Following Beijing's release of detailed rules for reforming the commodity housing sales system, on September 28 four Shanghai departments — the Municipal Housing and Urban-Rural Development Commission, the Municipal Housing Bureau, the Municipal Planning and Natural Resources Bureau, and the Shanghai Financial Regulatory Bureau — jointly issued the "Implementation Opinions on Implementing the Notice on Improving the Commodity Housing Sales System" (the "Implementation Opinions"), effective from September 28, 2026.

The Implementation Opinions mainly comprise policy measures in six areas: strengthening presale management, implementing completed-home sales, promoting the lead bank system, increasing financing support, optimizing land supply management, and ensuring quality oversight and market order regulation.

On August 28 this year, the Ministry of Housing and Urban-Rural Development, the Ministry of Natural Resources, and the National Financial Regulatory Administration jointly issued the Notice on Improving the Commodity Housing Sales System and a series of related policy provisions, steadily advancing reform of the commodity housing sales system, accelerating the building of a new model for real estate development, and promoting high-quality development of the sector. After the policies were introduced, the market engaged in extensive discussion over the detailed rules for implementing presales and completed-home sales. On September 24, Beijing took the lead in issuing supporting implementation opinions. Zhang Wenjing, general manager of the Shanghai data division at the China Index Academy, said Shanghai is the second city after Beijing to issue a systematic set of implementation rules. Overall, Shanghai's framework — cutting off old from new and applying policies by category — is in the same vein as Beijing's, with core institutional arrangements such as presale caps, full-amount fund supervision, disbursement upon completion filing, the lead bank system, and phased land payments aligned with Beijing, while retaining differentiated arrangements on the deposit ratio for completed-home sales, the setup of supervisory institutions, and land payment deadlines. In her view, the successive rollout of detailed rules in Beijing and Shanghai also provides a replicable model for other cities, and more cities are expected to accelerate follow-up implementation rules, which should gradually ease the wait-and-see sentiment caused by policy uncertainty.

Specifically, the Implementation Opinions make clear that for commodity housing projects whose land transfer announcements are newly published after August 28, 2026, those applying for presale must have completed the main structure topping-out of individual buildings. For projects already in the pipeline, policies are applied by category to ensure a smooth transition. At the same time, the Implementation Opinions stipulate that, from August 28, 2026, commodity housing projects on land newly announced for transfer will give priority to completed-home sales; for projects adopting completed-home sales, relevant information about such sales must be disclosed to the public in the land transfer announcement.

On deposits, Shanghai is also rolling out a deposit system for completed-home sales. After obtaining a construction permit, a real estate developer may sign a purchase deposit contract with a homebuyer, with the deposit generally not exceeding 3% of the total purchase price — a higher cap than Beijing's 1%.

In optimizing land supply management, Shanghai proposes implementing an integrated "planning, reserve, supply, and use" mechanism, strengthening the linkage between housing and land, enhancing market analysis, and adhering to a "one plot, one policy" approach for steady and orderly supply. On land payments, the Implementation Opinions specify that land prices may be paid in installments. For commodity residential land whose transfer announcements are published after August 28, 2026, the transfer price may be paid in installments in accordance with national regulations. The down payment must be paid within 30 calendar days from the date of signing the transfer contract, at no less than 50% of the total price; the remaining balance may be extended to within one year after signing the transfer contract; to adapt to market and project needs, it may be extended by another year after a decision made through prescribed procedures; installment payments do not accrue interest.

Zhang Wenjing analyzed that, compared with Beijing's direct arrangement requiring the balance to be paid within two years, Shanghai adopts a "1+1" model, with a nominally shorter settlement deadline but retaining flexibility to extend by another year through a decision, and the actual degree of relief for companies' funding pressure depends on how lenient the extension decision process is.

In addition, Shanghai also proposes implementing a project development company system, establishing and improving a quality assurance system for commodity housing projects, and coordinating efforts to advance "good housing" construction; continuously optimizing approval processes to create a sound business environment; and improving the public information disclosure mechanism for the real estate market, strengthening market oversight, and maintaining market order, among other requirements.

The following are the specific contents of the Implementation Opinions:

I. Comprehensively strengthen commodity housing presale management

(1) Standardize presale conditions and improve presale management. The Implementation Opinions make clear that for commodity housing projects whose land transfer announcements are newly published after August 28, 2026, those applying for presale must have completed the main structure topping-out of individual buildings. Project presale funds are subject to full-amount, whole-process supervision; fund supervision may be lifted only after the project passes comprehensive completion acceptance.

