COMTECH TELECOMMUNICATIONS CORP /DE/

Evaluation of Disclosure Controls and Procedures

As of the end of the period covered by this Annual Report on Form 10-K, we conducted an evaluation of the effectiveness of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934, as amended (the "Exchange Act")), which have been designed to provide reasonable assurance that the information required to be disclosed by us, in reports filed or submitted under the Exchange Act, is recorded, processed, summarized and reported, within the time periods specified in the SEC’s rules and forms and accumulated and communicated to management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosure.

Based on this evaluation, carried out by us under the supervision of our Chief Executive Officer and Chief Financial Officer, and with the participation of our management, we concluded that our disclosure controls and procedures were not effective as of July 31, 2026, as a result of the previously disclosed material weaknesses in our internal control over financial reporting discussed below.

Notwithstanding our material weaknesses, we have concluded that the consolidated financial statements and other financial information included in this Form 10-K fairly present in all material respects our financial condition, results of operations and cash flows for the periods presented in conformity with accounting principles generally accepted in the U.S. ("U.S. GAAP").

Management's Report on Internal Control Over Financial Reporting

Our management, including our Chief Executive Officer and Chief Financial Officer, is responsible for establishing and maintaining adequate internal control over financial reporting as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act.

Our management assessed the effectiveness of our internal control over financial reporting as of July 31, 2026. In making this assessment, we used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission in Internal Control – Integrated Framework (2013) (the "COSO framework"). Based on our assessment, we determined that, as of July 31, 2026, our internal control over financial reporting was not effective based on those criteria as a result of the material weaknesses described below.

A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the annual or interim financial statements will not be prevented or detected on a timely basis.

Previously Disclosed Material Weaknesses

As previously disclosed in Part II, Item 9A. Controls and Procedures of our Form 10-K for the fiscal year ended July 31, 2025, management identified material weaknesses in our internal control over financial reporting as of July 31, 2025.

Management, with the oversight of our Audit Committee, implemented several enhancements to internal control over financial reporting throughout fiscal year 2026, including those noted below:

•Conducted training for all control owners and relevant personnel to improve the design and documentation that supports effective control activities, including evidence of the completeness and accuracy of information used in controls;

•For those employees involved in the estimate at completion ("EAC”) process, we conducted specialized training sessions related to newly designed or enhanced control activities that were put in place for preparing and reviewing an EAC and its impact on the accuracy of financial reporting;

•With respect to our international component operations, we updated and documented our policies and procedures related to accounting and financial reporting, including adopting more robust information technology policies and procedures and the enhancement of certain control activities over user access, change management and review of third-party service organization reports;

•Hired a Vice President, Internal Audit, to lead our Sarbanes-Oxley compliance program, including the execution of our remediation plans, in conjunction with utilizing third-party consultants that were engaged in fiscal years 2025 and 2026 to assist us with remediation efforts; and

•Continued engaging with third-party specialists with the requisite knowledge, experience and resources to assist with complex accounting matters and transactions.

As a result, management established effective processes and controls over (i) inventory, other assets and complex accounting matters and transactions (including debt, convertible preferred stock and related embedded derivatives), and (ii) general information technology controls related to Allerium’s international component, and considers the related material weaknesses to be remediated as of July 31, 2026.

As of July 31, 2026, while we believe that our efforts have improved our internal control over financial reporting and resulted in the remediation of certain of the previously identified material weaknesses, remediation of the material weakness related to control activities over revenue recognition and contract liabilities, that resulted from the control environment material weakness, will require further testing of the design and operating effectiveness of internal controls over a sufficient period of time in order to conclude that the material weaknesses have been remediated.

Deloitte and Touche LLP, our independent registered public accounting firm, has performed an audit of our internal control over financial reporting as of July 31, 2026. The effectiveness of our internal control over financial reporting has been audited by Deloitte & Touche LLP, an independent registered public accounting firm, as stated in its report which appears in Part II, Item 8 of this Annual Report on Form 10-K.

Remediation Plan

While we believe that our efforts have improved our internal control over financial reporting and remediated certain material weaknesses identified as of July 31, 2025, as described above, remediation of the remaining material weaknesses will require continued focus and commitment. Management remains committed to remediating the remaining material weaknesses described above. We will continue to monitor the effectiveness of our enhancements made to internal control over financial reporting and refine the remediation plan, as appropriate. The material weaknesses cannot be considered remediated until the applicable controls have operated for a sufficient period of time and management has concluded, through testing, that these controls are operating effectively.

Changes In Internal Control Over Financial Reporting

Other than described above, there have been no changes in our internal control over financial reporting as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act that occurred during our fiscal quarter ended July 31, 2026, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.