August 7, 2018

Jesper Brandgaard
Executive Vice President and Chief Financial Officer
NOVO NORDISK A S
Novo Alle
DK-2880 Bagsvaerd
Denmark

       Re: NOVO NORDISK A S
           Form 20-F for the Fiscal year Ended December 31, 2017
           Filed February 8, 2018
           Form 6-K filed February 8, 2018
           File No. 333-82318

Dear Mr. Brandgaard:

        We have limited our review of your filings to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to the comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to the comment, we may have additional
comments.

Form 6-K filed February 8, 2018

Consolidated Financial Statements, page 58

1.    Please address the following regarding the line items that make up Total
equity on your
      Balance Sheet and Equity Statement:
        Tell us whether the amounts reported as Share capital represent only
the nominal or
         par share values.
        Tell us whether you present share premium in your line item titled
Retained earnings.
        Tell us how you considered paragraph 78(e) of IAS 1, which provides a
specific
         example showing the disaggregation of share capital into paid-in
capital and share
         premium, when establishing your equity line items.
 Jesper Brandgaard
NOVO NORDISK A S
August 7, 2018
Page 2

             To the extent you combine amounts contributed by shareholders with
cumulative
             historical earnings in your line item titled Retained earnings,
tell us how you
             determined that your presentation provides appropriate information
for the reader to
             effectively differentiate contributions by owners from accumulated
earnings.
             Similarly, tell us how you determined that such a presentation
allows readers to
             differentiate between dividends from accumulated earnings versus
dividends of
             shareholder contributions.
             Specifically address your consideration of paragraphs 30, 30A, and
55 of IAS 1 in
             your response.


       In closing, 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.

       You may contact Sasha Parikh at 202-551-3627 or Kevin Vaughn at
202-551-3494 with
any questions.



FirstName LastNameJesper Brandgaard                           Sincerely,
Comapany NameNOVO NORDISK A S
                                                              Division of
Corporation Finance
August 7, 2018 Page 2                                         Office of
Healthcare & Insurance
FirstName LastName