December 16, 2024

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

       Re: ICL Group Ltd.
           Correspondence filed December 11, 2024 File No. 1-13742
Dear Aviram Lahav:

        We have reviewed your filing and have the following comment. 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. We may have further comment.

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

1.     We note your response to comment 2. We understand from your response
that you
       consolidate the YPH results in your financial results, however the
provisions
       under Item 1303(b)(3)(iii) of Regulation S-K require resource and
reserve disclosure
       to be presented on an attributable basis. Please confirm that you will
present the YPH
       resource and reserve disclosure on an attributable basis. In the
alternative we would
       not object to the inclusion of an addition column(s) in your resource
and reserve tables
       that quantifies the amount of contained P2O5 tonnage associated with
your
       attributable interest, in addition to the quantity that is based on a
100% interest.
        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 202.551.3650 if you have questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services