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                                                            November 8, 2024

Alvaro Quintana Cardona
Chief Financial Officer
iQSTEL Inc
300 Aragon Avenue, Suite 375
Coral Gables, FL 33134

       Re: iQSTEL Inc
           Form 10-K for the Year Ended December 31, 2023
           FIle No. 000-55984
Dear Alvaro Quintana Cardona:

       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 Year Ended December 31, 2023
Audited Financial Statements
Note 2. Summary of Significant Accounting Policies
Revenue Recognition, page F-11

1.     We note the Company recognizes revenue related to "monthly usage charges
and
       other recurring charges" during the period in which the
telecommunication services
       are rendered. Please expand your revenue recognition policy and explain
to us:
           the specific performance obligations of the Company in its contracts
with its
           customers;
           what is specifically being used that results in "usage" charges; and
           the nature of the "other recurring charges" and the services
provided resulting in
           revenue recognition.

2.     With respect to each specified service promised to the end customer in
your revenue
       arrangements, please provide us your analysis of whether the Company is
the
       principle or agent. Identify in this analysis each specified service
being provided to
 November 8, 2024
Page 2

       the end customer and explain how the Company controls this service.
Refer to the
       guidance in ASC 606-10-55-36 through 55-40. Explain to us your
consideration of the
       indicators of control in ASC 606-10-55-39.
        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.

      Please contact Anastasia Kaluzienski at 202-551-3685 or Robert Littlepage
at 202-
551-3361 with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
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