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CORRESP
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CORRESP

 February 10, 2023

By Electronic Submission

 Mr. Robert S.
Littlepage

 Mr. Joseph Cascarano

 Office of Technology

 Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

Re:

IDEX Biometrics ASA

Form 20-F for the year ended December 31, 2021

Filed April 29, 2022

SEC File No. 001-39810

 Dear Mr. Littlepage and Mr. Cascarano:

Please find below our response to the comments regarding the above referenced filing provided by you in a letter to us dated January 4, 2023. We have
always taken our public filings seriously and we appreciate the time your staff has taken on this review.

 In response to your letter, set forth below is
the Staff’s comment in bold followed by the Company’s response to the Staff’s comment in regular type.

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

 Consolidated Statements of Changes in Equity, page F-5

1.
 We note your response to our prior comment and have considered the additional information you provided to us
during our call with you on November 8, 2022 to explain the nature and purpose of the Company’s reduction in share premium to offset against accumulated loss. However, we object to the Company’s reclassification of share
premium against accumulated loss. Please amend your Form 20-F for the fiscal year ended December 31, 2021 to restate your financial statements for the fiscal years ended
December 31, 2020 and 2021 accordingly. Alternatively, provide a materiality analysis to support your conclusion that the impact of the error is not material.

Response to Comment 1:

 The Company respectfully
acknowledges the Staff’s comments on this matter. In response to the Staff’s comments, the Company has revised its presentation of accounting losses absorbed by Share Premium and will make the following presentation changes and disclosures
in future filings:

•

 Reclassify the allocated Share Premium from Accumulated Loss by creating a new reserve, Capital Reduction
Reserve, on the Consolidated Statement of Financial Position and a column on the Consolidated Statement of Changes in Equity to reflect the absorption of accounting losses by the Share Premium. See below for the proposed presentation reflected on
the Company’s Consolidated Statement of Financial Position and the Consolidated Statement of Changes in Equity as of and for the year ended December 31, 2022.

 Consolidated Statements of Financial Position ($000s)

Note

December 31,
2022

December 31,
2021

 Assets

 Non-current assets:

 Goodwill

8

$
 968

 Intangible assets

8

1,965

 Property, plant, and equipment

9

1,301

 Right-of-use
assets

10

357

 Non-current receivables

87

 Total non-current assets

4,678

 Current assets:

 Prepaid expenses

851

 Inventory

13

1,234

 Accounts receivable, other

11

703

 Accounts receivable, trade

11

801

 Cash and cash equivalents

14

33,759

 Total current assets

37,348

 Total assets

$
42,026

 Equity and liabilities

 Share capital (NOK 0.15 par value per share, 1,166,326,584 and 1,010,388,454 shares issued and
outstanding at December 31, 2022 and 2021, respectively.

15

$
 20,410

 Share premium

15

9,452

 Share-based payment reserve

15

21,414

 Foreign currency translation effects

15

(12,312
)

 Capital reduction reserves

15

269,500

 Accumulated loss

15

(270,739
)

 Total equity

37,725

 Non-current liabilities:

 Non-current lease liabilities

10

11

 Total non-current liabilities

11

 Current liabilities:

 Accounts payable

12

685

 Current lease liabilities

10

362

 Public duties payable

393

 Other current liabilities

12

2,850

 Total current liabilities

4,290

 Total liabilities

4,301

 Total equity and liabilities

$
 42,026

 Consolidated Statements of Changes in Equity ($000s)

Share
Capital

Share
Premium

Share Based
payment
reserve

Foreign
Currency
Translation
Effect

Capital
Reduction
Reserve*

Accumulated
Loss*

Total
Equity

 Balance at December 31, 2019

$
15,445

$
197,639

$
15,903

$
(12,992
)

$
13,250

$
(211,433
)

$
17,812

 Share issuance

1,729

16,219

—

—

—

—

17,498

 Share-based compensation

77

—

2,761

—

—

—

2,838

 Net loss for the year

—

—

—

—

—

(26,754
)

(26,754
)

 Allocation of Share Premium

—

(210,250
)

—

—

210,250

—

—

 Other comprehensive income

—

—

—

670

—

—

670

 Balance at December 31, 2020

17,251

3,608

18,664

(12,322
)

223,500

(238,187
)

12,514

 Share issuance

3,107

51,205

—

—

—

—

54,312

 Share-based compensation

52

639

2,750

—

—

—

3,441

 Net loss for the year

—

—

—

—

—

(32,552
)

(32,552
)

 Allocation of Share Premium

—

(46,000
)

—

—

46,000

—

—

 Other comprehensive income

—

—

—

10

—

—

10

 Balance at December 31, 2021

$
20,410

$
9,452

$
21,414

$
(12,312
)

$
269,500

$
(270,739
)

$
37,725

 Share issuance

 Share-based compensation

 Net loss for the year

 Other comprehensive income

 Balance at December 31, 2022

$

$

$

$

$

$

$

*
 See Note 2: Basis of Presentation.

