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SEC Comment Letter for IMMUTEP Ltd (IMMP, PRRUF) (CIK 0001506184) (IMMP) — Apr 7, 2026

IMMUTEP Ltd (IMMP, PRRUF) (CIK 0001506184)
Date: April 7, 2026 · CIK: 0001506184 · Accession: 0000000000-26-003496

Financial Reporting Internal Controls Regulatory Compliance

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File numbers found in text: 001-35428

Date
April 7, 2026
Author
Division of
Form
UPLOAD
Company
IMMUTEP Ltd (IMMP, PRRUF) (CIK 0001506184)

Letter

Re: IMMUTEP Ltd Form 20-F for the period ended June 30, 2025 Filed October 24, 2025 File No. 001-35428 Dear Marc Voigt:

April 7, 2026

Marc Voigt Chief Executive Officer IMMUTEP Ltd Level 32, Australia Square 264 George Street, Sydney 2000 New South Wales, Australia

We have reviewed your filing and have the following comment(s).

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 20-F for the period ended June 30, 2025 Item 5. Operating and Financial Review and Prospects A. Operating Results Comparison of Fiscal Year Ended June 30, 2025 to Fiscal Year Ended June 30, Research and Development and Intellectual Property Expense, page 43

1. Your disclosure explaining the increase in 'Research and Development and Intellectual Property Expense' from fiscal year 2024 to fiscal year 2025 of approximately A$20 million appears vague. To the extent you track any of your research and development costs, please provide disclosure to be included in future periodic reports, of the costs incurred during each period presented for each of your key research and development projects. If you do not track your research and development costs by project, please disclose that fact and explain why you do not maintain and evaluate research and development costs by project. For any costs not allocated to specific research and development projects, provide other quantitative or qualitative disclosure that provides more transparency as to the type of research and development expenses incurred (i.e. by nature or type of expense) which should reconcile to total research and development April 7, 2026 Page 2

expense on the Statements of Comprehensive Income. Tell us the periodic report that will reflect the revised research and development disclosures. 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 Sasha Parikh at 202-551-3627 or Christine Torney at 202-551-3652 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Life
Sciences

Show Raw Text
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<FILENAME>filename2.txt
<TEXT>
 April 7, 2026

Marc Voigt
Chief Executive Officer
IMMUTEP Ltd
Level 32, Australia Square
264 George Street, Sydney 2000
New South Wales, Australia

 Re: IMMUTEP Ltd
 Form 20-F for the period ended June 30, 2025
 Filed October 24, 2025
 File No. 001-35428
Dear Marc Voigt:

 We have reviewed your filing and have the following comment(s).

 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 20-F for the period ended June 30, 2025
Item 5. Operating and Financial Review and Prospects
A. Operating Results
Comparison of Fiscal Year Ended June 30, 2025 to Fiscal Year Ended June 30,
2024
Research and Development and Intellectual Property Expense, page 43

1. Your disclosure explaining the increase in 'Research and Development and
Intellectual
 Property Expense' from fiscal year 2024 to fiscal year 2025 of
approximately A$20
 million appears vague. To the extent you track any of your research and
development
 costs, please provide disclosure to be included in future periodic
reports, of the costs
 incurred during each period presented for each of your key research and
development
 projects. If you do not track your research and development costs by
project, please
 disclose that fact and explain why you do not maintain and evaluate
research and
 development costs by project. For any costs not allocated to specific
research and
 development projects, provide other quantitative or qualitative
disclosure that provides
 more transparency as to the type of research and development expenses
incurred (i.e. by
 nature or type of expense) which should reconcile to total research and
development
 April 7, 2026
Page 2

 expense on the Statements of Comprehensive Income. Tell us the periodic
report that
 will reflect the revised research and development disclosures.
 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 Sasha Parikh at 202-551-3627 or Christine Torney at
202-551-3652 if you
have questions regarding comments on the financial statements and related
matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Life
Sciences
</TEXT>
</DOCUMENT>