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June 25, 2024
How Meng Hock
Chief Executive Officer
OMS Energy Technologies Inc.
10 Gul Circle
Singapore 629566
Re:OMS Energy Technologies Inc.
Draft Registration Statement on Form F-1
Submitted May 29, 2024
CIK No. 0002012219
Dear How Meng Hock:
            We have reviewed your draft registration statement and have the following comments.
            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 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 the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional comments.
Draft Registration Statement on Form F-1
Risk Factors
We may not maintain the listing of our Ordinary Shares on the New York Stock Exchange...,
page 33
1.You state here that you intend to apply to list Ordinary Shares on the New York Stock
Exchange concurrently with this offering. However, your disclosure on the cover page
states that you “will not close this offering unless such Ordinary Shares will be listed on
the New York Stock Exchange at the completion of this offering.” Please confirm whether
this offering is conditional on the NYSE's approval of your listing.
Management's Discussion and Analysis of Financial Conditions and Results of Operations, page
51
2.We note that you have six reportable segments based on geographical regions. Please note
that information provided in your MD&A must relate to all separate segments and/or other

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June 25, 2024
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subdivisions (e.g., geographic areas, product lines) of the company. See Item 5 of Form
20-F.
Business, page 71
3.Please include a breakdown of total revenues by category of activity and geographic
market for each of the last three financial years. See Item 4.B.2 of Form 20-F.
Employees, page 88
4.We note that you have operations in Saudi Arabia, Indonesia, Malaysia, Brunei, Thailand,
and Singapore. Please disclose here the geographic location of employees as required by
Item 6.D of Form 20-F.
Consolidated Financial Statements
1 Organization and Principal Activities, page F-8
5.We refer to footnote (1) on page F-8, where you state you have control of two entities
through contractual arrangements. Please provide more robust disclosures regarding these
two subsidiaries in accordance with paragraphs 7 and 10 of IFRS 12.
2.7 Property and Equipment, page F-17
6.Please explain why you depreciate land. We refer to guidance in paragraph 58 of IAS 16.
Also, disclose the judgement and assumptions used to determine the depreciation of land
and buildings up to 60 years.
2.12 Cash and cash equivalents, page F-19
7.You disclose that cash and cash equivalents are comprised of cash in bank balances, cash
on hand and short-term fixed deposits with original maturities of six months or less. Tell
us why the maturity time period is six months or less and how you considered paragraph 7
of IAS 7 when determining this policy.
8.Disclose the jurisdiction(s) that holds your cash and cash equivalents and address to what
extent financial institutions in those jurisdictions insure your cash and cash
equivalents. Disclose any restrictions associated with the transfer of cash outside its
current jurisdiction(s).
2.18 Related Parties, page F-23
9.Disclose if your key management personnel, as well as close family members are related
parties. We refer to guidance in IAS 24.
17 - Segment Reporting, page F-32
10.With regard to your segment reconciliation, please specify and quantify items included in
the "others" column. Also, total assets and total liabilities do not reconcile to your

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 June 25, 2024 Page 3
 FirstName LastName
How Meng Hock
OMS Energy Technologies Inc.
June 25, 2024
Page 3
Consolidated Statements of Financial Position on page F-3. We refer to guidance in
paragraphs 21 and 28 of IFRS 8.
General
11.Once you have an estimated offering price or range, please explain to us how you
determined the fair value of the common stock underlying your equity issuances and the
reasons for any differences between the recent valuations of your common stock leading
up to the initial public offering and the estimated offering price. This information will help
facilitate our review of your accounting for equity issuances including
stock compensation. Please discuss with the staff how to submit your response.
12.Please provide us with supplemental copies of all written communications, as defined in
Rule 405 under the Securities Act, that you, or anyone authorized to do so on your behalf,
have presented or expect to present to potential investors in reliance on Section 5(d) of the
Securities Act, whether or not you retained, or intend to retain, copies of those
communications.
            Please contact Inessa Kessman at 202-551-3371 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Aliya Ishmukhamedova at 202-551-7519 or Mitchell Austin at 202-551-3574 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Yarona Yieh