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                              February 1, 2024

       Lisa Gibbs
       Chief Financial Officer
       Amtech Systems, Inc.
       131 South Clark Drive
       Tempe, Arizona 85288

                                                        Re: Amtech Systems, 
Inc.
                                                            Form 10-K for the 
Fiscal Year Ended September 30, 2023
                                                            Filed December 14, 
2023
                                                            File No. 000-11412

       Dear Lisa Gibbs:

              We have limited our review of your filing to the financial 
statements and related
       disclosures 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 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 September 30, 2023

       Liquidity and Capital Resources, page 42

   1.                                                   We note that on page 44 
and elsewhere in your Form 10-K you disclose that you were not
                                                        in compliance with the 
Debt to EBITDA and Fixed Charge Coverage Ratio financial
                                                        covenants under your 
loan agreement, and that you entered into a forebearance agreement
                                                        with the bank related 
to such non-compliance, pursuant to which the bank agreed to
                                                        forbear through January 
17, 2025 from exercising its rights and remedies available to it as
                                                        a result of such 
defaults. In future filings, please expand your disclosures of liquidity and
                                                        capital resources to 
address the following:
                                                            Describe the terms 
of each covenant covered by the forebearance agreeement, or any
                                                             similar 
agreements, including a presentation of the required and actual ratio/amount
                                                             as of the most 
recent compliance date.
                                                            Explain how 
additional future violations of this or other debt covenants would impact
                                                             your liquidity and 
capital resources. Specifically, you should state whether
                                                             noncompliance with 
any covenants could lead to the acceleration of payments
 Lisa Gibbs
Amtech Systems, Inc.
February 1, 2024
Page 2


              due under any of your debt arrangements. Refer to Items 303(b)(1) 
and (c)(1)
              of Regulation S-K.

       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.



FirstName LastNameLisa Gibbs                                 Sincerely,
Comapany NameAmtech Systems, Inc.
                                                             Division of 
Corporation Finance
February 1, 2024 Page 2                                      Office of 
Technology
FirstName LastName