December 27, 2024

Aksel C. Olesen
Chief Financial Officer
SFL Corp Ltd.
14 Par-la-Ville Road
Hamilton HM08 Bermuda

       Re: SFL Corp Ltd.
           Form 20-F for the Fiscal Year ended December 31, 2023
           Filed March 14, 2024
           File No. 001-32199
Dear Aksel C. Olesen:

       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. 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
Financial Segments
Note 4. Segment Information, page F-20

1.     We note your disclosure indicating you operate within a single
reportable segment,
       although it is unclear how this reconciles with other disclosures in
your earnings
       releases and investor presentations on your website, which identify and
focus on five
       market categories, including container, car carrier, tanker, dry bulk,
and energy.

       For example, within the investor presentations you report for each of
these categories,
       the number and type of vessels, average contract duration, charter
types, operating
       days, utilization, revenues, and operating expenses; and during some
earnings calls
       you have referred to margins for particular vessels. We see that you
discuss various
       risks that appear to be specific to the energy market category on page
15, and
       that drilling contract revenues for 2023 reflect a substantial increase,
which was
       not characteristic of changes reported for the other revenue categories.
 December 27, 2024
Page 2

       Given the foregoing, please clarify how assessing performance and
allocating
       resources would not be oriented towards, and informed by financial
metrics associated
       with the five market categories that you have identified, if this is
your view. Please
       explain to us how you considered and applied the guidance in FASB ASC
280-10-50-
       1, 10, 11 and 12, including the guidance specific to aggregation in
10-55-7A, B, and
       C, if applicable, in formulting your position regarding segment
disclosures.

       As part of your response, please describe the information that is
provided to your
       chief operating decision maker and the manner by which assessments of
performance
       are conducted and decisions regarding resource allocations are made,
with respect to
       the various market categories referenced above.

       However, if additional reportable segments are identified, please submit
the revisions
       that you propose to address the requirements in FASB ASC 280. Please
also revise
       your disclosures as necessary to clarify how the activity that is
associated with each of
       the market categories correlates with your financial presentation. For
example, if
       revenues of your energy market category are synonymous with your
drilling contract
       revenues, this should be apparent from your disclosures.


        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 Lily Dang at 202-551-3867 or John Cannarella at
202-551-3337 if you
have questions regarding comments on the financial statements and related
matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation