September 16, 2019

Wangchun Ye
Chairman and Chief Executive Officer
OneConnect Financial Technology Co., Ltd.
55F, Ping An Financial Center
No 5033 Yitian Road, Futian District
Shenzhen, Guangdong
People's Republic of China

       Re: OneConnect Financial Technology Co., Ltd.
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted August 26, 2019
           CIK No. 0001780531

Dear Dr. Ye:

      We have reviewed your amended draft 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. Unless we note otherwise, our references
to prior
comments are to comments in our August 9, 2019 letter.

       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.

Amendment No. 1 to Draft Registration Statement on Form F-1

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Operating Metrics, page 78

1.     We note your response to prior comment 5. Assuming that you have now
disclosed all
       key operating metrics that you regularly review, please revise your
disclosure at the top of
       this page to clarify this point. In this regard, your current disclosure
seems to imply there
       are other key operating metrics that you regularly review; some of which
you have
       disclosed here and some of which you have not disclosed.
 Wangchun Ye
FirstName LastNameWangchun YeCo., Ltd.
OneConnect Financial Technology
Comapany 16, 2019
September NameOneConnect Financial Technology Co., Ltd.
September 16, 2019 Page 2
Page 2
FirstName LastName
2.       We note your response to prior comment 5 and the related revised
disclosure
         regarding revenue per premium customer. Please further revise to
clarify why the
         substantial increase in number of new premium customers did not drive
a similarly
         substantial increase in premium customer revenue. With respect to this
point, please
         explain and disclose whether new premium customers tend to purchase
lower priced
         products, a fewer number of products, etc. that would explain why
revenue did not
         increase accordingly.
3.       We note your response and revised disclosure to prior comment 6.
Please tell us whether
         you are aware of any other legal entities that fall under the same
corporate group and are
         considered one consolidated customer. If so, please revise to disclose
this information for
         each such customer. Further, please revise to disclose your definition
of a customer,
         specifically addressing how you treat legal entities that are
consolidated by one corporate
         group as one customer.
4.       We note your response and revised disclosure to prior comment 8.
Please revise to clarify
         whether the total number of customers presented represents both
premium and basic
         customers combined, or whether this represents only basic customers.
If the former,
         please revise footnote 2 to disclose the information provided in your
response letter
         regarding how and when you evaluate premium customer count (i.e.,
annually). If the
         latter, please further revise to present revenue from premium and
basic customers on
         separate line items and clarify this information in separate footnotes
to the table.
5.       We note your response to prior comment 11 regarding the net expansion
rate for 2017.
         However, it appears that additional information is necessary to
understand the extent to
         which the rate changed from the prior period. Please revise to
disclose the net expansion
         rate for 2017 to provide appropriate context regarding a key operating
metric that you
         have presented.
6.       We note your response to prior comment 12. Please revise to provide
this information in
         your disclosure to explain why you review this metric only for premium
customers. In
         this regard, please clarify that you do not review net expansion rate
for Ping An Group
         but, rather, you review year-on-year revenue as an indicator of
growth. Also, clarify why
         you do not look at net expansion rate for basic customers, as a
significant majority are
         non-paying and the ratio would be misleading. Finally, revise the
first paragraph of your
         disclosure to clarify that you use this metric to evaluate premium
customer acquisition,
         retention and expansion.
Liquidity and Capital Resources, page 90

7.       Please refer to prior comment 14 and disclose the identities of the
other three banks with
         which you have credit facility agreements. We note that you have a
revolving credit of
         $349.6 million with one of these banks, of which you have drawn down
$174.7
         million which represents 15% of your total assets as of June 30, 2019.
 Wangchun Ye
OneConnect Financial Technology Co., Ltd.
September 16, 2019
Page 3
Principal [and Selling] Shareholders, page 164

8.       Please refer to prior comment 17 and disclose the names of members of
the RC
         Management Committee, including the employees of Ping An Group and its
subsidiaries.
         Given that these committee members are employees of an affiliate of
the company, it
         appears that disclosure should be provided regarding their identity
and the nature of any
         material relationships with the company or with the affiliate. For
additional guidance,
         refer to Question 140.02 of our Regulation S-K Compliance and
Disclosure
         Interpretations.
Description of Share Capital
History of Securities Issuances
Ordinary Shares, page 177

9.       You disclose that View Foundation's selling shareholder has agreed to
apply RMB66.6
         million from the proceeds of the consideration you pay to acquire View
Foundation to
         subscribe for a certain number of your ordinary shares. Please tell us
the timing of the
         acquisition. Clarify whether the selling shareholder intends to
participate in this registered
         offering or whether you are issuing the shares concurrently pursuant
to an exemption from
         registration. Revise to identify the selling shareholders and any
other conditions to
         closing.
Consolidated Statements of Comprehensive Income, page F-3

10.    We note your response to prior comment 20. We also note, as disclosed in
note 2.8, that
       you have determined the useful lives of your intangible assets,
including application and
       platform assets (3 years) and purchased software assets (2-5 years).
Guidance in IAS
       38.88-93 requires determination of both how the asset will be used and
consumed, as well
       as the period of benefit. Given this requirement, it is unclear from
your response why you
       are unable to reliably determine the portion of your intangible assets'
utility that was
       consumed related to cost of revenue versus research and development. We
further note
       that your current income statement presentation of functional expenses
that excludes
       amortization of intangible assets results in the presentation of
functional expense income
       statement line items that are incomplete, and it appears that your
current presentation does
       not provide investors any insight into the total cost you incurred to
generate revenue or the
       amount incurred for other functional activities, such as research and
development.
FirstName LastNameWangchun Ye financial statement presentation to report line
items
       Accordingly, please revise your
Comapany NameOneConnect Financial Technology Co., Ltd. are complete or further
advise.
       comprised of functional expenses of a similar nature that
September 16, 2019 1 paragraphs 15, 29, 85, 85A, 99, and 103.
       Refer to IAS Page 3
FirstName LastName
 Wangchun Ye
FirstName LastNameWangchun YeCo., Ltd.
OneConnect Financial Technology
Comapany 16, 2019
September NameOneConnect Financial Technology Co., Ltd.
Page 4
September 16, 2019 Page 4
FirstName LastName
       You may contact Brittany Ebbertt, Senior Staff Accountant, at (202)
551-3572 or Craig
Wilson, Senior Assistant Chief Accountant, at (202) 551-3226 if you have
questions regarding
comments on the financial statements and related matters. Please contact
Mitchell Austin, Staff
Attorney, at (202) 551-3574 or Jan Woo, Legal Branch Chief, at (202) 551-3453
with any other
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of
Information Technologies
                                                           and Services
cc:      Shuang Zhao, Esq.