Patel Engineering Ltd — Regulatory Filings 2026

May 28, 2026

Patel

PATEL ENGINEERING LTD.

CIN: L99999MH1949PLC007039

May 28, 2026

To,

Bombay Stock Exchange Ltd.,
Phiroze Jeejeebhoy Towers,
Dalal Street,
Mumbai 400 001

The National Stock Exchange of India Ltd.
Exchange Plaza,
Bandra - Kurla Complex,
Mumbai 400 051

Company Code No. 531120
Company Code: PATELENG

Dear Sir/Madam,

Subject: Annual Secretarial Compliance Report for the year ended March 31, 2026

Pursuant to Regulation 24A of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, please find enclosed herewith the Annual Secretarial Compliance Report of the Company for the year ended March 31, 2026.

Kindly take the same on record.

Thanking You,

Yours Faithfully,

For Patel Engineering Limited

SHOBHA
RANJIT SHETTY
Digitally signed by
SHOBHA RANJIT SHETTY
Date: 2026.05.28
16:37:08 +05'30'

Shobha Shetty
Company Secretary
Membership No.: F10047

Encl: As above

REGD. OFFICE:
Patel Estate Road, Jogeshwari (W), Mumbai – 400 102. India
Phone +91 22 26767500, 26782916 Fax +91 22 26782455, 26781505
Email headoffice@pateleng.com Website: www.pateleng.com

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MAKARAND M. JOSHI & CO.
COMPANY SECRETARIES
MMJC

Secretarial Compliance Report of Patel Engineering Limited for the financial year ended March 31, 2026

We, M/s. Makarand M. Joshi & Co., Practicing Company Secretaries, have examined:

(a) all the documents and records made available to us and explanation provided by Patel Engineering Limited ('the listed entity'),
(b) the filings/ submissions made by the listed entity to the Stock Exchanges,
(c) website of the listed entity,
(d) any other document/filing, as may be relevant, which has been relied upon to make this certification,

for the financial year ended on March 31, 2026 ('review period') in respect of compliance with the provisions of:

(a) the Securities and Exchange Board of India Act, 1992 ('SEBI Act') and the Regulations, circulars, guidelines issued thereunder; and
(b) the Securities Contracts (Regulation) Act, 1956 ('SCRA'), rules made thereunder and the Regulations, circulars, guidelines issued thereunder by the Securities and Exchange Board of India ('SEBI');

The specific Regulations, whose provisions and the circulars/guidelines issued thereunder, have been examined, include: -

a) Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 (hereinafter referred as 'Listing Regulations');
b) Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018;
c) Securities and Exchange Board of India (Substantial Acquisition of Shares and Takeovers) Regulations, 2011;
d) Securities and Exchange Board of India (Buyback of Securities) Regulations, 2018; (Not Applicable to the Company during the review period)

Head Office
Ecstasy, 802-805, 8th Floor, Citi Of Joy, JSD, Mulund West, Mumbai- 400080, Maharashtra
Board Number: +91 22 3100 8600 Website: www.mmjc.in, www.csrcares.in
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e) Securities and Exchange Board of India (Share Based Employee Benefits and Sweat Equity) Regulations, 2021;
f) Securities and Exchange Board of India (Issue and Listing of Non-Convertible Securities) Regulations, 2021;
g) Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015; and circulars/ guidelines issued thereunder.

Further in terms of SEBI Circular no SEBI/HO/CFD/CFD-PoD-2/CIR/P/2024/185 dated December 31, 2024 in respect requirement of disclosure of Employee Benefit Scheme Documents in terms of regulation 46(2)(za) of Listing Regulations.

and based on the above examination, we hereby report that, during the review period:

(a) The listed entity has complied with the provisions of the above Regulations and circulars/guidelines issued thereunder except as specified in Annexure A:
(b) The listed entity has taken following actions to comply with the observations made in previous reports:

Sr. No.	Observations/Remarks of the Practicing Company Secretary in the previous reports	Observations made in The secretarial compliance report for the year ended ...	Compliance Requirement (Regulations/circulars/guidelines including specific clause	Details of violation / deviations and actions taken / penalty imposed, if any, on the listed entity	Remedial actions, if any, taken by the listed entity	Comments of the PCS on the actions taken by the listed entity
Not Applicable

(c) We hereby report that, during the Review Period the compliance status of the listed entity is appended as below:

Sr. No.	Particulars	Compliance Status (Yes/No/NA)	Observations / Remarks by PCS*
1.	Secretarial Standards:
The compliances of the listed entity are in accordance with the applicable Secretarial Standards (SS) issued by the Institute of Company Secretaries India (ICSI).	Yes	-
2.	Adoption and timely updation of the Policies:
• All applicable policies under SEBI Regulations are adopted with the approval of Board of Directors of the listed entities.	Yes	-

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	• All the policies are in conformity with SEBI Regulations and have been reviewed & timely updated as per the regulations/circulars/guidelines issued by SEBI.	Yes	-
3.	Maintenance and disclosures on Website:
• The Listed entity is maintaining a functional website.
• Timely dissemination of the documents/information under a separate section on the website.
• Web-links provided in annual corporate governance reports under Regulation 27 (2) of Listing Regulations are accurate and specific which redirects to the relevant document(s)/section of the website.	Yes
Yes
Yes
4.	Disqualification of Director:
None of the Directors of the listed entity are disqualified under Section 164 of Companies Act, 2013 as confirmed by the listed entity.	Yes	-
5.	Details related to Subsidiaries of listed entity have been examined w.r.t.:
(a) Identification of material subsidiary companies
(b) Requirements with respect to disclosure of material as well as other subsidiaries	(a) NA
(b) Yes	No such Material subsidiary
6.	Preservation of Documents:
The listed entity is preserving and maintaining records as prescribed under SEBI Regulations and disposal of records as per Policy of Preservation of Documents and Archival policy prescribed under the Listing Regulations.	Yes	-
7.	Performance Evaluation:
The listed entity has conducted performance evaluation of the Board, Independent Directors and the Committees during the financial year as prescribed in SEBI Regulations.	Yes	-

MUMBAI
A FEDERAL REGULATION

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| 8. | Related Party Transactions (RPT):

(a) The listed entity has obtained prior approval of Audit Committee for all Related party transactions ('RPTs').

