September 9, 2024

Zane Rowe
Chief Financial Officer
Workday, Inc.
6110 Stoneridge Mall Road
Pleasanton, CA 94588

       Re: Workday, Inc.
           Form 10-K for the year ended January 31, 2024
           Response dated September 4, 2024
           File No. 001-35680
Dear Zane Rowe:

       We have reviewed your September 4, 2024 response to our comment letter
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 our
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. Unless we
note otherwise, any references to prior comments are to comments in our August
5, 2024 letter.

Form 10-K for the Year Ended January 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 37

1.     Please address the following as it relates to your response and proposed
revised
       disclosures to prior comment 2.
           We note you currently disclose that gross and net retention rates
exceeded 95% and
           100%, respectively, for the periods presented in your recent Form
10-K and Form
           10-Q filings. To the extent you intend to provide similar
disclosures in future filings,
           revise to ensure that the amounts provided appropriately reflect
your current net
           retention rates.
           You state that net retention rate is calculated by taking the
current period-end ARR of
           your customers that you    retained" year-over-year. Clarify whether
you calculate
           ARR using existing customers from the corresponding period and
compare that to
           ARR for the current period from the same set of customers. If so,
revise to clarify as
 September 9, 2024
Page 2

           such. To the extent you do not use the same customer base for each
period in your
           calculation, explain further how this measure factors in customer
churn.
             Tell us the amount of subscription contracts that are excluded
from your calculation
           of ARR. To the extent material to total subscription contracts,
revise to disclose the
           percentage of ARR that is excluded from such measure.

       Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at
202-551-3499 if
you have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Technology
cc:   David Bell