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September 13, 2023

BY EDGAR

Ms. Guobadia and Mr. Hiller

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Energy & Transportation

100 F Street, NE

Washington, D.C. 20549-0405

Ecopetrol S.A.

Form 20-F for Fiscal Year Ended December 31, 2022

Filed April 1, 2020

File No. 001-34175

Dear Ms. Wall and Mr. Hiller:

Ecopetrol S.A. (the “Company”) has received a
comment letter dated August 17, 2023 from the staff of the Division of Corporation Finance (the “Staff”) of the United States
Securities and Exchange Commission (the “Commission”) concerning the Company’s annual report on Form 20-F for fiscal
year ended December 31, 2022 (the “Form 20-F”) filed on March 29, 2023. On behalf of the Company, I advise you as follows
regarding your comments noted below:

Form 20-F for the Fiscal Year ended December 31, 2022

4. Financial Review

4.6 Operating Results, page 120

 1. We note that you have various disclosures on pages 109 through 144 that appear to be oriented towards
the disclosure requirements of Item 5 of Form 20-F. However, we do not see among these disclosures any tabulations of the accounts that
comprise, or commentary regarding, your Statement of Financial Position which appears on page F-6.

The descriptions of purpose and objectives included
in the Item 5 disclosure requirements include various references to financial condition, as in expressing the need for disclosures of
your financial, changes in financial condition, an explanation of factors that have materially affected or are reasonably likely to affect
your financial condition, quantitative and qualitative descriptions of the reasons underlying material changes, including material offsetting
changes within line items, associated statistical data, and material events and uncertainties that would cause reported financial information
not to be necessarily indicative of your future financial condition.

    Ms. Sandra Wall and Mr. Karl Hiller

United States Securities and Exchange Commission, p. 2

Instruction 2 to Item 5 also stipulates that the
discussion must focus on the primary financial statements that are presented in the document.

We believe that a discussion and analysis of the
accounts that comprise your Statement of Financial Position would be inherent in meeting these disclosure requirements. Please expand
your disclosures to cover these incremental details regarding your financial condition as reflected in this statement to comply with Item
5 of Form 20-F.

Response:

In response to the Staff’s comment, the table
below and accompanying discussion and analysis present the main accounts that comprise the Company’s Statement of Financial Position
as well as the factors that have materially affected our financial condition, quantitative and qualitative descriptions of the reasons
underlying such material changes, including material offsetting changes within line items and material events and uncertainties that would
cause reported financial information not to be necessarily indicative of our future financial condition. The Company advises the Staff
that it will revise its future filings to present a table of the main accounts that comprise our Statement of Financial Position and accompanying
commentary.

    Table - Consolidated Balance Sheet

    As of December 31,

    % Change

    Balance sheet
    2022
    2021

    2022
    2021

    (COP million)

    Total assets
    302,792,431
    242,426,616

    60,365,815
    24.9%

    Liabilities
    188,889,342
    151,842,844

    37,046,498
    24.4%

    Equity
    113,903,089
    90,583,772

    23,319,317
    25.7%

    Total liabilities and equity
    302,792,431
    242,426,616

    60,365,815
    24.9%

The Ecopetrol Group's assets grew COP$60,365,815
million compared to the previous year, mainly due to:

  §
  An increase in accounts receivable (COP$28,771,606 million), mainly due to an increase in the value of the FEPC account receivable
(COP$18,472,082 million) and the positive effect of the foreign exchange on concessions assets in ISA Brazil.

  §
  An increase in property, plant, and equipment, natural and environmental resources, right-of-use assets and intangible assets (COP$20,103,962
million) generated by: i) higher capital expenditure mainly in Ecopetrol S.A. and Permian, and ii) the positive effect of foreign currency
translation in companies whose functional currencies are different from the Colombian Peso. The above was partially offset by the depreciation
and amortization for the year (COP$12,128,991 million).

  §
  An increase in the deferred tax asset (COP$4,367,622 million) which resulted from an increase in U.S. dollar loans payable by
the Ecopetrol Group, due to the devaluation of the Colombian Peso in 2022 (21%), and an increase
in debt levels for the Ecopetrol Group.

    Ms. Sandra Wall and Mr. Karl Hiller

United States Securities and Exchange Commission, p. 3

  §
  An increase in inventories, mainly due to crude oil in transit at the end of the year (COP$3,481,822 million).

  §
  An increase in investments in associates and joint ventures (COP$1,139,414 million), mainly due to the effect of translating investments
made in foreign currencies to the Colombian Peso.

