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CORRESP

 Huize Holding Limited

49/F, Building T1, Qianhai Financial Centre, Linhai Avenue

Qianhai Shenzhen-Hong Kong Cooperation Zone

Shenzhen 518000

 People’s
Republic of China

 April 22, 2022

VIA EDGAR

 Mr. Robert Klein

Mr. Marc Thomas

 Division of Corporation Finance Office of
Finance

 U.S. Securities and Exchange Commission

 100 F
Street, NE

 Washington, D.C. 20549

Re:
 Huize Holding Limited (the “Company”)

Form 20-F for the Fiscal Year Ended December 31, 2020

Filed on March 22, 2021

File No. 001-39216

Dear Mr. Klein and Mr. Thomas:

 This
letter sets forth the Company’s responses to the comments contained in the letter dated April 12, 2022 from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding
the Company’s Form 20-F for the fiscal year ended December 31, 2020 (the “2020 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 2020 Form 20-F.

Form 20-F for the Fiscal Year Ended December 31, 2020

Part I, page 4

1.
 In future filings, please revise to also disclose that, in addition to the potential significant decline in
value of the Class A common shares or ADSs, these securities may become worthless.

 In response to the
Staff’s comment, the Company proposes to add, at the onset of Part I, the disclosure substantially in the form below in its future Form 20-F filings:

 Securities and Exchange Commission

April 22, 2022

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 2

 “We face various legal and operational risks and uncertainties
associated with being based in or having our operations primarily in China and the complex and evolving PRC laws and regulations. For example, we face risks associated with regulatory approvals on offerings conducted overseas by and foreign
investment in China-based issuers, the use of the VIE, anti-monopoly regulatory actions, oversight on cybersecurity and data privacy, as well as the lack of PCAOB inspection on our auditors, which may impact our ability to conduct certain
businesses, accept foreign investments, or list on or remain listed on a United States or other foreign exchange. These risks could result in a material adverse change in our operations and the value of our ADSs, significantly limit or completely
hinder our ability to offer or continue to offer securities to investors, or cause the value of such securities to significantly decline or become worthless. For a detailed description of risks related to doing business in China, see
“Item 3. Key Information—D. Risk Factors—Risks Relating to Doing Business in China.””

2.
 We note your response to comment 3. In future filings, please revise to indicate that the information to be
disclosed will be included within Part I of the document (i.e. the Form 20-F) as previously requested, in addition to presenting the information in a risk factor.

In response to the Staff’s comment, the Company proposes to add, at the onset of Part I, the disclosure substantially in the form below in
its future Form 20-F filings:

 “In addition, since our auditor is
headquartered in the mainland of China, a jurisdiction where the PCAOB has been unable to conduct inspections without the approval of the Chinese authorities, our auditor is currently not inspected by the PCAOB. As a result, our ADSs may be delisted
and our ADSs and shares may be prohibited from trading in the over-the-counter market under the Holding Foreign Companies Accountable Act. The delisting of our ADSs, or
the threat of their being delisted, may materially and adversely affect the value of your investment. Additionally, the inability of the PCAOB to conduct inspections deprives our investors with the benefits of such inspections. For a detailed
description of risks related to doing business in China, see “Item 3. Key Information—D. Risk Factors—Risks Relating to Doing Business in China.””

3.
 In future filings, please revise to update the proposed disclosures regarding Chinese laws, rules and
regulations, including the CAC and CSRC.

 The Company undertakes to include appropriate disclosure of developments
and updates regarding Chinese laws, rules and regulations, including the CAC and CSRC, by the time it files its annual report on Form 20-F for the fiscal year ended December 31, 2021 and onwards.

 Securities and Exchange Commission

April 22, 2022

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4.
 We refer to the response to comment 4 of your letter dated October 21, 2021. We note that the Company
intends to include in future filings, early in Item 3, the organizational structure diagram as shown in Item 4. In addition to the proposed disclosures included in the response to comment 4, please revise your disclosures, in future filings, to also
include the following items.

•

 The diagram should show the structure of the company, including the domicile using dotted lines to show
contractual relationships as opposed to solid lines.

•

 The diagram should clearly identify the entity in which investors hold their interest and the entities in
which the company’s operations are conducted.

