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International General Insurance Holdings Ltd.

74 Abdel Hamid Sharaf Street, P.O. Box 941428

Amman 11194, Jordan

November 8, 2024

VIA EDGAR

U.S. Securities & Exchange Commission

Division of Corporation Finance

Office of Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Michael Volley and Amit Pande

 Re: International General Insurance Holdings Ltd.

Form 20-F for Fiscal Year Ended December 31, 2023

File No. 001-39255

Dear Mr. Volley and Mr. Pande:

On behalf of International General Insurance Holdings Ltd. (the “Company”), we are responding to the comment letter
received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”),
dated October 1, 2024 (the “Comment Letter”), regarding the Company’s Form 20-F for fiscal year ended December
31, 2023 which was filed with the Commission on April 8, 2024 (the “20-F”).

Set forth below are the Company’s responses
to the Staff’s comments in the Comment Letter. For reference purposes, the Staff’s comments are reproduced in bold below,
followed by the Company’s response to the comment. The numbered paragraphs below correspond to the numbered comments in the Comment
Letter.

Form 20-F for Fiscal Year Ended December
31, 2023

Note 2. Summary of Significant Accounting Policies - (k) Deferred
policy acquisition costs, page F-13.

1. Please refer to prior comment 3. We note
the one-time policy election in ASC 944-30-25-1A was required to be made before fiscal years beginning after December 15, 2011. Considering
this election was not made when available, please revise to apply the guidance in ASC 944-30-25-1A and restate your financial statements
and related disclosure, or tell us why a restatement is not required. Refer to paragraph 59 in ASU 2018-09 for additional guidance.

Company response: We acknowledge
the Staff’s position that the one-time policy election in ASC 944-30-25-1A was required to be made before fiscal years beginning
after December 15, 2011. In deference to the view of the Staff, the Company agrees that we will begin to apply the accounting treatment
in accordance with the Staff’s position going forward beginning in our Form 20-F for the year ended December 31, 2024. The Company
will absorb the catch-up effect of this revised accounting treatment on the prior years in its financial statements for the year ended
December 31, 2024. In the letter below, we have described for the Staff our initial analysis of this matter, explained why the Company
has concluded that the error is not material and does not require a restatement, and provided the language we intend to include in our
Form 20-F for the year ended December 31, 2024 in order to address this matter.

First Time Adopter of US GAAP

While we acknowledge and accept the Staff’s
position on ASC 944-30-25-1A and will update our Form 20-F for the year ended December 31, 2024 accordingly, we would like to explain
to the Staff how we had reached our prior conclusion that the accounting policy election, as outlined in ASC 944-30-25-1A, was available
to us, as a first-time adopter of US GAAP on January, 1 2023.

Upon transitioning to US GAAP, we carefully reviewed
ASC 944-30-25-1A and paragraph 59 of ASU 2018-09, which we interpreted as allowing a one-time policy election to continue expensing costs
that had not been previously capitalized. This exemption, introduced by ASU 2010-26, set a deadline for this election before fiscal years
beginning after December 15, 2011.

We noted that the deadline for the policy election
under Topic 944-30-25-1A, as further outlined in ASU 2018-09, paragraph 59, had already passed. However, we believed that ASU 2018-09,
paragraph 59, was specifically intended to apply to existing companies that had already been filing under US GAAP, and did not address
or consider the position of first-time adopters transitioning from a different accounting framework, as typically US GAAP does not provide
guidance on first-time adoption.

Therefore, as there was no specific standard in
US GAAP governing first-time adoption, we relied on the principle that our Company, although new to US GAAP, should be treated as if we
had always been reporting under US GAAP. Consequently, we exercised the policy election under ASC 944-30-25-1A with the respective transition
requirements of the standard in line with how companies that had always applied US GAAP would have done, making the election within our
first set of US GAAP financial statements. This distinction was critical for us, as we transitioned from a separate reporting regime using
International Financial Reporting Standards (“IFRS”), where we had historically not capitalized internal acquisition costs,
even prior to the fiscal years in question. In our view, this distinction made us eligible for the exemption under the US GAAP framework.
In reaching our initial conclusion, we consulted with our accounting advisors and our policy election was discussed and agreed with our
external auditors.

