SCHLUETER & ASSOCIATES, P.C.

5655 SOUTH YOSEMITE STREET, SUITE 350

GREENWOOD VILLAGE, CO 80111

TELEPHONE: +1-303-292-3883

FACSIMILE: +1-303-648-5663

Email: hfs@schlueterintl.com

June 3, 2024

VIA EDGAR

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attn: Ms. Isabel Rivera

Dear Ms. Rivera:

We represent Energys Group Limited (the “Company” or the “Registrant”) as U.S. counsel. We are filing herewith Amendment 6 to the Company’s Registration Statement on Form F-1 relating to a proposed initial public offering in the United States of the Company’s Ordinary Shares.

The purpose of this letter is to respond to the comment letter dated May 24, 2024 from the Division of Corporation Finance, Office of Real Estate and Construction (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission” or “SEC”) relating to Amendment 5 of the Company’s Registration Statement. For your convenience, the comments have been reproduced below, followed by the Company’s response.

Amendment No. 5 to Form F-1 filed May 10, 2024

General

Response:

In response to this comment, the Registrant supplementally informs the Staff as follows:

The Ordinary Shares previously held by Majestic Dragon Investment Co., Limited were contributed to Bright Forever Investments Limited on April 24, 2024 and the Preferred Shares were contributed to Bright Forever Investments Limited on April 26, 2024. The consideration paid for the Ordinary Shares was US$1.00; the same amount was paid for the Preferred Shares. Please note that Majestic Dragon Investment Co., Limited and Bright Forever Investments Limited are under common ownership and that, therefore, the transfer was merely a change in record ownership, but not in beneficial ownership.

Moonglade Investment Limited decided to sell some of its shares after it was removed as a selling shareholder. Being acquainted with the principals of the Reselling Shareholders, Mr. Michael Lau approached them, on behalf of Moonglade, and offered to sell them some of Moonglade’s shares. Mr. Lau agreed to register the shares for resale in conjunction with the Company’s IPO. The purchasers of the shares from Moonglade are not affiliated with Moonglade, Moonglade’s shareholders, officers, or directors or with the Company. The purchasing shareholders act for and on their own behalf.

U.S. Securities and Exchange Commission

June 3, 2024

Page 2

Dividends and Dividend Policy, page 37

Response:

In response to this comment, the Registrant has added disclosure to the section titled “Dividends and Dividend Policy” that clarifies that the Board of Directors does not intend to pay any dividends on our Ordinary Shares or on our Preferred Shares for the foreseeable future and that the Preferred Shares carry a right to receive non-cumulative dividends at the rate of $0.40 per share per annum (i.e., 8%) out of funds legally available therefor, but only when and as declared by the Board of Directors.

Exhibits

Response:

In response to this comment, the Registrant has revised, or caused to be revised, and re-filed the following exhibits: (i) the form of underwriting agreement as Exhibit No. 1.1; (ii) the opinion of Harney Westwood & Riegels as Exhibit 5.02; and (iii) the filing fee table as Exhibit No. 107.

Response:

In response to this comment, the Registrant has filed the Banking Facilities Letter dated August 23, 2023 from DBS Bank (Hong Kong) Limited to New Vision Lighting Limited as Exhibit 10.22.

Alternate Pages for Resale Prospectus

The Selling Shareholders, page Alt-2

Response:

In response to this comment, the Registrant has amended the footnotes to the table such that footnote 4 now discloses that Bright Forever Investments Limited is wholly owned by Ms. Fung Ming Pang, who also owns Majestic Dragon Investment Co., Ltd., and footnote 5 now discloses that Majestic Dragon Investment Co. Limited contributed the 680,000 Ordinary Shares and the 6,800 Preferred Shares to Bright Forever Investments Limited, which is under common ownership with it, on April 24, 2024 and April 26, 2024, respectively.

If you have any questions relating to the Registration Statement, please contact Kevin Cox, the Registrant’s Chief Executive Officer, at his email address of kevin.cox@energysgroup.com, or Michael Lau, the Registrant’s Chief Technical Officer, at his email address of michael.lau@energysgroup.com.

U.S. Securities and Exchange Commission

June 3, 2024

Page 3

Please copy any correspondence or requests for information to the undersigned and Celia Velletri. The undersigned’s email is set forth above, and Ms. Velletri’s email is cv@schlueterintl.com. If you wish to speak with us, please feel free to call me at 303-292-3883 or Celia Velletri at 303-907-4842.