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                              January 26, 2024

       Quek Leng Chuang
       Chairman of the Board and Chief Executive Officer
       ESGL Holdings Limited
       101 Tuas South Avenue 2
       Singapore 637226

                                                        Re: ESGL Holdings
Limited
                                                            Amendment No. 3 to
Registration Statement on Form F-1
                                                            Filed January 12,
2024
                                                            File No. 333-274586

       Dear Quek Leng Chuang:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies to your
facts and circumstances
       or do not believe an amendment is appropriate, please tell us why in
your response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.

       Amendment No. 3 to Form F-1

       Exhibits
       Exhibit 5.1, page 1

   1.                                                   Each of numbered
assumptions 5 through 10 of Schedule 2 to the legality opinion appears
                                                        to be overly broad.
Please obtain and file a revised opinion without those assumptions, or
                                                        provide an explanation
as to why each of those assumptions would be appropriate.
                                                        Counsel may assume in a
legality opinion that representations of officers and employees
                                                        are correct as to
questions of fact, including with regard to these items. On the other hand,
                                                        counsel may not assume
any of the material facts underlying the opinion or any readily
                                                        ascertainable facts.
See Staff Legal Bulletin No. 19 at Section II.B.3.a.
       Compensation of Directors and Executive Officers, page 66

   2.                                                   Please provide updated
compensation disclosure for the fiscal year ended December 31,
                                                        2023. See Item 4.a of
Form F-1 and Form 20-F, Item 6.B. We also note the
 Quek Leng Chuang
ESGL Holdings Limited
January 26, 2024
Page 2
       compensation disclosure for 2021 and 2022 which appears under "Related
party
       transactions" in Note 20 of the Notes to the Consolidated Financial
Statements at page F-
       124.

       Please contact Timothy S. Levenberg, Special Counsel, at 202-551-3707 or
Irene
Barberena-Meissner, Staff Attorney, at 202-551-6548 with any questions.



                                                            Sincerely,
FirstName LastNameQuek Leng Chuang
                                                            Division of
Corporation Finance
Comapany NameESGL Holdings Limited
                                                            Office of Energy &
Transportation
January 26, 2024 Page 2
cc:       David J. Levine, Esq., of Loeb & Loeb, LLP
FirstName LastName