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March 16, 2023
Herman Billung
Chief Executive Officer
Himalaya Shipping Ltd.
S.E. Pearman Building, 2nd floor
9 Par-la-Ville Road
Hamilton HM 11, Bermuda
Re:Himalaya Shipping Ltd.
Registration Statement on Form F-1
Filed February 27, 2023
File No. 333-270337
Dear Herman Billung:
            We have reviewed your registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form F-1
Prospectus Summary
Listing, page 12
1.We note your disclosure that your previously issued common shares will remain listed on
the Euronext Expand and you intend to file the Norwegian Prospectus before the
Norwegian FSA for the admission to listing and trading of the common shares offered in
this public offering on Euronext Expand, upon which approval the Company intends to
publish the Norwegian Prospectus and your common shares will be tradeable from the
New York Stock Exchange to the Euronext Expand.  We also note your related disclosure
on page 39 that your common shares issued in this initial public offering will not be
immediately tradeable between the New York Stock Exchange and Euronext Expand.

 FirstName LastNameHerman Billung
 Comapany NameHimalaya Shipping Ltd.
 March 16, 2023 Page 2
 FirstName LastNameHerman Billung
Himalaya Shipping Ltd.
March 16, 2023
Page 2
Please revise to clarify whether investors will be able to purchase shares in one market
and sell shares in the other market.  If so, also explain how trading between the exchanges
would operate.
Risk Factors
Our bye-laws provide that the federal district courts of the United States of America are the sole
and exclusive forum, page 44
2.We note your disclosure regarding your exclusive forum provision in your bye-laws.
However, such provision does not appear to be set forth in your amended bye-laws filed
as Exhibit 3.3.  Please revise or advise.
Use of Proceeds, page 47
3.Please disclose the estimated net amount of the proceeds broken down into each principal
intended use thereof.  See Item 3.C of Form 20-F. In that regard, we note that you have
not disclosed the amount of proceeds that you intend to use to pay for the costs of the
scrubbers you describe in this section.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Bridge Facility, page 63
4.We note your disclosure regarding the Bridge Facility with DNB Markets.  Please file
such agreement as an exhibit, or provide your analysis as to why such agreement is not
required to be filed.  Refer to Item 601 of Regulation S-K.
Description of Share Capital, page 119
5.We note your response to prior comment 6 that indicates the waiver would not be
effective as a waiver of the right to sue for violations of the Securities Act or the
Exchange Act.  If you do not intend for this provision to be applicable to actions under the
Securities Act or Exchange Act, please revise to state this information, and tell us how
you will inform investors in future filings that the provision is not intended to apply to any
such actions. In addition, we note your disclosure regarding the exception in the provision
for actions involving fraud or dishonesty. However, it does not appear that such exception
is included in the provision as set forth in your amended bye-laws filed as Exhibit 3.3.
Please revise or advise.
            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.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.

 FirstName LastNameHerman Billung
 Comapany NameHimalaya Shipping Ltd.
 March 16, 2023 Page 3
 FirstName LastName
Herman Billung
Himalaya Shipping Ltd.
March 16, 2023
Page 3
            You may contact Lily Dang, Staff Accountant at 202-551-3867 or Mark Wojciechowski,
Staff Accountant at 202-551-3759 if you have questions regarding comments on the financial
statements and related matters. Please contact Michael Purcell, Staff Attorney at 202-551-5351
or Laura Nicholson, Special Counsel at 202-551-3584 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:       James McDonald