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March 10, 2023
Rajat Marwah
Chief Financial Officer
Algoma Steel Group Inc.
105 West Street
Sault Ste. Marie, Ontario
P6A 7B4, Canada
Re:Algoma Steel Group Inc.
Form 20-F for the Fiscal Year Ended March 31, 2022
Filed June 17, 2022
File No. 001-40924
Dear Rajat Marwah:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended March 31, 2022
Item 5. Operating and Financial Review and Prospects
Management's Discussion and Analysis
Non-IFRS Financial Measures, page 61
1.We note your discussion of the company's use of non-IFRS financial measures at the
beginning of your MD&A section before any discussion of the comparable IFRS
measures. This presentation without similar discussion and analysis of the comparable
IFRS measures with equal or greater prominence gives the non-IFRS measures more
prominence. Please revise your discussion accordingly or move the discussion to a
location in MD&A where the IFRS measures are presented with equal or greater
prominence. Refer to Question 102.10 of the C&DIs on Non-GAAP Financial Measures
on the SEC's Division of Corporation Finance website.

 FirstName LastNameRajat Marwah
 Comapany NameAlgoma Steel Group Inc.
 March 10, 2023 Page 2
 FirstName LastName
Rajat Marwah
Algoma Steel Group Inc.
March 10, 2023
Page 2
Overall Results, page 70
2.If your operations have experienced or are experiencing inflationary pressures or rising
costs, please expand to identify the principal factors contributing to the inflationary
pressures the company has experienced and clarify the resulting impact on the company.
Please also revise to identify actions planned or taken, if any, to mitigate inflationary
pressures.
Steel Revenue and Cost of Sales, page 71
3.We note from your disclosure on page 61 that net sales realization (NSR) and cost per ton
of steel products sold are financial measures that are not defined as IFRS measures. Your
steel revenue and costs of sales discussion and analysis on pages 71-73 are provided on a
non-IFRS basis without providing similar discussion and analysis of the the comparable
IFRS measures which gives the non-IFRS measures undue prominence. Please explain
how you presentation complies with Item(e)(1)(i)(A) of Regulation S-K or alternatively,
revise your discussion accordingly. Refer to Question 102.10 of the C&DIs on Non-
GAAP Financial Measures on the SEC's Division of Corporation Finance website for
further guidance.
Notes to the Consolidated Financial Statements
Significant Accounting Policies
Revenue Recognition, page F-18
4.We note your revenue recognition policy on page F-18; however, we do not consider the
information sufficient in meeting the disclosure objective of the paragraph 110 of IFRS
15. The objective of the disclosure requirements is for an entity to disclose sufficient
information to enable users of financial statements to understand the nature, amount,
timing, and uncertainty of revenue and cash flows arising from your contracts with
customers. Consideration should be given to the level of detail necessary to satisfy the
disclosure objective. The information should be specific to the company and avoid the use
of boilerplate language. In this regard, please revise to disclose specific information
regarding your performance obligations including, but not limited to, when you typically
satisfy your performance obligations (e.g. upon shipment, upon delivery,
etc.). Furthermore, provide disclosure regarding the methods, inputs and assumptions used
for allocating the transaction price, including allocating returns and allowances, trade
discounts, volume rebates discounts and other variable considerations. Your revised
disclosure should comply with the disclosure requirements outlined paragraph 116-129 of
IFRS 15, as applicable.

 FirstName LastNameRajat Marwah
 Comapany NameAlgoma Steel Group Inc.
 March 10, 2023 Page 3
 FirstName LastName
Rajat Marwah
Algoma Steel Group Inc.
March 10, 2023
Page 3

            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.
            You may contact Andi Carpenter at 202-551-3645 or Jean Yu, Assistant Chief
Accountant, at 202-551-3305 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing