June 20, 2019

Virgilio Deloy Capobianco Gibbon
Chief Executive Officer
Afya Limited
Alameda Oscar Niemeyer, No 119, Sala 504
Vila da Serra, Nova Lima, Minas Gerais
Brazil

       Re: Afya Limited
           Amendment No. 2 to
           Draft Registration Statement on Form F-1
           Submitted June 10, 2019
           CIK No. 0001771007

Dear Mr. Gibbon:

      We have reviewed your amended draft 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 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 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 the information you provide in response to these comments
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Our references to prior comments are to comments in our June 4, 2019
letter.

Amendment No. 2 to Draft Registration Statement on Form F-1

Prospectus Summary
Overview, page 5

1.     We note that you currently disclose the percentages your acquisitions
represent in terms of
       combined tuition fee growth as compared to organic growth. With a view
toward
       providing balanced disclosure of your business strategy, recent growth,
and cash
       generation, also disclose the respective percentages of your net revenue
growth resulting
       from your recent acquisitions.
 Virgilio Deloy Capobianco Gibbon
Afya Limited
June 20, 2019
Page 2
Selected Financial and Other Information
Combined Tuition Fees, page 85

2.       We note your response to comment 10 and your disclosures on page 27
that the tuition fee
         data for CCSI was obtained from the internal management records of
CCSI. In your
         initial draft registration statement, you indicated that tuition fee
data was not available
         from CCSI for the year ended December 31, 2017 and for the period from
January 1, 2018
         to May 30, 2018 (the period prior to your acquisition of CCSI), and to
calculate the CCSI
         data presented for those periods, you multiplied the number of
students enrolled at CCSI
         by the monthly tuition fee amounts charged for those periods. Please
reconcile your most
         recent response to your initial disclosures indicating that tuition
fee data was not
         available. Further, tell us what procedures you performed to assess
the reliability of the
         underlying data used to calculate CCSI tuition fees for purposes of
this metric.
         Additionally, to the extent that you continue to include CCSI in this
metric, please revise
         to disclose how you calculated combined tuition fees for CCSI and how
you assessed the
         reliability of the underlying data.
        You may contact Lisa Etheredge, Staff Accountant, at (202) 551-3424 or
Robert S.
Littlepage, Accounting Branch Chief, at (202) 551-3361 if you have questions
regarding
comments on the financial statements and related matters. Please contact Joshua
Shainess,
Attorney-Adviser, at (202) 551-7951 or Kathleen Krebs, Special Counsel, at
(202) 551-3350
with any other questions.



FirstName LastNameVirgilio Deloy Capobianco Gibbon            Sincerely,
Comapany NameAfya Limited
                                                              Division of
Corporation Finance
June 20, 2019 Page 2                                          Office of
Telecommunications
FirstName LastName