23. Contingent liabilities

The Group is subject to various claims, legal proceedings and regulatory matters arising in the ordinary course of business. Based on the information available at the reporting date, the directors do not consider that it is probable that these matters will result in an outflow of economic benefits or no reliable estimate can be made of such outflow; accordingly, no provisions have been recognised in respect of the items set out below. These matters are therefore disclosed as contingent liabilities.

Environmental and regulatory matters

Penalties under threat

TSIJ operates two cokes and gas plants (CGP1 and CGP2). In 2024, the Environmental Agency for the North Sea Canal Area (EA NZKG) measured alleged exceedances of emission thresholds for substances of very high concern (ZZS) at both plants. As a result, on 19 December 2024 the EA NZKG imposed penalty orders with a combined maximum exposure of €27 million. Objections lodged by TSIJ were largely rejected in November 2025, and no appeal was filed.

With respect to CGP1, recovery decisions totalling €17,065,000 were imposed and paid in December 2025 and April 2026, respectively. The penalty order relating to CGP1 has therefore been fully executed.

On May 11, 2026 TSIJ received a recovery decision of € 3.250.000 for exceedance of MVP1 at CGP2. TSIJ has made the decision to file objections against the recovery decision. Further recovery decisions relating to CGP2 may still follow, as the penalty order for CGP2 has not yet been fully executed. The remaining maximum exposure is €6,500,000.

On 19 December 2024, the EA NZKG sent TSIJ a notice regarding alleged non-compliance at CGP2 concerning the state of maintenance of the plant, and particularly the oven walls. The EA NZKG indicated that should the non-compliance not be remedied in time, it will consider revoking the permit for CGP2. In January 2025, TSIJ submitted its statement of objections, which objections were rejected in December 2025. TSIJ has initiated appeal proceedings, which proceedings are ongoing.

On 23 April 2026, the EA NZKG has notified TSIJ that the EA is preparing an intention to revocate (part of) the environmental permits of CGP 1 and CGP2, based on the EA’s view that the remedial sanctions imposed under penalty for both CGPs have not had their intended effect. The EA NZKG furthermore states that the violations of environmental standards continue and that it is plausible that remediation within a reasonable time is not feasible. The letter of the EA, and the uncertainty it creates regarding the timeline for revocation of the permits, and whether this timeline ensures a closure of the CGPs in a safe, responsible and controllable manner, may lead to further litigation.

TSN is currently exploring a faster-than-previously planned closure of the CGPs 1 and 2. The technical and logistical complexity of such a closure is significant, particularly in relation to ensuring proper safeguards for environmental aspects and safety. TSN’s focus is on finding a solution that is appropriate for all stakeholders, taking into account all relevant interests, including the continuity of the business.

Dust and HF emissions continuous casters

In September 2023, the EA NZKG imposed a penalty order for alleged exceedance of dust emissions at Continuous Caster Machine 22 (“CGM22”), with a maximum amount of €500,000. Appeal proceedings against this penalty order are ongoing. In 2024, a second penalty order was imposed for CGM22 for further alleged exceedances of dust emissions, providing for penalties of €500,000 per violation, up to a maximum of €2,000,000. Appeal proceedings in respect of this second penalty order are also ongoing.

In connection with the second penalty order for CGM22, in March 2026 TSIJ received a recovery decision for €500,000 for exceedance of dust emissions, which was paid. On 30 March 2026, TSIJ additionally received an intention to impose a further recovery decision of €500,000, which was also paid. These recovery measures form part of the pending appeal proceedings and do not conclude the enforcement process. Further recoveries cannot be excluded.

On 16 October 2025, the EA NZKG imposed a separate penalty order for Continuous Caster Machine 21 (“CGM21”) for alleged exceedance of dust and hydrogen fluoride (HF) emissions, with a maximum exposure of €2,400,000. As of the reporting date, no penalties or recovery decisions have been imposed under this order. TSIJ has submitted objections against the penalty order, which are still pending.

Given the ongoing legal proceedings and enforcement actions, the ultimate financial impact of these matters cannot yet be reliably estimated but could be material.

Penalty order – Sinter Plant emissions

In December 2025, TSIJ received a penalty order relating to the Sinter Plant, following alleged exceedances of hydrogen fluoride, chromium and nickel in off‑gas emissions downstream of the bag filter. The order provides for a maximum aggregate penalty of € 2,400,000. To date, no penalties have yet been claimed. TSIJ has made the decision not file objections against this penalty order.

Steel slag classification

In April 2026, the Dutch Human Environment and Transport Inspectorate (ILT) issued a penalty order under payment relating to the classification of LD steel slag, asserting that the material should be classified as hazardous under CLP. The penalty amounts to €15 per ton, with a maximum exposure of €10 million, payable within 30 days.

Management considers steel slag to be non‑hazardous under the EU REACH regulation. A formal response contesting the draft penalty has been submitted, and supporting research is ongoing within the REACH registration consortium. As the order was received after the balance sheet date and remains contested, no provision has been recognised. A contingent liability of up to €10 million exists.

Legal proceedings and claims

The Group is involved in a limited number of legal proceedings and claims, including civil, administrative and employment‑related matters, arising from normal business activities. This includes, among others, collective and representative claims relating to environmental and health matters. The outcome of these proceedings is inherently uncertain and dependent on future legal developments. Based on legal advice received and management’s assessment, no outflow of economic benefits is considered probable at the reporting date and therefore no provision has been recognised.

