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September 8, 2023
Pablo Manuel Vera Pinto
Chief Financial Officer
Vista Energy, S.A.B. de C.V.
Pedregal 24, Floor 4
Colonia Molino del Rey, Alcaldía Miguel Hidalgo
Mexico City, 11040
Mexico
Re:Vista Energy, S.A.B. de C.V.
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 24, 2023
File No. 001-39000
Dear Pablo Manuel Vera Pinto:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Presentation of Information
Measurements, Oil and Natural Gas Terms and Other Data, page 6
1.Please expand the information relating to oil and natural gas measured as barrels of oil
equivalent (“boe”) to additionally provide the factor for converting your natural gas
volumes disclosed in cubic feet to equivalent barrels of oil (e.g., the number of cubic feet
of gas per barrel of oil equivalent). Refer to Instruction 3 to Item 1202(a)(2) of Regulation
S-K.
Business Overview
Reserves, page 67

 FirstName LastNamePablo Manuel Vera Pinto
 Comapany NameVista Energy, S.A.B. de C.V.
 September 8, 2023 Page 2
 FirstName LastNamePablo Manuel Vera Pinto
Vista Energy, S.A.B. de C.V.
September 8, 2023
Page 2
2.Please modify the tabular presentations of your proved developed and proved
undeveloped reserves provided on page 68 to additionally provide your net gas quantities
(consumption plus natural gas sales) expressed in terms of cubic feet of natural gas, e.g.,
as Bcf. Also modify your presentations to include separate disclosure of the net quantities
of your reserves by individual country, e.g., disclose and clearly identify the reserves
attributable to Argentina and to Mexico. Please provide us with an illustration of your
proposed disclosure revisions. Refer to the requirements in Item 1201(d) and the
illustration in Item 1202(a)(1) of Regulation S-K.
3.Please expand your disclosure to include a reconciliation and accompanying explanation
of the material changes that occurred in proved undeveloped reserves during the year
ended December 31, 2022. Your discussion should separately identify and quantify the net
change attributable to each of the individual items, such as revisions, extensions and
discoveries, transfers through conversion of reserves to developed status, sales and
acquisitions, that contributed to the overall change in the net quantities of your proved
undeveloped reserves. To the extent that two or more unrelated factors are combined to
arrive at the overall change for an individual item, your disclosure should separately
identify and quantify each individual factor, including offsetting factors, that contributed
to the change so that the change in net reserve quantities that occurred between December
31, 2021 and December 31, 2022 is fully explained.

The disclosure of revisions in the previous estimates of your proved undeveloped reserves
in particular should identify the individual factors such as the changes caused by
commodity prices, well performance, unsuccessful and/or uneconomic proved
undeveloped locations or the removal of proved undeveloped locations due to changes in a
previously adopted development plan, as applicable.

Please note that you may disclose the changes in the net quantities of your proved
undeveloped reserves by individual product of oil and natural gas or alternatively in terms
of barrels of oil equivalent, e.g., “total all products” consistent with the guidance and
example shown in FASB ASC 932-235-55-2 relating to the disclosure of the changes that
occurred in total proved reserves. Please provide us with an illustration of your proposed
disclosure revisions.

Refer to Item 1203(b) of Regulation S-K and your responses to prior comment 1 in the
letters dated September 28 and October 16, 2020 regarding disclosure in your Form 20-F
for the year ended December 31, 2019.
Productive Wells, page 72
4.Please expand your disclosure of productive wells, present activities and drilling activities
to additionally include non-operated wells, if any. Also clarify your disclosure to indicate
that the number of wells shown under the sections “Present Activities” and “Drilling
Activities” represent net wells, if true. Refer to the disclosure requirements in Items 1205,
1206 and 1208 and the definition of a net well in Item 1208(c)(2) of Regulation S-K.

 FirstName LastNamePablo Manuel Vera Pinto
 Comapany NameVista Energy, S.A.B. de C.V.
 September 8, 2023 Page 3
 FirstName LastName
Pablo Manuel Vera Pinto
Vista Energy, S.A.B. de C.V.
September 8, 2023
Page 3
Production, page 73
5.Please expand your disclosure of production for each of the last three fiscal years shown
on pages 73 and 119 to provide the comparable information relating to your assets in
Mexico. Refer to the disclosure requirements in Item 1204(a) of Regulation S-K.
Notes to Consolidated Financial Statements as of December 31, 2022 and 2021, and for the
Years Ended December 31, 2022, 2021 and 2020
Note 35. Supplementary Information on Oil and Gas Activities (Unaudited)
Estimated Crude Oil and Natural Gas Reserves, page F-91
6.Please expand the tabular presentation of your proved developed and proved undeveloped
reserves, by individual product type and by country, presented on pages F-92 through F-
93 to additionally provide the net quantities at the beginning of the initial period shown in
the reserves reconciliation, e.g., December 31, 2019. Refer to FASB ASC 932-235-50-4.

            In closing, 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.
            You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 or Brad Skinner,
Office Chief, at (202) 551-3489 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation