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                                                             November 25, 2024

Toby Guanhua Wu
Chief Financial Officer
Aesthetic Medical International Holdings Group Limited
1122 Nanshan Boulevard
Nanshan District, Shenzhen
Guangdong Province, China 518052

       Re: Aesthetic Medical International Holdings Group Limited
           20-F for Fiscal Year Ended December 31, 2023
           Response Letter dated November 18, 2024
           File No. 1-39088
Dear Toby Guanhua Wu:

        We have reviewed your November 18, 2024 response to our comment letter
and have
the following comments. Please respond to this letter within ten business days
by providing
the requested information or advise us as soon as possible when you will
respond. If you do
not believe a comment applies to your facts and circumstances, please tell us
why in your
response. After reviewing your response to this letter, we may have additional
comments.

Response Letter dated November 18, 2024
Risks related to doing business in the PRC, page 27

1.     We note your response to previous comment 1 with proposed revised
disclosure on
       page 27:

          The PRC government may intervene or exert influence on our operations
at any
       time, which could result in a material adverse change in our operations
and the
       value of our ADSs and ordinary shares.

       The PRC government has significant authority to intervene or exert
influence on our
       business operations in various aspects at any time, which could result
in a material
       adverse change in our operations and the value of our ADSs and ordinary
shares. We
       operate through our subsidiaries in mainland China, Hong Kong, the
British Virgin
       Islands and the United States. In particular, the operational and legal
risks associated
       with being based in and having operations in mainland China also apply
to our
       operations in Hong Kong. As Hong Kong currently operates under a
different set of
       laws from mainland China, the laws, regulations and the discretion of
the
 November 25, 2024
Page 2

      governmental authorities in mainland China discussed in this annual
report are
      expected to apply to our entities and businesses in mainland China,
rather than entities
      or businesses in Hong Kong. However, there can be no assurance as to
whether the
      government of Hong Kong will enact laws and regulations similar to
mainland China,
      or whether any laws or regulations of mainland China will become
applicable to our
      operations in Hong Kong in the future. risks associated with being based
in and
      having operations in mainland China may also apply to operations in the
special
      administrative regions of Hong Kong. With respect to the legal risks
associated with
      being based in and having operations in mainland China, the laws,
regulations and the
      discretion of the governmental authorities in mainland China discussed in
this annual
      report are expected to apply to entities and businesses in mainland
China, rather than
      entities or businesses in Hong Kong which operate under different sets of
laws from
      mainland China. However, the legal risks associated with being based in
and having
      operations in mainland China could apply to the operations in Hong Kong,
if the laws,
      regulations and the discretion of the governmental authorities in
mainland China
      become applicable to entities and businesses in Hong Kong in the future.
Therefore,
      uncertainties in the laws and regulations of mainland China from time to
time and the
      interpretation and enforcement of the laws and regulations of mainland
China could
      limit the legal protection available to you and us, hinder our ability to
offer or
      continue to offer the ADSs, result in a material adverse effect on our
business
      operations, and affect our reputation, which might further cause the ADSs
to
      significantly decline in value or become worthless. Changes in the
economic, political
      or social conditions, or government policies of mainland China could also
materially
      and adversely affect our business, financial condition, and results of
operations.

      Please revise your underlined sentence to note that the risk that any
laws or
      regulations of mainland China will become applicable to your operations
in Hong
      Kong in the future could be at any time and with no advance notice.


      Please contact Conlon Danberg at 202-551-4466 or Margaret Sawicki at
202-551-
7153 with any questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Industrial
Applications and
                                                           Services