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March 19, 2024
Brian Van Abel
Executive Vice President and Chief Financial Officer
Xcel Energy, Inc.
414 Nicollet Mall
Minneapolis, MN 55401
Re:Xcel Energy, Inc.
Form 10-K for the Fiscal Year ended December 31, 2023
Filed February 21, 2024
File No. 001-03034
Dear Brian Van Abel:
            We have limited our review of your filing to the financial statements and related
disclosures 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.
Form 10-K for the Fiscal Year ended December 31, 2023
Management's Discussion and Analysis, page 26
1.We note that your measures of the electric and natural gas margins on pages 28 and 29
appear to exclude certain amounts that would be attributable to cost of revenues and
reflected in measures of gross margin in accordance with GAAP, such as operating and
maintenance expenses and depreciation and amortization.

Therefore, it appears that your margin measures should be identified as non-GAAP
measures and that you would need to adhere to the disclosure requirements in Item 10(e)
of Regulation S-K. For example, electric gross margin and natural gas gross margin, each
reflecting all costs and expenses applicable to revenues, would be identified as the most
directly comparable GAAP measures in providing the disclosures required by
Item 10(e)(1)(i)(A) and (B) of Regulation S-K; reconciliations to your non-GAAP
measures should begin with these GAAP measures.

 FirstName LastNameBrian Van Abel
 Comapany NameXcel Energy, Inc.
 March 19, 2024 Page 2
 FirstName LastName
Brian Van Abel
Xcel Energy, Inc.
March 19, 2024
Page 2
Please also include analyses of the changes in these most directly comparable GAAP
measures, similar to those provided for changes in your non-GAAP measures of the
electric and gas margins. Your may refer to the answers to Questions 100.05 and
102.10(a) and (b) of our C&DI's pertaining to Non-GAAP measures if you require further
clarification. You may view this guidance at the following website address:
https://www.sec.gov/corpfin/non-gaap-financial-measures.htm

Please submit the revisions that you propose to address these concerns also with respect to
any corresponding disclosures made by your four utility subsidiaries.
            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.
            Please contact Sondra Snyder at 202-551-3332 or Robert Babula at 202-551-3339 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation