SecProbe.io

September 13, 2024
Jihan Wu
Chief Executive Officer
Bitdeer Technologies Group
08 Kallang Avenue
Aperia Tower 1, #09-03/04
Singapore 339509
Re:Bitdeer Technologies Group
Form 20-F for the Fiscal Year Ended December 31, 2023
File No. 001-41687
Dear Jihan 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 Ended December 31, 2023
Item 5. Operating and Financial Review and Prospects
Non-IFRS Financial Measures, page 77
1.Please revise your future filing disclosure to provide your discussion of Profit/(loss) for
the year/period before your disclosures of the Adjusted EBITDA and Adjusted Profit. The
IFRS amounts should be presented with equal or greater prominence than non-IFRS
measures.  Specifically, we note the non-IFRS disclosures are included on pages 77-78
before the IFRS measures, which are discussed in the Results of Operations section on
pages 85-93.  Refer to Question 102.10(a) of the Non-GAAP Compliance and Disclosure
Interpretations.

September 13, 2024
Page 2
Financial Statements
Note 2. Summary of Significant Accounting Policies
(q) Revenue recognition
Self-mining, page F-21
2.Please respond to the following and revise your disclosure in future filings as necessary to
address the following concerning your revenue recognition under IFRS 15:
•Tell us and disclose the payment mechanism(s) used by your mining pools (for
example, FPPS, PPLNS, etc.).
•Disclose, if true, that you consider the mining pool operators to be your
customers and you decide when to provide services under the contracts.
•You disclose that the contracts with mining pool operators are terminable at any time
by either party. Clarify whether or not your contracts are terminable at any time by
either party without penalty. If they are, revise your disclosure accordingly and tell us
your consideration for whether, as a result of the termination rights, the mining pool
agreement is continuously renewed for accounting purposes and the accounting
duration of your contracts is less than 24 hours. If true, tell us your consideration of
disclosing that your enforceable right to compensation only begins when, and
continues as long as, you provide hash computation services to the mining pools, the
duration of the contract is less than 24 hours and the contract continuously renews
throughout the day.
•Assuming you conclude that your contracts are continually renewed, tell us whether
you determined that the mining pool operator’s implied renewal option is not a
material right as the terms, conditions, and compensation amounts are at then market
rates. Refer to Appendix B40 of IFRS 15.
•You disclose that your only performance obligation is providing computing power.
Tell us whether a more accurate description of your promise is a service to perform
hash calculations for the pool operator, and if so, make corresponding revisions in
future filings to your accounting policy and related disclosures.
•Disclose how payments are generally calculated, including the various components of
the payment (for example, block reward, transaction fees, less pool operator fee) and
the period over which the computations take place (for example, generally midnight
to midnight UTC). Also disclose the nature of the noncash consideration received (for
example, bitcoin).
•You disclose that the Group recognizes the revenue when the variable consideration
is reasonably estimable and the performance obligation of providing computing
power has been satisfied. Disclose whether revenue is recognized on the same day
that control of the contracted service transfers to the mining pool operator. Refer to
IFRS 15.31.
•Clarify for us, by way of example, when and how you determine the amount of
revenue to recognize each day for the noncash consideration received and revise your
disclosure to clarify the timing and method of valuing the noncash consideration
received.

September 13, 2024
Page 3
Note 3. Use Of Judgments and Estimates, page F-33
3.We note your disclosure on pages 28, 37, 38, and F-33 that, "there is currently no specific
definitive guidance in IFRS or alternative accounting frameworks for the accounting for
the revenue from the self-mining business."  We are unclear how these statements are
consistent with management's responsibility to provide financial statements it asserts are
compliant with IFRS as issued by the IASB.  In that regard, we observe that the IFRS
accounting standards are the source of authoritative generally accepted accounting
principles and that there is guidance whose scope applies to your transactions.  Please
revise future filings to remove this disclosure.
            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.
            Please contact Kate Tillan at 202-551-3604 or David Irving at 202-551-3321 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets