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CORRESP
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    QIWI PLC

12 Kennedy Avenue, Kennedy Business Centre, 2nd Floor, 1087-Nicosia, Cyprus

+357 22-65-33-90, fax +357 22-76-09-18, office@qiwi.com.cy, qiwi.com

December 29, 2022

VIA EDGAR

Division of Corporation Finance

Office of Trade & Services

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Robert Shapiro

                                                         Lyn Shenk

                                                         Nicholas Nalbantian

                                                         Cara Wirth

    RE:
    QIWI PLC

    Form 20-F for Fiscal Year Ended December 31, 2021

    Filed April 29, 2022

    File No. 001-35893

Ladies and Gentlemen:

I am writing on behalf of
QIWI PLC (“QIWI”, “Company” or “we”) in response to the comments of the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) set forth in the letter from the Division of Corporation
Finance dated December 15, 2022 (the “Comment Letter”) with respect to the above-referenced Form 20-F for the fiscal
year ended December 31, 2021 (the “Form 20-F”) as filed with the Commission on April 29, 2022.

This letter is being filed
with the Commission electronically via the EDGAR system today. The headings and numbered paragraphs below correspond to the headings and
numbered paragraphs set forth in the Comment Letter. For the Staff's convenience, we have set forth below each of the numbered comments
of your letter in italics followed by QIWI’s responses thereto. Capitalized terms used but not defined in this letter have the meanings
given to them in the Form 20-F.

Robert Shapiro

Lyn Shenk

Nicholas Nalbantian

Cara Wirth

December 29, 2022

Page 2

Form 20-F for Fiscal Year Ended
December 31, 2021

D. Risk Factors, page 7

Comment 1: We note you provide
a number of financial services functions and have assets in Russia. Consider disclosing the risk that the Russian government may nationalize
your assets and quantify the potential impact to your financial statements, if material.

Company Response:

We respectfully refer the Staff to the
disclosure included in the risk factor “The conflict
between Russia and Ukraine, and particularly its 2022 escalation, the U.S., EU, UK and other countries’ sanctions that have been
imposed in connection therewith, the resulting economic crisis that is beginning to unravel in Russia, and the measures that are being
adopted by Russia in response, could adversely impact our operations and financial condition.”… “In addition,
Russia has imposed, or is considering, other severe measures aimed at mitigating the effect of sanctions, including significant restrictions
on foreign companies executing transactions and generally doing business in Russia, nationalization of foreign-held businesses under
certain circumstances, criminalization of compliance with sanctions, and others.” …“Overall, the military conflict
in Ukraine is continuing to unravel, and we cannot predict how it will unfold or the impact it will have on our business or results of
operations.” on pages 9-12 of the Form 20-F that the Company believes appropriately discloses this potential risk. On the date
of the Annual Report the Company was not and on the date of this letter the Company is not aware of any plans by the Russian Government
to nationalize the Company’s assets in Russia.

Risks Relating to Current Geopolitical
Environment

The conflict between Russia and
Ukraine, and particularly its 2022 escalation, the U.S., EU, UK and other countries' sanctions that have..., page 9

Comment 2: We note your disclosure
on page 11 that two of your former directors, Nadiya Cherkasova and Elena Titova, have been designated under US and EU sanctions. Please
explain whether and how the sanctions imposed on these individuals, and in the case of Elena Titova her immediate resignation as a director
following her designation as a sanctioned person, had or may have a material impact on your business.

Company Response:

We respectfully inform the
Staff that the board changes in March and April of 2022 had no material impact on our business and they are not expected to have any
material impact on our business in the future. Ms. Nadiya Cherkasova and Ms. Elena Titova voluntarily stepped down as members of the
Board of Directors of QIWI PLC on March 21, 2022 and April 20, 2022, respectively. As a result of Ms. Titova’s resignation the
Company was temporarily not compliant with Rule 5605(c)(2) of the Nasdaq Rules. This has been disclosed on page 117 of our Form 20-F
under Item 6C: “As a result of Ms. Titova’s resignation from the Board, the Company is not compliant with Rule 5605(c)(2)
of the Nasdaq Rules, which requires a company to have an audit committee comprised of at least three independent directors… the
Company must evidence compliance no later than October 17, 2022.” The non-compliance was remediated following the election
of the Board of Directors at the Annual General Meeting held on September 21, 2022 and therefore within the remediation period prescribed
by Nasdaq.

Robert Shapiro

Lyn Shenk

Nicholas Nalbantian

Cara Wirth

December 29, 2022

Page 3

Trading in our ADSs has been halted by Nasdaq and there
can be no assurance when or if it will resume, while trading in our ADSs on the..., page 12

Comment 3: We note your disclosure that trading in your ADSs
has been halted. Please describe any corollary impacts associated with the trading halt. For example, describe whether such trading suspension
may trigger default or redemption rights associated with existing debt.

Company Response:

We respectfully inform the Staff that the trading halt of our ADSs
did not result in any default or redemption rights under any of our existing debt facilities or bond instruments and has not in any other
material way affected our operations.

Risks Relating to Our Business and Industry

Unauthorized or improper disclosure of data, whether
through cybersecurity breaches, computer viruses or otherwise, could expose us to..., page 28

Comment 4: We note your risk factor that you may be subject
to cyberattacks. To the extent material, disclose any new or heightened risk of potential cyberattacks by state actors or others since
Russia’s invasion of Ukraine and whether you have taken actions to mitigate such potential risks. Additionally, if there have been
more recent cyberattacks since your last disclosed event that occurred in January 2014, please revise to state as much and update your
risks to reflect your current status.

Company Response:

We respectfully inform the Staff that we do not believe that we face
any new or heightened risks of potential cyberattacks by state actors or others since Russia’s invasion of Ukraine. Furthermore,
our operations have not been subject to any material cyberattacks since January 2014. In March and April 2022 we experienced an increase
in the number of denial-of-service (DDos) attacks and we immediately reacted by increasing the capacity of our servers. We do not consider
these DDoS attacks material, they did not succeed in having any material impact on our operations or our information technology systems,
and such attacks were successfully resolved within our routine information security processes. We describe “Our Technology Platform”
along with the “Information Security” features under Item 4B on page 69 of the Form 20-F.

Robert Shapiro

Lyn Shenk

Nicholas Nalbantian

Cara Wirth

December 29, 2022

Page 4

B. Business Overview

Employees, page 73

Comment 5: Please disclose whether you continue
to pay employees in Russia, including a discussion of whether they continue to engage in work for you and whether you have a legal obligation
to continue to pay employees regardless of work status.

Company Response:

We respectfully inform the Staff that we continue to maintain a workforce
in Russia and this has not been affected by the recent geopolitical events.

A Russian law governed employment agreement may be terminated in accordance
with the general provisions provided for under Russian labor law. Under Russian labor law in the event the Company liquidates its operations
in Russia it will be required to pay its Russian employees up to 3 months of severance payments in cases where an employee could not find
another job within a certain period of time. The Company neither has plans to liquidate its Russian operations nor expects to terminate
the employment of its employees located in Russia, and therefore we do not see a material risk arising from the Company’s obligations
under Russian labor law. Therefore, the Company respectfully submits to the Staff that no additional disclosure is required in the Form
20-F to address this point.

Comment 6: Please disclose any material risks posed to your
business directly or indirectly due to having most of your employees located in Russia, for example relating to security, internet accessibility,
or other infrastructure concerns. In addition, disclose steps you have taken or may take to address these risks, such as relocating personnel
to other geographic regions.

Company Response:

We respectfully inform the Staff that other than as disclosed
in our Form 20-F, as of the date of our Form 20-F and as of the date of this letter we do not believe there any material risks posed to
our business, directly or indirectly, due to having our employees located in Russia, including risks relating to security, internet accessibility,
or other infrastructure concerns. If the Company faces any such risks in the future its board and management may consider appropriate
actions available to the Company to address such risks, including, if required, the relocation of any of our employees.

Robert Shapiro

Lyn Shenk

Nicholas Nalbantian

Cara Wirth

December 29, 2022

Page 5

Item 5. Operating and Financial Review and Prospects,
page 80

Comment 7: We note that a portion of your operations
or those of companies with which you do business is conducted through kiosks located in Russian and Kazakhstan. Please describe the direct
or indirect impact of Russia’s invasion of Ukraine on your business. In addition, please also consider any impact:

 · resulting from sanctions, limitations on obtaining relevant government approvals, currency exchange
limitations, or export or capital controls, including the impact of any risks that may impede your ability to sell assets located in Russia,
Belarus, or Ukraine, including due to sanctions affecting potential purchasers;

 · resulting from the reaction of your investors, employees, customers, and/or other stakeholders to
any action or inaction arising from or relating to the invasion, including the payment of taxes to the Russian Federation; and

 · that may result if Russia or another government nationalizes your assets or operations in Russia,
Belarus, or Ukraine. If the impact is not material, please explain why.

Company Response:

We respectfully inform the Staff that the Company did not experience
any direct or indirect material impact in the performance of its kiosks and terminals network in Russia and Kazakhstan due to Russia’s
invasion of Ukraine.

We also respectfully refer the Staff to our disclosure on page 88 of
Form 20-F “Impact of geopolitical developments in Russia and related sanctions” and references provided in this section
to Item 3D Risk Factors – “The conflict between Russia and Ukraine, and particularly its 2022 escalation, the U.S., EU,
UK and other countries’ sanctions that have been imposed in connection therewith, the resulting economic crisis that is beginning
to unravel in Russia, and the measures that are being adopted by Russia in response, could adversely impact our operations and financial
condition” as a general overview of the direct or indirect impact of Russia’s invasion of Ukraine on our business.

Robert Shapiro

Lyn Shenk

Nicholas Nalbantian

Cara Wirth

December 29, 2022

Page 6

With respect to the Staff’s comment relating to the impact on
the Company’s operations from sanctions, limitations on obtaining relevant government approvals, currency exchange limitations,
or export or capital controls, including the impact of any risks that may impede our ability to sell assets located in Russia, Belarus,
or Ukraine, including due to sanctions affecting potential purchasers we respectfully submit that:

 · as
of the date of the Form 20-F and as of the date of this letter, the Company was not and is currently not required to seek any governmental
approvals in order to continue its operations as a result of the sanctions;

 · the
Company disclosed potential risks on currency exchange, export and capital controls on page 10 of its Form 20-F: “These and
other numerous sanctions introduced in the wake of the full-blown military conflict in Ukraine, particularly the cut-off of CBR's access
to its international reserves, resulted in rapid deterioration of Russia’s financial ecosystem, liquidity issues at numerous players
in the industry, widespread bank runs, and foreign currency shortages…To mitigate the high exchange rate and financial market volatility,
and to preserve remaining foreign currency buffers, Russia's authorities have introduced capital-control measures that prevent currency
outflows…. The sanctions imposed on Russia together with its retaliatory response have materially impaired ability of Russian entities
to execute cross-border transactions… Discussions are constantly ongoing with respect to introduction of further sanctions, including
various limits on trade in energy with Russia (in addition to those already introduced), which represent a major source of income for
the country. If such measures are adopted, this could further exacerbate the economic crisis unraveling in Russia.” …
“These sanctions have had and will continue to have the effect of damaging the Russian economy to the point of likely sending
it into a major recession in 2022-2023.” In addition, in our Form 20-F we disclosed that we are exposed to currency risks as
our financial statements are expressed in Russian rubles, while our revenues and expenses outside Russia are in local currencies and
some of our assets and liabilities are in foreign currencies - see Item 11 Quantitative and Qualitative Disclosures About Market Risk
 – Foreign Exchange Risk on page 146 of Form 20-F. We also refer the Staff to page 88 of our Form 20-F where we provide our view
on impact of geopolitical developments in Russia with respect to cross-border operations affected amongst others by currency restrictions
and capital control measures, and state: “Despite the limitations on cross-border transactions, payments and fund transfers
as further described below, we do not expect any meaningful impact from such limitations, as 87% of our operations are denominated in
Rubles (which are not affected by sanctions in any way). Moreover, certain payment services providers have ceased their operations in
Russia, resulting in a decrease in competition in the Russian market.”, “Russian authorities have introduced capital-control
measures that prevent currency outflows. Such measures affect our ability to transfer funds from our Russian subsidiaries to our Cypriot
parent company, QIWI plc. Although most of our assets are located in Russia, most of our contractual obligations are performed in Russia
and QIWI plc has enough reserves in its accounts to fulfil its commitments, we are still taking such capital-control measures into account
when considering distribution of dividends and other cash expenditure”;

Robert Shapiro

Lyn Shenk

Nicholas Nalbantian

Cara Wirth

December 29, 2022

Page 7

 · the
Company does not have any assets located in Ukraine and does not currently have any plans to sell any of its assets in Belarus or Russia.

With respect to the comment of the Staff on considering any impact
resulting from the reaction of our investors, employees, customers, and