 of NI 44-101;

e) the Corporation’s most recent audited financial statements disclose:

i) gross revenue derived from mining operations, of at least C$55,000,000 for the Corporation’s most recently completed financial year, and

ii) gross revenue, derived from mining operations, of at least C$165,000,000 in the aggregate for the Corporation’s 3 most recently completed financial years;

f) the Corporation has filed any technical reports that would be required to be filed with a preliminary short form prospectus under National Instrument 43-101 – Standards of Disclosure for Mineral Projects;

g) the Corporation is not an ineligible issuer (as defined in the Blanket Order);

h) the Corporation is not an investment fund;

i) the Corporation has no outstanding asset-backed securities;

j) the Base Shelf Prospectus:

i) complies with the requirements of National Instrument 41-101 - General Prospectus Requirements, NI 44-101, and National Instrument 44-102 - Shelf Distributions (except those requirements from which the Corporation is exempt under sections 4 and 5 of the Blanket Order);

ii) does not qualify the distribution of any asset-backed security;

iii) includes as part of the basic disclosure about the distribution the following statement on the cover page: “filed in reliance on an exemption from the preliminary base shelf prospectus requirement for a well-known seasoned issuer”; and

iv) includes cover page disclosure confirming that the Corporation qualifies as a WKSI and the date of that determination;

ORLA MINING

TSX-OLA | www.orlamining.com | 2

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k) concurrently with the filing of the Base Shelf Prospectus and this letter, the Corporation has paid the fee otherwise required for the filing of a preliminary short form prospectus; and

l) the Corporation has delivered to the regulator any personal information forms that would be required under section 4.1 of NI 44-101 if the Corporation were filing a preliminary short form prospectus.

[Remainder of Page Intentionally Left Blank]

ORLA
MINING
TSX-OLA | www.orlamining.com | 3

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If you have any questions or require further information in respect of the foregoing, please do not hesitate to contact Jen Hansen, the external legal counsel of the undersigned at 604-691-6114 or jhansen@cassels.com.

ORLA MINING LTD.

Per: "Etienne Morin"
Etienne Morin
Chief Financial Officer

ORLA MINING
TSX-OLA | www.orlamining.com | 4