111 Huntington Avenue, Boston, Massachusetts 02199

617-954-5000

April 15, 2024

VIA EDGAR

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:MFS^® Active Exchange Traded Funds Trust (the “Trust”), on behalf of MFS^® Active Core Plus Bond ETF, MFS^® Active Growth ETF, MFS^® Active International ETF, MFS^® Active Intermediate Muni Bond ETF, and MFS^® Active Value ETF (the “Funds”); Initial Registration Statement on Form N-1A

Ladies and Gentlemen:

Enclosed herewith for filing pursuant to (1) the Securities Act of 1933, as amended, (2) the Investment Company Act of 1940, as amended, and (3) Regulation S-T, including Inline XBRL, please find an initial Registration Statement of the Trust on Form N-1A (the “Registration Statement”).

The Registration Statement is being filed for the purpose of registering shares of the Funds, each a series of the Trust (a newly created Massachusetts business trust).

Please note that the references "TBU" and/or "report does not exist" that appear in the Registration Statement will be replaced with the appropriate required information in a future amendment to the Registration Statement.

If you have any questions concerning the foregoing, please call the undersigned at 617-954-5843 or Allison Frebowitz at 617-954-5115.

Sincerely,

BRIAN E. LANGENFELD

Brian E. Langenfeld

Vice President and Managing Counsel