Core Viewpoint - The introduction of commercial real estate investment trusts (REITs) in China aims to revitalize the commercial property market and provide new financing avenues for enterprises, particularly in a challenging real estate environment [4][5]. Group 1: Expansion of Public REITs - The China Securities Regulatory Commission (CSRC) has released a draft for public consultation regarding the pilot launch of commercial real estate REITs, expanding the scope of public REITs to include commercial office facilities and urban renewal projects [4]. - The National Development and Reform Commission (NDRC) has also updated the industry scope for infrastructure REITs, adding categories such as sports venues and commercial complexes [4]. Group 2: Market Opportunities Amidst Challenges - The launch of commercial real estate REITs is seen as a response to the ongoing downward pressure in the real estate market, providing a mechanism to improve asset structures and facilitate a shift from "heavy development" to "heavy operation" for enterprises [5]. - The expansion of public REITs to include commercial real estate assets enriches the asset types available in the market, offering investors more choices [5]. Group 3: Regulatory Framework and Implementation - The overall regulatory framework for commercial real estate REITs will follow that of infrastructure public REITs, with simplified requirements for fund managers and custodians [6]. - The specifics regarding categories and review mechanisms are still pending further details from the CSRC, and a dual-track review system could enhance efficiency and flexibility in the market [6]. Group 4: Market Dynamics and Valuation - The secondary market for infrastructure public REITs is currently under pressure due to year-end product unlocks and increased supply expectations [8]. - Historical dividend yields for office and hotel REITs in Japan average around 4.0% and 3.7%, respectively, which are comparable to current yields of infrastructure public REITs, indicating that product valuation and operational quality will be critical for future investments [8].

Group 1: Report Industry Investment Rating - Not provided in the content Group 2: Core Views of the Report - On November 28, 2025, the CSRC issued the "Announcement on Launching the Pilot Program of Commercial Real Estate Investment Trusts (Request for Comments)" to solicit opinions on the pilot program of commercial real estate investment trusts. On December 1, 2025, the National Development and Reform Commission expanded the industry scope of infrastructure REITs to include commercial office facilities and urban renewal facilities, and added sub - categories such as stadiums, commercial complexes, and four - star and above hotels in consumer infrastructure [3][10][14]. - Launched during the real estate downturn, it provides an opportunity to revitalize the trillion - dollar commercial and office market. It can improve the asset structure of enterprises, help the real estate industry transform into a new development model, and enrich the types of underlying assets in the domestic public REITs market [3][10]. - It is necessary to pay attention to the institutional connection, and detailed rules are still awaited. The overall institutional framework of commercial real estate REITs follows that of infrastructure public REITs, and the specific categories and review mechanisms need further clarification. Implementing a dual - track review system may improve efficiency and accelerate market expansion. The applicability of the key expansion and recruitment mechanism and pilot tax policies in commercial REITs also needs attention [3]. - The secondary market of infrastructure public REITs is under short - term pressure. The valuation and operation quality of new products are the keys. The historical average dividend yields of Japanese office building REITs and hotel REITs are similar to those of current infrastructure public REITs equity - type products [3]. - Investment advice: In a low - interest - rate environment, high - dividend public REITs have an obvious interest - rate spread advantage. With the expansion of categories and improvement of the system, the market is expected to develop rapidly. Attention should be paid to the progress of new - category projects, products with strong underlying asset demand, and expansion and recruitment [3]. Group 3: Summary by Relevant Catalog 3.1 Public REITs Expand to the Commercial Field - On November 28, 2025, the CSRC solicited opinions on the pilot program of commercial real estate investment trusts, with the feedback deadline on December 27, 2025 [10]. - The National Development and Reform Commission is promoting the expansion of infrastructure REITs to more industries and asset types. On December 1, 2025, it issued the "List of Industry Scope of Infrastructure Real Estate Investment Trusts (REITs) Projects (2025 Edition)", expanding to commercial office facilities, urban renewal facilities, and adding sub - categories in consumer infrastructure [14]. - In Q3 2024, there were 736 five - star hotels in China, accounting for 43.5% of the operating income of star - rated tourist hotels, and 2073 four - star hotels, accounting for 37.6%. The scope of the new expansion includes commercial office facilities (super - A and A - grade commercial buildings in super - large and large cities) and urban renewal projects (old - block and old - factory renovation projects), with isolation mechanisms set up [12]. 3.2 The CSRC Solicits Opinions on the Commercial REITs Pilot - Product definition: A commercial real estate investment trust fund is a closed - end publicly offered securities investment fund that invests in commercial real estate asset - backed securities to obtain the ownership or operating rights of commercial real estate, operates and manages commercial real estate to obtain stable cash flows such as rent and fees, and distributes the main income to fund share holders [15]. - Application process: To apply for the raising of a commercial real estate investment trust fund, the fund manager should submit the registration application materials stipulated by the "Securities Investment Fund Law" and the CSRC to the CSRC [20]. - Current situation of infrastructure public REITs: The current application process is "local NDRC - national NDRC - CSRC", with a long review process and a relatively small market scale. As of November 30, 2025, the issuance scale of the public REITs market (initial offering and expansion and recruitment) was about 209.5 billion yuan, and the market value was about 219.9 billion yuan. For commercial real estate assets with a higher degree of marketization, applying only to the CSRC can shorten the review process and accelerate market expansion [25]. - The scale of China's commercial real estate is huge, about 40 - 50 trillion yuan. Some enterprises are preparing for relevant application work, such as Fosun's progress in the independent listing plan of Sanya Atlantis through the REITs model [25]. 3.3 Pay Attention to the Institutional Connection - The overall institutional framework of commercial real estate REITs follows that of infrastructure public REITs. The "Request for Comments on Commercial REITs" is more concise in terms of the requirements for fund managers and custodians, fund manager responsibilities, and asset requirements. The asset sub - types in the "List of Industry Scope of Infrastructure Real Estate Investment Trusts (REITs) Projects (2025 Edition)" are more specific [26]. - Implementing a dual - track review system for infrastructure public REITs and commercial real estate REITs can provide more choices for issuers, improve review efficiency, and accelerate market expansion. The applicability of the expansion and recruitment mechanism and pilot tax policies in commercial REITs needs attention [27].

Core Viewpoint - The performance of public REITs in the first quarter remains robust despite a volatile market environment, with significant support from policies and increasing interest from private capital [1][4][5]. Group 1: Performance Overview - A total of 62 public REITs have disclosed their operating data, achieving a combined revenue of 4.779 billion yuan and a net profit of 840 million yuan in the first quarter [1]. - 15 products reported revenues exceeding 100 million yuan, and 29 products had net profits over 10 million yuan, indicating a stable income for investors [1]. - Consumer REITs showed impressive growth, with revenues for specific products like Huaxia Huayun Commercial REIT increasing by 82.28% year-on-year [2]. Group 2: Market Expansion and Support - The number of public REITs is expected to continue expanding, with 7 new REITs listed this year, bringing the total to 65 [4]. - Local governments, such as Guangdong, are actively promoting the cultivation and application of infrastructure REITs, supporting more private capital projects [1][5]. - Non-state-owned enterprises are also showing interest in public REITs, with companies like CapitaLand submitting applications for consumer infrastructure REITs [5]. Group 3: Challenges for Private Enterprises - Private enterprises face challenges in participating in the REITs market, including the need for higher yield rates and market acceptance [6]. - The requirements for asset clarity and stable cash flow are high, with a need for a compound annual growth rate of net operating income (NOI) of at least 5% over three years [6][7]. - To successfully issue REITs, private enterprises must improve asset compliance, operational quality, and governance structures [7].