United States securities and exchange commission logo June 12, 2024 W. Troy Rudd Chief Executive Officer AECOM 13355 Noel Road Dallas, TX 75240 Re: AECOM Form 10-K for Fiscal Year Ended September 20, 2023 File No. 000-52423 Dear W. Troy Rudd: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services