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                             March 28, 2022

       Roger Hamilton
       Chief Executive Officer
       Genius Group Ltd.
       8 Amoy Street, #01-01
       Singapore 049950

                                                        Re: Genius Group Ltd.
                                                            Amendment No. 9 to
Registration Statement on Form F-1
                                                            Filed March 25,
2022
                                                            File No. 333-257700

       Dear Mr. Hamilton:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.

       Amendment No. 9 to Registration Statement on Form F-1 Filed March 25,
2022

       Summary Combined Unaudited Pro Forma Financial Data for Genius Group
(Including IPO
       Acquisitions)
       Footnotes Relating to the Financial Statements Above, page 76

   1.                                                   Please refer to
footnote (5)(b). Your revised disclosure in footnote (5) and on page 122 in
                                                        your filing now
indicates that the revised purchase price for University of Antelope Valley
                                                        includes a note payable
of $17,500,000, which provides for an interest rate of 5%. Please
                                                        revise your pro forma
statements of operations for the year ended December 31, 2020 and
                                                        the six months ended
June 30, 2021 to include a pro forma adjustment for the interest
                                                        expense associated with
this note payable or explain why you do not believe this is
                                                        required.
 Roger Hamilton
Genius Group Ltd.
March 28, 2022
Page 2
General

2.    We note your disclosure on pages 191, 192, and 199 indicates that the IPO
deadline/terms
      under the relevant acquisition agreements for E-Square, Education Angels,
and PIN were
      extended to April 30, 2022. However, the extending letters that you filed
as exhibits 2.19,
      2.20, and 2.21 indicate that the IPO deadline/terms under these
acquisition agreements
      were extended through June 30, 2022. Please revise to reconcile the
prospectus disclosure
      with the terms of these extending letters. As a related matter, please
update your
      disclosure on page 198 to indicate that the IPO deadline/terms under your
Stock Purchase
      Agreement with UAV were extended through April 30, 2022.
       You may contact Patrick Kuhn at 202-551-3308 or Linda Cvrkel at
202-551-3813 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Nicholas Lamparski at 202-551-4695 or Erin Jaskot at 202-551-3442 with
any other
questions.



                                                           Sincerely,
FirstName LastNameRoger Hamilton
                                                           Division of
Corporation Finance
Comapany NameGenius Group Ltd.
                                                           Office of Trade &
Services
March 28, 2022 Page 2
cc:       Benjamin S. Reichel
FirstName LastName