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 April 15, 2025

Yeoh Chee Wei
Chief Executive Officer
Empro Group Inc.
21, Jalan 15/23, Tiong Nam Industry Park, 40200 Shah Alam
Selangor, Malaysia

 Re: Empro Group Inc.
 Amendment No. 5 to Registration Statement on Form F-1
 Filed March 31, 2025
 File No. 333-282155
Dear Yeoh Chee Wei:

 We have reviewed your amended registration statement and have the
following
comments.

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies 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 this letter, we may have additional comments. Unless
we note
otherwise, any references to prior comments are to comments in our February 11,
2025 letter.

Amendment No. 5 to Registration Statement on Form F-1 filed March 31, 2025
Operating Costs, page 49

1. Please expand your disclosure to fully explain how your 2024 cost of
goods sold
 decreased by 5% even though your total sales increased by 48%. See the
guidance in
 Item 5 of Form 20-F.
Statement of Profit or Loss and Other Comprehensive Income, page F-5

2. With reference to the material components of your operating costs
identified on page
 49, please explain how your presentation of cost of goods sold includes
all costs
 incurred necessary to generate revenue in the periods presented. Refer
to
 paragraph 103 of IAS 1.
 April 15, 2025
Page 2

Note 1 - Corporate Information, page F-11

3. We note that on November 4, 2024, Empro Group acquired 100% of EMP
Solutions'
 equity. Please address the following:
 In light of the November 4, 2024 acquisition date, please provide
the financial
 statements of the registrant, Empro Group. See Item 4. of Form F-1.
Ensure those
 financial statements appropriately reflect the historical operations
of EMP
 Solutions as required by common control accounting.
 Your disclosure on page 43 indicates that this transaction has been
accounted for
 using a merger method in accordance with Malaysia accounting
practices under
 IFRS for common control transactions. Please expand your disclosures
herein an
 on page 43 to discuss your accounting for this acquisition. In this
regard, we note
 that the audit report for EMP Solutions indicates that the financial
statements have
 been prepared in accordance with International Financial Reporting
Standards
 issued by the International Accounting Standards Board.
Note 3, page F-16

4. It appears that the disclosures outlined in paragraphs 22 and 32-34 of
IFRS 8 may be
 required. Please clarify for us how you considered this guidance.
Note 24, page F-44

5. With reference to the guidance in paragraph 64 of IAS 33, please address
why your
 EPS data does not give effect to the January 15, 2025 transaction
disclosed on page 8.
 In this regard, we note that your financial statements were authorised
for issue on
 March 21, 2025. See also SAB Topic 4:C.
 Please contact Al Pavot at 202-551-3738 or Jeanne Baker at 202-551-3691
if you
have questions regarding comments on the financial statements and related
matters. Please
contact Robert Augustin at 202-551-8483 or Katherine Bagley at 202-551-2545
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
Industrial Applications and
 Services
cc: Michael T. Campoli
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