Flutter Entertainment plc

Evaluation of Disclosure Controls and Procedures

Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, has evaluated the effectiveness of the design and operation of our disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”) as of December 31, 2025. Based on the evaluation of our disclosure controls and procedures, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were effective as of December 31, 2025.

Management’s Report on Internal Control Over Financial Reporting

Flutter’s management 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 internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with GAAP. Our internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of Flutter; (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with GAAP, and that receipts and expenditures of Flutter are being made only in accordance with authorizations of management and directors of Flutter; and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of Flutter’s assets that could have a material effect on the consolidated financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Flutter’s management assessed the effectiveness of our internal control over financial reporting as of December 31, 2025, utilizing the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control-Integrated Framework (2013 Framework). Based on the assessment by Flutter’s management, we determined that our internal control over financial reporting was effective as of December 31, 2025.

Flutter’s management’s assessment for fiscal 2025 excluded the internal controls over financial reporting of Snai, acquired by Flutter during 2025. Total assets and total revenues of Snai, a wholly owned subsidiary, represented 12% and 5% of the related consolidated financial statement amounts as of and for the year ended December 31, 2025.

The effectiveness of our internal control over financial reporting as of December 31, 2025 has been audited by KPMG, an independent registered public accounting firm, as stated in their report, which is included in Part II, Item 8 of this Annual Report on Form 10-K.

Previously Reported Material Weaknesses

As previously reported in Part II, “Item 9A—Controls and Procedures” of our Annual Report on Form 10-K for the year ended December 31, 2024, we identified material weaknesses in our internal control over financial reporting. A material weakness is a deficiency, or combination of deficiencies, in our internal control over financial reporting such that there is a reasonable possibility that a material misstatement of our consolidated financial statements would not be prevented or detected on a timely basis.

In order to remediate the identified deficiencies, management developed and executed a comprehensive remediation plan. In fiscal 2025, we have taken action in relation to the prior year material weaknesses as follows:

(i) designing and implementing an effective risk assessment to identify and communicate appropriate objectives in relation to financial reporting error and fraud;

•In the prior year we documented risk assessments for our financial reporting processes and developed an effective enterprise-wise risk assessment process. In the current year we continued enhancing our risk assessments for financial reporting processes, as described in (ii) and (v) below.

•We have also developed and implemented enhanced fraud risk assessment processes, the outputs of which are integrated with our enterprise-wide risk and financial reporting risk assessment processes.

•Our activities were reviewed by senior finance leadership and overseen by the Audit Committee.

(ii) designing, implementing and operating effective control activities, including management review controls, in relation to certain complex accounting, valuation and other areas, principally the review of manual journal entries, balance sheet reconciliations, cost allocations for income statement presentational purposes, acquisition accounting, treasury accounting and carrying values for impairment testing;

•For certain business processes, we reassessed our end-to-end process, performed a new risk assessment, and then identified and designed relevant control activities to be performed to address those risks. These activities were supported by external consultants who have extensive experience in internal controls and, where relevant, specialist subject matter area knowledge.

•We issued new policies and procedures to provide guidance on the design, implementation and operating effectiveness of control activities to our finance teams, and senior finance leadership monitored the adoption of these.

•We reconfigured our consolidation system hierarchies and remapped certain data elements to enable a clear alignment of carrying values to reporting units.

•Targeted training and coaching of relevant personnel operating controls has been provided, in particular on requirements for management review controls.

(iii) designing, implementing and operating effective general IT controls related to user access management and change management;

•Management has designed and implemented enhanced IT processes and controls for the systems and tools relevant to internal control over financial reporting, specifically strengthening user access and change management controls.

•Targeted training, guidance and coaching of relevant personnel responsible for operating general IT controls to ensure consistent and effective performance.

•Mitigating control activities have been performed, documented and monitored where necessary, to confirm that any exceptions do not threaten the integrity of the IT control environment.

(iv) maintaining sufficient documentation to evidence the processes and controls in place to ensure adequate review over financial reporting;

•We have enhanced our external financial reporting process and recruited additional personnel with GAAP and SEC reporting experience to implement and operate newly designed controls and maintain sufficient control documentation.

and (v) designing, implementing and operating effective control activities in Sisal, our Italian business acquired in August 2022 that operates on a different ERP to the majority of the Group.

•Management has designed, implemented and operated effectively enhanced IT processes and controls for the systems and tools relevant to internal control over financial reporting at Sisal.

•Mitigating control activities have been performed, where necessary, to demonstrate exceptions do not threaten the integrity of the IT control environment.

•For certain business processes, we reassessed our end-to-end process, performed a new risk assessment, and then identified and designed relevant control activities to be performed to address those risks.

•Targeted training and coaching of relevant personnel operating controls has been provided.

Management has determined, through its current year testing, that the controls have been designed and implemented effectively and that these controls operated effectively for a sufficient period of time. Based on the remediation measures above, management concluded that the previously disclosed material weaknesses have been remediated as of the year ended December 31, 2025.

Changes in Internal Control over Financial Reporting

Except for the improvements to our internal control over financial reporting to remediate the material weaknesses as otherwise described herein, there were no other changes in our internal control over financial reporting during our most recent fiscal quarter that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

In fiscal 2024, management commenced a multi-year finance transformation project that includes, but is not limited to, the upgrading and migrating of certain accounting and finance systems to a new enterprise resource planning system, with corresponding re-engineering of business process and internal controls over financial reporting. This transformation project will continue through 2027 and is expected to modify the design and implementation of certain internal control processes in 2026 and 2027.