August 25, 2025

Ron Bain
Chief Financial Officer
VAALCO Energy, Inc.
2500 CityWest Blvd., Suite 400
Houston, Texas 77042

       Re: VAALCO Energy, Inc.
           Form 10-K for the Fiscal Year ended December 31, 2024
           Filed March 17, 2025
           File No. 001-32167
Dear Ron Bain:

       We have reviewed your August 15, 2025 response to our comment letter and
have the
following comment.

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.
Unless we note otherwise, any references to prior comments are to comments in
our July 18,
2025 letter.

Form 10-K for the Fiscal Year ended December 31, 2024
General

1.     We note that in your responses to prior comments 1, 4, 5 and 6, you
identify various
       inadvertent errors in disclosures relating to the reconciliation of
total proved reserves,
       and the reconciliation of the standardized measure for the years ending
December 31,
       2024 and 2023. You indicate that while you consider the errors to be
immaterial, you
       will nevertheless "clarify disclosures in future filings," which we
understand to mean
       that you will correct the disclosures in your next annual report on Form
10-K.

       Please confirm that we have properly understood your intentions in this
regard, i.e.
       that you will prospectively revise the reconciliations showing the
changes in total
       proved reserves and the standardized measure to correct the errors
identified in your
       response letter, including the changes to total proved reserves and the
standardized
 August 25, 2025
Page 2

       measure for the year ended December 31, 2023.


       Please contact John Hodgin at 202-551-3699 if you have questions
regarding the
engineering comment. Please contact Karl Hiller, Branch Chief, at 202-551-3686
with any
other questions.



                                                         Sincerely,

                                                         Division of
Corporation Finance
                                                         Office of Energy &
Transportation