Item 9A. CONTROLS AND PROCEDURES

Evaluation of Disclosure Controls and Procedures

As of December 31, 2025, management carried out, under the supervision and with the participation of our Chief Executive

Officer and Chief Financial Officer, an evaluation of 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). Based on this evaluation,

our Chief Executive Officer and Chief Financial Officer concluded that, as of December 31, 2025, our disclosure controls and

procedures were effective in ensuring that information required to be disclosed by us in the reports that we file or submit under

the Securities Exchange Act of 1934, as amended (the "Exchange Act"), is recorded, processed, summarized and reported

within the time periods specified in applicable rules and forms and are designed to ensure that information required to be

disclosed in those reports is accumulated and communicated to management, including our Chief Executive Officer and Chief

Financial Officer, as appropriate to allow timely decisions regarding required disclosure.

Management Report on Internal Control over Financial Reporting

Our management is responsible for establishing and maintaining an adequate system of internal control over financial reporting

(as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act), pursuant to Rule 13a-15(c) of the Exchange Act. Our

internal control over financial reporting is 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 management

assessed the effectiveness of our internal control over financial reporting as of December 31, 2025. In making this assessment,

our management used the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission

(COSO) in 2013, Internal Control-Integrated Framework. As of December 31, 2025, management believes that the Company’s

internal control over financial reporting is effective based on those criteria. Our independent registered public accounting firm

has issued an audit report on our internal control over financial reporting, which is included in this annual report.

In connection with management's evaluation, our management team excluded from its assessment of the effectiveness of our

internal control over financial reporting as of December 31, 2025, the internal controls related to two subsidiaries that we

acquired during the year ended December 31, 2025, and for which financial results are included in our consolidated financial

statements.

During 2025, the Company acquired Gringo, a leading Brazil-based vehicle registration and compliance payment company; and

Alpha, a leading provider of B2B cross-border foreign exchange solutions to corporations and investment funds in the UK.

Collectively, we refer to these transactions as the 2025 Acquisitions. In the evaluation of internal control over financial

reporting, management excluded the operations of acquired entities in the 2025 Acquisitions from the assessment of internal

control over financial reporting as of December 31, 2025. These operations were excluded in accordance with the SEC’s

general guidance because they and the related entities were acquired in purchase business combinations in 2025. These 2025

Acquisitions constituted 23.8% of total assets at December 31, 2025, and 2.0% of revenues, net for the year then ended.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements.

Projections of any evaluation of effectiveness for 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.

Remediation of Previously Reported Material Weakness

As previously disclosed in Part II-Item 9A "Controls and Procedures" in our Annual Report on Form 10-K for the year ended

December 31, 2024, we identified a material weakness in our internal control over financial reporting related to information

technology general controls (ITGCs) in the area of user access management over certain information technology systems used

in the execution of controls that support the Company’s financial reporting processes. Our business process application and

manual controls that are dependent on the affected ITGCs were also deemed ineffective because they could have been adversely

impacted.

With respect to the material weakness above, management, under the oversight of the Audit Committee, implemented measures

designed to ensure that control deficiencies contributing to the material weakness was remediated, and that these controls are

designed, implemented and operating effectively. The remediation actions included: (i) enhancement of the information

technology compliance oversight function; (ii) development of a training program addressing ITGCs and other policies,

including educating control owners concerning the principles and requirements of internal controls, with a focus on those

related to user access over information technology systems impacting financial reporting; (iii) documentation of underlying

ITGCs to enhance the information evidencing the performance of ITGCs; (iv) development of enhanced integration

functionality and controls related to the ongoing implementation of user access information technology system; and (v)

enhancement of the information technology management review and testing plan to monitor ITGCs, with a specific focus on

systems supporting our financial reporting processes.

During the quarter ended December 31, 2025, we completed our testing of the operating effectiveness of internal controls

impacted by these remediation efforts and determined the material weakness had been fully remediated as of December 31,

Changes in Internal Control over Financial Reporting

Except for the actions taken to remediate the material weakness described above, there have been no other changes in our

internal control over financial reporting (as defined in Rules 13a-15(f) or 15d-15(f) of the Exchange Act) during our fourth

quarter ended December 31, 2025 that have materially affected, or are reasonably likely to materially affect, our internal control

over financial reporting.

Report of Independent Registered Public Accounting Firm

To the Stockholders and the Board of Directors of Corpay, Inc.

Opinion on Internal Control over Financial Reporting

We have audited Corpay, Inc. and subsidiaries’ internal control over financial reporting as of December 31, 2025, based on

criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the

Treadway Commission (2013 framework) (the COSO criteria). In our opinion, Corpay, Inc. and subsidiaries (the Company)

maintained, in all material respects, effective internal control over financial reporting as of December 31, 2025, based on the

COSO criteria.

As indicated in the accompanying Management Report on Internal Control over Financial Reporting, management’s assessment

of and conclusion on the effectiveness of internal control over financial reporting did not include the internal controls of Gringo

and Alpha (the 2025 Acquisitions), which are included in the 2025 consolidated financial statements of the Company and

constituted 23.8% of total assets as of December 31, 2025 and 2.0% of revenues, net for the year then ended. Our audit of

internal control over financial reporting of the Company also did not include an evaluation of the internal control over financial

reporting of the 2025 Acquisitions.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States)

(PCAOB), the consolidated balance sheets of the Company as of December 31, 2025 and 2024, the related consolidated

statements of income, comprehensive income, equity and cash flows for each of the three years in the period ended December

31, 2025, and the related notes and our report dated February 26, 2026 expressed an unqualified opinion thereon.

Basis for Opinion

The Company’s management is responsible for maintaining effective internal control over financial reporting and for its

assessment of the effectiveness of internal control over financial reporting included in the accompanying Management Report

on Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Company’s internal control

over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to be

independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and

regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the

audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all

material respects.

Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material

weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk and

performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a

reasonable basis for our opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A company’s 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 generally

accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures

that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and

dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit

preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and

expenditures of the company are being made only in accordance with authorizations of management and directors of the

company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or

disposition of the company’s assets that could have a material effect on the 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.

/s/ Ernst & Young LLP

Atlanta, Georgia

February 26, 2026