Notwithstanding our reason for taking the election,
we acknowledge and accept the Staff’s position and thus we have quantified the impact of deferring the internal underwriting costs
related directly to the successful acquisition of new or renewal insurance and reinsurance contracts according to the guidance set forth
in ASC 944-30-25-1A and ASC 944-30-25-1AA. As described in the following section, we concluded that the error in making the one-time election
was immaterial to our financial statements and to the most relevant financial statement line items. Accordingly, given the Staff’s
view on this question, while we do not believe that a restatement of the financial statements is required, the Company agrees that we
will begin to apply the accounting treatment in accordance with the Staff’s position going forward beginning in our Form 20-F for
the year ended December 31, 2024 and we will absorb the catch-up effect of this revised accounting treatment on the prior years in our
financial statements for the year ended December 31, 2024. In the following section we present out materiality analysis, and in the subsequent
section we have presented the revised accounting policy disclosure we would propose to include in our next Form 20-F.

    2

Materiality assessment

Historically, the internal underwriting costs
related directly to the successful acquisition of new or renewal insurance and reinsurance contracts were expensed and recorded under
the line item “General and administrative expenses” in the statement of income. However, given the Staff’s position
that the policy election is not available, these internal underwriting costs that are directly related to the successful acquisition of
new and renewal of insurance and reinsurance contracts will be reclassified to “Net policy acquisition expenses” and deferred,
with amortization aligned with the earning of the corresponding premiums. These costs will continue to be reported within the expenses
section of the statement of income. In addition, the Company will recognize any deferred internal underwriting costs related to the successful
acquisition of new or renewal insurance and reinsurance contracts on the balance sheet under “Deferred policy acquisition costs,
net of ceding commission.”

To evaluate the materiality of the error, we considered
the guidance in ASC 250, which incorporates the guidance in Staff Accounting Bulletin (SAB) No. 99 “Materiality” and SAB No.
108 (SAB Topic 1.N: Quantifying Misstatements in Financial Statements). In accordance with the guidance, we have considered both quantitative
and qualitative factors in our assessment of materiality as described below.

The correction had an immaterial impact on the
Consolidated Balance Sheets, Consolidated Statements of Income, Consolidated Statements of Comprehensive Income, and Consolidated Statements
of Shareholders’ Equity for each period presented in the Form 20-F as of December 31, 2023.

There was no net impact on the Statements of Cash
Flows. Although net income increased, there was a corresponding offset in deferred policy acquisition costs within the net cash provided
by operating activities section of the Statement of Cash Flows.

Based on the materiality analysis performed, management
concluded that the correction had no material effect on key metrics (both GAAP and Non-GAAP), including net income, earnings per share,
underwriting income, combined ratio, return on average equity, core operating income, core operating income per share, and core operating
return on average equity. These metrics are considered relevant to investors and analysts. Management believes they provide meaningful
period-to-period comparisons, helping investors and analysts assess the Company’s performance and make informed decisions. Additionally,
management uses these key financial metrics to evaluate operating performance.

    3

The error also had an immaterial impact on the
results of the Company’s reportable segments.

As a result of this analysis, management concluded
that the error had no material impact on our key financial metrics, primary financial statements, or materially affected financial statement
line items for any period presented in the Form 20-F as of December 31, 2023. The tables below show the various financial metrics before
and after the correction.

Importantly, the error did not alter the trend
in the Company’s financial performance. Key financial metrics, including net income and basic and diluted earnings per share, continued
to reflect the same growth from fiscal year 2021 to fiscal year 2023 as was previously reported.

The correction did not impact the Company’s
financial statements for the year ended December 31, 2020 and earlier periods, as those were reported under IFRS. Under IFRS, we expensed
direct internal underwriting costs attributable to successful underwriting efforts, as allowed. Therefore, the correction does not affect
any of the Company’s results reported under IFRS.

The tables below reflect the impact of the correction
under the Rollover and Iron Curtain methods as prescribed by Staff Accounting Bulletin (SAB”) No. 108 (SAB Topic 1.N: Quantifying
Misstatements in Financial Statements) and ASC 250 (dollars in thousands, except per share amounts).

Rollover Method

    2021
    2022
    2023

    Deferred policy acquisition costs, net of ceding commission
    As stated
    $ 56,767
    $ 57,941
    $ 65,272

    Revised
    $ 58,262
    $ 59,631
    $ 66,964

    Change
    $ 1,495
    $ 1,690
    $ 1,692

    Change %
      2.6 %
      2.9 %
      2.6 %

    Net income for the year
    As stated
    $ 46,814
    $ 89,234
    $ 118,194

    Revised
    $ 47,187
    $ 89,429
    $ 118,196

    Change
    $ 373
    $ 195
    $ 2

    Change %
      0.8 %
      0.2 %
      -

    2021
    2022
    2023

    Income before tax
    As stated
    $ 48,628
    $ 92,166
    $ 126,048

    Revised
    $ 49,001
    $ 92,361
    $ 126,050

    Change
    $ 373
    $ 195
    $ 2

    Change %
      0.8 %
      0.2 %
      -

    Underwriting income
    As stated
    $ 103,970
    $ 148,630
    $ 183,089

    Revised
    $ 101,935
    $ 145,972
    $ 180,390

    Change
    $ (2,035 )
    $ (2,658 )
    $ (2,699 )

