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VIA EDGAR Division of Corporate Finance Office of Energy & Transportation Attention: Staff of the Division of Corporate Finance, Office of Energy & Transportation 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 Mr. Hodgin and Mr. Skinner:

By letter delivered September 8, 2023, you provided comments of the staff of the Office of Energy & Transportation (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on the annual report on Form 20-F for the fiscal year ended December 31, 2022 filed on April 24, 2023 (the “Form 20-F”) by Vista Energy, S.A.B. de C.V. (“Vista” or the “Company”). The Company is submitting herewith via EDGAR responses to the Staff’s comments.

For ease of reference, the text of the Staff’s comments is set forth in full in this letter in boldface type and our responses are immediately below.

Capitalized terms used and not otherwise defined herein shall have the meanings set forth in the Form 20-F.

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.

Response: We acknowledge the Staff’s comment, and in response, we respectfully advise the Staff that we will expand our disclosure in our future filings with the information set forth below under the section “Presentation of Information—Measurements, Oil and Natural Gas Terms and Other Data.”

Office of Energy & Transportation

September 21, 2023

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“boe” means one barrel of oil equivalent, which equals approximately 158.9873 cubic meters of natural gas and 5,614.5841 cubic feet of natural gas.

Business Overview

Reserves, page 67

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.

Response: We acknowledge the Staff’s comment, and in response, we propose to modify the tabular presentations of our proved developed and proved undeveloped reserves in our future filings as set forth in the illustration below under the section “Item 4. Information on the Company—Business Overview—Oil and Natural Gas Reserves.”

Oil and Natural Gas Reserves

Reserves

[…]

The following table sets forth summary information about the oil and natural gas net proved developed and undeveloped reserves of the assets we own in Argentina and Mexico as of December 31, 2022. The proved developed and undeveloped reserves estimates included below were calculated at their respective working interest percentages.

Office of Energy & Transportation

September 21, 2023

Page

Crude oil, condensate and NGL(1) (MMbbl)

Consumption plus natural gas sales(2) (MMboe)

Consumption plus natural gas sales(2) (Bcf)

Total proved reserves (MMboe)

% Oil

Net Proved developed:

68.5

17.7

99.3

86.2

%

Argentina

68.3

17.7

99.2

86.0

%

Mexico

0.2

0.0

0.1

0.2

%

Net Proved undeveloped:

139.5

25.9

145.6

165.4

%

Argentina

136.8

24.9

139.7

161.7

%

Mexico

2.7

1.1

5.9

3.8

%

Total Net Proved

208.0

43.6

244.9

251.6

%

Argentina

205.1

42.5

238.9

247.7

%

Mexico

2.9

1.1

6.0

4.0

%

Total figures may not add up due to rounding.

(1) Our hydrocarbon liquid volumes include crude oil, condensate and NGL (LPG and natural gasoline). We do not include separate figures for NGL reserves because they represented less than 1% of our proved developed and undeveloped reserves as of December 31, 2022.

(2) Natural gas consumption represented 11% of total natural gas reserves (consumption plus natural gas sales) as of December 31, 2022.

As of December 31, 2022, the oil and gas proved reserves of the assets we own (developed and undeveloped) totaled 251.6 MMboe (208.0 MMbbl of oil, condensate and NGL and 244.9 Bncf, or 43.6 MMboe of gas). Proved undeveloped reserves of crude oil, condensate and NGL represented 66% of our total proved reserves.

Office of Energy & Transportation

September 21, 2023

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Total Proved Developed

Total Proved Undeveloped

Total Proved

Crude oil, condensate and NGL(1)

Consumption plus natural gas sales(2)

Total of oil and gas proved developed reserves

Crude oil, condensate and NGL(1)

Consumption plus natural gas sales(2)

Total of oil and gas proved undeveloped reserves

Crude oil, condensate and NGL(1)

Consumption plus natural gas sales(2)

Total of oil and gas proved reserves

(MMbbl)

(MMboe)

(Bcf)

(MMboe)

(MMbbl)

(MMboe)

(Bcf)

(MMboe)

(MMbbl)

(MMboe)

(Bcf)