We propose adding the following disclosure in the notes to the financial statements to draw the reader’s attention to this presentation change:

Note to financial statements – Note 2: Basis of Presentation

During the year ended December 31, 2022, the Company revised its classification related to the presentation of Capital Reduction Reserve
to reflect the legal decision of the absorption of historical accounting losses into Share Premium. Previously, the Company presented allocation of Share premium to absorb losses as a component of Accumulated Loss. The Company changed its
presentation to reflect the amount of transfer losses to Share Premium separately from accumulated losses on the Consolidated Statements of Financial Position and Consolidated Statements of Changes in Equity. The Company has applied this change to
all periods.

 We propose adding the following disclosure in the notes to the financial statements to describe the
components of shareholders’ equity:

 Note to financial statements – Note 3: Accounting policies - Other accounting policies

 Equity is comprised of the following:

•

 Share Capital: comprised of the nominal amount of the parent’s ordinary shares. This capital is not
distributable in the form of dividends under the Norwegian Public Limited Liability Companies Act (the “PLLC Act”) (refer to Note 15: Share Capital and Share Premium).

•

 Share Premium: comprised of: (1) the amount received attributable to Share Capital, in excess of the nominal
amount of shares issued by the parent company, reduced by; (2) issuance costs directly attributable to the capital increase and; (3) transfers into the Capital Reduction Reserve, (refer to Note 15: Share Capital and Share Premium).

•

 Share Based Payment Reserve: comprised of Share-based payment reserve.

•

 Foreign Currency Translation Effects: comprised of Currency Translation Difference.

•

 Capital Reduction Reserve: comprised of the absorption of accumulated losses of the Company by the Share Premium,
as resolved by the Company’s Board of Directors (refer to Note 15: Share Capital and Share Premium).

•

 Accumulated Loss: is comprised of cumulative historical losses of the Company.

We propose including the below language in Note 15. Although the amounts are presented in the primary financial statements, this additional language will
explain the underlying decision and have the effect of making certain that financial statement users understand the transfer made of Share Premium.

Note to the financial statements – Note 15: Share Capital and Share Premium:

During the years ended December 31, 2021 and December 31, 2020, the Board of Directors, approved the transfer of $46.0 million
and $210.3 million, respectively, of Share Premium to absorb uncovered losses as allowed under Norwegian law. As a result, Share Premium has been reduced by a cumulative amount of $269.5 million as of the year ended December 31, 2021
and $223.5 million as of the year ended December 31, 2020 against Capital Reduction Reserve. The transfer has no impact on the total equity, comprehensive income (loss), assets (including cash) nor liabilities.

Analysis of Current Presentation

 We do not believe the
current presentation of the components of equity is inappropriate under IFRS, however we acknowledge there are other acceptable alternative presentations. As a result, we do not believe it is necessary amend and restate the 2021 Consolidated
Financial Statements to be compliant with IFRS. We believe the original presentation reflects the change of legal and economic nature of the absorption in an area in which IFRS does not have explicit guidance and there is diversity in other
regulatory environments. We also do not believe that the reclassification materially impacts a reasonable investor’s understanding of our financial position as discussed further below. Accordingly, we do not believe any revision of the
financial statement should be considered a correction of an error, but we believe that the suggested change in presentation noted above, should be treated as a reclassification in the 2022 Consolidated Financial Statements. We believe this is
consistent with how similarly situated issuers have treated similar changes previously.

 The components of equity historically presented by the Company
are consistent with widespread practice in Norway and other jurisdictions where the presentation of equity components often is aligned with the local regulation and reflect the legal nature and status of equity components based on local law. We
believe the IFRS framework and

standards are purposely not prescriptive regarding the components in equity to allow compatibility with different legal requirements. The Share Premium of the Company has been permanently reduced
due to the decision by the Company’s management and resolution by the Board of Directors to cover part of the accounting losses by allocation from one unrestricted equity component (i.e., Share Premium) to another unrestricted equity component
(i.e., Accumulated Loss).

