Litigation

TSN and its subsidiaries are involved in multiple legal proceedings, ranging from civil law to administrative and criminal law. TSN actively manages these matters, using internal legal experts and external counsels.

Below, TSN provides an overview of the material ongoing and potential legal proceedings and investigations.

1. On 19 December 2025, Stichting Frisse Wind initiated proceedings against TSN and its subsidiary Tata Steel IJmuiden (“TSIJ”). The proceedings initiated by Stichting Frisse Wind concern a collective action under the Dutch Act on Collective Settlement of Class Actions  (Wet Afwikkeling Massaschade in Collectieve Actie).  
   
   Stichting Frisse Wind states that it is acting on behalf of approximately 330,000 residents living in the vicinity of TSN and TSIJ. Stichting Frisse Wind 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.
   
   On 25 March 2026, the litigation started with the admissibility phase. On 29 July 2026, TSN and TSIJ will submit their statement of defence in the admissibility phase.
   
   If the claim is found to be admissible, the first opt-out opportunity occurs. Residents who do not wish to be part of the class action can opt-out and are then no longer represented by Stichting Frisse Wind nor bound by the outcome of the case. Hereafter parties are invited to settlement negotiations. If a settlement is reached, residents who do not wish to be covered by the settlement can opt-out. If parties do not reach a settlement, the litigation will proceed with the merit’s phase.
   
   This collective action litigation is a complex and extensive litigation, which is expected to last for multiple years in first instance alone.
   
   

2. In May 2023, a court in Germany decided that TSIJ infringed on a valid German utility model as of July 2015 by selling a specific low-waviness steel grade. TSIJ no longer produces or sells this specific steel grade and has appealed the court’s decision that TSIJ infringed the German utility model. The appeal court appointed an expert, who issued his report in November 2025 and concluded that the theory underlying the court’s decision is not widely accepted or plausible. The appeal proceedings continue.
   
   

3. TSIJ has two Cokes and Gas Plants (“CGP1 and CGP2”, together the “CGPs”) which provide two Blast Furnaces (“BF6 and BF7”) with coke and the site operations with coke oven gas. 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”) MVP1 (including PAH) and MVP2 at  CGP1 oven stacks and MVP1 (including PAH) and g.02 at the CGP2 oven stacks.
   
   MVP1 refers to solid substances of very high concern. MVP2 refers to gaseous or vaporous substances of very high concern. PAHs refer to Polycyclic Aromatic Hydrocarbons, a hazardous organic pollutant and g.02 is the gaseous phase of Polycyclic Aromatic Hydrocarbons.
   
   Further to these measurements, on 19 December 2024, the EA NZKG imposed two penalty orders with a maximum total amount of €27 million on TSIJ for alleged non-compliance, requiring it to stop the exceedances and stay below emission thresholds. TSIJ has submitted a statement of objections against these penalty orders. In November 2025, the Province of North Holland sent its decision on the objections raised by TSIJ, largely upholding the penalty orders. TSIJ has made the decision not to appeal.
   
   On 3 February 2026, TSIJ received the recovery decision of in total €8.532.500,- for exceedance of both MVP1 and MVP2 at CGP1. This amount was paid. On 16 April 2026, TSIJ received a second recovery decision of in total €8.532.500,- for exceedance of both MVP1 and MVP2 at CGP1. This amount was paid. The 19 December 2024 penalty order for CGP1 is now fully executed. TSIJ has made the decision to file objections against the recovery decision. 
   
   On May 11, 2026 TSIJ received a recovery decision of €3.250.000 for exceedance of MVP1 at CGP2. The 19 December 2024 penalty order for CGP2 is not yet fully executed. TSIJ has made the decision to file objections against the recovery decision.
   
   

4. 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.
   
   

5. In September 2022, the EA NZKG issued a penalty order on the so-called green pushes – pushing cokes from the oven before the coking process is fully complete – at the CGPs in IJmuiden.
   
   TSIJ submitted its objections, which were rejected, and requested a permit for the green pushes, which was denied. TSIJ appealed the decision on objections. In April 2025, the court decided to deny TSIJ’s requests. TSIJ appealed against this judgement with the Administrative Jurisdiction Division of the Council of State (Afdeling bestuursrechtspraak van de Raad van State, “ABRvS”). These proceedings are ongoing. In August and October 2025, TSIJ received two penalty orders for green pushes of €100,000 each. In April 2026 TSIJ has received two intentions from the EA NZKG of recovery decisions of € 100,000 for alleged green pushes. TSIJ is opposing these (intentions for) recovery. 
   
   

6. 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 NDZKG 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. Reference is made to the 'Going Concern' section in the Basis of preparation. 
   
   

7. 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 of €500,000. Appeal proceedings are ongoing. In 2024, TSIJ received a second penalty order for the CGM22, again for exceedance of dust emissions, of €500,000 per violation and a maximum of €2,000,000. Appeal proceedings regarding this second penalty order are ongoing.
   
   On 16 October 2025, TSIJ received the order under penalty for Continuous Caster Machine 21 ("CGM21") for exceedance of dust and hydrogen fluoride (HF) with a total maximum of €2,400,000.
   To date no penalties or intentions for penalties have been received under this order under penalty. TSIJ has submitted objections against the penalty order for CGM21.
   
   On 2 March 2026, the EA sent TSN a recovery under penalty order for exceedance of dust emissions at CGM22 for the payment of €500,000. The amount has been paid. This recovery under penalty order is part of the appeal proceedings against the second penalty order. On 30 March 2026, an intention for a recovery order for exceedance of dust emissions at CGM22 was received of €500,000. The amount has been paid. This recovery under penalty order is part of the appeal proceedings against the second penalty order.
   
   

8. In December 2025, TSIJ received a penalty order for the Sinter Plant due to alleged exceedances of hydrogen fluoride, chromium and nickel in the off-gases after the bag filter of the Sinter Plant, for a total potential penalty of €2,400,000. To date, no penalties have yet been claimed. TSIJ has made the decision not to file objections against this penalty order.

Potential litigation:

1. 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 focusing on the alleged introduction of hazardous substances that could affect public health into the soil, air or surface water. On 29 November and 6 December 2022, The Public Prosecution Office 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 and that the investigation into a.o. the role of the 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.
   
   

2. 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.
   
   

3. On 8 April 2025, the EA NZKG 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 issued a written interrogation document with 44 questions , which were answered by TSIJ. The timing and outcome of this investigation are unknown.
   
   

4. 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 the 2024 e-MJV assessment. An investigation has not been started as of yet.
   
   

5. On 22 April 2026, TSIJ received the order under penalty from ILT (Inspectie Leefomgeving and Transport), ordering TSIJ to bring LD steel slag to the market subject to the CLP classification “hazardous”, and ensure compliance with the order within 31 days from the date of the order under penalty. TSIJ has taken the necessary steps to ensure timely compliance with the order under penalty.
   
   Steel slag is a necessary by-product of TSIJ’s steelmaking process. Steel slag is used by third parties for circular use in in particular infrastructure-related materials. TSIJ has strengthened its duty of care efforts to ensure that steel slag is used responsibly in these and other applications. This includes providing steel slag customers with clear risk documents on safe applications. 
   
   At the same time TSIJ is experiencing increased regulatory complexity due to the temporary ban in the Netherlands for these applications and in evidencing that the steel slag brought to the (European) market is treated as a by-product instead of waste. This complex regulatory landscape leads to a heightened risk of enforcement and litigation.