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June 18, 2024
Jianfeng Wu
Co-Chief Financial Officer
Atour Lifestyle Holdings Limited
1st Floor, Wuzhong Building
618 Wuzhong Road
Minhang District, Shanghai , 201103
People's Republic of China
Re:Atour Lifestyle Holdings Limited
Form 20-F for the Fiscal Year Ending December 31, 2023
Filed April 26, 2024
File No. 001-40540
Dear Jianfeng Wu:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the fiscal year ending December 31, 2023
Item 3. Key information, page 1
1.At the outset of Item 3, provide prominent disclosure about the legal and operational risks
associated with being based in or having the majority of the company’s operations in
China. Your disclosure should make clear whether these risks could result in a material
change in your operations and/or the value of your securities or could significantly limit or
completely hinder your ability to offer or continue to offer securities to investors and
cause the value of such securities to significantly decline or be worthless. Your disclosure
should address how recent statements and regulatory actions by China’s government, such
as those related to data security or anti-monopoly concerns, have or may impact the
company’s ability to conduct its business, accept foreign investments, or list on a U.S. or
other foreign exchange.

 FirstName LastNameJianfeng  Wu
 Comapany NameAtour Lifestyle Holdings Limited
 June 18, 2024 Page 2
 FirstName LastNameJianfeng  Wu
Atour Lifestyle Holdings Limited
June 18, 2024
Page 2
2.Under Implication of the Holding Foreign Companies Accountable Act, please disclose
the location of your auditor’s headquarters.
Item 3.D. Risk Factors, page 4
3.In your summary of risk factors, disclose the risks that your corporate structure and having
the majority of the company’s operations in China poses to investors. In particular,
describe the significant regulatory, liquidity, and enforcement risks with cross-references
to the more detailed discussion of these risks elsewhere. For example, specifically discuss
risks arising from the legal system in China, including risks and uncertainties regarding
the enforcement of laws and that rules and regulations in China can change quickly with
little advance notice; and the risk that the Chinese government may intervene or influence
your operations at any time, or may exert more control over offerings conducted overseas
and/or foreign investment in China-based issuers, which could result in a material change
in your operations and/or the value of your securities. Acknowledge any risks that any
actions by the Chinese government to exert more oversight and control over offerings that
are conducted overseas and/or foreign investment in China-based issuers could
significantly limit or completely hinder your ability to offer or continue to offer securities
to investors and cause the value of such securities to significantly decline or be worthless.
Risks Related to Doing Business in China, page 29
4.We note the changes made to your disclosure in this section, including the risk factors on
pages 29, 30, 36, and 39, compared to the language used in your initial public offering
registration statement. However, it is unclear that there have been changes in the
regulatory environment in the PRC since your initial public offering registration statement
was filed that would warrant the revised disclosure mitigating the risks related to doing
business in China. Please tell us and revise your disclosure in future filings to revert to the
language used in your initial public offering registration statement on Form F-1 dated
November 7, 2022. Additionally, please tell us and revise your disclosure in future filings
to explain the basis for your statement on page 30 that: “The overall effect of legislation
over the past three decades has significantly enhanced the protections afforded to various
forms of foreign investments in China.”
Item 5. Operating and Financial Review and Prospects
5E. Critical Accounting Estimates
Customer loyalty program, page 90
5.Please revise your disclosure in future filings to include your estimate of breakage for all
periods along with a sensitivity analysis illustrating the impact of the breakage estimate on
revenue.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.

 FirstName LastNameJianfeng  Wu
 Comapany NameAtour Lifestyle Holdings Limited
 June 18, 2024 Page 3
 FirstName LastName
Jianfeng  Wu
Atour Lifestyle Holdings Limited
June 18, 2024
Page 3
            Please contact Babette Cooper at 202-551-3396 or Mark Rakip at 202-551-3573 if you
have questions regarding comments on the financial statements and related matters. Please
contact Ronald E. Alper at 202-551-3329 or Brigitte Lippmann at 202-551-3713 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Kevin Zhang