August 19, 2025

Elizabeth Senez
Chief Financial Officer
ENDEAVOUR SILVER CORP
# 1130-609 Granville Street
Vancouver
British Columbia
Canada V7Y 1G5

       Re: ENDEAVOUR SILVER CORP
           Form 40-F for the Fiscal Year Ended December 31, 2024
           Filed March 11, 2025
           File No. 001-33153
Dear Elizabeth Senez:

       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 40-F for the Fiscal Year Ended December 31, 2024
Exhibit 99.2
Consolidated Financial Statements for the Year Ended December 31, 2024
17. Segment Disclosures, page 29

1.     We note you disclose net earnings and comprehensive earnings for each of
your
       reportable segments in the far right column of your table at page 29.
Please revise
       your disclosure to explain how you have allocated costs to your segments
with details
       sufficient to understand the methods used and types of costs allocated
to provide an
       understanding of the reported segment information. Refer to paragraph
27(b) of IFRS
       8.
 August 19, 2025
Page 2

18. Income Taxes, page 31

2.     We note your disclosures related to the adverse tax ruling you received
in June 2015
       related to disputes between your subsidiary, MSCG and the Mexican tax
authorities.
       We note that the tax assessment totaled $6.1 million and that subsequent
efforts to
       appeal the matter have been rejected by the courts and that you are in
discussions with
       the tax authorities to settle this estimated tax liability. Please
explain your basis for
       recording $964 thousand accrual for this tax liability and the
underlying guidance in
       IAS 12 that supports your accounting.
19. Financial Instruments and Fair Value Measurements, page 34

3.     We note your discussion of the fair value hierarchy at Note 11(b)
describes your
       specific assets and liabilities included in the Level 1, Level 2 and
Level 3 categories
       and the inputs and valuation methods used to determine their fair values
at page 34.
       Please revise your narrative disclosures to identify your derivative
liabilities in
       the appropriate category.
        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 Ranjit Singh Pawar at 202-551-2702 or Craig Arakawa at
202-551-
3650 if you have questions regarding comments on the financial statements and
related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation