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CORRESP
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October 11, 2019

FILED VIA EDGAR

Donald Field

Division of Corporation Finance

Office of Life Sciences

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    Midatech Pharma PLC

    Registration Statement on Form F-3

    Filed September 23, 2019

    File No. 333-233901

Dear Mr. Field:

On behalf of our
client, Midatech Pharma PLC, a foreign private issuer incorporated under the laws of England and Wales (the
“Company”), we are submitting this letter in response to the written comment of the staff (the
“Staff”) of the Securities and Exchange Commission (the “SEC”), as contained in your letter of
comment dated October 3, 2019 to the Company regarding the Company’s Registration Statement on Form F-3 (File No.
333-233901) (the “Registration Statement”), as filed with the SEC on September 23, 2019. The Company is
concurrently filing via EDGAR Amendment No. 1 (the “Amendment”) to the Registration Statement, marked in
accordance with Rule 310 of Regulation S-T. For the convenience of the Staff, we are supplementally providing a marked copy
of the Amendment.

The Company respectfully
submits the following response with respect to the comment contained in the October 3, 2019 letter. For ease of reference, the
Staff’s comment is set forth in italic type immediately before the corresponding response submitted by the Company.

Registration Statement on Form F-3

General

 1. Please refer to Section 7.6 of Exhibit 4.2. We note that the depositary is entitled to refer
any dispute or difference for final settlement by arbitration in accordance with the Commercial Arbitration Rules of the American
Arbitration Association. Please revise the prospectus to describe the arbitration provision and to disclose the impact of this
provision on holders of your ADSs for claims under federal securities laws.

In response
to the Staff’s comment, the Company has amended its Deposit Agreement, dated as of December 4, 2015, by and among
the Company, Deutsche Bank Trust Company Americas, as depositary (the “Depositary”) and the holders and
beneficial owners of American depositary shares evidenced by the American depositary receipts issued thereunder, as amended
(the “Deposit Agreement”), to clarify that the arbitration provision relates to claims arising out of the
contractual relationship between the parties and does not preclude an ADS holder from pursuing claims under the federal
securities laws in federal courts. The amended Deposit Agreement also clarifies that no disclaimer of liability under the
federal securities laws is intended by any provision of the Deposit Agreement. The Company filed the amendment to the Deposit
Agreement as Exhibit (a)(3) to its Post-Effective Amendment No. 2 to Form F-6, which was filed with the SEC on October 11,
2019.

Securities and Exchange Commission

October 11, 2019

Page 2

Further, in response
to the Staff’s comment, the Company has revised the disclosure on page 32 of the Amendment to describe the arbitration
provisions of the Deposit Agreement and clarify that such provision does not preclude an ADS holder from pursuing claims under
the federal securities laws in federal courts.

*            *            *

The Company will furnish
a letter at the time its requests acceleration of the effective date of the Registration Statement acknowledging the statements
set forth in the Staff’s comment letter.

If the Staff should
have any questions, or would like further information, concerning the response above, please do not hesitate to contact me at (617)
856-8362 (jmccaffrey@brownrudnick.com).

    Sincerely,

    /s/ Jason S. McCaffrey

    Jason S. McCaffrey

    cc:
    Justin Dobbie, SEC Staff

    Craig Cook, Chief Executive Officer

    Stephen Stamp, Chief Financial Officer