CSRC Seeks Public Comment on Draft Announcement to Launch a Pilot for Commercial Real Estate REITs

Commercial REITs pilot in China: CSRC seeks public comment on the Draft Announcement for commercial real estate REITs.

Key Points

China Securities Regulatory Commission (Zhengjianhuì 中国证监会, CSRC) has released a Draft Announcement titled “Announcement on Launching a Pilot for Commercial Real Estate Investment Trusts (Draft for Comments).”

The Draft Announcement is open for public consultation and aims to implement central government decisions and the new “Nine Measures” for the capital market.

The goal is to promote the high‑quality development of the REITs market, broaden capital‑market financing tools, support new models for real estate development, and strengthen the multi‑layer capital market’s service to the real economy.

Quick take: what the Draft Announcement covers

The Draft Announcement is organized into eight articles and sets core principles and regulatory expectations for a pilot of commercial real estate REITs.

Key points from the Draft are practical and focused on governance, risk control, and market structure.

Product definition

• Commercial real estate REITs (shāngyè bùdòngchǎn tóuzī xìntuō jījīn 商业不动产投资信托基金, REITs) are defined as closed‑end, publicly offered securities investment funds that hold commercial real estate to generate stable cash flows and distribute income to fund unit holders.

Registration and operational requirements

• The Draft clarifies requirements for fund registration and ongoing operation.
• It lists qualifications and responsibilities for fund managers and custodians.
• It sets expectations for due‑diligence, required application materials, and criteria for eligible commercial real estate assets.
• The Draft requires the fund manager’s proactive operational management of assets.

Roles and responsibilities of market participants

• The Draft emphasizes the roles of fund managers and professional institutions.
• The Draft tightens and clarifies legal and regulatory responsibilities for these participants.
• The Draft requires strict adherence to professional standards and supervisory rules.

Regulatory framework and risk monitoring

• The Draft strengthens regulatory duties and clarifies responsibilities of relevant regulatory bodies for commercial real estate REITs.
• The Draft expects active risk monitoring and implementation of risk mitigation or resolution measures as needed.

Reference to existing guidance

• Other matters not expressly set out in the Draft will be handled by reference to the “Guidelines for Publicly Offered Infrastructure Securities Investment Funds (Trial)” (gōngkāi mùjí jīchǔ shèshī zhèngquàn tóuzī jījīn zhǐyǐn（shìxíng） 公开募集基础设施证券投资基金指引（试行）) and relevant rules.

What the CSRC is asking from the public

The CSRC invites comments from all sectors of society on the Draft Announcement.

After reviewing public feedback, the CSRC will revise the Draft as appropriate and complete the required procedures before issuing the final Announcement and putting the pilot into effect.

Why this matters — practical insights for investors, founders, and operators

Commercial REITs present a structural shift in how commercial property liquidity and cash flows can be packaged and offered to public investors in China.

Here are clear implications to watch for:

• Broader financing tools: The pilot aims to expand capital‑market financing tools for real estate, which can help diversify funding beyond bank loans and developer financing.
• Institutional role: Expect fund managers, custodians, and service providers to play bigger, more regulated roles in asset oversight.
• Market discipline and transparency: Public offering and registration requirements will push better disclosure and operational standards for commercial real estate assets.
• Risk monitoring: Increased regulatory duties aim to provide earlier detection of stress in the sector and clearer mechanisms for mitigation and resolution.
• Alignment with infrastructure guidelines: Where gaps exist, reliance on existing infrastructure fund guidelines provides a tested framework to accelerate market rollout.

How founders, investors, and tech operators should read this

• Founders building property tech, asset management platforms, or lending products should track the pilot rules for product eligibility and custody requirements.
• Investors — both institutional and retail — should note the closed‑endnature and income distribution focus when assessing liquidity and return expectations.
• Service providers like appraisers, auditors, and legal counsel will likely see demand increase as fund managers comply with due diligence and ongoing operational obligations.

Practical next steps

• Market participants who want to influence the final text should consider submitting comments during the public consultation window.
• Prepare to review and align internal compliance, reporting, and asset management capabilities if you plan to participate in the pilot.
• Follow final guidance closely once the CSRC issues the final Announcement and the pilot is launched.

Notes and legal reminder

• This public consultation is intended to promote a clear, consistent regulatory framework for the pilot and to support a wider, safer market for commercial REITs in China.
• Where Chinese institutional names appear, the format used in this article is: English name (pinyin 中文名). For example: China Securities Regulatory Commission (Zhengjianhuì 中国证监会, CSRC).
• No investment advice is provided here.
• Market participants should perform their own due diligence and consult professional advisors before acting on policy developments.

References

• Announcement soliciting public comments on the draft ‘CSRC Announcement on Launching a Pilot for Commercial Real Estate Investment Trusts (Draft for Comments)’ – China Securities Regulatory Commission (中国证监会 Zhōngguó Zhèngjiànhuì)
• 关于《中国证监会关于推出商业不动产投资信托基金试点的公告（征求意见稿）》公开征求意见 – 东方财富网 (Dōngfāng Cáifù Wǎng)

Commercial REITs pilot in China.