 The Company undertakes to present its organizational structure
diagram, early in Item 3 and in Item 4.C, in the manner as requested by the Staff in its annual report on Form 20-F for the fiscal year ended December 31, 2021 and onwards. Please find the below
organizational structure diagram to be included in the annual report on Form 20-F for the fiscal year ended December 31, 2021 as an example:

5.
 We note your response to comment 2. In future filings, please revise to address whether such permissions or
approvals are required and whether the Company consulted with legal counsel, and if not, please explain the reasons why.

 Securities and Exchange Commission

April 22, 2022

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In response to the Staff’s comment, the Company proposes to include the disclosure substantially in the form below under a subsection at the onset of Item 3 titled “Permissions Required
from the PRC Authorities for Our Operations” in its future Form 20-F filings:

“We conduct our business primarily through our PRC subsidiary, the VIE and its subsidiaries in China. Our operations in
China are governed by PRC laws and regulations. As of the date of this annual report, as advised by Commerce & Finance Law Offices, our legal counsel as to PRC Law, our PRC subsidiary, the VIE and its subsidiaries have
obtained the requisite licenses and permits from the PRC government authorities that are material for the business operations of our holding company, the VIE and its subsidiaries in the PRC in all material respects, including, among others, the
value-added telecommunications business operating license, the license to operate insurance brokerage business, the license to operate insurance agency business, the record-filing certificate on insurance adjustment assessment business and the
record-filing certificate on the graded protection of information system security. Any failure to obtain or delay in obtaining such permissions or approvals, or a rescission of any such approval if obtained by us, would subject us to sanctions by
the applicable PRC regulatory authorities. These regulatory authorities may impose fines and penalties on our operations in China, limit our ability to pay dividends outside of China, limit our operating privileges in China, delay or restrict the
repatriation of the proceeds from our offshore offerings into China or take other actions that could materially and adversely affect our business, financial condition, results of operations, and prospects, as well as the trading price of our
ADSs.”

6.
 We refer to the response to comment 7 from your letter dated October 21, 2021. With regard to the
Company’s discussion of cash flows through their organization in the response, please address the following in future filings.

•
 Please disclose whether you have difficulty in transferring cash to/from the holding company, the subsidiaries,
the VIEs, and investors.

•
 Please include quantitative disclosure regarding the transfer of cash to/from the holding company, the
subsidiaries, the VIEs and investors.

•
 Please include cross-references to the condensed consolidating schedule and the consolidated financial
statements.

•
 Please disclose, or cross-reference to the relevant section at the onset of Part 1 whether or not you have cash
management policies that dictate how funds are transferred between the VIEs and your subsidiaries. If you have such policies, also cross reference them to a more detailed description at the onset of Item 3.

 Securities and Exchange Commission

April 22, 2022

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•
 Please disclose here, at the onset of Item 3, in the summary of risk factors section and the risks factor
section that there is no assurance that the PRC government will not intervene or impose restrictions on the company’s ability to transfer cash.

The Company undertakes to address the Staff’s comments in its annual report on Form
20-F for the fiscal year ended December 31, 2021 and onwards. Please find below proposed disclosure of cash flows through its organization in the annual report on Form
20-F for the fiscal year ended December 31, 2021 as an example:

 “Cash Flows through
Our Organization

 We have established stringent controls and procedures for cash flows within our
organization. Each transfer of cash between our Cayman Islands holding company and a subsidiary, the VIE or the subsidiaries of the VIE is subject to internal approval. The cash of our group is under the unified management of our finance department,
and is dispatched and applied to each operating entity based on the budget and operating conditions of the specific operating entity. Each cash requirement, after raised by an operating entity, is required to go through a three-level review process
of our finance department. The funding team of the finance department will allocate the cash to the operating entity after the application for cash requirement is approved by the responsible person in the finance department. To date, we have not had
difficulty in transferring cash between our Cayman Islands holding company and a subsidiary, the VIE or the subsidiaries of the VIE. The cash inflows of the Cayman Islands holding company were primarily generated from our initial public offering in
February 2020. In 2020 and 2021, the Cayman Islands holding company transferred cash in the total amount of RMB196.7 million (US$30.9 million) to our PRC subsidiary and the subsidiaries of the VIE through our offshore intermediate holding
entities in two methods: (i) Hong Kong Smart Choice Ventures Limited, our Hong Kong subsidiary, made capital contribution to Zhixuan International Management Consulting (Shenzhen) Co., Ltd., our WFOE, in the amount of RMB0.5 million in
2020, and RMB129.5 million (US$20.3 million) in 2021; our WFOE and its subsidiary then provided inter-company loan of RMB128.0 million (US$20.1 million) to the VIE in 2021; (ii) through cross-border guarantee, where our Hong Kong
subsidiary provided guarantee to certain China-based commercial banks or their offshore branches by pledging offshore cash deposits, and the onshore branches of these banks granted loans to the subsidiaries of the VIE, namely, Huize Insurance
Brokerage Co., Ltd. and Shenzhen Huize Shidai Co., Ltd, in the amount of RMB85.4 million in 2020, and RMB14.0 million (US$2.2 million) in 2021. The subsidiaries of the VIE repaid the loan in a total amount of RMB32.7 million (US$5.1
million) in 2021. For the years ended December 31, 2019, 2020 and 2021, no assets other than cash were transferred between our Cayman Islands holding company and a subsidiary, no

