March 4, 2019

Chi Yuen Leong
President
BioNexus Gene Lab Coporation
Level 8, Tower 8, Avenue 5, The Horizon
Bangar South
No. 8 Jalan Kerinchi
59200 Kuala Lumpur
Malaysia

       Re: BioNexus Gene Lab Coporation
           Amendment No. 1 to Registration Statement on Form S-1
           Filed February 25, 2019
           File No. 333-229399

Dear Mr. Leong:

      We have reviewed your amended registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our February 19,
2019 letter.

Amendment No. 1 to Registration Statement on Form S-1

Financial Statements and Exhibits, page II-1

1.     Please amend your filing to include updated audited consolidated
financial statements for
       the year ended December 31, 2018. Your discussion in MD&A and elsewhere
in the filing
       should be similarly revised to include updated financial information for
the year ended
       December 31, 2018. Refer to Rule 8-08(b) of Regulation S-X.
 Chi Yuen Leong
BioNexus Gene Lab Coporation
March 4, 2019
Page 2
Report of Independent Registered Public Accounting Firm , page II-2

2.    The report date referenced in the consent of the independent registered
public accounting
      firm included as exhibit 23 of February 25, 2019 is inconsistent with the
report date of the
      report of the independent registered public accounting firm of December
17, 2018
      included on page II-2 of your registration statement. Please revise so
that these report
      dates are consistent.
Signatures, page II-21

3.    We reissue prior comment 7. It remains unclear who is your controller or
principal
      accounting officer. Please identify your controller or principal
accounting officer and
      include their signature. See Instruction 1 to the Signatures to Form S-1.
       You may contact Steve Lo at 202-551-3394 or Linda Cvrkel at 202-551-3813
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Ruairi Regan at 202-551-3269 or Pam Howell at 202-551-3357 with any other
questions.



                                                            Sincerely,

FirstName LastNameChi Yuen Leong                            Division of
Corporation Finance
                                                            Office of
Beverages, Apparel and
Comapany NameBioNexus Gene Lab Coporation
                                                            Mining
March 4, 2019 Page 2
cc:       Daniel Luciano, Esq.
FirstName LastName