December 19, 2024

Fredrik Westin
Chief Financial Officer
Autoliv, Inc.
Klarabergsviadukten 70, Section B7
Box 70381
Stockholm, Sweden SE-107 24

       Re: Autoliv, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Forms 8-K Furnished July 19, 2024 and October 18, 2024
           Response dated November 22, 2024
           File No. 001-12933
Dear Fredrik Westin:

        We have reviewed your November 22, 2024 response to our comment letter
and have
the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our October
7, 2024 letter.

Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to the Consolidated Financial Statements
1. Basis of Presentation
Segment Reporting, page 60

1.     We note your response to prior comment 5 and have the following
comments:

             Please provide a more detailed description, with supporting
examples, of the roles
           and responsibilities of the Division Presidents, and compare and
contrast those
           roles with that of the EVP of Operations and the CEO.

             In addition to the consolidated information for the Company, you
describe three
 December 19, 2024
Page 2

             other perspectives    of financial information in the EMT
Financial Report,
          including Division financial performance information. You indicate
the three
          other perspectives are not the primary tool used by the CODM in
evaluating and
          deciding upon significant operating or strategic decisions and that
it is helpful in
          understanding the efficiency of manufacturing operations within a
geographic
          region. You also indicate that the financial or other impact on
specific geographic
          regions may help inform resource allocation decisions. Please expand
on your
          discussion of how this information is used, with supporting examples,
including
          the following:
            o why financial performance information for Divisions is prepared
and
               provided to the CODM;
            o what information comprises the Division financial performance
information,
               and whether actual results are compared against forecast;
            o why the Division financial information includes costs that are
allocated from
               the Global and Corporate Functions;
            o how it is used by the CODM, and why such use does not represent
regular
               review by the CODM for the allocation of resources and
assessment of
               performance at the Division level; and
            o how financial information for the Divisions is used by
individuals that report
               to the CODM, such as the Division Presidents and EVP of
Operations.

            At the top of page 14 of your response, you indicate that the CEO
meets with
          direct reports of a specific team at least monthly and reviews actual
financial
          results for the Company by region at those meetings. Please describe
the regional
          information reviewed by the CODM and what is discussed.

            You indicate that none of the Division forecasts are individually
approved by the
          CFO and are only included in the consolidated forecast for final
approval by the
          CEO. Please tell us what    included in the consolidated forecast
means, including
          whether the individual forecasts are provided to the CODM as part of
the
          consolidated forecast and whether the CODM reviews them in approving
the
          consolidated budget.

            You indicate that Divisions execute on the strategic plans given to
them by the
          CEO. We also note your discussion of the Company   s forecasts.
Please tell us
          what items a Division President is responsible for in the forecast of
their Division.
          Please further tell us whether Division Presidents are responsible
for operating
          within their respective forecast and what approvals are necessary, if
any, if a
          Division Presidents wants or expects to exceed forecasted expenses or
          expenditures.
 December 19, 2024
Page 3

Forms 8-K Furnished July 19, 2024 and October 18, 2024
Exhibit 99.1 Press Release of Autoliv, Inc. dated July 19, 2024, page 1

2.     We note your response to prior comment 9 and that you present non-GAAP
trade
       working capital in both your Form 8-K earnings releases and Forms 10-K
and 10-Q
       periodic reports. Please explain to us in further detail how you
determined trade
       working capital solely represents a performance measure as opposed to a
liquidity
       measure or a combined performance and liquidity measure. We note your
       reconciliation of the measure to working capital, a standard measure of
a company's
       liquidity, your presentation and discussion of the measure within the
liquidity and
       capital resources sections of your periodic reports, and your
disclosures that
       management focuses on the measure due to "the need to optimize cash
generation."
Exhibit 99.1 Press Release of Autoliv, Inc. dated October 18, 2024
Reconciliation of U.S. GAAP to Non-U.S. GAAP Measures, page 16

3.     In future earnings releases, please fully reconcile each non-GAAP
measure presented
       pursuant to Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, ensure
that you
       separately identify and quantify each non-GAAP adjustment for each
period
       presented. For example, we note that you have not provided this
information for all
       items in the "Adjustments" columns of pages 19 and 20 that date back to
2019.
       Please contact Andrew Blume at 202-551-3254 or Kevin Woody at
202-551-3629 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Manufacturing