The increase (COP$37,046,498 million) in total liabilities
during 2022 was mainly due to:

  §
  An increase in debt (COP$20,073,911 million) mainly due to the devaluation of the Colombian Peso against the U.S. dollar in 2022.
The effect of exchange rate fluctuations on our debt is recognized mainly in equity as a result of the application of hedge accounting
on our net investment abroad and our cash flow.

  §
  An increase in income tax (COP$8,470,068 million), mainly due to higher net profit in 2022.

  §
  An increase in accounts payable (COP$6,355,922 million), resulting from an increase in economic activity and higher prices in
2022.

  §
  An increase in unpaid employee benefits (COP$1,586,194 million), mainly due to a decrease in the valuation of trust assets for
the payment of Ecopetrol’s employment liabilities.

Ecopetrol Group equity as of December 2022 was COP$113,903,089
million. Equity attributable to Ecopetrol shareholders was COP$86,154,927 million, an increase of COP$17,665,380 million compared to December
2021, mainly as a result of the effect of the net profit for the year.

4.6.1.8 Segment Performance and Analysis, page 127

 2. We note your discussion and analysis of segment activity, including transportation and logistics, refining
and petrochemicals, and electric power transmission and toll roads concessions, in which you attribute changes in revenue, cost of sales,
operating expenses, and net income to a combination of several different factors.

Item 5 of Form 20-F generally requires a quantitative
and qualitative description of the reasons underlying material changes, including material changes within a line item that offset one
another, to the extent necessary for an understating of the business.

Please quantify material changes that offset one
another within a line item, to provide investors with better insight into the underlying reasons for the changes that are reflected in
your financial statements, as necessary to adhere to this guidance.

Response:

In response to the Staff’s comment, the Company
would like to expand our discussion and analysis of segment activity included in sections 4.6.1.9 through 4.6.1.12 of our Form 20-

    Ms. Sandra Wall and Mr. Karl Hiller

United States Securities and Exchange Commission, p. 4

F for 2022 to quantify material changes that offset
one another within a line item. The information in these sections has been organized in accordance with materiality. We present the information
below in the same order in which it was presented in our Form 20-F for 2022. The Company advises the Staff that it will revise its future
filings to quantify material changes that offset one another within a line item.

4.6.1.9 Exploration and Production Segment
Results

Cost of Sales

In 2022, the 22.7% or COP 2,237,455 million increase
in fixed cost as compared to 2021 was partially offset by a 2.7% or COP$59,738 million decrease in costs for reversals in the Bicentenario
pipeline and other minor items.

In 2022, the 13.7% or COP 4,176,843 million increase
in variable cost as compared to 2021 was partially offset by a 4.6% or COP$192,783 million due to decrease in tariffs resulting
from the acquisition of the El Morro-Araguaney pipeline, a higher availability of the Caño Limón – Coveñas
pipeline during 2022 and other minor items.

In 2021, the 30.1% or COP 7,044,043 million increase
in variable cost as compared to 2020 was mainly offset by a 16.5% or COP$1,161,956 million decrease due to (i) the recovery of international
reference prices that affect the valuation of inventories, (ii) a decrease in transported volume due to lower production, (iii) transit
of sales to third parties in the Asian market to be recognized in January 2022, and (iv) a decrease in nafta purchase volume
to third parties.

Operating Expenses

The 34.2% increase in operating expenses before impairment
of non-current assets in 2022 as compared to 2021, was partially offset by (i) a 5.0% or COP$224,437 million decrease
in expenses related to the updating of processes, resulting from new legal, tax and environmental provisions, and (ii) a 2.5% or COP$110,573
mainly due to the profit from the sale of the Casanare, Estero, Garcero, Orocue and Corocora fields in 2022 and other minor items.

The 73.3% increase in operating expenses before impairment
of non-current assets in 2021 as compared to 2020, was partially offset by a 11.1% or COP$288,616
million decrease in labor expenses due to a recognition of the voluntary retirement plan in 2020 and no similar recognition in 2021.

The 4.5% decrease in operating expenses before impairment
of non-current assets in 2020 as compared to 2019, was offset by a 28.9% or COP$783,661 million increase
in expenses due to (i) certain employees choosing to accept a voluntary retirement plan we offered in 2020, (ii) the write off of
certain assets due to the completion of economic feasibility studies, (iii) an increase in environmental provisions and asset retirement
obligations for noncommercial wells, (iv) an increase in social investment costs associated with our

    Ms. Sandra Wall and Mr. Karl Hiller

United States Securities and Exchange Commission, p. 5

support to the country to combat the COVID-19 pandemic,
and (v)  an increase in fees and freight costs for exports to China and Korea.

