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                             May 6, 2024

       Su-Leng Tan Lee
       Chief Executive Officer and Acting Chief Financial Officer
       BioNexus Gene Lab Corp
       Unit 02, Level 10, Tower B, Avenue 3, The Vertical
       Business Suite II, Bangsar South
       8 Jalan Kerinchi
       Kuala Lumpur, Malaysia 59200

                                                        Re: BioNexus Gene Lab
Corp
                                                            Form 10-K filed
April 16, 2024
                                                            Form 10-Q/A filed
March 26, 2024
                                                            File No. 001-41750

       Dear Su-Leng Tan Lee:

              We have limited our review of your filings to the financial
statements and related
       disclosures 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.

       Form 10-K for the Fiscal Year Ended December 31, 2023

       Item 4. Controls and Procedures., page 36

   1.                                                   We note that you
concluded that your disclosure controls and procedures were effective as
                                                        of December 31, 2023.
In forming this conclusion, please tell us how you considered
                                                        the material weaknesses
you had as of December 31, 2022. In this regard, we note that (i)
                                                        your disclosure on page
37 indicates that during the year ended December 31, 2023 there
                                                        had been no change in
internal control over financial reporting and (ii) you disclosed in
                                                        each of your Form 10-Qs
filed during 2023 that no material changes in
                                                        your internal control
over reporting had occurred.
   2.                                                   We note management
conducted an assessment of the effectiveness of your internal
                                                        control over financial
reporting as of December 31, 2023. Please amend your filing to
                                                        provide their
conclusion on the effectiveness of your internal controls over financial
 Su-Leng Tan Lee
BioNexus Gene Lab Corp
May 6, 2024
Page 2
         reporting pursuant to Item 308(a)(3) of Regulation S-K. If you
concluded that your
         internal controls over financial reporting were effective, please
discuss the actions
         undertaken to remediate your prior material weaknesses. Note that any
revisions should
         include proper disclosures regarding changes in internal control over
financial reporting
         pursuant to Rule 308(c) of Regulation S-K.
Exhibit 31.1, page 1

3.       Please identify the certifying individual by name and remove their
title in the introductory
         line of the certification. Refer to Item 601(b)(31) of Regulation S-K.
Please address this
         comment as it relates to the certifications filed in connection with
your fiscal year 2023
         Form 10-Qs.
Form 10-Q/A for the Quarter Ended September 30, 2023

Item 4. Controls and Procedures, page 31

4.       We note that the Company   s management concluded, as of the end of
the period covered
         by this report, that the Company   s disclosure controls and
procedures were
            capable   . Please amend your filing to disclose management   s
conclusion regarding
         whether your disclosure control and procedures were effective or not
effective. If
         management concludes that the disclosure controls and procedures are
effective, please
         reference your prior material weaknesses in internal controls over
financial reporting and
         provide us with sufficient information to understand how you reached
your conclusion.
         If actions were undertaken to remediate the material weakness, such
remediation
         requires disclosures to address the changes in internal control over
financial reporting.
         Refer to Rule 308(c) of Regulation S-K. Address this comment as it
relates to your June
         30, 2023 and March 30, 2023 Form 10-Qs.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       Please contact Jeanne Baker at 202-551-3691 or Terence O'Brien at
202-551-3355 with
any questions.



                                                               Sincerely,
FirstName LastNameSu-Leng Tan Lee
                                                               Division of
Corporation Finance
Comapany NameBioNexus Gene Lab Corp
                                                               Office of
Industrial Applications and
May 6, 2024 Page 2                                             Services
FirstName LastName