T1 Energy Inc.

Evaluation of Disclosure Controls and Procedures

Disclosure controls and procedures are controls and other procedures designed to ensure that information required to be disclosed by us is recorded, processed, summarized, and reported within the time periods specified in the SEC 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. The Company’s management carried out an evaluation, under the supervision and with the participation of our Chief Executive Officer and Chief Financial Officer, of the effectiveness of the design and operation of our disclosure controls and procedures (as such term is defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of June 30, 2026. Based upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that our disclosure controls and procedures were not effective as of June 30, 2026 due to the material weakness described below.

In light of this material weakness, management performed additional analysis and other procedures to help ensure that our consolidated financial statements were prepared in accordance with U.S. generally accepted accounting principles (“U.S. GAAP”). Accordingly, management believes that the consolidated financial statements included in this Quarterly Report on Form 10-Q fairly present, in all material respects, our financial position, results of operations, and cash flows as of and for the periods presented, in accordance with U.S. GAAP.

Material Weakness

As previously disclosed in the Company’s Annual Report on Form 10-K for the year ended December 31, 2025, management identified the following material weakness related to the Company’s G1 entity:

•The Company had ineffective general information technology controls that support the consistent operation of the Company’s Oracle-based information technology (“IT”) system. Therefore, automated process-level controls and manual controls dependent upon the accuracy and completeness of information derived from that IT system were also ineffective because they could have been adversely impacted.

•The Company did not effectively design, implement or operate process-level controls regarding revenue and inventory processes.

Management concluded that the material weakness was primarily attributable to deficiencies in oversight, resources, information and communication, and monitoring activities, as previously disclosed.

Remediation Plan

Management has continued to execute its remediation plan during the second quarter of 2026. Remediation efforts during the quarter have primarily focused on establishing elements of the Company’s control environment, including governance, training, and financial close processes. Actions completed or initiated during the quarter include the following:

•Management continues to utilize a centralized close management platform to integrate corporate and G1 month-end and quarter-end financial close tasks. This platform is intended to support the assignment of responsibilities, identification of task dependencies, and monitoring of financial close activities.

•Management, with the assistance of third-party advisors, held trainings for control owners and key personnel related to SOX compliance requirements, control documentation expectations, and control execution responsibilities.

•Management, with the assistance of third-party advisors, completed process walkthroughs for all in-scope processes and systems to help ensure owners are aware of their defined controls, control descriptions are up-to-date, and process flowcharts reflect the current state of operations.

•Management has implemented a self-certification process whereby control owners certify that controls, as designed, are in place and have been performed, or are expected to be performed, in accordance with applicable requirements. This process has been established and was executed in connection with the preparation of this Quarterly Report.

•Management established procedures for reporting to executive leadership and the Audit Committee on a recurring basis regarding the effectiveness of internal controls and the status of remediation efforts.

•Management has recently fulfilled various internal roles in its ongoing initiative aimed at maintaining sufficiently trained and experienced individuals.

Remediation efforts related to general information technology controls within the Company’s Oracle-based IT system and process-level controls over revenue and inventory remain ongoing. Certain elements of controls have been designed and, in some cases, implemented; however, these controls have not operated for a sufficient period of time to allow management to complete operating effectiveness testing.

Accordingly, management has not yet concluded that the material weakness has been remediated. Management expects remediation efforts to continue throughout fiscal year 2026 and will evaluate the effectiveness of the remediated controls once they have been implemented and have operated for a sufficient period of time.

Changes in Internal Control over Financial Reporting

Except as described above, no changes in our internal control over financial reporting occurred during the three months ended June 30, 2026 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.