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CORRESP

 FOIA Confidential Treatment Request by Autoliv, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83).

 This letter requests confidential treatment of the bracketed portions of this letter (designated by “[***]”).

 January 30, 2025

Division of Corporation Finance

 Office of Manufacturing

Securities and Exchange Commission

 100 F Street, N.E.

Washington, D.C. 20549

 Attn: Andrew Blume and Kevin Woody

Re:
 Autoliv, Inc.

Form 10-K for the Fiscal Year Ended December 31, 2023

Form 8-K furnished July 19, 2024 and October 18, 2024

File No. 001-12933

Dear Mr. Blume and Mr. Woody:

 We
hereby respond to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”), as set forth in the Staff’s letter of comments dated December 19, 2024 (the “Comment
Letter”), to the above referenced filings of Autoliv, Inc. (the “Company”). The Company has filed, via EDGAR, this letter (tagged Correspondence).

The Company has the following responses to the Staff’s comments in the Comment Letter. For your convenience, we have reproduced in
italics below each comment from the Comment Letter with the response following. We have also numbered each of the Staff’s comments and referenced those numbers in the responses to assist the Staff in its review.

Pursuant to 17 C.F.R. § 200.83 (“Rule 83”), the Company requests confidential treatment for portions of its responses to Staff
comment 1. Specifically, the Company requests that portions of its responses to Staff comment 1 that have been redacted from the version of this letter filed via the Commission’s EDGAR system and marked by bracketed asterisks “[***]”
be maintained in confidence, not be made part of any public record and not be disclosed to any person, including in response to any request under the Freedom of Information Act, 5 U.S.C. § 552 (“FOIA”), as such response contains
confidential information. An unredacted version of this letter is being provided to the Commission under separate cover along with the request for confidential treatment under Rule 83.

Form 10-K for the Fiscal year Ended December 31, 2023

Notes to the Consolidated Financial Statements

1. Basis of Presentation

 Segment Reporting,
page 60

 Question 1:

 We note
your response to prior comment 5 and have the following comments:

•

 Please provide a more detailed description, with supporting examples, of the roles and responsibilities of the
Division Presidents, and compare and contrast those roles with that of the EVP of Operations and the CEO. (1)

 FOIA Confidential Treatment Requested by Autoliv, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83). This letter

 requests confidential treatment of the bracketed portions of this letter (designated by “[***]”)

United States Securities and Exchange Commission

  Page
 2

•

 In addition to the consolidated information for the Company, you describe three “other perspectives”
of financial information in the EMT Financial Report, including Division financial performance information. You indicate the three other perspectives are not the primary tool used by the CODM in evaluating and deciding upon significant operating or
strategic decisions and that it is helpful in understanding the efficiency of manufacturing operations within a geographic region. You also indicate that the financial or other impact on specific geographic regions may help inform resource
allocation decisions. Please expand on your discussion of how this information is used, with supporting examples, including the following:

•

 why financial performance information for Divisions is prepared and provided to the CODM; (2)(a)

•

 what information comprises the Division financial performance information, and whether actual results are
compared against forecast; (2)(b)

•

 why the Division financial information includes costs that are allocated from the Global and Corporate
Functions; (2)(c)

•

 how it is used by the CODM, and why such use does not represent regular review by the CODM for the allocation
of resources and assessment of performance at the Division level; (2)(d) and

•

 how financial information for the Divisions is used by individuals that report to the CODM, such as the
Division Presidents and EVP of Operations. (2)(e)

•

 At the top of page 14 of your response, you indicate that the CEO meets with direct reports of a specific team
at least monthly and reviews actual financial results for the Company by region at those meetings. Please describe the regional information reviewed by the CODM and what is discussed. (3)

•

 You indicate that none of the Division forecasts are individually approved by the CFO and are only included in
the consolidated forecast for final approval by the CEO. Please tell us what “included in the consolidated forecast” means, including whether the individual forecasts are provided to the CODM as part of
the consolidated forecast and whether the CODM reviews them in approving the consolidated budget. (4)

