December 3, 2024

Aviram Lahav
Chief Financial Officer
ICL Group Ltd.
Millennium Tower, 23 Aranha Street
P.O. Box 20245
Tel Aviv , 61202 Israel

       Re: ICL Group Ltd.
           Form 20-F for the Fiscal year Ended December 31, 2023
           File No. 001-13742
Dear Aviram Lahav:

         We have reviewed your filing and have the following comments. Please
respond to
this letter 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 a comment applies
to your
facts and circumstances, please tell us why in your response. After reviewing
your response
to this letter, we may have additional comments.

Form 20-F for the Fiscal year Ended December 31, 2023
D. Property, Plant and Equipment, page 136

1.     We note your disclosure for YPH China includes the point of reference
for mineral
       resources on an in-situ basis, and the point of reference for mineral
reserves as
       materials delivered to the processing plant primary crusher. Please
revise subsequent
       filings to include the point of reference for mineral resources and
mineral reserves for
       your other properties, as required by Item 1303(b)(3)(iv) and Item
1304(d)(1) of
       Regulation S-K. Please confirm this disclosure will be included with
your summary
       resource and reserve tables and under your individual property resource
and reserve
       tables.


2.     It appears that the resource and reserve disclosure for YPH China is
presented on a
       100% basis, however we note from page 33 of your consolidated financial
       statements that you have a 50% interest in this property. Please revise
subsequent
       filings to present resource and reserve quantities based on your
attributable interest in
       the property, as required by Item 1303(b)(3)(iii) of Regulation S-K.
 December 3, 2024
Page 2


Item 19. Exhibits, page 278

3.     We note that you have filed one technical report summary that includes
the
       information concerning resources and reserves on five unrelated
properties. A
       technical report summary is required to be filed for each material
property as required
       by Item 1302(b) of Regulation S-K. Please file a technical report
summary for each
       material property in which you disclose resources and reserves.

       Please consult with your qualified person to ensure the information
required under
       Item 601(b)(96)(iii)(B)(18) and (19) is included in each technical
report summary that
       is prepared in support of mineral reserve disclosure. This disclosure
should include
       the entire cash flow analysis that is based on a life-of-mine annual
production
       schedule, which should also be disclosed. Please see Item
601(b)(96)(iii)(A) for
       information regarding the required paragraphs in the technical report
summary.
        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. Please contact John Coleman at 202.551.3610 or Craig
Arakawa at
202.551.3650 if you have questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services