December 9, 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 Registration Statement on Form F-1
           Filed December 2, 2019
           File No. 333-234666

Dear Dr. Ye:

      We have reviewed your amended 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. Unless
we note
otherwise, our references to prior comments are to comments in our [Month day,
year] letter.

Amendment No. 1 to Form F-1 filed December 2, 2019

Dilution, page 67

1.     Please provide us with a reconciliation between net tangible book value
and your interim
       condensed consolidated balance sheet on F-92. To this extent, it appears
you are including
       ordinary shares issued in November 2019 in the calculation of your net
tangible book
       value as of September 30, 2019. Please revise to include these shares,
and related
       proceeds and expenses, in your calculation of as-adjusted net tangible
book value as they
       are disclosed in item (ii) in the table here as being reflected within
that calculation and
       because they were issued subsequent to the September 30 period end and
should not be
 Wangchun Ye
OneConnect Financial Technology Co., Ltd.
December 9, 2019
Page 2
       included. Please advise or revise.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies, Judgments, and Estimates
Revenue Recognition, page 108

2.     We note from your revised disclosure on page 110 that you act as the
principal in your
       business origination services transactions and record revenue and
expense on a gross
       basis. Please tell us how your accounting complies with IFRS 15,
paragraphs B34 to
       B37, to support your determination as principal for each of the elements
comprising the
       business origination services noted on page 110, i.e. financial
institution customer
       leads, design of marketing plans, and sourcing leads from channel
partners. Revise the
       business origination service revenue accounting policy disclosures in
your notes to the
       financial statements to address this principal relationship since this
is a significant policy
       disclosure matter.
        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
December 9, 2019 Page 2
cc:       Shuang Zhao, Esq.
FirstName LastName