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                             December 4, 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. 4 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted November
20, 2023
                                                            CIK No. 0001971828

       Dear Kevin Cox:

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

              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 the 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.

       Amendment No. 4 to Draft Registration Statement on Form F-1 submitted
November 20, 2023

       Experts, page 129

   1.                                                   Please revise to
disclose that the financial statements included in your prospectus have
                                                        been audited by WWC,
PC, an independent registered public accounting firm, as of and
                                                        for the years ended
June 30, 2023 and 2022.
              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.
 Kevin Cox
Energys Group Limited
December 4, 2023
Page 2



                                     Sincerely,
FirstName LastNameKevin Cox
                                     Division of Corporation Finance
Comapany NameEnergys Group Limited
                                     Office of Real Estate & Construction
December 4, 2023 Page 2
cc:       Celia Velletri
FirstName LastName