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                               December 12, 2023

       Marco Wiren
       Chief Financial Officer
       NOKIA CORP
       Karakaari 7
       Fl-02610 Espoo
       Finland

                                                        Re: NOKIA CORP
                                                            Form 20-F
                                                            Filed March 2, 2023
                                                            File No. 001-13202

       Dear Marco Wiren:

              We have limited our review of your filing to the financial 
statements and related
       disclosures and have the following comment(s).

              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 filed March 2, 2023

       General facts on Nokia
       Alternative performance measures, page 117

   1.                                                   We note you present a 
measure you identify as "free cash flow". In future filings, please
                                                        revise the measure you 
present or revise the title of the measure you present to be
                                                        consistent with the 
guidance in Question 102.07 of the Non-GAAP Financial Measures
                                                        Compliance & Disclosure 
Interpretations.
       Financial Statements
       Note 33. Subsequent events
       New euro-denominated notes, page 176

   2.                                                   We note your subsequent 
events disclosure states you issued EUR 500 million 4.375%
                                                        "sustainability-linked" 
notes due August 2031. Please tell us, and disclose in future filings,
 Marco Wiren
NOKIA CORP
December 12, 2023
Page 2
         the following:

                Describe the specific key sustainability performance indicators 
associated with these
              notes as well as the specific benchmarks or goals for each 
performance indicator.
                To the extent applicable, describe how the key sustainability 
performance indicator
              will be reliably measured.
                Describe the implications to the variability of cash flows if 
the key sustainability
              performance indicators are not met.
                Disclose how you intend to account for the debt and whether or 
not you have
              recognized any embedded derivatives associated with the 
sustainability-linked
              features. To the extent you don't believe the debt instruments 
contain embedded
              derivatives, please provide the basis for your conclusion under 
IFRS 9.

       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 Kevin Stertzel at 202-551-3723 or Anne McConnell at 
202-551-3709 with
any questions.



FirstName LastNameMarco Wiren                                  Sincerely,
Comapany NameNOKIA CORP
                                                               Division of 
Corporation Finance
December 12, 2023 Page 2                                       Office of 
Manufacturing
FirstName LastName