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                            October 24, 2023

       Kevin Cox
       Chief Executive Officer
       Energys Group Limited
       Franklyn House, Daux Road
       Billingshurst, West Sussex
       RH149SJ
       United Kingdom

                                                        Re: Energys Group
Limited
                                                            Amendment No. 3 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted October
11, 2023
                                                            CIK No. 0001971828

       Dear Kevin Cox:

            We have reviewed your amended draft registration statement and have
the following
       comments.

              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 a comment applies 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 this
letter and your amended
       draft registration statement or filed registration statement, we may
have additional comments.

       Amended Draft Registration Statement on Form F-1 submitted October 11,
2023

       Risk Factors, page 11

   1.                                                   As previously requested
in comment 3, please clearly disclose throughout the prospectus
                                                        that the legal and
operational risks associated with operating in China also apply to
                                                        operations in Hong
Kong, and remove disclosure that is inconsistent with this statement,
                                                        such as in the risk
factors on page 28 regarding the enactment of the law of the PRC on
                                                        Safeguarding National
Security in the Hong Kong Special Administrative Region and the
                                                        limitations on legal
protections in Hong Kong.
 Kevin Cox
FirstName LastNameKevin Cox
Energys Group  Limited
Comapany
October 24,NameEnergys
            2023       Group Limited
October
Page 2 24, 2023 Page 2
FirstName LastName
Bank Borrowings, page 43

2.       We acknowledge your response to comment 6. Please revise your
disclosure to clarify, as
         applicable, (i) that the shareholder guarantor of your credit
facilities is Tom Ko Yuen Lau
         and (ii) the relationship of that shareholder guarantor to your
company, since we note that
         he is currently described in your prospectus as a former shareholder
of Sky Shadow
         Limited. Please also revise to describe any conflicts of interest
arising from these
         guarantees.
3.       Please clearly disclose the current interest rate as of the most
recent date for the loans
         discussed in this section, for those loans where you have not
disclosed a fixed rate but
         instead refer to the applicable current rate, a percentage added to
prime, etc. Please also
         disclose the duration of the DBS Bank Banking Facility, the Standard
Chartered Bank
         (Hong Kong) Limited loan, the China Citic Bank International Limited
Facility Letter,
         and the GAI Facility.
4.       The Standard Chartered Bank (Hong Kong) Limited loan facility filed as
Exhibit 10.15
         and your accompanying disclosure on page 45 of your prospectus is
missing the material
         terms of the agreement (e.g., loan amount, maturity). Similarly, the
8% Promissory Notes
         filed as Exhibit 4.2 are missing their material terms as they have
been filed as a "form of"
         promissory note. Please provide the executed versions of these
agreements and ensure
         your prospectus disclosure provides a description of their material
terms.
Index to Consolidated Financial Statements, page F-1

5.       Please update your financial statements and corresponding financial
information
         throughout the filing to comply with Item 8.A.4 of Form 20-F pursuant
to the
         requirements outlined within Item 4 of Form F-1.
       Please contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at
202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Isabel Rivera at 202-551-3518 or Pam Howell at 202-551-3357 with any
other questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Real
Estate & Construction
cc:      Celia Velletri