United States securities and exchange commission logo November 3, 2022 Virgilio Gibbon Chief Executive Officer Afya Limited Alameda Oscar Niemeyer , No. 119 Room 504 Vila da Serra Nova Lima Minas Gerais MG, Brazil Re: Afya Limited Form 20-F for Fiscal Year Ended December 31, 2021 Filed April 29, 2022 File No. 001-38992 Dear Virgilio Gibbon: We have completed our review of your filing. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Sincerely, Division of Corporation Finance Office of Trade & Services