The application process for commercial real estate REITs has commenced. As of February 8, the first batch of 10 commercial real estate REITs has been submitted for approval, aiming to raise a total of 37.7 billion yuan. According to Zhang Jiqiang from Huatai Securities Fixed Income, this marks the first submission of commercial real estate REITs following the China Securities Regulatory Commission's (CSRC) announcement on December 31, 2025, regarding the pilot program for commercial real estate investment trust funds. This development signifies that China's public REITs market has officially entered a period of comprehensive development encompassing both infrastructure and commercial real estate.
It is reported that REITs policies are accelerating the formation of a multi-layered market. On the supply side, a diversified product system has emerged, including infrastructure REITs, commercial real estate REITs, and inter-institutional REITs. Securities companies play the role of financial advisors in REITs business. In this first batch of 10 commercial real estate REIT applications, GTHT and CITIC SEC, acting as financial advisors, account for 6 of the submissions.
Data from Wind shows that the first batch currently under application includes 10 commercial real estate REITs, with 9 listed on the Shanghai Stock Exchange and 1 on the Shenzhen Stock Exchange. Specific examples include the Everbright AMERSHINY Commercial Real Estate Closed-End Securities Investment Fund, the Bosera Shandong Railway Investment Road & Bridge Closed-End Infrastructure Securities Investment Fund, the GTHT砂之船 Closed-End Commercial Real Estate Securities Investment Fund, the ChinaAMC CapitaLand Closed-End Commercial Real Estate Securities Investment Fund, and the ChinaAMC Yintai Department Store Closed-End Commercial Real Estate Securities Investment Fund.
In terms of fundraising scale, the CICC Vipshop Closed-End Commercial Real Estate Securities Investment Fund aims to raise 7.47 billion yuan, the GTHT砂之船 Closed-End Commercial Real Estate Securities Investment Fund targets 5.064 billion yuan, the ChinaAMC Yintai Department Store Closed-End Commercial Real Estate Securities Investment Fund plans to raise 4.2785 billion yuan, and the HSBC Shanghai Real Estate Closed-End Commercial Real Estate Securities Investment Fund seeks 4.002 billion yuan.
Regarding the underlying assets of these commercial real estate REITs, the asset types are diverse, already covering hotels, office buildings, shopping malls, and commercial complexes. Huatai Fixed Income analysis indicates that hotel assets are typically positioned as four-star or above establishments. As discretionary consumption items, they are significantly affected by economic cycles. Among this first batch, only the Huaan Jinjiang project involves hotel assets. Furthermore, many of the initial projects are issued as single retail malls or commercial complexes. The former benefits from national policies promoting consumption, while the latter, with their multi-format assets, offer greater resilience against economic cycle risks.
Taking the CICC Vipshop Closed-End Commercial Real Estate Securities Investment Fund as an example, its real estate projects are the Zhengzhou Shanshan Outlets and the Harbin Shanshan Outlets, with an expected fundraising scale of 7.47 billion yuan. The Zhengzhou Shanshan Outlets project opened in September 2016 and has been operational for nearly 10 years. Developed in three phases, it includes a two-story above-ground plaza and underground parking (Phase I), a three-story above-ground plaza (with the third level for parking, Phase II), and a single-story above-ground plaza (Phase III), with a total construction area of approximately 112,000 square meters. As of December 31, 2025, the remaining land use term for this project is about 30.68 years. The Harbin Shanshan Outlets project opened in September 2015 and has been operational for nearly 11 years. It consists of commercial space from one to three stories above ground and one level of underground parking, with a total construction area of 130,600 square meters. As of December 31, 2025, the remaining land use term is approximately 27.14 years.
Commercial real estate REITs involve various types of intermediary institutions, including fund managers, custodians, financial advisors, accounting firms, and law firms. For instance, in the Huaan Jinjiang Closed-End Commercial Real Estate Securities Investment Fund, the fund manager is Huaan Fund, the custodian is China CITIC Bank, and the financial advisor is GTHT. Regarding financial advisors for the first 10 REITs, the involved institutions include GTHT (4 projects), CITIC SEC (2 projects), Huatai United, China International Capital Corporation Limited, and Shenwan Hongyuan Underwriting & Sponsorship. These are predominantly leading securities firms.
In late December last year, the CSRC's "Notice on Promoting the High-Quality Development of the Real Estate Investment Trust Fund (REITs) Market" explicitly stated the need to "supervise fund managers, custodians, financial advisors, asset-backed security managers, original equity holders, and other professional institutions to strictly perform their duties in accordance with laws, regulations, contractual agreements, and public commitments."
Policy support is actively driving this initiative. Reports indicate that commercial real estate REITs are still in their early stages. The CSRC's announcement at the end of December last year marked the formal beginning of commercial real estate REITs. Industry insiders believe that commercial real estate REITs are a crucial component in perfecting the public REITs, inter-institutional REITs, and Pre-REITs ecosystem. They help support the construction of a new model for real estate development and assist real estate companies in achieving a virtuous cycle of "investment, financing, management, and exit."
The CSRC emphasized the significant importance of developing commercial real estate REITs. Promoting the commercial real estate REITs market is a key measure for the capital markets to implement the decisions and deployments of the Party Central Committee and the State Council regarding "revitalizing stock assets," "optimizing incremental assets," and "increasing the proportion of direct financing." It is an effective market-based mechanism to support the new model for real estate development and holds great significance for promoting the healthy development of the REITs market, enhancing the functionality of REITs, and continuously improving the inclusivity and adaptability of the capital market system.
Local securities regulatory bureaus are also actively promoting the implementation of commercial real estate REITs. From late January to early February, the Beijing Securities Regulatory Bureau, in conjunction with relevant Beijing municipal units, held a "Policy Interpretation Training Session on Beijing Commercial Real Estate REITs." The meeting provided an in-depth interpretation of the policy implications, systematically outlined practical pathways, and mobilized and deployed efforts for the first batch of pilot applications. It was stated that Beijing, with its large scale of high-quality commercial assets and solid market foundation, should seize the opportunity and develop steadily in the commercial real estate REITs innovation pilot.
The Sichuan Securities Regulatory Bureau is also strengthening inter-departmental coordination to actively prepare for the commercial real estate REITs pilot. It has liaised with the Provincial State-owned Assets Supervision and Administration Commission, the Provincial Financial Office, and other units to jointly assess the stock of commercial real estate eligible for application. The bureau is promoting the policy to major bond issuers within its jurisdiction, large central and state-owned enterprises, and intermediary institutions operating in Sichuan, and is maintaining a roster of potential projects based on asset quality and corporate willingness.
Several listed companies are also preparing to actively apply for commercial real estate REITs. On January 28, Poly Development released an "Announcement on Carrying out Commercial Real Estate REITs Application and Issuance Work and Related Authorization Matters." The announcement stated that, in response to policy calls such as the CSRC's announcement on the pilot program and the notice on promoting high-quality development of the REITs market, and to further build the company's professional capabilities in real estate operation, optimize its capital structure, and enhance its core competitiveness and sustainable development capacity, the company plans to use its held commercial real estate projects as underlying assets to initiate the application and issuance process for commercial real estate investment trust funds.