SecProbe.io

January 31, 2020
Neil Sorahan
Chief Financial Officer
Ryanair Holdings plc
c/o Ryanair DAC
Dublin Office
Airside Business Park, Swords
County Dublin, K67 NY94, Ireland
Re:Ryan Holdings plc
Form 20-F for the Fiscal Year Ended March 31, 2019
Filed July 30, 2019
File No. 0-29304
Dear Mr. Sorahan:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended March 31, 2019
Liquidity and Capital Resources
Contractual Obligations, page 56
1.You disclose purchase obligations of 12.3 billion euros at March 31, 2019. In note (b) of
the contractual obligations table you disclose that the purchase obligations are based on a
non-discounted list price. The amount of the purchase obligations appears to be based on
the Basic Price per aircraft of $102.5 million disclosed in footnote 23, times the firm
deliveries of 135 planes under the 2014 Boeing Contract after factoring in the U.S. dollar
euro exchange rate.  It appears that you did not use the specific pricing terms of your
aircraft purchase agreements with Boeing and that you have not disclosed your purchase
obligations for the firm deliveries of 29 planes under the Boeing 2013 Contract.

 FirstName LastNameNeil  Sorahan
 Comapany NameRyanair Holdings plc
 January 31, 2020 Page 2
 FirstName LastName
Neil  Sorahan
Ryanair Holdings plc
January 31, 2020
Page 2
The disclosures you provide under Item 5.F of Form 20-F should reflect the amounts you
are required and expect to pay under your purchase obligations, and should include details
of any provisions that are necessary to understand any material uncertainty or variability
in the timing and amounts of the specified obligations.

The disclosures that you provide in your financial statements should also include the
actual amounts of contractual commitments for the acquisition of property, plant and
equipment to comply with paragraph 74(c) of IAS 16.

Please explain to us why you believe your existing disclosure complies with the relevant
requirements of Form 20-F and IAS 16.
            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.
            You may contact Yolanda Guobadia, Staff Accountant, at (202) 551-3562 or Gus
Rodriguez, Accounting Branch Chief, at (202) 551-3752 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       David I. Gottlieb