•

 You indicate that Divisions execute on the strategic plans given to them by the CEO. We also note your
discussion of the Company’s forecasts. Please tell us what items a Division President is responsible for in the forecast of their Division. Please further tell us whether Division Presidents are responsible for operating within
their respective forecast and what approvals are necessary, if any, if a Division Presidents wants or expects to exceed forecasted expenses or expenditures. (5)

 FOIA Confidential Treatment Requested by Autoliv, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83). This letter

 requests confidential treatment of the bracketed portions of this letter (designated by “[***]”)

United States Securities and Exchange Commission

  Page
 3

 RESPONSE

Executive Summary

 As described in the
Company’s initial response and further described below, the Company has determined that it has one operating segment. The CEO regularly reviews the consolidated financial information of the Company and makes decisions on how to allocate
resources and assesses the performance of the Company based on such information.

 The Company has an EVP, Operations as well as Division Presidents, but
the CEO is the only person that has the authority to make decisions to allocate resources and therefore is the Chief Operating Decision Maker (CODM). Although each Division President’s title includes a geographic designation (e.g., President of
Americas), the responsibilities of a Division President are primarily limited to overseeing the manufacturing operations within a Division (or geographic area) and do not include responsibility for many of the activities that occur within a
designated geographic area or region. For example, RD&E activities are managed globally even though different projects occur in different geographic regions.

A Division President is also not responsible for all of the profit or loss that occurs within their geographic region. For example, sales decisions, product
engineering and raw material sourcing decisions are all made at the global level using the consolidated financial information. This is why the financial measures that affect their compensation are based on global results and not divisional results
(except for the President, Autoliv Europe who has a one-time, short-term incentive award tied to certain results of Division Europe that will not continue in 2025 as noted in the Company’s initial
response).

 The purpose of the disclosure of segment information is, as stated in ASC 280-10-10-1:

 to provide information about the different types of business activities in
which a public entity engages and the different economic environments in which it operates to help users of financial statements do all of the following:

a.
 Better understand the public entity’s performance,

b.
 Better assess its prospects for future net cash flows and

c.
 Make more informed judgments about the public entity as a whole.

Disaggregated information of the Company by geography does not further this understanding because:

i.
 Responsibility for negotiating sales contracts, including pricing, [***]. Geographic revenue therefore is not
useful to the CODM in assessing performance nor would it provide users with additional information about the Company’s performance, cash flow prospects or the Company’s consolidated operations.

ii.
 [***]. Again, such information is not useful to the CODM in assessing performance and would not assist users in
understanding the Company’s performance or prospects for future cash flows.

 FOIA Confidential Treatment Requested by Autoliv, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83). This letter

 requests confidential treatment of the bracketed portions of this letter (designated by “[***]”)

United States Securities and Exchange Commission

  Page
 4

iii.
 [***]. The CODM does not use the geographic financial results in evaluating whether these costs are being
managed well. [***]. Again, the geographic information would therefore not assist users in understanding the Company’s results or prospects.

While the Division financial information is available to the CODM, it does not present the entire or complete picture of a geographic region. Many costs are
allocated on a global basis—partly through transfer pricing for tax purposes—rather than being specifically tied to a specific region. Additionally, many of the inputs are determined on a global scale. These allocations vary from year to
year based on the results of the Company. The change in these allocations, without any other change in the business operations, makes the consistency and comparability of the financial information difficult from period to period which reduces the
usefulness of this information on making resource allocations. Additionally, given the CODM makes most of the decisions on a global basis, the Division financial information is not useful (i.e., cannot be used) for allocating resources given those
decisions are not based on specific regions. Therefore, the Division financial information is not regularly reviewed by the CODM, as contemplated by ASC
280-10-50-1b, to make decisions regarding the allocation of resources or assess performance and is inconsistent with how the CODM
manages the business.

I.
 The roles and responsibilities of the EVP, Operations, the CEO and the Division Presidents are
different and only the CEO has the authority to make decisions to allocate resources. (1) (5)

 Below is a detailed
description of the roles and responsibilities of the CEO, EVP, Operations and Division President.

