UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

FORM SD

SPECIALIZED DISCLOSURE REPORT

AXALTA COATING SYSTEMS LTD.

(Exact name of registrant as specified in its charter)

Bermuda			001-36733			98-1073028
(State or other jurisdiction of incorporation)			(Commission File Number)			(IRS Employer Identification No.)

Two Commerce Square

2001 Market Street

Suite 3600

Philadelphia, Pennsylvania 19103

(Address of principal executive offices)

Tabitha R. Oman

Vice President, Deputy General Counsel & Chief Compliance Officer

Assistant Secretary

(855) 547-1461

(Name and telephone number, including area code, of the person to contact in connection with this report)

Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:

ý Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2020.

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Section 1 - Conflict Materials Disclosure

Item 1.01 Conflict Minerals Disclosure and Report

This Form SD of Axalta Coating Systems Ltd. (the “Company”) is filed pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1 through December 31, 2020.

The description of our reasonable country of origin inquiry (“RCOI”) process, the results of our inquiry, and the determination we reached because of our RCOI process is included in our Conflict Minerals Report, which is attached as Exhibit 1.01 to this Form SD and is publicly available at: http://ir.axaltacs.com/investors/sec-filings/default.aspx.

We have also posted our Conflict Minerals Policy on our website, which can be accessed at: https://www.axalta.com/corporate/en_US/sustainability/human-rights.html.

The information on our website is not, and should not be deemed to be, a part of this Conflict Minerals Report, or incorporated into any other filings we make with the SEC.

Item 1.02 Exhibit

A copy of the Company’s Conflict Minerals Report is filed as Exhibit 1.01 hereto.

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report:

Exhibit number			Description
1.01			Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.

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SIGNATURES

    Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

						AXALTA COATING SYSTEMS LTD.
Date:			May 27, 2021			By:			/s/ Tabitha R. Oman
									Tabitha R. Oman
									Vice President, Deputy General Counsel and Chief Compliance Officer
									Assistant Secretary