That sure looks like a drill file.
Both Gerber files and Drill files use a format similar to “G-Code”, which is probably the oldest file formats still in widespread use. It was designed in the late '50-ies !
Lines starting with a semicolon are comment, and this means that there is no information about drill sizes in your file (Computer should ignore the comment).
If you compare your file with a drill file generated by KiCad, it’s quite obvious what to change. I see definitions for “T1” through “T12”, which are tool numbers, and the “C” after their definitions are either diameter or radius of the tools. Later those tool numbers are used to switch to those tools.
X & Y are used for coordinates, and your file uses a different format for coordinates, although both use “METRIC”.
For quick compare. Here is the start of a drill file generated by KiCad.
M48
; DRILL file {KiCad 5.1.10-88a1d61d58~88~ubuntu20.04.1} date Mon May 17 23:03:10 2021
; FORMAT={-:-/ absolute / metric / decimal}
; #@! TF.CreationDate,2021-05-17T23:03:10+02:00
; #@! TF.GenerationSoftware,Kicad,Pcbnew,5.1.10-88a1d61d58~88~ubuntu20.04.1
; #@! TF.FileFunction,Plated,1,2,PTH
FMAT,2
METRIC
T1C0.400
T2C0.600
T3C1.000
%
G90
G05
T1
X108.966Y-108.458
T2
X103.148Y-110.363
X104.648Y-110.363
T3
X85.75Y-92.243
X85.75Y-94.783
X85.75Y-97.323
X85.75Y-99.863
X85.75Y-102.403
X85.75Y-104.943
X85.75Y-107.483
X85.75Y-110.023
X85.75Y-112.563
X85.75Y-115.103
X85.75Y-117.643
Your drill files have coordinates in a fixed format. I do not know if KiCad is able to handle those in drill files. I had a look at a gerber file made by KiCad and it has a similar fixed format without a decimal dot in the numbers.
But if you want to know more details, then look up some official documentation of these file formats.