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                            April 7, 2022

       Xiaoming Hu
       President and Chief Executive Officer
       Kandi Technologies Group, Inc.
       Jinhua New Energy Vehicle Town
       Jinhua, Zhejiang Province
       People's Republic of China
       Post Code 321016

                                                        Re: Kandi Technologies
Group, Inc.
                                                            Form 10-K for the
Year Ended December 31, 2021
                                                            Filed March 15,
2022
                                                            File No. 001-33997

       Dear Mr. Hu:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments 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
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for the Year Ended December 31, 2021

       Part I, page 1

   1.                                                   We note your disclosure
on page 8 that Kandi New Energy was a VIE prior to March 14,
                                                        2022. Accordingly,
please revise your definitions on page 1 to clearly disclose how you
                                                        will refer to the
holding company, subsidiaries, and VIEs when providing the disclosure
                                                        throughout the document
so that it is clear to investors which entity the disclosure is
                                                        referencing and which
subsidiaries or entities are conducting the business
                                                        operations. Refrain
from using terms such as "we" or "our" when describing activities or
                                                        functions of a VIE. For
example, disclose, if true, that your subsidiaries and/or the VIE
                                                        conduct operations in
China, that the VIE is consolidated for accounting purposes but is
                                                        not an entity in which
you owned equity prior to March 14, 2022, that these contracts have
                                                        not been tested in
court, and that the holding company does not conduct operations.
 Xiaoming Hu
FirstName   LastNameXiaoming
Kandi Technologies    Group, Inc.Hu
Comapany
April       NameKandi Technologies Group, Inc.
       7, 2022
April 27, 2022 Page 2
Page
FirstName LastName
         Disclose clearly the entity (including the domicile) in which
investors are purchasing an
         interest. Define the term "PRC operating entities" that is used
starting on page 11.
Item 1
Business Introduction, page 2

2.       We note your disclosure that you are a Delaware holding company with
operations
         conducted by your subsidiaries based in China. Please additionally
disclose that you are
         not a Chinese operating company and that this structure involves
unique risks to
         investors. Provide a cross-reference to you detailed discussion of
risks facing the
         company as a result of this structure.
3.       We note your prominent disclosure about the legal and operational
risks associated with
         being based in or having the majority of the company   s operations in
China on page 2.
         Please revise your disclosure to make clear whether these risks could
result in a material
         change in the value of your securities or cause the value of your
securities to significantly
         decline or be worthless. Your risk factors section should address, but
not necessarily be
         limited to, the risks highlighted in this section.
4.       Disclose each permission or approval that you or your subsidiaries are
required to obtain
         from Chinese authorities to operate your business and to offer
securities to foreign
         investors. State whether you or your subsidiaries are covered by
permissions
         requirements from the China Securities Regulatory Commission,
Cyberspace
         Administration of China (CAC), or any other governmental agency that
is required to
         approve your or your subsidiaries    operations, and state
affirmatively whether you have
         received all requisite permissions or approvals and whether any
permissions or approvals
         have been denied. Please also describe the consequences to you and
your investors if you
         or your subsidiaries: (i) do not receive or maintain such permissions
or approvals, (ii)
         inadvertently conclude that such permissions or approvals are not
required, or (iii)
         applicable laws, regulations, or interpretations change and you are
required to obtain such
         permissions or approvals in the future.
5.       Provide a clear description of how cash is transferred through your
organization. Disclose
         your intentions to distribute earnings or settle amounts owed under
applicable
         agreements. State whether any transfers, dividends, or distributions
have been made to
         date between the holding company, its subsidiaries, and consolidated
VIEs, or to
         investors, and quantify the amounts where applicable. Quantify any
cash flows and
         transfers of other assets by type that have occurred between the
holding company, its
         subsidiaries, and the consolidated VIEs, and direction of transfer.
Quantify any dividends
         or distributions that a subsidiary or consolidated VIE has made to the
holding company
         and which entity made such transfer, and their tax consequences.
Similarly quantify
         dividends or distributions made to U.S. investors, the source, and
their tax consequences.
         Your disclosure should make clear if no transfers, dividends, or
distributions have been
         made to date. Describe any restrictions on foreign exchange and your
ability to transfer
         cash between entities, across borders, and to U.S. investors. Describe
any restrictions and
 Xiaoming Hu
FirstName   LastNameXiaoming
Kandi Technologies    Group, Inc.Hu
Comapany
April       NameKandi Technologies Group, Inc.
       7, 2022
April 37, 2022 Page 3
Page
FirstName LastName
         limitations on your ability to distribute earnings from the company,
including your
         subsidiaries, to the parent company and U.S. investors as well as the
ability to settle
         amounts owed under applicable agreements. Provide cross-references to
the condensed
         consolidating schedule and the consolidated financial statements.
6.       Please disclose whether your auditor is subject to the determinations
announced by the
         PCAOB on December 16, 2021, and whether and how the Holding Foreign
Companies
         Accountable Act (HFCAA) and related regulations will affect your
company. Disclose
         that trading in your securities may be prohibited under the HFCAA if
the PCAOB
         determines that it cannot inspect or investigate completely your
auditor, and that as a
         result an exchange may determine to delist your securities.
7.       We note your response to our prior comments 2 and 3. Please further
revise your
         disclosure to address the following:

                Clearly state, if true, that you have not yet produced and sold
your K23 and K27
              electric vehicles (other than the low-speed "neighborhood"
version) in any markets.

                Update the disclosure that you expect to make the first U.S.
deliveries of the UTV
              K32 in the late first quarter of 2022, since the quarter has now
ended.         Disclose
              whether the UTV K32 has been or will be sold in markets other
than the United
              States and the expected obstacles and timetable.

                Clarify your "home market" for purposes of discussing imports
and exports, taking
              into account that the registrant is a U.S. entity. For example,
the following
              sentence is difficult to understand and should be revised for
clarity: "There are two
              major sales modes of our export products: the first mode is
indirect sales to domestic
              import and export companies for external sales, and the second is
direct sales to
              foreign importers."

                Correct the reference to the year 2028 on page 4.
8.       We note several recent developments, including (i) Zhejiang Kandi
Technologies'
         agreement to acquire 100% of Jiangxi Huiyi, (ii) the joint venture
between Kandi Hainan
         and Jiangsu Xingchi to establish Hainan Kandi Holding New Energy
Technology, and (iii)
         the framework agreement with Hunan Hengrun Automobile to jointly
produce battery-
         swappable electric vehicles. Please describe the material terms of
these agreements in
         your business section and file these agreements as exhibits to the
Form 10-K.
Item 1
Business Introduction
Selected Condensed Consolidated Financial Schedule, page 8

9.       Please revise your schedules to directly reflect the intercompany
activities and balances
         related to the VIE Agreement(s) in your consolidating schedules and
present
 Xiaoming Hu
FirstName   LastNameXiaoming
Kandi Technologies    Group, Inc.Hu
Comapany
April       NameKandi Technologies Group, Inc.
       7, 2022
April 47, 2022 Page 4
Page
FirstName LastName
         intercompany activities, balances for receivables and payables, and
cash flows in separate
         lines for each entity. Additionally, footnote significant activities
within the schedules to
         assist investors in understanding the relationships and transactions
from your historical
         contractual arrangement(s).
Item 1A
Risk Factors, page 11