 We believe that the legal framework in Norway with respect to the legality of distributions and the legal practices that
unrestricted equity components (which for the Company is all the equity reserves other than share capital) are available for distribution support the presentation of the approved reduction in share premium and corresponding transfer to the
accumulated losses in the 2021 financial statements.

 Furthermore, the Company is dual listed on Nasdaq and the Oslo Stock Exchange, and we have
identified several companies on the Oslo Stock Exchange using IFRS that also recorded loss allocations against share premium in 2020 and 2021 in order to align with the changed legal status of such reserves following the legal decision to absorb
accumulated losses by unrestricted share premium equity component, as allowed by Norwegian Company Law. Accordingly, we believe an inability to reduce share premium in a transparent manner could create confusion among investors in Norway giving the
diverse presentation.

 We also continue to believe there is no specific guidance on the transfer among equity components in the consolidated statement of
changes in equity in the IFRS standards. Paragraph 106 in IAS Presentation of Financial Statements requires disaggregation of equity into various components that should be identified in the Consolidated Statements of Changes in Equity and IAS
1.107 provides examples of such components without defining them. The Conceptual Framework 4.66, 7.12 and 7.13 reference legal, regulatory or other requirements that can affect particular components of equity, such as share capital and retained
earnings. Furthermore, paragraph 23 in IFRS 2 Share-based Payment states “However, this requirement does not preclude the entity from recognising a transfer within equity, i.e. a transfer from one component of equity to another.”
The wording in IFRS 9.B5.7.1 is another example illustrating the lack of prescription provided in the IFRS standards on equity components: “Amounts presented in other comprehensive income shall not be subsequently transferred to profit or loss.
However, the entity may transfer the cumulative gain or loss within equity.” BC.5.26 in IFRS 9 Financial Instruments states “An entity may transfer the cumulative gain or loss within equity. In the light of jurisdiction-specific
restrictions on components of equity, the IASB decided not to provide specific requirements related to that transfer.” In summary, equity components are not defined by IFRS and IFRS acknowledges that local laws and regulations may impact their
nature. Furthermore, there is no prescriptive guidance restricting transfers between components, and there are examples within the IFRS requirements explicitly allowing for such transfers. Also, we are not aware of any accompanying literature that
suggests any prescriptiveness on this matter. On this basis, we do not believe the previous presentation policy is necessarily in conflict with the requirements of IFRS.

Materiality Assessment

 As explained above, we do not
believe the revision of the presentation necessitates an amended Form 20-F for the fiscal year ended December 31, 2021. Reissuance of previously issued financial statements via a restatement is not
addressed by IFRS, but IAS 8 Accounting Policies, Changes in Accounting Estimate and IFRS Practice Statement 2 Making Materiality Judgements provides guidance on materiality that we have assessed.

We also considered aspects as to whether users of the financial statements may consider a reclassification material, noting that we do not believe they would.
Investors are primarily interested in our revenue pipeline and control of our operating expenses. The reclassification would not impact either of those items. The reclassification only impacts two components within equity and does not change total
equity. It also has no impact to total assets, total liabilities or total shareholders’ equity in the Consolidated Statements of Financial Position of the Company as of December 31, 2021. In addition, there was no impact to the
Consolidated Statement of Profit and Loss of the Company or to the Consolidated Statement of Cash Flows of the Company. As originally presented, the transfers from Share Premium to Accumulated Losses were on separate lines of the Consolidated
Statement of Changes to Equity and thus allowed users of the financial statements to easily identify the items. With our listing on the Oslo Stock Exchange and related financial reporting obligations, we contend that restating the 2021 Form 20-F financial statements could lead to investor confusion as there would be two different issued financial statements.

 We have also considered the guidance in SAB 99, “Materiality”, which provides several
considerations to evaluate materiality. While the amount involved alone is not insignificant, the impact of the reclassification is not material. The current presentation of a separate line showing the reclassification, was made such that the nature
and impact of the transfer was transparent to the users of the financial statements. The reclassification is within equity and thus has no impact on total equity, total assets and total liabilities. Further, we note that the reclassification
(1) does not arise from an estimate; (2) does not impact net income or mask any trend in earnings; (3) does not hide a failure to meet analysts’ consensus expectations; (4) did not result in a change from an income to a loss
position or vice versa; (5) does not materially impact a segment or business that plays a significant role in the Company’s operations or profitability; (6) did not have any impact on our compliance with any regulatory requirements;
(7) did not impact our financial covenants and contractual requirements; (8) was unrelated to metrics impacting manage