(MMboe)

Argentina:

Bajada del Palo Oeste

47.2

11.1

62.2

58.3

108.7

19.5

109.5

128.2

155.9

30.6

171.7

186.4

Bajada del Palo Este

3.9

1.5

8.5

5.4

2.8

0.3

1.8

3.1

6.7

1.8

10.2

8.5

Charco del Palenque

0.6

0.1

0.5

0.7

0.0

0.0

0.0

0.0

0.6

0.1

0.5

0.7

Coirón Amargo Norte

0.6

0.2

1.0

0.8

0.0

0.0

0.0

0.0

0.6

0.2

1.0

0.8

Entre Lomas Rio Negro

3.3

1.7

9.4

5.0

0.4

0.5

3.1

1.0

3.7

2.2

12.5

6.0

Entre Lomas Neuquén

1.1

0.4

2.3

1.5

0.0

0.0

0.0

0.0

1.1

0.4

2.3

1.5

Jagüel de los Machos

2.0

0.5

3.1

2.6

0.1

0.0

0.1

0.1

2.1

0.6

3.2

2.7

Jarilla Quemada

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

25 de Mayo–Medanito

2.7

0.2

1.2

2.9

0.1

0.0

0.0

0.1

2.8

0.2

1.2

3.0

Acambuco

0.1

0.6

3.3

0.7

0.0

0.0

0.0

0.0

0.1

0.6

3.3

0.7

Aguada Federal

6.8

1.4

7.8

8.2

24.7

4.5

25.1

29.2

31.5

5.9

33.0

37.4

Bandurria Norte

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

0.0

Argentina Subtotal

68.3

17.7

99.2

86.0

136.8

24.9

139.7

161.7

205.1

42.5

238.9

247.7

Mexico:

CS-01

0.2

0.0

0.1

0.2

2.7

1.1

5.9

3.8

2.9

1.1

6.0

4.0

Mexico Subtotal

0.2

0.0

0.1

0.2

2.7

1.1

5.9

3.8

2.9

1.1

6.0

4.0

Total

68.5

17.7

99.3

86.2

139.5

25.9

145.6

165.4

208.0

43.6

244.9

251.6

(1) Our hydrocarbon liquid volumes include crude oil, condensate and NGL (LPG and natural gasoline). We do not include separate figures for NGL reserves because they represented less than 1% of our proved developed and undeveloped reserves as of December 31, 2022.

(2) Natural gas consumption represented 11% of total natural gas reserves (consumption plus natural gas sales) as of December 31, 2022.

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.

Office of Energy & Transportation

September 21, 2023

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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.

Response: We acknowledge the Staff’s comment, and in response, we propose to expand the disclosure in our future filings as set forth in the illustration below under the section “Item 4. Information on the Company—Business Overview—Oil and Natural Gas Reserves.”

Changes in our proved undeveloped reserves during 2022

As of December 31, 2022, we had an estimated volume of proved undeveloped reserves of 165.4 million barrels of oil equivalent (MMboe). This compares to an estimate of proved undeveloped reserves of 116.9 MMboe as of December 31, 2021. The total increase of 48.5 MMboe (41.4 MMbbl of crude oil, condensate and NGL and 40.2 Bcf of natural gas) in proved undeveloped reserves in 2022 is attributable to:

Argentina:

•

an increase of 41.48 MMbbl of crude oil, condensate and NGL and 40.45 Bcf of natural gas due to extensions and discoveries, mainly related to (a) the drilling of 13 wells (4 pads) targeting the Vaca Muerta formation in the Bajada del Palo Oeste concession (+14.08 MMbbl, +13.91 Bcf); (b) the drilling of two wells (one pad) in the Bajada del Palo Este concession (+2.71 MMbbl, +1.39 Bcf) and (c) the drilling of 28 wells (13 pads) in the Aguada Federal concession (+24.69 MMbbl, +25.15 Bcf);

•

a decrease of 3.43 MMbbl of crude oil, condensate and NGL and 3.48 Bcf of natural gas due to the conversion of proved undeveloped reserves to proved developed reserves as a result of the drilling of one undeveloped pad (four wells) targeting the Vaca Muerta unconventional reservoir in the Bajada del Palo Oeste concession in association with Trafigura;

