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CORRESP
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    Manuel Garciadiaz

    manuel.garciadiaz@davispolk.com

    Davis
                                            Polk & Wardwell llp

450 Lexington Avenue

New York, NY 10017

    October 27, 2022

    Re:

    Afya Limited

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

    Filed April 29, 2022

    File No. 001-38992

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Trade & Services

100 F Street, N.E.

Washington, D.C. 20549

    Attn:
    Robert Shapiro

    Lyn Shenk

Ladies and Gentlemen:

On behalf of our client, Afya Limited (the “Company”),
this letter sets forth the Company’s responses to the comments provided by the staff (the “Staff”) of the Division
of Corporation Finance of the U.S. Securities and Exchange Commission (the “Commission”) in its letter dated October
13, 2022 (the “Comment Letter”). On April 29, 2022, the Company publicly filed an Annual Report on Form 20-F for the
fiscal year ended December 31, 2021 (the “Annual Report”) via the Commission’s Electronic Data Gathering, Analysis
and Retrieval system (“EDGAR”) to the Commission.

For the convenience of the Staff, each comment from the Comment Letter
is restated in italics prior to the Company’s response to such comment. All references to page numbers and captions (other than
those in the Staff’s comments) correspond to pages in the filed version of the Annual Report. We have also included our proposed
changes that we expect to include in future filings in response to each of the Staff’s two comments as Exhibit A and Exhibit
B hereto, respectively, as indicated below.

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

Item 3. Key Information

A. Selected Financial Data

Operating Data, page 11

 1. In the "Key Revenue Drivers" and "Key Operational Drivers" sections of your August 22, 2022 earnings release
you provide more extensive operating data than disclosed in the "Operating Data" table in your annual report. To the extent
this additional operating data is material to investors' understanding of your business, please consider revising to include the additional
data.

Response: The Company respectfully acknowledges the
Staff’s comment and advises the Staff that, the Company intends to include such additional operating data in future filings of its
annual reports, consistent with the information included in its August 22, 2022 earnings release. The

Company’s disclosure will be substantially consistent
with the disclosures included in Exhibit A hereto.

Item 5. Operating and Financial Review
and Prospects

A. Operating Results

Historical Consolidated Results of
Operations, page 109

 2. Please revise to quantify factors to which changes are attributed. For example, you disclose the increase in revenue was primarily
driven by: (i) organic revenue growth, mainly due to the maturation of medical school seats; (ii) consolidation of the results of operations
of acquired companies in 2021 including two Mais Medicos campuses opened at the end of 2020, (iii) increase in the average ticket of Medical
programs and, (iv) the fact that PEBMED has 12 months of net revenue in 2021, against approximately five months in 2020. Please also revise
to discuss and analyze results of operations for each of your reportable segments.

Response: The Company respectfully acknowledges the
Staff’s comment and advises the Staff that, in future filings, the Company intends to include additional information to quantify
factors to which changes are attributed and to discuss and to analyze results of operations for each of its reportable segments. The Company’s
disclosure will be substantially consistent with the disclosures included in Exhibit B hereto.

* * *

The new or enhanced disclosures proposed above in items 1 and 2 will
be included in our Form 20-F for the year ended December 31, 2022.

Please do not hesitate to contact me at +1-212-450-6095 or manuel.garciadiaz@davispolk.com
or Elliot M. de Carvalho at +55-11-4871-8405 or elliot.decarvalho@davispolk.com if you have any questions regarding the foregoing or if
I can provide any additional information.

Very truly yours,

/s/ Manuel Garciadiaz

Manuel Garciadiaz

    cc:
    Virgilio Deloy Capobianco Gibbon, Chief Executive Officer, Afya Limited

    Luis Andre Carpintero Blanco, Chief Financial Officer, Afya Limited

Exhibit A

Set forth below
is certain additional operating data on our key revenue drivers for our three reportable segments and key operational drivers for our
Digital Services segment:

Key Revenue Drivers – Undergrad Segment

    As of and for the fiscal year ended December 31,

    2021
    2020
    2019

    UNDERGRAD SEGMENT

    Medical School

    Approved Seats
      2,731
      2,143
      1,572

    Operating Seats
      2,481
      1,893
      1,222

    Total Students (end of period)
      16,017
      11,030
      6,597

    Average Total Students
      14,492
      9,413
      5,887

    Average Total Students (ex-Acquisitions)(1)
      10,872
      9,413
      5,887

    Tuition Fees (Total) (in R$ millions)
      1,511,442
      910,966
      550,208

    Tuition Fees (ex-Acquisitions) (in R$ millions)(1)
      1,123,944
      910,966
      550,208

    Medical School Gross Avg. Ticket (ex-Acquisitions)(R$/month)(1)(2)
      8,615
      8,065
      6,950

    Medical School Net Avg. Ticket (ex-Acquisitions)(R$/month)(1)(3)
      6,433
      N/A

      N/A

    Undergraduate Health Science

    Total Students (end of period)
      19,882
      10,325
      6,494

    Average Total Students
      15,918
      10,733
      6,588

    Average Total Students (ex-Acquisitions)(1)
      11,173
      10,733
      6,588

