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MINISO
Group holding limited

8F, M Plaza, No. 109,
Pazhou Avenue

Haizhu District,
Guangzhou 510000 Guangdong Province

The
People’s Republic of China

February 1, 2024

VIA EDGAR

Mr. Robert Shapiro

Mr. Doug Jones

Ms. Rebekah Reed

Mr. Dietrich King

Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    RE:
    MINISO Group
    Holding Limited (the “Company”)

    Annual Report on Form 20-F
    for the Fiscal Year Ended June 30, 2023

    Filed
    on October 19, 2023 (File No. 001-39601)

Dear
Mr. Shapiro, Mr. Jones, Ms. Reed
and Mr. King:

This
letter sets forth the Company’s response to the comments contained in the letter dated January 18, 2024 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 June 30, 2023 filed with the Commission on October 19, 2023 (the
 “2023 Form 20-F”) and the Company’s response to the Staff’s comments
regarding the 2022 Form 20-F submitted on December 13, 2023. The Staff’s comments are repeated below in bold and 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 2023 Form 20-F.

Form 20-F
for the Fiscal Year Ended June 30, 2023

Item
3. Key Information, page 4

 1. We
                                            note your response to prior comment 1, particularly the statement that your business operations
                                            in Hong Kong do not fall within the scope of relevant Hong Kong data security laws and regulations.
                                            In future filings, please further revise to disclose the basis for this conclusion and explain
                                            how data security and anti-monopoly regulations could materially impact your Hong Kong operations.
                                            Additionally, please provide the requested risk factor disclosure related to data security
                                            regulations in Hong Kong.

In
response to the Staff’s comment, the Company respectfully proposes to include the following revised disclosure (page reference
is made to the 2023 Form 20-F to illustrate the approximate location of the disclosure) in
its future Form 20-F filings (with further revisions shown in bold on top of the proposed disclosure in the Company’s prior
response), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

    Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission
 December 13, 2023
 Page 2

Pages 4 – 5

Doing Business in China

…

Risks
and uncertainties arising from the legal system in mainland China, including risks and uncertainties regarding the enforcement
of laws and quickly evolving rules and regulations in mainland China, could result in a material adverse change in our operations
and the value of our ADSs. For more details, see “Item 3. Key Information—D. Risk Factors—Risks Relating to Doing Business
in China—Uncertainties in the interpretation and enforcement of laws and regulations in mainland China could limit the legal
protections available to you and us.”

In
addition to our operations in mainland China, we have operations in Hong Kong. The operational
risks associated with being based in and having operations in mainland China also apply to operations in Hong Kong. While entities and
businesses in Hong Kong operate under different sets of laws from mainland China, the legal risks associated with being based in and
having operations in mainland China could apply to our operations in Hong Kong, if the laws applicable to mainland China become applicable
to entities and businesses in Hong Kong in the future.

We
believe that there is uncertainty as to whether the courts of Hong Kong would (i) recognize or enforce judgments of United States
courts obtained against us or our directors or officers predicated upon the civil liability provisions of the securities laws of the
United States or any state in the United States, or (ii) entertain original actions brought in Hong Kong against us or our directors
or officers predicated upon the securities laws of the United States or any state in the United States. A judgment of a court in the
United States predicated upon U.S. federal or state securities laws may been forced in Hong Kong at common law by bringing an action
in a Hong Kong court on that judgment for the amount due thereunder, and then seeking summary judgment on the strength of the foreign
judgment, provided that the foreign judgment, among other things, is (i) for a debt or a definite sum of money (not being taxes
or similar charges to a foreign government taxing authority or a fine or other penalty), and (ii) final and conclusive on the merits
of the claim, but not otherwise. Such a judgment may not, in any event, be so enforced in Hong Kong if (a) it was obtained by fraud,
(b) the proceedings in which the judgment was obtained were opposed to natural justice, (c) its enforcement or recognition
would be contrary to the public policy of Hong Kong, (d) the court of the United States was not jurisdictionally competent, or (e) the
judgment was in conflict with a prior Hong Kong judgment. Hong Kong has no arrangement for the reciprocal enforcement of judgments with
the United States. As a result, there is uncertainty as to the enforceability in Hong Kong, in original actions or in actions for enforcement,
of judgments of United States courts of civil liabilities predicated solely upon the federal securities laws of the United States or
the securities laws of any State or territory within the United States.

    Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission
 December 13, 2023
 Page 3

There
are relevant laws and regulations in Hong Kong regarding data security, such as the Personal Data (Privacy) Ordinance and the Unsolicited
Electronic Messages Ordinance, which impose obligations regarding the collection and handling of personal data in Hong Kong. As
of the date of this annual report, our business operations in Hong Kong do not engage in any collection of personal data. As such,
we believe that our business operations in Hong Kong do not fall within the scope of the laws and regulations currently effective
in Hong Kong regarding data security and we believe that data security laws and regulations in Hong Kong have no impact on our business
operations in Hong Kong. Were we to engage in a collection of personal data or other activities in Hong Kong that fall within the
scope of the relevant data security laws and regulations, we would have to ensure compliance with such laws and regulations, and any
violation thereof could result in a material adverse impact on our business, financial condition, and results of operations. However
In addition, new laws or regulations related to data security in Hong Kong may be enacted or promulgated in
the future, or the scope of our business operations in Hong Kong may change in the future, and such new
laws and regulations may also have a material impact on our business in Hong Kong.

Our
business operations in Hong Kong are also subject to the Competition Ordinance in Hong Kong, which prohibits anti-competitive agreements,
abuse of market power and anti-competitive mergers and acquisitions. As of the date of this annual report, no issues relating to the
Competition Ordinance or our compliance with the Competition Ordinance have resulted in any material impact on our ability to conduct
business. We are not now nor have ever been a party to any inquiries or investigations relating to the Competition Ordinance.

As
of the date of this annual report, regulatory actions related to data security or anti-monopoly concerns in Hong Kong do not have a material
impact on our ability to conduct business, accept foreign investment in the future, continue to list on a United States stock exchange
or maintain our listing status on the Hong Kong Stock Exchange. However, new regulatory actions related to data security or anti-monopoly
concerns in Hong Kong may be taken in the future, and such regulatory actions may have a material impact on our ability to conduct business,
accept foreign investment, continue to list on a United States stock exchange or maintain our listing status on the Hong Kong Stock Exchange.
For a detailed description of risks related to doing business in China, please refer to risks disclosed under “Item 3.D. Key Information—Risk
Factors—Risks Related to Doing Business in China.”

Pages 38 – 39

Failure
to protect personal or confidential information against security breaches could subject us to significant reputational, financial and
legal consequences and substantially harm our business and results of operations.

…

    Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission
 December 13, 2023
 Page 4

We are
constantly in the process of evaluating the potential impact of the PRC Cyber Security Law, the Data Security Law, the Personal Information
Protection Law and other laws, regulations and policies relating to cybersecurity, privacy, data protection and information security
on our current business practices. All these laws and regulations may result in additional expenses and obligations to us and subject
us to negative publicity, which could harm our reputation and negatively affect the trading price of the ADSs. We expect that these areas
will receive greater public scrutiny and attention from regulators and more frequent and rigid investigation or review by regulators,
which may increase our compliance costs and subject us to heightened risks and challenges. Despite our efforts to comply with applicable
laws, regulations and other obligations relating to cybersecurity, privacy, data protection and information security, it is possible
that our practices, offerings or services could fail to meet all of the requirements imposed on us by such laws, regulations or obligations.
We have not experienced any material breaches of any of our cybersecurity measures and we have not been subject to any penalties, fines,
suspensions, or investigations from the CAC. However, as uncertainties remain with respect to the interpretation and implementation of
these laws, regulations and policies regarding cybersecurity, privacy, data protection and information security and how these laws, regulations
and policies will be implemented in practice, we cannot assure you that we will comply with such laws, regulations and policies and we
may be ordered to rectify or terminate any actions that are deemed illegal by regulatory authorities. Any failure or perceived failure
to comply with these laws, regulations or policy may result in inquiries and other proceedings or actions against us by governmental
authorities, users, consumers or others, such as warnings, fines, penalties, required rectifications, service suspension or removal of
mobile apps from the relevant app stores and/or other sanctions, as well as negative publicity and damage to our reputation, which could
cause us to lose customers and business partners and have an adverse effect on our business and results of operations.

