May 6, 2025

Cameron Frymyer
Executive Vice President and Chief Financial Officer
Babcock & Wilcox Enterprises, Inc.
1200 East Market Street, Suite 650
Akron, OH 44305

       Re: Babcock & Wilcox Enterprises, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2024
           Filed March 31, 2025
           File No. 001-36876
Dear Cameron Frymyer:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 10-K for the Fiscal Year Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Consolidated Results of Operations, page 37

1.     Please revise your results of operations to ensure that you discuss all
material changes
       in your statements of operations line items on a consolidated basis. As
noted in Item
       303(b) of Regulation S-K, MD&A should discuss your business as a whole
with
       segment information provided as necessary for an understanding of your
business.
Non-GAAP Financial Measures, page 39

2.     We note the non-GAAP adjustments for "Product development" and "Letter
of credit
       fees" in your calculation of Adjusted EBITDA. We further note that
product
       development costs include "expenses that relate to sales, marketing, and
other
       business development expenses for...products and services still under
development
       and not yet widely available" and letter of credit fees represent
expenses "routinely
       incurred in the course of executing customer contracts." Considering
these
 May 6, 2025
Page 2

       costs appear to represent normal, recurring, cash operating expenses
necessary to
       operate your business, please remove these adjustments from future
filings or tell us
       why you believe inclusion complies with non-GAAP rules. Refer to
Question 100.01
       of the Non-GAAP Financial Measures Compliance and Disclosure
Interpretations.
Liquidity and Capital Resources
Cash and Cash Flows, page 46

3.     Please provide a more informative analysis and discussion of changes in
operating,
       investing and financing cash flows for each period presented. In doing
so, explain the
       underlying reasons and implications of material changes between periods
to provide
       investors with an understanding of trends and variability in cash flows.
Also provide
       an analysis of any known trends and uncertainties that will result in or
that are
       reasonably likely to result in a material increase or decrease in your
liquidity. Ensure
       your discussion and analysis is not merely a recitation of changes
evident from the
       financial statements. Refer to Item 303(a) of Regulation S-K and Section
IV.B of SEC
       Release No. 33-8350.
Critical Accounting Policies and Estimates, page 47

4.     Please enhance your disclosures to provide qualitative and quantitative
information
       necessary to understand the estimation uncertainty and the impact your
critical
       accounting estimates have had or are reasonably likely to have on your
financial
       condition and results of operations. In addition, discuss how much each
estimate
       and/or assumption has changed over a relevant period and the sensitivity
of reported
       amounts to the underlying methods, assumptions and estimates used. The
disclosures
       should supplement, not duplicate, the description of accounting policies
or other
       disclosures in the notes to the financial statements. Refer to
       Item 303(b)(3) of Regulation S-K and SEC Release No. 33-8350.
Notes to Consolidated Financial Statements
Assets and liabilities held for sale and discontinued operations, page 63

5.     You disclose that when you classify a disposal group as held for sale,
you first test "all
       assets other than goodwill," then goodwill, and then the disposal group
in its entirety.
       Please tell us how your impairment testing order complies with ASC
360-10-35-39. In
       particular, clarify if you test long-lived assets for impairment before
or after
       goodwill.
        In closing, 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.
 May 6, 2025
Page 3



       Please contact Andrew Blume at 202-551-3254 or Kevin Woody at
202-551-3629
with any questions.



                                                      Sincerely,

                                                      Division of Corporation
Finance
                                                      Office of Manufacturing