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DiDi Global Inc.

No. 1 Block B, Shangdong Digital Valley

No. 8 Dongbeiwang West Road

Haidian District, Beijing

People’s
Republic of China

    February 13, 2023

    VIA EDGAR

    Ms. Mara
    Ransom

    Mr. Donald
    Field

    Mr. Joel Parker

    Mr. Scott
    Stringer

    Division of Corporate Finance

    Office of Trade & Services

    U.S. Securities and Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549

 Re: DiDi Global Inc. (the “Company”)

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

    Filed on May 2, 2022

    File
                                            No. 001-40541

Dear Ms. Ransom, Mr. Field, Mr. Parker
and Mr. Stringer,

This letter sets forth the
Company’s responses to the comments contained in the letter dated December 22, 2022 from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) regarding the Company’s annual report on Form 20-F
for the fiscal year ended December 31, 2021 filed with the Commission on May 2, 2022 (the “2021 Form 20-F”).
The Staff’s comments are repeated below in bold and are followed by the Company’s responses thereto. All capitalized terms
used but not defined in this letter shall have the meaning ascribed to such terms in the 2021 Form 20-F.

Annual Report on Form 20-F for the
Fiscal Year Ended December 31, 2021

Introduction, page 2

 1. We note that your definition of China and the PRC excludes Hong Kong, Macau and Taiwan. Please revise
to clarify that the legal and operational risks associated with operating in China also apply to operations in Hong Kong and Macau. This
disclosure may appear in the definition itself or in another appropriate discussion of legal and operational risks applicable to the company.

In response to the Staff’s comment,
the Company respectfully proposes to revise the referenced disclosure as shown below (page reference is made to the 2021 Form 20-F
to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through
and additions underlined). In addition, the Company respectfully advises the Staff that the proposed disclosure below does not include
Macau as the Company does not have operations in Macau Special Administrative Region.

      1

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

February 13, 2023

Page 2

Page 2:

“China” or the “PRC”
refers to the People’s Republic of China, excluding, for the purposes of this prospectus only, Hong Kong, Macau and Taiwan.

Page 3:

“Summary of Risk Factors

Below is a summary of material risks
we face, organized under relevant headings. All the operational risks associated with being based in and having operations in mainland
China as discussed in risk factors under “Item 3. Key Information—D. Risk Factors—Risks Relating to Our Business and
Industry” also apply to operations in Hong Kong Special Administrative Region. With respect to the legal risks associated with being
based in and having operations in mainland China as discussed in risk factors under “Item 3. Key Information—D. Risk Factors—Risks
Relating to Our Corporate Structure” and “Item 3. Key Information—D. Risk Factors—Risks Relating to Doing Business
in China,” the laws, regulations and discretion of mainland China governmental authorities discussed in this annual report are expected
to apply to mainland China entities and businesses, rather than entities or businesses in Hong Kong Special Administrative Region which
operate under a different set of laws from mainland China.”

 2. We note that your definition of “the VIEs” or “the variable interest entities”
refers to “our variable interest entities.” Please revise to refrain from using terms such as “we” or “our”
when describing activities or functions of the VIEs. For example, disclose, if true, that your subsidiaries and/or the VIE conduct operations
in China, that the VIE is consolidated for accounting purposes but is not an entity in which you own equity.

In response to the Staff’s comment,
the Company respectfully proposes to revise the referenced disclosure as shown below (page reference is made to the 2021 Form 20-F
to illustrate the approximate location of the disclosure) in its future Form 20-F filings (with deletions shown as strike-through
and additions underlined):

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

February 13, 2023

Page 3

Page 2:

 · “VIEs” refers to variable interest entities, and “the VIEs” or “the variable
interest entities” refers to our the variable interest entities whose financial results have been consolidated
into our consolidated financial statements based solely on contractual arrangements in accordance with U.S. GAAP, including the principal
variable interest entity, namely Beijing Xiaoju Science and Technology Co., Ltd. All of the VIEs are domestic PRC companies in
which we do not have any equity ownership but whose financial results have been consolidated into our consolidated financial statements
based solely on contractual arrangements in accordance with U.S. GAAP.

 · “We,” “us,” “our company” and “our” refers to DiDi Global
Inc., our Cayman Islands holding company and its subsidiaries, and, in the context of describing our operations and consolidated financial
information, the VIEs and their subsidiaries. it’s consolidated variable interest entities and the subsidiaries of the
consolidated variable interest entities.

Page 6:

DiDi Global Inc. is not an operating
company in China but a Cayman Islands holding company with no equity ownership in its VIEs.…… All of the VIEs are domestic
PRC companies in which we do not have any equity ownership but whose financial results have been consolidated into our consolidated financial
statements based solely on contractual arrangements in accordance with U.S. GAAP.

In addition, the Company further undertakes
to refrain from using terms such as “we” or “our” when describing activities or functions of the VIEs and to change
all instances of “our variable interest entities” to “the variable interest entities” and “our VIEs”
to “the VIEs” in its future Form 20-F filings.

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

February 13, 2023

Page 4

Summary of Risk Factors, page 3

 3. In your Summary of Risk Factors, disclose the risks that your corporate structure and being based in
or having the majority of the company’s operations in China poses to investors. In particular, describe the significant regulatory,
liquidity, and enforcement risks with specific cross-references (title and page number) to the more detailed discussion of these
risks in the annual report. For example, specifically discuss risks arising from the legal system in China, including risks and uncertainties
regarding the enforcement of laws and that rules and regulations in China can change quickly with little advance notice; and the
risk that the Chinese government may intervene or influence your operations at any time, or may exert more control over offerings conducted
overseas and/or foreign investment in China-based issuers, which could result in a material change in your operations and/or the value
of your securities. Acknowledge any risks that any actions by the Chinese government to exert more oversight and control over offerings
that are conducted overseas and/or foreign investment in China-based issuers could significantly limit or completely hinder your ability
to offer or continue to offer securities to investors and cause the value of such securities to significantly decline or be worthless.

In response to the Staff’s comment,
the Company respectfully proposes to include the following additional disclosure (page reference is made to the 2021 Form 20-F
to illustrate the approximate location of the disclosure) in “Risks Relating to Doing Business in China” under “Summary
of Risk Factors” section as shown below in its future Form 20-F filings (with additions underlined). The Company further undertakes
to provide the specific risk factor cross reference (with title and page number) to each risk disclosed in “Risks Relating
to Our Corporate Structure” and “Risks Relating to Doing Business in China” under the “Summary of Risk Factors”
section in its future Form 20-F filings.

Page 3:

“Risks
Relating to Doing Business in China

 · Uncertainties with respect to the PRC legal system could adversely affect us. The PRC governmental
authorities may continue to promulgate new rules and regulations or amend existing rules and regulations that could affect our
business operations. See “Item 3. Key Information—D. Risk Factors—Risks Relating to Doing Business in China—Uncertainties
with respect to the PRC legal system could adversely affect us.” on page 46.

 · The PRC government has jurisdiction over our business operations and may exercise discretion
                                                                                                                                pursuant to PRC laws and regulations. The PRC government may intervene or influence our operations by taking regulatory actions if
                                                                                                                                we fail to comply with applicable PRC laws, regulations or regulatory requirements, and our operations may be materially affected by
                                                                                                                                such regulatory actions, and if such regulatory actions are taken to exert oversight over offerings conducted overseas and/or
                                                                                                                                foreign investment in China-based issuers, our operations and the value of our securities may be materially affected. In the event
                                                                                                                                that we fail to comply with any PRC legal and regulatory requirement in relation to overseas securities issuance or foreign
                                                                                                                                investment, our ability to offer or continue to offer securities to investors could be significantly limited or completely hindered
                                                                                                                                and the value of such securities could significantly decline or be worthless. See “Item 3. Key Information—D. Risk
                                                                                                                                Factors—Risks Relating to Doing Business in China—We may be required to obtain approval or subject to filing or other
                                                                                                                                requirements from the CSRC or other PRC governmental authorities for any future listing or other financing activities” on
                                                                                                                                page 53 and “—The PRC government has jurisdiction over our business operations and may exercise discretion pursuant
                                                                                                                                to PRC laws and regulations. If we fail to comply with applicable PRC laws, regulations or regulatory requirements, our operations
                                                                                                                                and the value of our securities may be materially affected.” on page 46.

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

February 13, 2023

Page 5

 · You may experience difficulties in effecting service of legal process, enforcing foreign judgments
or bringing actions in China against us or our management named in this annual report based on foreign laws. All of our directors and
senior executive officers reside within China for at least a significant portion of the time, and it will be more difficult to enforce
liabilities and enforce judgments on those individuals. See “Item 3. Key Information—D. Risk Factors—Risks Relating
to Doing Business in China—You may experience difficulties in effecting service of legal process, enforcing foreign judgments or
bringing actions in China against us or our management named in this annual report based on foreign laws” on page 57.

Item 3. Key Information, page 6

 4. We note your disclosure regarding the permissions required for your operations. Revise to also disclose
each permission or approval that you, your subsidiaries, or the VIEs are required to obtain from Chinese authorities to offer your securities
to foreign investors. State whether you, your subsidiaries, or VIEs are covered by permissions requirements from the China Securities
Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any other governmental agency that is required to approve the
VIE’s operations, and state affirmatively whether you have received all requisite permissions or approvals and whether any permissions
or approvals have been denied. Please also describe the consequences to you and your investors if you, your subsidiaries, or the VIEs:
(i) do not receive or maintain such permissions or approvals, (ii) inadvertently conclude that such permissions or approvals
are not required, or (iii) applicable laws, regulations, or interpretations change and you are required to obtain such permissions
or approvals in the future. In this regard, we also note your disclosure that the company is subject to a cybersecurity review and rectification
measures in China. Revise to discuss in greater detail the current status of the company’s cybersecurity review to include details
regarding the review steps, specific rectification measures required to fully cooperate with such review and associated timing. Clarify
how your operations have been or, will be, impacted by such review (including whether your operations are expected to change once the
cybersecurity review is completed). We note certain responsive disclosure was contained in a Form 6-K filed on May 11, 2022,
however, we also note press reports that the apps you were required to take down have since been restored and that you were assessed a
fine for data breaches. Such disclosure should be updated, revised and additional specific details should be provided so that investors
can fully understand the current status of the company’s cybersecurity review and its impact on your business and operations. Lastly,
please revise the associated risk factor on page 15 and the annual report throughout accordingly.

In response to the Staff’s comment,
the Company respectfully proposes to include the following revised disclosure (page reference is made to the 2021 Form 20-F
to illustrate the approximate location of the disclosure) as shown below in its future Form 20-F filings (with additions underlined):

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

February 13, 2023

Page 6

Page 7:

“Permissions Required from
the PRC Authorities for Our Securities Offerings and Operations

Our operations in China are governed
by PRC laws and regulations. As of the date of this annual report, after consulting our PRC legal counsel, Fangda Partners, we believe
our PRC subsidiaries and the VIEs and their subsidiaries have obtained all the requisite licenses and permits
from the PRC government authorities that are material for our business operations in Chi