United States securities and exchange commission logo March 10, 2023 David Lamont Chief Financial Officer BHP Group Ltd 171 Collins Street Melbourne, Victoria 3000 Australia Re: BHP Group Ltd Form 20-F for the Fiscal Year Ended June 30, 2022 Filed September 6, 2022 File No. 001-09526 Dear David Lamont: We have reviewed your filing 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 these comments 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 our comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 20-F for the Fiscal Year Ended June 30, 2022 Exhibits Exhibit 96, page 263 1. Please revise your Western Australia Iron Ore Technical Report Summary to include the mine life for each mine area and provide a mine map of the final mine outline for each mining area as required by Item 601(b)(96)(iii)(B)(13) of Regulation S-K. 2. Please revise your technical reports to include annual cash flow forecasts based on an annual production schedule for the life of the project as required by Item 601(96)(iii)(B)(19)(ii) of Regulation S-K. This should include the entire discounted cash flow analysis. David Lamont FirstName BHP GroupLastNameDavid Lamont Ltd Comapany March NameBHP Group Ltd 10, 2023 March2 10, 2023 Page 2 Page FirstName LastName 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. You may contact John Coleman at 202-551-3610 or Craig Arakawa at 202-551-3650 if your have questions about comments. Sincerely, Division of Corporation Finance Office of Energy & Transportation