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September 25, 2023
Kevin Cox
Chief Executive Officer
Energys Group Ltd
Franklyn House, Daux Road
Billingshurst, West Sussex
RH149SJ
United Kingdom
Re:Energys Group Ltd
Amended Draft Registration Statement on Form F-1
Submitted September 14, 2023
CIK 0001971828
Dear Kevin Cox:
            We have reviewed your amended draft 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 providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  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 the information you provide in response to these comments and your
amended draft registration statement or filed registration statement, we may have additional
comments.
Draft Registration Statement on Form F-1 submitted September 14, 2023
Risk Factors
Risks Related to Our Business Operations, page 11
1.We note the revisions made in response to comment 4.  Please revise to add the negative
cash flow from operations for the periods disclosed.

 FirstName LastNameKevin Cox
 Comapany NameEnergys Group Ltd
 September 25, 2023 Page 2
 FirstName LastName
Kevin Cox
Energys Group Ltd
September 25, 2023
Page 2
Risks Related to Doing Business in Hong Kong and to Having Our Products Manufactured in
China
Limitations on our legal protections relative to our Hong Kong Subsidiaries and our products. ,
page 29
2.Please remove the mitigating language regarding your belief that a relocation would not
have a material adverse effect on your operations.  Such information is inconsistent with
other disclosure in this risk factor.
Enforceability of Civil Liabilities, page 30
3.We partially reissue comment 6.  Please add a discussion here and in your risk factors
regarding the risks associated with the enforcement of laws with respect to your products
manufacturing and intellectual property in China, including the ability to effect service of
process.  Please clearly disclose throughout the prospectus that the legal and operational
risks associated with operating in China also apply to operations in Hong Kong, and
remove disclosure that is inconsistent with this statement, such as in the risk factor on
page 29 regarding the limitations on legal protections in Hong Kong.
Use of Proceeds, page 32
4.We note your response to comment 7.  Please provide the bank prevailing rates for the
loans anticipated to be repaid as of a recent date.
History and Corporate Structure, page 51
5.We note your disclosure in response to comment 2.  Please state the reason for the
transfers of the Moonglade shares from Sky Shadow to Messrs. Cox and Adams.
Exhibits
6.We note a number of exhibits were filed in response to comment 13.  Please provide clear
disclosure regarding each of these material contracts.  We note, as examples only, that the
Arbuthnot credit facility discussed on pages 21 and 44 and the 8% Promissory
Notes discussed on page 43, have not been filed.  Please file these financing agreements or
tell us why they are not material contracts.
7.Please ensure that your filing includes all required exhibits and that such exhibits are filed
in a text searchable format, and to the extent applicable, with conformed signatures.  Refer
to Part II, Item 8 of Form F-1, Section 5.1 of the EDGAR Filer Manual (Volume II)
EDGAR Filing (Version 66) (June 2023), and Item 301 of Regulation S-T.

 FirstName LastNameKevin Cox
 Comapany NameEnergys Group Ltd
 September 25, 2023 Page 3
 FirstName LastName
Kevin Cox
Energys Group Ltd
September 25, 2023
Page 3
            You may contact Jeffrey Lewis at 202-551-6216 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Isabel Rivera at 202-551-3518 or Pam Howell at 202-551-3357 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Celia Velletri