July 8, 2019

Zhou Pengwu
Chief Executive Officer
Aesthetic Medical International Holdings Group Ltd.
1122 Nanshan Boulevard
Nanshan District, Shenzhen
Guangdong Province, China 518052

       Re: Aesthetic Medical International Holdings Group Ltd.
           Amendment No. 1 to
           Draft Registration Statement on Form F-1
           Submitted May 30, 2019
           CIK No. 0001757143

Dear Dr. Pengwu:

       We have reviewed your amended draft registration statement 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 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 our comments apply 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 comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Amendment No. 2 to Draft Registration Statement on Form F-1

Recent developments, page 7

1.     We note your disclosure of estimated preliminary results for the three
months ended
       March 31, 2019, and specifically, your reference to revenue growth.
Please revise
       these recent development disclosures to include a balanced discussion of
both revenues
       and a measure of income, such as net income/loss.

        You may contact Charles Eastman, Staff Accountant, at (202) 551-3794 or
Robert S.
Littlepage, Accountant Branch Chief, at (202) 551-3361 if you have questions
regarding
 Zhou Pengwu
Aesthetic Medical International Holdings Group Ltd.
July 8, 2019
Page 2

comments on the financial statements and related matters. Please contact Joshua
Shainess,
Attorney-Adviser, at (202) 551-7951 or Celeste M. Murphy, Legal Branch Chief,
at (202) 551-
3257 with any other questions.



FirstName LastNameZhou Pengwu                         Sincerely,
Comapany NameAesthetic Medical International Holdings Group Ltd.
                                                      Division of Corporation
Finance
July 8, 2019 Page 2                                   Office of
Telecommunications
FirstName LastName