February 27, 2019

Jeremy Hodara
Co-Chief Executive Officer
Jumia Technologies AG
Charlottenstra e 4
10969 Berlin, Germany

       Re: Jumia Technologies AG
           Amendments No. 1 and 2
           Draft Registration Statement on Form F-1
           Submitted January 31 and February 12, 2019
           CIK No. 0001756708

Dear Mr. Hodara:

      We have reviewed your amended draft registration statements 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form F-1 Amendment No. 2, Submitted February
12, 2019

Prospectus Summary, page 1

1.     We note your response to comment 3. If you will be a controlled company
after this
       offering, please disclose that fact in this section and include
appropriate risk factor
       disclosure.
 Jeremy Hodara
FirstName LastNameJeremy Hodara
Jumia Technologies AG
Comapany NameJumia Technologies AG
February 27, 2019
February 27, 2019 Page 2
Page 2
FirstName LastName
Summary Consolidated Financial and Operating Data
Consolidated Statement of Profit or Loss, page 14

2.       The amount presented for Revenue in U.S. Dollars does not appear to be
correct based on
         an exchange rate of E1.00 to U.S. $1.1456. Please revise as
appropriate or tell us why you
         believe no such revision is required.
Dilution, page 71

3.       Please revise to disclose your historical net tangible book value as
of December 31, 2018
         on an aggregate basis and per ordinary share. As it appears this
information is currently
         available it should be populated in the next amendment.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview, page 75

4.       We note your response to comment 7 and your disclosure on page 86 that
"an increase in
         gross profit was more than offset by higher fulfillment expense and
adjusted general and
         administrative expense." In an appropriate place in this section
please revise your
         disclosure to provide investors with an analysis of your losses so
that they can determine
         whether the losses will continue or are related to one-time events. In
this regard, your
         discussion should address those key variable and other qualitative and
quantitative factors
         that are necessary for an understanding and evaluation of trends
relating to your
         operations, including your losses.
Critical Accounting Estimates and Judgments, page 87

5.       We note from your response to comment 10 that you do not consider your
revenue
         recognition accounting policies to be a critical accounting policy.
However, we note you
         adopted IFRS 15, Revenue from Contracts with Customers effective
January 1, 2018. In
         addition, you disclose in Note 3 on page F-19 that you applied certain
significant
         judgments in applying the new standard. In light of your disclosure,
please tell us why
         you believe the application of IFRS 15 did not involve any significant
estimates or
         judgments that may represent critical accounting policies for which
disclosure is required.
6.       Once you have an estimated offering price or price range for shares to
be issued in this
         offering, please explain to us in detail how you determined the fair
value of the common
         stock underlying your equity issuances and disclose the reasons for
any disparity between
         the valuations of your common stock in the twelve month period leading
up to the initial
         public offering and the estimated offering price.
 Jeremy Hodara
FirstName LastNameJeremy Hodara
Jumia Technologies AG
Comapany NameJumia Technologies AG
February 27, 2019
February 27, 2019 Page 3
Page 3
FirstName LastName
Business
Jumia Logistics, page 106

7.       We note your disclosure in the first paragraph on page 107 that for
the nine months ended
         September 30, 2018 about a third of your packages were delivered to
rural cities and about
         a fifth to secondary cities. Please update to provide this information
for the year ended
         December 31, 2018 or tell us why you believe no such revision is
necessary.
Share-Based Incentive Plans, page 130

8.       We note your disclosure that you exchanged call options issued to
approximately 200
         participants under your 2016 Plan against call options in your 2019
Plan during 2019.
         Please tell us and disclose how you plan to account for the exchange
of these options
         under IFRS.
Consolidated Financial Statements
Consolidated Statement of Comprehensive Income for the Years Ended December 31,
2018 and
2017, page F-4

9.       We note that you have net losses for the years ended December 31, 2018
and 2017. Thus
         it appears you should retitle your statements of comprehensive income
to be statements of
         operations and comprehensive income (loss). Please revise or tell us
why you believe no
         revision is necessary.
Consolidated Statement of Cash Flows For the Years Ended December 31, 2018 and
2017, page
F-6

10.      We note that you classified E350 thousand of cash flows related to the
buyback of non-
         controlling interests within investing activities in your statement of
cash flows. Based on
         the guidance in paragraph 17 of IAS 7 it appears that cash used to
buyback non-
         controlling interests should be classified within financing activities
on the statement of
         cash flows. Please revise or tell us why you believe no such revision
is necessary.
Note 2.f) Financial instruments   initial recognition and subsequent
measurement, page F-9

11.      We note your disclosure that you applied IFRS 9 prospectively, with an
original
         application date of 1/1/2018. However, paragraph 7.2 provides that
IFRS 9 should be
         adopted retrospectively. Please explain how and why you determined
that prospective
         adoption of this standard was appropriate and in accordance with IFRS
9.
Note 5. Material partly-owned subsidiaries, page F-23

12.      We note your disclosure that the equity interest held by the
non-controlling interests
         declined in 2018 primarily as a result of the roll-up of
participations in subsidiaries from
         the previous share-based compensation plan to participations in the
holding entity (Jumia
         UG & Co.) which was legally executed during 2018. In order to assist
us in
 Jeremy Hodara
Jumia Technologies AG
February 27, 2019
Page 4
      understanding this disclosure, please explain these roll-up transactions.
In this regard,
      a diagram may help facilitate analysis. Please also tell us how these
roll-up transactions
      are reflected in your disclosures in Note 13 Share-based compensation on
pages F-30
      through F-33. We may have further comment.
        You may contact Sondra Snyder, Staff Accountant at 202-551-3332 or Jim
Allegretto,
Senior Assistant Chief Accountant at 202-551-3849 if you have questions
regarding comments
on the financial statements and related matters. Please contact Scott M.
Anderegg, Staff
Attorney at 202-551-3342 or Lilyanna Peyser, Special Counsel at 202-551-3222
with any other
questions.



                                                            Sincerely,
FirstName LastNameJeremy Hodara
                                                            Division of
Corporation Finance
Comapany NameJumia Technologies AG
                                                            Office of Consumer
Products
February 27, 2019 Page 4
cc:       Krystian Czerniecki
FirstName LastName