August 6, 2019

James J. Huang
Chief Investment Officer
Indonesia Energy Corporation Limited
Dea Tower I, 11th Floor, Suite 1103
Jl. Mega Kuningan Barat Kav. E4.3 No.1-2
Jakarta 12950, Indonesia

       Re: Indonesia Energy Corporation Limited
           Registration Statement on Form F-1
           Filed July 30, 2019
           File No. 333-232894

Dear Mr. Huang:

       We have reviewed your 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.

Form F-1

Risk Factors
Our business requires significant capital investment . . . , page 25

1.     Your response to prior comment 3 states that the $42.9 million you will
incur in future
       development costs will be financed initially with cash generated by your
operating
       activities in Kruh Block under the Technical Assistance Contract and
with part of the
       proceeds from your initial public offering. Additional financing will
come from the cash
       generated by your operating activities through the cost recovery system
from the Joint
       Operation Partnership (or KSO) in Kruh Block along with financial
support from your
       shareholders and other sources of financing. Please provide us with
additional
       information detailing the sources of capital you reasonably expect will
exist to finance the
 James J. Huang
FirstNameEnergy Corporation Huang
Indonesia LastNameJames J. Limited
Comapany2019
August 6, NameIndonesia Energy Corporation Limited
August 6, 2019 Page 2
Page 2
FirstName LastName
         development of your proved reserves. Your response should be specific
with regards to
         the sources of the full amount management believes will be necessary
to implement your
         development plan for the Kruh Block.
Use of Proceeds , page 43

2.       We note your revised disclosure on page F-29 indicating that you
intend to use part of the
         proceeds from the initial public offering for the development plan in
the Kruh Block.
         Please revise your use of proceeds section to provide the approximate
amount intended to
         be used for this purpose. Refer to Item 504 of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 54

3.       The revised disclosure provided in response to prior comment 4 states
that you expect to
         generate approximately $3.3 million in revenues from July 2019 to June
2020 to support
         your capital expenditures. Revise to provide additional context
regarding the existence
         and timing of commitments for capital expenditures and other
reasonably likely cash
         requirements during this period. See section IV of SEC Release No.
33-8350 for
         additional guidance.
Notes to Consolidated Financial Statements
Supplementary Information for Oil and Gas Producing Activities (Unaudited)
Proved Reserves the Company Expects to Lift in Kruh Block, page F-25

4.       We have read your response to comment 2. Provide us with your
development schedule
         indicating for each annual period the estimated additional capital
expenditures to reconcile
         the difference between the $27.0 million in future well costs and the
approximate $42.9
         million in total future development costs disclosed in the
standardized measure of
         discounted future net cash flows.
5.       We have read your response to comment 9 and note that the changes in
proved reserves
         related to the reserves added from the drilling program of 18 wells
following the extension
         of the Kruh Block operatorship are described as revisions of previous
estimates and that
         the reserves added from the extension of the operatorship of the Kruh
Block until May
         2030 are described as extensions and discoveries. These descriptions
do not appear to be
         consistent with the descriptions of such changes provided in FASB ASC
932-235-50-5(a)
         and 50-5(d), respectively. Revise your descriptions of changes as
necessary to align your
         disclosure with the change categories described in FASB ASC
932-235-50-5 or tell us
         why a revision is not necessary.
 James J. Huang
Indonesia Energy Corporation Limited
August 6, 2019
Page 3
Standardized Measure of Discounted Future Net Cash Flows Relating to Proved Oil
and Gas
Reserves, page F-28

6.       Your revised disclosure under this section indicates, in part, that
only approximately $10
         million out of the approximately $42.9 million in future development
costs is initially
         required to fund the development plan relating to the Kruh Block.
Explain to us, in
         reasonable detail, the basis for this statement. As part of your
response, explain how this
         disclosure is consistent with the disclosure on page F-26 which
indicates $13.5 million in
         future development costs in 2020, excluding the capital expenditures
for production
         facilities.
7.       Provide us with a breakdown of the costs for the items that are
included in the initial $10
         million figure, e.g. the costs to drill and complete wells, costs for
production equipment,
         facilities and related infrastructure, etc.
General

8.       We note your response to our prior comment 1. Please supplementally
provide us with
         copies of all supporting materials for the industry statistics you
cite in your registration
         statement.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        For questions regarding comments on engineering matters, you may
contact John
Hodgin, Petroleum Engineer, at (202) 551-3699. You may contact Jeannette Wong,
Staff
Accountant, at (202) 551-2137 or Ethan Horowitz, Accounting Branch Chief, at
(202) 551-3311
if you have questions regarding comments on the financial statements and
related matters.
Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or, in
her absence,
Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any other
questions.



FirstName LastNameJames J. Huang                                 Sincerely,
Comapany NameIndonesia Energy Corporation Limited
                                                                 Division of
Corporation Finance
August 6, 2019 Page 3                                            Office of
Natural Resources
FirstName LastName