ACCURAY INC

Evaluation of Disclosure Controls and Procedures

Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of the design and operation of our disclosure controls and procedures (as defined in Rule 13a‑15(e) of the Exchange Act) as of the end of the period covered by our Annual Report on Form 10-K for the fiscal year ended June 30, 2026 (the “Evaluation Date”).

Based on this evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, due to the material weakness described below that was not remediated as of the Evaluation Date, our disclosure controls and procedures were not effective to provide reasonable assurance that the information required to be disclosed by us in the reports we file or submit under the Exchange Act is recorded, processed, summarized, and reported within the time periods specified in the SEC’s rules and forms, and that such information is accumulated and communicated to our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

Management’s Report on Internal Control over Financial Reporting

Management is responsible for establishing and maintaining adequate internal control over financial reporting, as such term is defined in Rule 13a‑15(f) of the Exchange Act. Under the supervision and with the participation of the Chief Executive Officer and Chief Financial Officer, management conducted an evaluation of the effectiveness of our internal control over financial reporting based upon the guidelines established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) 2013.

Based on this evaluation, management concluded that as of June 30, 2026 our internal control over financial reporting was not effective due to the material weakness described below that was not remediated as of the Evaluation Date. The effectiveness of our internal control over financial reporting as of June 30, 2026 has been audited by Grant Thornton LLP, an independent registered public accounting firm, as stated in their report included herein.

Previously Disclosed Material Weakness Not Yet Remediated

As disclosed in Item 9A of our Annual Report on Form 10-K/A for the fiscal year ended June 30, 2025 issued on February 17, 2026, a material weakness was identified related to the review of the footnote schedules supporting financial statement disclosures. As of June 30, 2026, enhanced control activities have been designed and implemented but have not operated effectively for a sufficient period of time, and management had not completed sufficient testing, to conclude that the material weakness has been remediated.

Remediated Previously Disclosed Material Weakness

Also as disclosed in Item 9A of our Annual Report on Form 10-K/A for the fiscal year ended June 30, 2025 issued on February 17, 2026, a material weakness was identified related to the inadequate controls to appropriately analyze all relevant information required for complete and accurate presentation under GAAP principally resulting from an incorrect assessment during the initial adoption of ASC 606,Revenue from Contracts with Customers. To remediate this material weakness, management designed and implemented enhanced controls to ensure all relevant information required for complete and accurate presentation and disclosure, including the initial assessment of the impact of adopting new accounting pronouncements. As of June 30, 2026, these control activities have been appropriately designed and implemented, and have operated effectively for a sufficient period of time to conclude that the previously identified material weakness has been remediated.

Remediation Measures

To remediate the material weakness that was not remediated as of the Evaluation Date, management has designed and implemented enhanced review controls specific to financial statement footnote disclosure. These enhancements are intended to ensure greater precision in preparing and reviewing financial statement disclosures, including additional reviewer involvement in the review of the footnote schedules supporting the financial statement disclosures. As of June 30, 2026, these control activities have been appropriately designed and implemented but have not operated effectively for a sufficient period of time, and management had not completed sufficient testing, to conclude that the previously identified material weakness has been remediated

Changes in Internal Control over Financial Reporting

Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, has evaluated any changes in our internal control over financial reporting that occurred during the year ended June 30, 2026, and has concluded that other than the changes described above under “Previously Disclosed Material Weakness Not Yet Remediated” and "Remediated Previously Disclosed Material Weakness" there were no changes in our internal control over financial reporting that occurred that have materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.

Inherent Limitations of Internal Controls

Internal control over financial reporting cannot provide absolute assurance of achieving financial reporting objectives because of its inherent limitations. Internal control over financial reporting is a process that involves human diligence and compliance and is subject to lapses in judgment and breakdowns resulting from human failures. Internal control over financial reporting also can be circumvented by collusion or improper management override. Because of such limitations, there is a risk that material misstatements may not be prevented or detected on a timely basis by internal control over financial reporting. However, these inherent limitations are known features of the financial reporting process. Therefore, it is possible to design into the process safeguards to reduce, though not eliminate, this risk.