SecProbe.io

Mail Stop 3561
October 4, 2016

Michele L. Santana
Chief Financial  Officer
Signet Jewelers Limited
Clarendon House
2 Church Street
Hamilton HM11
Bermuda

Re: Signet Jewelers Limited
 Form 10-K for Fiscal Year Ended January 3 0, 2016
Filed March 24 , 2016
File No. 1 -32349

Dear M s. Santana :

We have limited our review  of your filing  to the financial statements and related
disclosures and have the following comment s.  In our comment s, we may ask you to provide us
with information so we may better understand your disclosure.

Please respond to these comment s within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If  you do not believe our
comment s apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to the comment s, we may have  additional comments.

Form 10 -K for Fiscal Year Ended January 3 0, 2016

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 51

Critical Accounting Policies, page 75

1. Please include a qualitative and quantitative analysis of the sensitivity of reported results
to changes in your assumptions, judgments, and estimates, including the likelihood of
obtaining materially different results if different assumptions are applied. If reasonably
likely changes in inputs to estimates would have a material effect on your financial
condition or results of operations, the impact that could result given the range of
reasonable outcomes should be disclosed and quantified. Please refer to SEC Release No.
34-48960. In your response, please show us what your disclosure would look like.

Michele L. Santana
Signet Jewelers Limited
October 4, 2016
Page 2

 Accounts Receivable, page 77

2. We note your use of a form of recency -aging of accounts receivable for measuring
delinquency and establishing loss allowances for your in -house credit receivable
portfolio.   Please tell us your consideration of discussing the impact o n bad debt expense
and the allowance for uncollectible a ccounts of basing your allowance on the age of
accounts receivable on a recency  as opposed to contractual basis.  For example, tell us
your consideration of disclosing the aging  of accounts receivabl e on a contractual basis as
compared to the aging  of accounts receivable based on your recency -aging methodology
as of each balance sheet date; i.e., the dollar amount of accounts that is contractually
delinquent but still considered current or performing,  based on your recency -aging
methodology.

Item 8. Financial Statements and Supplementary Data

Notes to the Consolidated Financial Statements

9. Other operating income, net, page 103
3. Please tell us how you have complied with the guidance in SAB Topic 8:B.  In this
regard, we note the example disclosures in the SAB topic include disclosure of the costs
of administering the customer finance operations and the resulting net income or cost  of
the consumer credit operations.  Your disclosure here and in the forepart of the document
on page 20 regarding the impact on earnings of your in -house customer finance programs
does not appear to include the costs of administering the credit portfolio.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since t he company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment s, please provide  a written statement fro m the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of the
United States.

Michele L. Santana
Signet Jewelers Limited
October 4, 2016
Page 3

You may contact Robyn Manuel, Staff Accountant , at 202-551-3823  or me a t 202 -551-
3344  with any  questions.

Sincerely,

 /s/ William H. Thompson

William H. Thompson
Branch Chief
Office of Consumer Products