    Tuition Fees (Total) (in R$ millions)
      239,512
      152,539
      98,488

    Tuition Fees (ex-Acquisitions) (in R$ millions)(1)
      148,381
      152,539
      98,488

    Other Undergraduate

    Total Students (end of period)
      25,219
      14,851
      10,878

    Average Total Students
      20,198
      14,087
      10,613

    Average Total Students (ex-Acquisitions)(1)
      10,734
      14,087
      10,613

    Tuition Fees (Total)(in R$ millions)
      239,235
      172,961
      145,631

    Tuition Fees (ex-Acquisitions)(in R$ millions)(1)
      147,239
      172,961
      145,631

    Total Tuition Fees

    Tuition Fees (Total)(in R$ millions)
      1,990,189
      1,236,466
      794,327

    Tuition Fees (ex-Acquisitions)(in R$ millions)(1)
      1,419,574
      1,236,466
      794,327

 (1) For the fiscal year ended December 31, 2021, “ex-Acquisitions” excludes: UniRedentor (only
January 2021; Closing of UniRedentor was on January 31, 2020), UniSL (from January to April 2021; Closing of UniSL was in May 2020), FCMPB
(from January to October 2021; Closing of FCMPB was in November 2020), FESAR (from January to October 2021; Closing of FESAR was in November
2020), UNIFIPMoc and FIPGuanambi (from June to December 2021; Closing of UNIFIPMoc and FIPGuanambi was in June 2021), UNIGRANRIO (from
August to December 2021; Closing of UNIGRANRIO was in August 2021) and Garanhuns (from November to December 2021; Closing of Garanhuns
was in November 2021).

 (2) Medical School Gross Avg. Ticket (ex-Acquisitions) is calculated as Tuition Fees (ex-Acquisitions) divided
by the Average Total Students (ex-Acquisitions), divided by the number of months in the period.

 (3) Medical School Net Average Ticket (ex-Acquisitions) disclosure is presented beginning with the year ended
December 31, 2021 (and future periods), as information for calculation of this metric is not available for prior periods.

Key Revenue Drivers – Continuing Education Segment

    As of and for the fiscal year ended December 31,

    2021
    2020
    2019

    CONTINUING EDUCATION SEGMENT

    Medical Specialization & Others

    Total Students (end of period)
      3,189
      4,181
      1,588

    Average Total Students
      3,252
      4,266
      1,663

    Average Total Students (ex-Acquisitions)
      3,064
      4,266
      1,663

    Net Revenue (Total)(in R$ millions)
      72,983
      107,196
      60,193

    Net Revenue (ex-Acquisitions)(in R$ millions)(1)
      70,822
      107,196
      60,193

 (1) For the fiscal year ended December 31, 2021, “ex-Acquisitions” excludes UniRedentor (only
January 2021; Closing of UniRedentor was on January 31, 2020).

Key Revenue Drivers – Digital Services Segment

    As of and for the fiscal year ended December 31,

    2021
    2020
    2019

    DIGITAL SERVICES SEGMENT

    Content & Technology for Medical Education

    Medcel Active Payers

    Prep Courses & CME - B2P
      17,171
      11,316
      9,577

    Prep Courses & CME - B2B
      4,460
      1,723
      1,182

    Além da Medicina Active Payers
      —
      —
      —

    Cardio Papers Active Payers
      —
      —
      —

    Medical Harbour Active Payers
      —
      —
      —

    Clinical Decision Software

    Whitebook Active Payers
      125,372
      106,977
      —

    Clinical Management Tools(2)

    iClinic Active Payers
      17,978
      —
      —

    Shosp Active Payers
      2,305
      —
      —

    Digital Services Total Active Payers (end of period)
      167,286
      120,016
      12,347

    Net Revenue (Total)(in R$ millions)
      151,958
      93,152
      40,557

    Net Revenue - B2P (in R$ millions)
      142,716
      —
      —

    Net Revenue - B2B (in R$ millions)
      9,242
      —
      —

    Net Revenue (ex-Acquisitions)(in R$ millions)(1)
      99,003
      93,152
      40,557

 (1) For the fiscal year ended December 31, 2021, “ex-Acquisitions” excludes: PEBMED (from January
to July 2021; Closing of PEBMED was in July 2020), Medphone (from January to October 2021; Closing of Medphone was in November 2020),
iClinic (from January to December 2021; Closing of iClinic was in January 2021), Medicinae (from March to December 2021; Closing of Medicinae
was in March 2021), Medical Harbour (from April to December 2021; Closing of Medical Harbour was in April 2021), Cliquefarma (from April
to December 2021; Closing of Cliquefarma was in April 2021), Shosp (from May to December 2021; Closing of Shosp was in May 2021) and RX
PRO (from October to December 2021; Closing of RX PRO was in October 2021).

 (2) Clinical management tools include our telemedicine and digital prescription features.