4.6.1.10 Transportation and Logistics Segment
Results

Sales

The 0.3 % decrease
in transportation and logistics segment sales in 2021 as compared with 2020 was partially offset by a COP$564,330 million increase in
revenues associated with increased refined products transported volumes, which in turn was primarily due to the recovery of demand and
higher reversal cycles in the Bicentenario pipeline.

4.6.1.11 Refining and Petrochemicals Segment
Results

Cost of Sales

The 87.9% increase
in cost of sales for this segment in 2021 as compared with 2020 was partially offset by a greater share of the loads of domestic crude
oil as compared to imported crude oil (85% and 15%, respectively) at the Cartagena Refinery, which resulted in a more cost-effective crude
slate.

Impairment Reversal (Loss)

In 2022, we
recognized an impairment recovery of non-current assets in this segment totaling COP 1,096,021 million, as compared to an impairment loss
of COP 305,466 million in 2021. The recovery recorded in 2022 was mostly related to the Cartagena Refinery due mainly to i) favorable
market conditions, ii) high differentials of distilled products sustained in the short term due to the impact of the Ukraine-Russia crisis
and iii) optimization of the mix of throughput of the Cartagena Refinery as a result of the differential in domestic crudes.

The impairment
recovery recorded in 2022 was partially offset by the increase in the discount rate which went from 5.27% in 2021 to 7.6% in 2022.

Additionally,
higher amounts of income taxes in line with higher production margins and profits mainly in the Cartagena Refinery also served to offset
the upward effect of impairment recovery in our income statement.

4.6.1.12 Electric Power Transmission and
Toll Roads Concessions Segment Results

In 2021, the
electric power transmission and toll roads segment revenues from contracts with customers were COP 4,113,198 million, which included COP
1,348,322 million for toll road concessions. Toll road concession revenues were positively affected by higher returns on contract assets
and a COP$1,378,547 million increase in revenues from maintenance of concessions and toll management in Chile, partially offset by the
negative

    Ms. Sandra Wall and Mr. Karl Hiller

United States Securities and Exchange Commission, p. 6

effects of the termination of the Ruta del Maule
concession contract, valued at COP$30,225 million.

4.9 Financial Indebtedness and Other Contractual Obligations,
page 139

 3. Please reconcile your disclosure on page 139, stating that you had outstanding consolidated indebtedness
of COP 23.5 billion at December 31, 2022, with your disclosure in the table of contractual obligations on page 141, indicating the outstanding
balance of financial sector debt and bonds was COP 113,107.4 billion, and disclosure about the composition of loans and borrowing in Note
20 on Page F-77, indicating that balance plus lease liabilities and related party debt was COP 115,134.8 billion at year-end.

If this disclosure was intended to be a U.S. dollar
equivalent, please clarify the exchange rate that was utilized and the manner of selecting that rate and explain why it does not appear
to agree with the rate utilized for convenience translations disclosed on page 1.

With regard to Table 64 on page 139, where you have
listed various issuances of debt along with the original currency denominated amounts, it would be helpful to include another column showing
the outstanding year-end balances in Colombian pesos, along with a summation that is reconciled to the corresponding amounts on page F-77.

Response:

In response to the Staff’s comment, the Company
advises the Staff that the figure stated as outstanding consolidated indebtedness on page 139 (COP$23.5 billion) is expressed in the wrong
currency. The figure on page 139 was indeed intended to be USD$23,514 million (the U.S. dollar equivalent of COP$113,107.4 billion corresponding
to the outstanding balance of financial sector debt and bonds excluding lease liabilities and related party debt, figures expressed at
amortized cost, stated on pages 141 and F-77), restated at an exchange rate of COP$4,810.20 per U.S. dollar.

The exchange rate used corresponds to the closing
rate for December 31, 2022, which is different from the 2022 average exchange rate disclosed on page 1. As we are referring to the account
balance at year end, we may not use the 2022 average exchange rate for re-expressing Colombian Peso amounts in U.S. dollar figures.

The Company advises the Staff that it will revise
its future filings to provide the correct

Colombian Peso equivalent.

With respect to Table 64 on page 139, the Company
respectfully disagrees with the Staff’s comments indicating that “it would be helpful to include another column showing the
outstanding year-end balances in Colombian pesos, along with a summation that is reconciled to the corresponding amounts on page F-77.”

We believe that a better approach is to include
an additional column presenting outstanding nominal year-end balances in the original currency of each facility as we have done below

    Ms. Sandra Wall and Mr. Karl Hiller

United States Securities and Exchange Commission, p. 7

and include a cross-reference to the notes to our
financial statements where investors may find outstanding amortized year-end balances