Collective action Stichting Frisse Wind

In December 2025, Stichting Frisse Wind initiated collective proceedings against TSN and its subsidiary Tata Steel IJmuiden (TSIJ) under the Dutch Act on Collective Settlement of Class Actions (Wet Afwikkeling Massaschade in Collectieve Actie, “WAMCA”). Stichting Frisse Wind states that it is acting on behalf of residents living in the vicinity of TSN and TSIJ and argues that TSN and TSIJ have systematically and on a large scale emitted hazardous substances and has failed to take timely and adequate steps to mitigate the harmful consequences of its operations. TSN and TSIJ deny the allegations and will strongly defend their position in court.

Stichting Frisse Wind’s claims for relief include confirmation that TSN is liable towards the local residents for current and future damages, compensation for alleged immaterial damages (vulnerability to symptoms / illness and loss of enjoyment of life) of approximately €685 million, material damages of approximately €718 million for loss of property value plus a yet to be quantified amount for loss of enjoyment of living / residency and payment of extrajudicial damages, including costs for (post-judgement) claim handling estimated at at least €8 million.

The proceedings entered the admissibility phase in March 2026. If the claim is declared admissible, opt‑out opportunities for affected residents and potential settlement discussions will follow; failing settlement, the case would proceed to a merits phase. This collective action litigation is a complex and extensive litigation, which is expected to last for multiple years in first instance alone. At this stage, the outcome and potential financial impact of the proceedings cannot be reliably estimated. Accordingly, no provision has been recognised, and the matter is disclosed as a contingent liability.

Criminal prosecution case

On 19 May 2021 a criminal complaint was filed on behalf of more than 800 people and ten foundations against Tata Steel and its de facto managers. In February 2022 the Public Prosecution Office initiated a criminal investigation into focusing on the alleged introduction of hazardous substances that could affect public health into the soil, air or surface water. On November 29 and December 6, 2022, The Public Prosecution Office has performed judicial site visits to gain more insight into the steel production process and the operations of the Cokes and Gas Plants. On 12 March 2026 the Public Prosecution Office visited TSIJ to claim administrative documents. The Public Prosecution Office has communicated that that a large part of the investigation is now finalised, that the investigation into a.o. the role of de facto managers is however still ongoing. The timing and outcome of the complete investigation into TSIJ and into the role of the de facto managers are uncertain. As such we have not recorded a (contingent) liability.

On 27 March 2023, an unusual incident leading to a blast furnace gas emission occurred at Blast Furnace 7. In April 2025, TSIJ received an official report containing several allegations regarding this event. The timing and outcome of this investigation are unknown.

On 8 April 2025, the EA NZKG has informed TSIJ that a criminal investigation has been initiated into the exceedance of emission limit values for dust at Continuous Caster Machines (“CGMs”) 21, 22 and/or 23 from 2020 to 2025. On 4 February 2026 the EA NZKG has issued a written interrogation document with 44 questions , which were answered by TSIJ. The timing and outcome of this investigation are unknown.

On 5 December 2025 a criminal complaint was filed by Greenpeace and Stichting Frisse Wind for an alleged (repeated) violation of the reporting obligation stemming from the PRTR Regulation (Regulation (EC) No 166/2006) with regard to the emission of various harmful substances, including substances of very high concern over the years 2020-2024. Greenpeace and Stichting Frisse Wind allege that actual emissions in previous years were higher than reported based on 2024 e-MJV assessment. No investigation has started as of yet.

Environmental remediation and future compliance obligations

The Group operates complex industrial installations which give rise to long‑term environmental compliance obligations, including obligations related to emissions control, waste handling and site restoration. While the Group is committed to complying with applicable environmental regulations and has programmes in place to address identified issues, certain future costs may depend on regulatory interpretations, technological solutions and the timing of enforcement actions. To the extent that such obligations relate to future events or do not meet the recognition criteria of IAS 37 at the reporting date, they have not been provided for and are disclosed as contingent liabilities.

Following the entry into force of the Environmental Act, the competent authority is required to assess whether TSIJ’s environmental permit should be amended to include a requirement to provide financial security. Such financial security, if imposed, is intended to support compliance with the permit and to cover potential liability for damage to the physical environment. As at the balance sheet date, the environmental permit has not been amended and no financial security obligation has been imposed. The Company is in ongoing discussions with the competent authority (EA NZKG). The nature, form and potential amount of any financial security cannot yet be reliably estimated.

Tax contingent liabilities

The Group operates in multiple tax jurisdictions and is subject to periodic tax audits, reviews and inquiries by tax authorities, including in the Netherlands, Germany, Belgium, Turkey, and the United States. Certain tax matters are under discussion or review as at 31 March 2026, including transfer pricing positions, corporate income tax assessments, customs duties, indirect tax matters and the application of international tax legislation such as Pillar Two. The outcome of these matters depends on future events and is subject to inherent uncertainty.

Based on management’s assessment, supported by external tax advice, no outflow of economic benefits is considered probable in respect of these matters at the reporting date, or the amounts cannot be reliably estimated. Accordingly, no provision has been recognised. Where appropriate, amounts have been provided for in the financial statements when the recognition criteria under IAS 37 or IAS 12 were met. The directors do not expect the resolution of the remaining tax matters to have a material adverse effect on the Group’s financial position or liquidity.