There
are relevant laws and regulations in Hong Kong regarding data security, such as the Personal Data (Privacy) Ordinance and the Unsolicited
Electronic Messages Ordinance, which impose obligations regarding the collection and handling of personal data in Hong Kong. As of the
date of this annual report, our business operations in Hong Kong do not engage in any collection of personal data. As such, we believe
that our business operations in Hong Kong do not fall within the scope of the laws and regulations currently effective in Hong Kong regarding
data security and we believe that data security laws and regulations in Hong Kong have no impact on our business operations in Hong Kong.
Were we to engage in a collection of personal data or other activities in Hong Kong that fall within the scope of the relevant data security
laws and regulations, we would have to ensure compliance with such laws and regulations, and any violation thereof could result in a
material adverse impact on our business, financial condition, and results of operations. In addition, new laws or regulations related
to data security in Hong Kong may be enacted or promulgated in the future, and such new laws and regulations may also have a material
impact on our business in Hong Kong.

…

    Division of Corporation Finance

Office of Trade & Services

Securities and Exchange Commission
 December 13, 2023
 Page 5

 2. We
                                            note your response to prior comment 2. In future filings, please further revise to elaborate
                                            on the “additional challenges” and “uncertainties and potential additional
                                            restrictions” presented by the data security regulations you have specified. Ensure
                                            that your disclosure allows investors to fully understand the impacts that these regulations
                                            have had or may have on your business operations and ability to accept foreign investment
                                            or maintain listing on a U.S. or foreign exchange.

In
response to the Staff’s comment, the Company respectfully proposes to include the following revised disclosure (page reference
is made to the 2023 Form 20-F to illustrate the approximate location of the disclosure) in
its future Form 20-F filings (with further revisions shown in bold on top of the proposed disclosure in the Company’s prior
response), subject to updates and adjustments to be made in connection with any material development of the subject matter being disclosed.

Pages 4 – 5

Doing Business in China

…

The
PRC government’s significant authority in regulating our operations and its oversight
over offerings conducted overseas by, and foreign investment in, China-based issuers could significantly limit or completely hinder our
ability to offer or continue to offer securities to investors. For example, the PRC Data Security Law and the PRC Personal Information
Protection Law in 2021 posed additional challenges to our cybersecurity and data privacy compliance.,
including without limitation, challenges in discharging our extra responsibilities in relation to establishing data security management
systems for our entire operational process, organizing education and training sessions on data security, employing corresponding technical
and other necessary measures to safeguard data security, formulating internal management systems and operating procedures, adopting corresponding
security technical measures, and preventing unauthorized access as well as breach, tampering, or loss of personal information.
The Cybersecurity Review Measures issued by the Cyberspace Administration of China, or the CAC and several other governmental authorities
in mainland China in December 2021, as well as and the Administration Regulations on
Cyber Data Security (Draft for Comments) published by the CAC for public comments in November 2021,
also resulted in uncertainties and potential additional restrictions on China-based overseas-listed companies like us.
For example, uncertainty exists as to the final form of the draft regulations and how the Cybersecurity Review Measures and the final
promulgated version of the draft regulations may be interpreted or implemented and whether the PRC regulatory agencies, including the
CAC, may adopt new regulations or detailed implementation ru