 Securities and Exchange Commission

April 22, 2022

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subsidiaries paid dividends or made other distributions to the Cayman Islands holding company, and no dividends or distributions were paid or made to U.S. investors. We intend to settle service
fees under our contractual arrangements with the VIE when there is a business need and as our WFOE sees fit. For details of the financial position, cash flows and results of operations of the VIE and its subsidiaries, see “Item 3. Financial
Information Related to the Consolidated Variable Interest Entity.”

 As a Cayman Islands holding company, we may
receive dividends from our PRC subsidiary through Hong Kong Smart Choice Ventures Limited. The Enterprise Income Tax Law of the PRC, or the EIT Law, and its implementing rules, provide that dividends paid by a PRC entity to a nonresident enterprise
for income tax purposes is subject to PRC withholding tax at a rate of 10%, subject to reduction by an applicable tax treaty with China.

Dividends paid by our wholly foreign-owned subsidiary in China to our intermediate holding company in Hong Kong will be subject
to a withholding tax rate of 10%, unless the relevant Hong Kong entity satisfies all the requirements under the Arrangement between China and the Hong Kong Special Administrative Region on the Avoidance of Double Taxation and Prevention of Fiscal
Evasion with respect to Taxes on Income and Capital and receives approval from the relevant tax authority. If our Hong Kong subsidiary satisfies all the requirements under the tax arrangement and receives approval from the relevant tax authority,
then the dividends paid to the Hong Kong subsidiary would be subject to withholding tax at the standard rate of 5%. Effective from November 1, 2015, the above mentioned approval requirement has been abolished, but a Hong Kong entity is still
required to file application package with the relevant tax authority, and settle the overdue taxes if the preferential 5% tax rate is denied based on the subsequent review of the application package by the relevant tax authority. Furthermore,
effective from January 1, 2020, a Hong Kong entity is entitled to judge by itself that it meets the conditions for entitlement to such treaty benefits. It could obtain such entitlement by itself at the time of making tax returns, or at the time
of making withholding declarations via withholding agents. At the same time, the Hong Kong entity shall collect, gather and retain relevant materials for future reference in accordance with applicable rules, and shall accept the follow-up administration of tax authorities. In addition, there is no assurance that the PRC government will not intervene or impose restrictions on our ability to transfer cash in the future. See “Item 3. Key
Information—D. Risk Factors— Risks Relating to Our Corporate Structure—We may rely principally on dividends and other distributions on equity paid by our WFOE to fund any cash and financing requirements we may have, and any limitation
on the ability of our WFOE to pay dividends to us could have a material adverse effect on our ability to conduct our business.”

 Securities and Exchange Commission

April 22, 2022

 Page 7

 If our holding company in the Cayman Islands or any of our subsidiaries
outside of the mainland of China were deemed to be a “resident enterprise” under the PRC Enterprise Income Tax Law, it would be subject to enterprise income tax on its worldwide income at a rate of 25%. See “Item 3. Key
Information—D. Risk Factors—Risks Relating to Doing Business in China— If we are classified as a PRC resident enterprise for PRC income tax purposes, such classification could result in unfavorable tax consequences to us and our non-PRC shareholders or ADS holders.”

 For purposes of illustration, the following
discussion reflects the hypothetical taxes that might be required to be paid within China, assuming that: (i) we have taxable earnings, and (ii) we determine to pay dividends in the future:

Taxation Scenario(1)

Statutory Tax and Standard Rates

 Hypothetical pre-tax earnings(2)

100
%

 Tax on earnings at statutory rate of
25%(3)

(25
%)

 Net earnings av