August 6, 2024

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

       Re: Genius Group Limited
           Amendment No. 4 to Registration Statement on Form F-1
           Filed July 24, 2024
           File No. 333-279795
Dear Roger James Hamilton:

     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 July 3, 2024 letter.

Amendment No. 3 to Registration Statement on Form F-1
Summary Combined Unaudited Pro Forma Financial Data and Audited Consolidated
Financial
Data, page S-11

1.     We note from your revised disclosures on page S-11 to your July 10, 2024
Form F-1/A, as
       part of the FatBrain acquisition, you assumed approximately $15.0
million in additional
       liabilities. Please revise pro forma adjustment 4b to disclose the terms
of the loan payable.
       Also, revise to include an adjustment to your pro forma profit and loss
statements to
       reflect the additional interest expense related to such loan.
FatBrain AI Financials, page S-12

2.     We note the revised disclosures provided in response to comment 2 of
your July 10, 2024
       letter. Please explain, in detail, LZG's role in the FatBrain
acquisition. Provide the details
       of any transactions between and among, LZG, Genius Group and Prime
Source Group,
 August 6, 2024
Page 2

       including the date of each transaction. In addition, according to
Exhibit 2.22, it appears
       that Genius Group acquired the assets of LZG and the exhibit refers to
financial
       statements of both LZG and each of the five subsidiaries of Primesource.
Please explain
       further how you determined the financial statements of LZG were not
required as part of
       this transaction and the specific guidance your relied upon.
Exhibits

3.     Tell us why you have provided the financial statements included in
Exhibit 21.C. To the
       extent you believe these financial statements are required, revise to
include a consent from
       Moore Kazakhstan as to the inclusion of their opinion related to such
financial statements.
       Alternatively, revise to remove this exhibit.
       Please contact Marion Graham at 202-551-6521 or Jeff Kauten at
202-551-3447 with any
other questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   Jolie Kahn