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February 26, 2024
Alvaro Quintana Cardona
Chief Financial Officer
iQSTEL Inc
300 Aragon Avenue, Suite 375
Coral Gables, FL 33134
Re:iQSTEL Inc
Registration Statement on Form S-1
Filed February 13, 2024
File No. 333-277029
Dear Alvaro Quintana Cardona:
            We have conducted a limited review of your registration statement and have the
following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Form S-1 filed February 13, 2024
Summary of the Offering, page 4
1.We note your disclosure that your artificial intelligence-enhanced metaverse product line
"goes beyond traditional virtual spaces by utilizing cutting-edge AI technology." It is
unclear how artificial intelligence technology relates to your business. Please provide a
more complete description of how you intend to utilize artificial intelligence in your
products and describe your current phase of development. In addition, explain the basis
for referring to your technology as “cutting-edge.”
Selling Shareholders, page 31
2.Please revise to correct the number of shares of common stock to be owned after the
offering by M2B Funding Corp. or advise. Your disclosure indicates that M2B Funding
Corp. currently beneficially owns 3,235,702 shares of common stock and will be receiving
22,222,222 shares under the Note for a total pre-offering holding of 25,457,924 shares.

 FirstName LastNameAlvaro Quintana Cardona
 Comapany NameiQSTEL Inc
 February 26, 2024 Page 2
 FirstName LastName
Alvaro Quintana Cardona
iQSTEL Inc
February 26, 2024
Page 2
Because the maximum number of shares it will be selling is 22,222,222 shares, the
disclosure should show that it will beneficially own 3,235,702 shares after the offering.
Exhibit Index, page 41
3.Please file the legality opinion as Exhibit 5.1. It appears to have been filed as Exhibit 99.1.
General
4.Please update the financial statements and other financial information in the filing to
include the year ended December 31, 2023. Refer to Rule 8-08 of Regulation S-X.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Lauren Pierce at 202-551-3887 or Mitchell Austin at 202-551-3574 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Scott Doney