SRSEC Reporting Desk

Magnitude International Ltd (MAGH) – SEC staff letter

2026-03-04 · Re: Form 20-F for the fiscal year ended April 30, 2025 Amendment No. 1 to Form 20-F for the fiscal year ended April 30, 2025 Response dated March 3, 2026 · Accession 0000000000-26-002232 · 1 staff comment(s) issued

Company response(s): 2026-03-06

Cybersecurity (Item 1C)ICFR & Disclosure ControlsExhibits, Certifications & Signatures

2026-03-04 · Form 20-F for the fiscal year ended April 30, 2025 Amendment No. 1 to Form 20-F for the fiscal year ended April 30, 2025 · Comment 1 · Item 15. Controls and Procedures, page 76 Agreed to revise
Staff comment: We note your response to our prior comment 1 and your amendment to your filing in response to our prior comments 1, 2, and 3 to include a conclusion regarding the effectiveness of your disclosure controls and procedures, include cybersecurity disclosures, and include the certifications from your principal executive officer and principal financial officer. In light of the amendment to address such previously omitted items, please tell us what consideration you gave to reconsidering your conclusion regarding your disclosure controls and procedures. letter →
Company response: 1 to our Form 20-F for the fiscal year ended April 30, 2025. Upon identifying the need to amend our original Form 20-F to include the previously omitted items, management, including our principal executive officer and principal financial officer (the “Certifying Officers”), re-evaluated the effectiveness of our disclosure controls and procedures (“DCP”) as of April 30, 2025. This re-evaluation was conducted specifically to determine whether the omission of these items from the original filing indicated a material weakness or a significant deficiency in our DCP that would alter the original conclusion of effectiveness. The re-evaluation considered the following factors: 1. Nature of the… response letter →
Cybersecurity (Item 1C)ICFR & Disclosure ControlsExhibits, Certifications & Signatures

Full letter on EDGAR → · Filing index · All Magnitude International Ltd (MAGH) correspondence

Cybersecurity (Item 1C) – what to check: Verify Item 1C describes processes, governance and board oversight, and that material incidents are evaluated for 8-K Item 1.05.

ICFR & Disclosure Controls – what to check: Describe material weaknesses, remediation steps and timing, and align ICFR conclusions with disclosure controls.

Exhibits, Certifications & Signatures – what to check:

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