November 22, 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.
           Registration Statement on Form F-1
           Filed November 13, 2019
           File No. 333-234666

Dear Dr. Ye:

       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 filed November 13, 2019

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Components of Results of Operations
Operating Expenses, page 86

1.     Please revise to include a narrative description and a discussion of
significant fluctuations
       for all material components of your cost of revenue, research and
development (R&D),
       sales and marketing (S&M) and general and administrative (G&A) expenses.
For
       example, with respect to cost of revenue, please include a description
of technology
       service fee expense and business origination fee expense, and address
the fluctuations in
       these amounts from period-to-period. Similarly, disclose quantitative
information and a
 Wangchun Ye
FirstName LastNameWangchun YeCo., Ltd.
OneConnect Financial Technology
Comapany 22, 2019
November NameOneConnect Financial Technology Co., Ltd.
Page 2
November 22, 2019 Page 2
FirstName LastName
         discussion of trends in each component of R&D, S&M and G&A expenses,
as
         appropriate. In addition, we note from your disclosure on page 132
that you also earn
         revenue from business origination services. Please revise to clarify
what constitutes
         business origination services revenue versus expense, how these relate
and how you
         account for these transactions.
Business
Our Solutions
Blockchain network-as-a-service, page 139

2.       We note that you have moved the discussion of your blockchain
network-as-a-service
         solution from the section discussing your yet-to-be launched solutions
to the section
         discussing your current solutions. Please revise to disclose whether
you have customers
         currently using this solution and whether you have generated any
revenue from it at this
         time.
Description of American Depositary Shares
Governing Law, page 205

3.       We note that claims against or involving the depositary brought by ADR
holders or
         beneficial owners and arising out of or based upon the deposit
agreement may only be
         instituted in a state or federal court in New York, New York. Please
disclose whether this
         provision applies to actions arising under the Securities Act or
Exchange Act. If so,
         please also add related risk factor disclosure.
4.       We note that the depositary is entitled to refer any dispute for final
settlement by
         arbitration in accordance with the Commercial Arbitration Rules of the
American
         Arbitration Association. Please disclose whether this arbitration
provision applies to
         claims under the federal securities laws and whether arbitration is
the exclusive means of
         resolving disputes. Please revise to disclose the materials risks to
and other impacts on
         shareholders associated with this provision.
        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.
 Wangchun Ye
OneConnect Financial Technology Co., Ltd.
November 22, 2019
Page 3

        You may contact Brittany Ebbertt, Senior Staff Accountant, at (202)
551-3572 or Craig
Wilson, Senior Advisor, 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,
FirstName LastNameWangchun Ye
                                                    Division of Corporation
Finance
Comapany NameOneConnect Financial Technology Co., Ltd.
                                                    Office of Technology
November 22, 2019 Page 3
cc:       Shuang Zhao, Esq.
FirstName LastName