 CEO

The CEO is the most senior executive officer in the organization. The CEO is supported by the Executive Management Team (EMT) and, more broadly, his other
direct reports, to implement and execute on the strategic and operating decisions made by him. [***]. The CEO is the Company’s CODM.

 EVP,
Operations

 The EVP, Operations reports to the CEO and leads the global Operations organization, which itself is responsible for the Autoliv industrial
set-up (footprint), Autoliv Production System (APS), and overseeing the Company’s global product lines and global manufacturing engineering. This officer is responsible for executing on the strategic
decisions made by the CEO that involve manufacturing, the product lines and facilities. The EVP, Operations has individuals within the various geographic regions that report to him. The current EVP, [***].

The EVP, Operations is responsible for overseeing the Company’s global operations and manufacturing functions. This includes developing and ensuring an
efficient process for producing and delivering the Company’s products in a way that maximizes value while minimizing costs, time and waste. These efforts are carried out in close collaboration with the Division Presidents to optimize the
Company’s industrial operations.

 [***].

 FOIA Confidential Treatment Requested by Autoliv, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83). This letter

 requests confidential treatment of the bracketed portions of this letter (designated by “[***]”)

United States Securities and Exchange Commission

  Page
 5

 Division President

The Company has four Division Presidents, each serving as the general manager of manufacturing operations for their respective geographic region. They oversee
the combined roles and responsibilities of plant managers within the countries in their region. The vast majority of the Company’s headcount is in direct manufacturing. This requires a level of management to manage these personnel. However,
primary decision-making authority resides not within the geographic regions but within the EMT. The authority of a Division President is limited with respect to overall business decisions within a geographic region. The primary role of the Division
President is to successfully oversee the day-to-day manufacturing operational performance of their region [***] to execute on the strategic plans as ultimately
determined by the CEO. [***]. This structure is why the Division Presidents’ (except for the one-time, short-term incentive award tied to certain results of Division Europe that will not continue in 2025
as noted in the Company’s initial response) compensation is not affected directly by divisional financial results, while it is affected directly by global financial results. [***].

[***].

 Comparison and Supporting Examples of Each of the
Roles of CEO, EVP, Operations and Division President

 A key strategy for the Company is to achieve and maintain cost competitiveness by continuously
implementing productivity improvement programs, optimizing its production footprint, and undertaking restructuring and capacity alignment initiatives, along with other measures to manage its cost structure. The CEO, EVP, Operations and Division
Presidents are all responsible for ensuring the operational efficiency of the Company, but they do so at different levels and to a different extent. The CEO focuses on the global strategy and long-term direction of the Company, the EVP, Operations
is focused on managing operational efficiency on a global basis and ensuring the implementation of the Company’s processes and procedures across the group, and the Division Presidents are focused on overseeing the
day-to-day operations of the facilities within their region. The CEO, the EVP, Operations and Divisions Presidents have different roles when carrying out the
Company’s operational initiatives.

 [***] This decision was part of the Company’s 1P1P strategy that focuses on product and process
standardization and reducing cost and complexity on a global basis. [***].

II.
 The Division Presidents do not have autonomy in a geographic region and are not responsible for
all activities that take place within a geographic region. They are primarily responsible for the efficiency of the manufacturing operations of the Company within a particular region. (1), (5)

The primary role of the Division President is to execute on the strategic plans as ultimately determined by the CEO and oversee the manufacturing operations in
their region. [***]. The Division Presidents oversee the plant managers and help to ensure efficient manufacturing operations in the short-term. [***]

 As
noted above, the Division Presidents do not have autonomy to operate without oversight from the CEO or the input from the Global Functions or Corporate Functions and do not manage or oversee the overall profitability of the products sold or
manufactured in their respective region. Most of the activities that impact revenue, costs and profitability that occur within a specific region are outside of the control of the Division President. [***]

 FOIA Confidential Treatment Requested by Autoliv, Inc. Pursuant to Rule 83 (17 C.F.R.
200.83). This letter

 requests confidential treatment of the bracketed portions of this letter (designated by “[***]”)

United States Securities and Exchange C