Key Operational Drivers – Digital Services Segment –
Monthly Active Users (MaU)

    As of and for the fiscal year ended December 31,

    2021
    2020
    2019

    DIGITAL SERVICES SEGMENT

    Content & Technology for Medical Education
      16,205
      14,658
      —

    Clinical Decision Software
      194,308
      162,512
      —

    Clinical Management Tools(1)
      37,030
      —
      —

    Physician-Patient Relationship
      —
      —
      —

    Total Monthly Active Users (MaU) - Digital Services(2)
      247,543
      177,170
      —

 (1) Clinical management tools include our telemedicine and digital prescription features.

 (2) Monthly Active Users (MaU) represents the number of unique individuals
that consumed digital services content in each one of our products in the last 30 days of a specific period.

Exhibit B

Historical Consolidated Results of Operations

Year Ended December 31, 2021 Compared to the Year
Ended December 31, 2020

The following table sets forth our historical consolidated
income statement data for the years ended December 31, 2021 and 2020:

    For the Year Ended December 31,

    2021
    2020
    Variation (%)

    (in R$ millions, except for percentages)

    Net revenue
      1,719.4
      1,201.2
      43.1 %

    Cost of services
      (652.3 )
      (434.7 )
      50.1 %

    Gross profit
      1,067.1
      766.5
      39.2 %

    General and administrative expenses
      (622.6 )
      (402.9 )
      54.6 %

    Other income (expenses), net
      (3.6 )
      (0.3 )
      926.2 %

    Operating income
      440.9
      363.3
      21.3 %

    Finance income
      64.6
      62.3
      3.7 %

    Finance expenses
      (243.8 )
      (98.3 )
      148.1 %

    Finance result
      (179.2 )
      (36.0 )
      398.2 %

    Share of income of associate
      11.8
      7.7
      53.2 %

    Income before income taxes
      273.5
      335.1
      (18.4 )%

    Income taxes expense
      (31.2 )
      (27.1 )
      15.2 %

    Net income
      242.3
      308.0
      (21.3 )%

Net revenue

Net revenue for the year
ended December 31, 2021 was R$1,719.4 million, an increase of R$518.2 million, or 43.1%, from R$1,201.2 million for the year ended December
31, 2020. On a per segment basis, our net revenue was primarily affected by the following:

 · In our Undergrad segment, net revenue for the year ended December 31, 2021 was R$1,498.4 million, an increase
of 49.5%, or R$495.9 million, from R$1,002.5 million for the year ended December 31, 2020. This increase was primarily attributable to:
(i) organic revenue growth of 13.4%, mainly due to the maturation of medical school seats and an increase of 6.8% in the average ticket
of Medical programs, from an average ticket of R$8,065 in 2020 compared to R$8,615 in 2021, resulting in an increase of R$133.9 million
in our Undergrad segment’s net revenue in 2021; and (ii) consolidation of the results of operations of acquired companies in
2021 (Unifipmoc and Unigranrio) including two Mais Medicos campuses opened at the end of 2020 (Santa
Ines and Cruzeiro do Sul), resulting in an increase of R$209.3 million in our Undergrad segment’s net revenue;

 · In our Continuing Education segment, net revenue for the year ended December 31, 2021 was R$73.0 million,
a decrease of 31.9%, or R$34.2 million, from R$107.2 million for the year ended December 31, 2020. This decrease was primarily attributable
to a 23.7% reduction in active paying students (from 4,181 active paying students in 2020 compared to 3,189 active paying students in
2021), primarily because of: (i) in-person practical programs that have not been offered since the first half of 2020; and (ii) physicians’
decision to postpone admission to specialization courses due to the COVID-19 pandemic; and

 · In our Digital Services segment, net revenue for the year ended December 31, 2021 was R$147.9 million,
an increase of 61.6%, or R$56.4 million, from R$91.5 million for the year ended December 31, 2020. This increase was primarily attributable
to: (i) the consolidation of the results of operations of acquired companies

in 2021 (iClinic,
Medicinae, Medical Harbour, Cliquefarma, Shosp and RX Pro), resulting in an increase of R$22.8 million in our Digital Services segment’s
net revenue in 2021; and (ii) the fact that PEBMED had consolidated 12 months of net revenue in 2021, against approximately five months
of net revenue in 2020, as the PEBMED acquisition was closed in July 2020, resulting in an increase of R$38.5 million in our Digital Services
segment’s net revenue in 2021.

Cost of services

Cost of services for the
year ended December 31, 2021 was R$652.3 million, an increase of R$217.6 million, or 50.1%, from R$434.7 million for the year ended December
31, 2020. As a percentage of net revenue, our cost of services increased to 37.9% for the year ended December 31, 2021, compared to 36.2%
for the year ended December 31, 2020. On a per segment basis, our cost of services was primarily affected by the following:

 · In our Undergrad segment, cost of services for the year ended December 31, 2021 was R$555.0 million, an
increase of R$173.0 million, or 45.3%, from R$382.0 million for the year ended December 31, 2020. This increase was primarily attributable
to (i) the consolidation of the results of operations of acquired companies in 2021 (Unifipmoc and Unigranrio), resulting in an increase
of R$86.1 million in our Undergrad segment’s cost of services; (ii) an increase of R$17.4 million in 2021 in severance and
other cost