    Change %
      (2.0 )%
      (1.8 )%
      (1.5 )%

    4

    Net policy acquisition expenses
    As stated
    $ 59,622
    $ 70,199
    $ 74,976

    Revised
    $ 61,657
    $ 72,857
    $ 77,675

    Change
    $ 2,035
    $ 2,658
    $ 2,699

    Change %
      3.4 %
      3.8 %
      3.6 %

    Earnings per share (basic)
    As stated
    $ 0.98
    $ 1.85
    $ 2.58

    Revised
    $ 0.99
    $ 1.85
    $ 2.58

    Change
    $ 0.01
      -
      -

    Change %
      1.0 %
      -
      -

    Earnings per share (diluted)
    As stated
    $ 0.98
    $ 1.84
    $ 2.55

    Revised
    $ 0.99
    $ 1.85
    $ 2.55

    Change
    $ 0.01
    $ 0.01
      -

    Change %
      1.0 %
      0.5 %
      -

Iron Curtain Method

    2023

    Deferred policy acquisition costs, net of ceding commission
    As stated
    $ 65,272

    Revised
    $ 66,964

    Change
    $ 1,692

    Change %
      2.6 %

    Net income for the year
    As stated
    $ 118,194

    Revised
    $ 119,886

    Change
    $ 1,692

    Change %
      1.4 %

    5

    2023

    Income before tax
    As stated
    $ 126,048

    Revised
    $ 127,740

    Change
    $ 1,692

    Change %
      1.3 %

    Underwriting income
    As stated
    $ 183,089

    Revised
    $ 182,080

    Change
    $ (1,009 )

    Change %
      (0.6 )%

    Net policy acquisition expenses
    As stated
    $ 74,976

    Revised
    $ 75,985

    Change
    $ 1,009

    Change %
      1.3 %

    Earnings per share (basic)
    As stated
    $ 2.58

    Revised
    $ 2.61

    Change
    $ 0.03

    Change %
      1.2 %

    Earnings per share (diluted)
    As stated
    $ 2.55

    Revised
    $ 2.58

    Change
    $ 0.03

    Change %
      1.2 %

In addition to the quantitative and qualitative
considerations discussed above, the Company also noted the following in its qualitative analysis of materiality:

 - The correction did not mask a change in earnings or other
trends.

 - The correction did not hide a failure to meet analysts’
consensus expectations for the	enterprise.

 - The correction did not change a loss into income or vice
versa.

 - The correction did not affect the Company’s compliance
with regulatory requirements.

 - The correction did not affect the Company’s compliance
with loan covenants or other contractual requirements.

 - The correction did not have the effect of increasing management’s
compensation – for example, by satisfying requirements for the award of bonuses or other forms of incentive compensation.

 - The correction did not involve the concealment of an unlawful
transaction.

 - This error will not be an ongoing misstatement since the
company will correct the error in its next Form 20-F for the year ended December 31, 2024 by taking the full impact of deferring the
internal underwriting costs related to the successful acquisition of new or renewal insurance and reinsurance contracts.

    6

While the Company has determined that a correction
is appropriate to address the identified error, it concluded that the impact of the correction on the Company’s financial statements,
after assessing materiality and considering the quantitative and qualitative factors set forth above, was not material to the Company’s
previously issued consolidated financial statements.

The Company intends to correct the error in future
periodic reports filed with the SEC, as applicable, and will include appropriate disclosure in the Form 20-F for the year ended December
31, 2024. Based on actual results to date and forecasts for fiscal year 2024, the impact of correcting the error in our fiscal year 2024
financial statements is expected to remain within acceptable materiality thresholds, consistent with the impacts discussed for fiscal
years 2021 through 2023.

Revision to Form 20-F for the Year Ended December 31, 2024

The “Deferred policy acquisition costs”
accounting policy in our financial statements for the year ended December 31, 2023 provided as follows:

 (k) Deferred policy acquisition costs

Acquisition costs that are directly related and
incremental to the successful acquisition or renewal of business are deferred and expensed over the same period over which the corresponding
premiums are recognised, in accordance with the earning pattern of the underlying contract. The Company’s insurance and reinsurance
operations capitalize incremental direct external costs that result from acquiring a contract but do not capitalize salaries, benefits
and other internal underwriting costs. Policy acquisition costs are net of ceding commissions received on business ceded under certain
reinsurance contracts.

For our Form 20-F for the year ending December
31, 2024 a