•

an increase of 1.65 MMbbl of crude oil, condensate and NGL and 1.24 Bcf of natural gas due to the following revisions to previous estimates:

•

an increase of 0.87 MMbbl of crude oil, condensate and NGL and 1.00 Bcf of natural gas due to a higher than expected performance in the unconventional Bajada del Palo Oeste concession, resulting from a lateral length adjustment with no changes in the type curve profile on a per foot basis;

•

an increase of 0.58 MMbbl of crude oil, condensate and NGL and 0.96 Bcf of natural gas due to higher crude oil average prices and higher natural gas prices, respectively;

•

an increase of 0.21 MMbbl of crude oil, condensate and NGL and a decrease of 0.71 Bcf of natural gas due to changes to the development plan, including (a) an increase of 0.31 MMbbl of crude oil, condensate and NGL and 1.34 Bcf of natural gas in the Entre Lomas Rio Negro concession due to

Office of Energy & Transportation

September 21, 2023

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the addition of a well in the Charco Bayo oilfield targeting the Tordillo and Punta Rosada formations; (b) an increase of 0.12 MMbbl of crude oil, condensate and NGL and 0.13 Bcf of natural gas due to the addition of two wells and two workovers in the Jagüel de los Machos block and (c) an increase of 0.05 MMbbl of crude oil, condensate and NGL and 0.02 Bcf of natural gas due to minor changes in activity in the 25 de Mayo-Medanito block. These upward revisions to previous estimates due to changes to the development plan were partially offset by a decrease of 0.28 MMbbl of crude oil, condensate and NGL, and totally offset by a decrease 2.21 Bcf of natural gas in the Bajada del Palo Oeste concession resulting from the removal of two wells targeting the Lotena conventional formation;

•

an increase of 6.94 MMbbl of crude oil, condensate and NGL and 6.99 Bcf of natural gas due to the addition of four wells as proved undeveloped reserves in the Bajada del Palo Oeste concession (previously unproved reserves), partially offset by a decrease of 4.94 MMbbl of crude oil, condensate and NGL and 4.99 Bcf of natural gas due to the impact on reserves resulting from the un-incorporated joint venture and investment agreement entered into with Trafigura on October 11, 2022.

Mexico:

•

a decrease of 0.34 MMbbl of crude oil, condensate and NGL and 0.02 Bcf of natural gas due to an adjustment of the type curve after the Vernet-1001 well result.

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.

Response: We acknowledge the Staff’s comment, and in response, we clarify that the wells information shown under the sections “Productive Wells”, “Present Activities” and “Drilling Activities” does not include any non-operated wells. Our only non-operated concession is Acambuco, in which we hold a 1.5% working interest. As of December 31, 2022, Acambuco had a total of five productive wells (representing five gross wells and zero net wells for the Company). During the year ended December 31, 2022, we did not participate in any drilling activities in Acambuco. Further, we respectfully note that the wells presented in tabular format under the section “Present Activities” are already broken down between gross wells and net wells.

We propose to modify and expand the disclosure in future filings (i) to clarify that the number of wells shown does not include any non-operated wells and (ii) to reflect the number of net wells under “Drilling Activities,” as set forth below.

Productive Wells

As of December 31, 2022, our total gross and net operated productive wells in Argentina and Mexico were as follows. The table includes the total gross and net operated productive wells by us and our subsidiaries. We did not drill any exploratory wells during 2022.

Oil

Gas

Total

Gross

Net

Gross

Net

Gross

Net

Argentina

1,079

1,074

1,149

1,144

Mexico

Office of Energy & Transportation

September 21, 2023

Page

Figures are approximate amounts.

The wells set forth above are located in concessions that we operate. Our only non-operated concession is Acambuco, where we hold a 1.5% working interest. As of December 31, 2022, Acambuco had a total of five productive wells (representing five gross wells and zero net wells for the Company).

[…]

Present Activities

The following table shows the number of wells in Argentina and Mexico that are in the process of being drilled or are in active completion st