(b) In case no prior approval obtained, the listed entity shall provide detailed reasons along with confirmation whether the transactions were subsequently approved/ratified/rejected by the Audit committee. | (a) No

(b) Yes | The Listed entity has obtained prior approval of Audit Committee for all RPT's, except in one instance. The said RPT was subsequently ratified by the Audit Committee. |
| --- | --- | --- | --- |
| 9. | Disclosure of events or information:

The listed entity has provided all the required disclosure(s) under Regulation 30 along with Schedule III of Listing Regulations within the time limits prescribed thereunder. | Yes | - |
| 10. | Prohibition of Insider Trading:

The listed entity is in compliance with Regulation 3(5) & 3(6) of SEBI (Prohibition of Insider Trading) Regulations, 2015. | Yes | - |
| 11. | Actions taken by SEBI or Stock Exchange(s), if any:

No actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges (including under the Standard Operating Procedures issued by SEBI through various circulars) under SEBI Regulations and circulars/ guidelines issued thereunder (or)

The actions taken against the listed entity/ its promoters/ directors/ subsidiaries either by SEBI or by Stock Exchanges are specified in the last column. | No | Details of action taken by SEBI or Stock exchanges have been specified in Annexure A |

MUMBAI
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| 12. | Resignation of statutory auditors from the listed entity or its material subsidiaries
In case of resignation of statutory auditor from the listed entity or any of its material subsidiaries during the financial year, the listed entity and / or its material subsidiary(ies) has / have complied with paragraph 6.1 and 6.2 of section V-D of chapter V of the Master Circular on compliance with the provisions of the Listing Regulations by listed entities. | NA | No Such event |
| --- | --- | --- | --- |
| 13. | Additional non-compliances, if any:
No additional non-compliance observed for any SEBI regulation/circular/guidance note, etc. except as reported above. | NA | No such additional non compliances |

*Observations/Remarks by PCS are mandatory if the Compliance status is provided as 'No' or 'NA'

Assumptions & Limitations of Scope and Review:

1. Compliance with the applicable laws and ensuring the authenticity of documents and information furnished, are the responsibilities of the management of the listed entity.

2. Our responsibility is to certify based upon our examination of relevant documents and information. This is neither an audit nor an expression of opinion.

3. We have not verified the correctness and appropriateness of financial Records and Books of Accounts of the listed entity.

4. This Report is solely for the intended purpose of compliance in terms of Regulation 24A (2) of the Listing Regulations and is neither an assurance as to the future viability of the listed entity nor of the efficacy or effectiveness with which the management has conducted the affairs of the listed entity.

For Makarand M. Joshi & Co.
Company Secretaries
ICSI UIN: P2009MH007000
Peer Review Cert. No.: 6832/2025

FCS No.: 8167
CP No.: 8968
UDIN: F008167H000364039

Date: May 14, 2026
Place: Mumbai

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Annexure A

Sr. No.	Compliance Requirement (Regulations/circulars/guidelines including specific clause)	Regulation / Circular No.	Deviations	Action Taken	Type of Action	Details of violation	Fine Amount	Observations/Remarks of the Practicing Company Secretary	Management Response	Remarks
1	The listed entity shall give notice in advance of at least three working days (excluding the date of intimation and the record date) to the recognised stock exchange(s) of the record date.	Regulation 60 (2) of Listing Regulations	Delay intimation of record date	National Stock Exchange of India Limited ('NSE')	Fine	Delay intimation of record date for payment of interest.	₹ 10,000/- (excluding GST)	For the month of September 2025, the record date for payment of interest was September 10,2025 and the same was intimated to NSE on September 9, 2025, resulting in non-compliance with Regulation 60(2) of Listing Regulations.	The Company has paid fine of Rs. 11,800 (including GST) to NSE for the said non-compliance.	-
2	The quorum for audit committee meeting shall either be two members or one third of the	Regulation 18(2)(b) of Listing Regulations	Presence of quorum in Audit Committee Meeting	-	-	The Audit Committee comprises three members, including two Independent Directors.	-	The requisite quorum was not present in the Audit Committee meeting held on November 13, 2025, in accordance with	Due to the unavoidable absence of one of our Independent director at the Audit Committee meeting dated	-

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	members of the audit committee, whichever is greater, with at least two independent directors.				However, at the Audit Committee Meeting held on November 13, 2025, only one Independent Director and one Executive Director were present, which was not in compliance with the requirements of the aforesaid regulation.		Regulation 18(2)(b) of the Listing Regulations.	November 13, 2025, the quorum requirement of presence of two independent directors prescribed under Regulation 18(2)(d) of SEBI LODR was not met in the said meeting. Accordingly, all the items transacted in the said meeting, have since been placed before the Audit Committee in its duly convened meeting held on February 14, 2026 with proper quorum and were duly ratified and confirmed. The Board of Directors has also taken note of the same at its meeting on February 14, 2026.

MUMBAI