(2) Apply policies by category for in-pipeline projects to ensure a smooth transition. The Implementation Opinions stipulate: First, for commodity housing projects that had obtained (including partially obtained) construction project planning permits but had not applied for presale permits on or before August 28, 2026, presale conditions, presale fund supervision, and other matters shall follow the original policy provisions. Second, for commodity housing projects that had obtained state-owned construction land use rights but had not obtained construction project planning permits on or before August 28, 2026, presale management policies for newly acquired land projects shall apply in principle; to maintain stable market supply and demand, if the district government ensures delivery can be completed on time, and under strengthened presale fund supervision, after filing with the municipal housing management department, presales may still be applied for under the original presale conditions before the end of 2027. Third, for commodity housing projects whose transfer announcements were already published on or before August 28, 2026 but which obtained state-owned construction land use rights after August 28, if they are launched before the end of 2027, presale conditions may follow the original policy provisions, but presale fund supervision shall follow the new policy provisions.

II. Orderly implement completed-home sales for commodity housing

The Implementation Opinions stipulate that, from August 28, 2026, commodity housing projects on land newly announced for transfer will give priority to completed-home sales; for projects adopting completed-home sales, relevant information about such sales must be disclosed to the public in the land transfer announcement. After obtaining the first registration of the housing, a real estate developer shall apply to the housing management department of the district where the project is located for filing of completed-home sales.

The Implementation Opinions make clear that a deposit system for completed-home sales will be promoted. A real estate developer may sign a purchase deposit contract with a homebuyer after obtaining a construction permit, with the deposit generally not exceeding 3% of the total purchase price. If the developer breaches the contract and cannot deliver the housing on schedule, the homebuyer has the right to propose termination of the deposit contract in accordance with the contract, and the developer shall return the deposit in accordance with the law and bear liability for breach of contract.

III. Promote the lead bank system

The Implementation Opinions make clear that the lead bank system shall be implemented. Starting from August 28, 2026, projects signing new loan contracts shall adopt the lead bank system. If a lending bank provides development loans alone, that lending bank is the lead bank; if lending banks form a syndicate to provide loans, the lead bank of the syndicated loan is the lead bank.

The Implementation Opinions stipulate that a real estate developer shall open a fund account at the lead bank. During the life of the project, all project-related funds — including development loans, the project's own funds, and completed-home sales proceeds — shall be managed through the fund account opened at the lead bank. The municipal and district real estate transaction centers, as housing fund supervisory institutions, shall implement fund supervision in accordance with regulations.

IV. Increase financing support

The Implementation Opinions make clear: First, standardize the issuance of individual mortgage loans. For projects that obtain presale permits starting from August 28, 2026, individual housing mortgage loans (including provident fund loans) may be issued only after completion filing, and loan funds shall be paid to the fund supervision account through entrusted payment. Second, increase support for development loans. For projects adopting completed-home sales and presales, reasonably meet the projects' financing needs in accordance with market-oriented principles, and align development loan issuance with the project construction cycle. Increase development loan support for completed-home sales projects and "good housing" projects. Third, promote a virtuous cycle between finance and real estate. Support eligible real estate developers in conducting project-based financing through bonds, equities, asset-backed securities, and real estate investment trusts, and meet the reasonable financing needs of real estate developers of different ownership types on an equal footing.

V. Optimize land supply management

To strengthen planning guidance, resource coordination, and market orientation, the Implementation Opinions make clear that an integrated "planning, reserve, supply, and use" mechanism shall be implemented, the linkage between housing and land strengthened, market analysis enhanced, and a "one plot, one policy" approach adhered to for steady and orderly supply.

The Implementation Opinions make clear that land prices may be paid in installments. For commodity residential land whose transfer announcements are published after August 28, 2026, the transfer price may be paid in installments in accordance with national regulations. The down payment must be paid within 30 calendar days from the date of signing the transfer contract, at no less than 50% of the total price; the remaining balance may be extended to within one year after signing the transfer contract; to adapt to market and project needs, it may be extended by another year after a decision made through prescribed procedures; installment payments do not accrue interest.

VI. Continue to ensure quality oversight and market order regulation

To strengthen coordination of policy measures, improve housing construction quality, and effectively safeguard the lawful rights and interests of homebuyers, the Implementation Opinions also propose implementing a project development company system, establishing and improving a quality assurance system for commodity housing projects, and coordinating efforts to advance "good housing" construction; continuously optimizing approval processes, improving management and service efficiency, and actively creating a sound business environment; and improving the public information disclosure mechanism for the real estate market, strengthening real estate market oversight, and maintaining good market order.