10.      In your summary of risk factors, disclose the risks that your
corporate structure and being
         based in or having the majority of the company   s operations in China
poses to investors.
         In particular, describe the significant regulatory, liquidity, and
enforcement risks with
         cross-references to the more detailed discussion of these risks in the
risk factors section.
         For example, specifically discuss risks arising from the legal system
in China, including
         risks and uncertainties regarding the enforcement of laws and that
rules and regulations in
         China can change quickly with little advance notice; and the risk that
the Chinese
         government may intervene or influence your operations at any time, or
may exert more
         control over offerings conducted overseas and/or foreign investment in
China-based
         issuers, which could result in a material change in your operations
and/or the value of
         your securities. Acknowledge any risks that any actions by the Chinese
government to
         exert more oversight and control over offerings that are conducted
overseas and/or foreign
         investment in China-based issuers could significantly limit or
completely hinder your
         ability to offer or continue to offer securities to investors and
cause the value of such
         securities to significantly decline or be worthless.
11.      We note your disclosure about the HFCAA. Please expand your risk
factors to disclose
         that the United States Senate has passed the Accelerating Holding
Foreign Companies
         Accountable Act, which, if enacted, would decrease the number of
"non-inspection
         years" from three years to two years, and thus, would reduce the time
before your
         securities may be prohibited from trading or delisted. Update your
disclosure to reflect
         that the Commission adopted rules to implement the HFCAA and that,
pursuant to the
         HFCAA, the PCAOB has issued its report notifying the Commission of its
determination
         that it is unable to inspect or investigate completely accounting
firms headquartered in
         mainland China or Hong Kong.
12.      In light of recent events indicating greater oversight by the CAC over
data security,
         particularly for companies seeking to list on a foreign exchange,
please revise your
         disclosure on pages 19-20 to explain how this oversight impacts your
business and your
         ability to offer securities to investors and to what extent you
believe that you are
         compliant with the regulations or policies that have been issued by
the CAC to date.
Item 2
Properties, page 27

13.      Please revise your disclosure to clearly describe the status of your
Haikou City factory,
         reconciling the apparent inconsistency between disclosure in this
section ("project
 Xiaoming Hu
Kandi Technologies Group, Inc.
April 7, 2022
Page 5
         completion acceptance is being processed") and disclosure on page F-22
which appears to
         indicate that the Hainan factory is currently manufacturing EV
products. Clearly
         distinguish between the current and expected production capacity at
each of your
         factories, and identify the "EV products" each manufactures.
Item 13
Certain Relationships and Related Transactions and Director Independence, page
49

14.      We note that your Chief Executive Officer, Hu Xiaoming, transferred
his 50% equity
         interests of Kandi New Energy to Zhejiang Kandi Technologies. Please
describe the
         material terms of this transaction, and any other related party
transactions, in this section.
         Refer to Item 404 of Regulation S-K.
Note 1 - Organization and Principal Activities, page F-10

15.      We note your disclosure that pursuant to certain VIE agreements signed
by Zhejiang
         Kandi Technologies and Mr. Hu Xiaoming, from January 2011 to March 13,
2022,
         Zhejiang Kandi Technologies is entitled to 100 % of the economic
benefits, voting rights
         and residual interests (100 % of profits and losses) of Jinhua Kandi
New Energy Vehicles
         Co., Ltd. Please revise your disclosures to describe the specific
terms and quantify
         amounts you were entitled to or liable for as part of your previous
contractual
         arrangement(s).
Notes to Consolidated Financial Statements
Note 6 - Summary of Significant Accounting Policies
(v) Consolidation of variable interest entities, page F-19

16.      Please revise to include disclosures required by ASC 810-10-50-3
regarding your variable
         interest entity for the reported periods. At a minimum, ensure that
you disclose the
         carrying amount and classification of the VIE   s assets and
liabilities included in the
         consolidated financial statements, as well as qualitative information
about the
         relationship(s) between those assets and liabilities.
General
FirstName LastNameXiaoming Hu
17.    We note that Dong Xueqin is your director as of December 2021. Please
update the table
Comapany    NameKandi
       of beneficial    Technologies
                     ownership        Group,
                               and other      Inc. as appropriate, such as
director independence
                                         sections
April 7,and compensation,
         2022 Page 5      to include information for this new director.
FirstName LastName
 Xiaoming Hu
FirstName   LastNameXiaoming
Kandi Technologies    Group, Inc.Hu
Comapany
April       NameKandi Technologies Group, Inc.
       7, 2022
April 67, 2022 Page 6
Page
FirstName LastName
        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 Melissa Gilmore at 202-551-3777 or Martin James at
202-551-3671 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Jennifer Angelini at 202-551-3047 or Jay Ingram at 202-551-3397 with
any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing
cc:      Elizabeth F. Chen