The Capital Markets Authority (CMA) wrote Real Estate Investment Trust (REIT) rules in 2017. It is the legal structure letting property owners sell shares in buildings the way companies sell shares in themselves. The need was that real estate is illiquid, capital-starved, and financed mostly through short-term bank loans ill-suited to assets that take decades to pay off.
REITs promised patient capital, pooling pension contributions, insurance premiums, and retail savings into property, and giving ordinary savers access to an asset class usually reserved for the wealthy. Nine years later, the rulebook sits unused. Not one REIT has listed on the Uganda Securities Exchange. Kenya, working from equivalent 2013 regulations, now has five REITs worth a combined Ksh30.3b (about $235m) as of March 2026, modest by global standards, but real.
Its newest, a green, dollar-denominated income REIT built around a commercial tower at Nairobi’s Two Rivers development, closed its public offer 103.3 percent oversubscribed in June 2026, raised $30.8m, and jumped 23 percent on debut. Rwanda looks closer to Uganda than it seems. Its capital markets authority introduced REIT regulations only in 2024, and by mid-2026, none had listed on the Rwanda Stock Exchange. This means Uganda isn’t the region’s only laggard, just the one that’s been waiting longest.
An old problem
Dickson Ssembuya, who heads research and market development at CMA, says one of the problems Uganda’s REITs market faces is the absence of precedent. ‘I think there is lack of proof of concept. And, of course, in the absence of other property owners either issuing a REIT to raise capital to develop property, you find that there is a bit of hesitancy. So, we need some sort of proof of concept around real estate investment trusts,’ he notes. But beyond this, he says, patchy valuation standards, thin technical skills among practitioners who have never structured such deals, a land tenure system still catching up to modern registry standards, and low awareness among property owners still present challenges.
And this is why, partly, nine years of inertia in a market badly needing an alternative to bank debt have gone by. However, a new valuation act and adoption of international ‘Red Book’ standards have begun standardising how Ugandan property is priced, long a sore point, since owners habitually inflated asking values beyond what institutional buyers would accept. The Landlord and Tenant Act has made it easier to enforce lease terms and evict defaulting tenants, addressing investors’ worries about weak legal recourse.
Land registry modernisation, while incomplete, has reduced, though not eliminated, the risk of duplicate or contested titles. The scaffolding, in other words, is largely built. What’s missing is a tenant to move in. A regional market pulling ahead Kenya is moving ahead. But its REIT market didn’t succeed on the first attempt. Two earlier vehicles, Stanlib I-REIT and ILAM Fahari I-REIT, both launched around 2015, traded thinly for years, hampered by minimum investment thresholds so high they effectively locked out retail investors and left the securities with almost no secondary-market liquidity.
It took roughly a decade, and a redesigned product with a $1,000 minimum subscription instead of the six-figure entry points that sank the earlier funds, before Kenya produced a REIT investors actually wanted to trade. That is a genuinely useful data point for Uganda. The lesson from the region’s most advanced market isn’t simply ‘REITs work,’ but REITs work once the product is designed for investors you actually have, a more specific and actionable finding than the regulatory-optimism version. Rwanda’s experience cuts the other way.
Its REIT framework looks similar to Uganda’s and Kenya’s on paper, and its land administration is, by regional consensus, considerably more advanced because the Land Tenure Regularisation Programme completed a nationwide systematic land registration exercise years ago and is widely cited as a model for East Africa. Yet, no REIT has listed in Kigali either. That is genuinely surprising, and it complicates any theory that land-title clarity alone is sufficient to produce a REIT market. Rwanda suggests good land administration is close to necessary. Uganda and Kenya’s early years suggest it’s nowhere near sufficient. Something else like market depth, product design, investor education, or simply time has to be present too.
The land question
Much of the technical conversation around Ugandan REITs eventually returns to a more basic problem: title. Property here sits across a genuinely complicated tenure system where freehold, leasehold, mailo and customary land coexist, sometimes overlapping on the same parcel, a legacy of colonial-era land policy no government has fully rationalised. When Uganda began digitising its land registry in 2013, only about 20 percent of land in the country was officially registered at all.
A decade and a $100m World Bank-financed modernisation programme later, registering a title still officially takes two weeks and, by local reporting, no one has yet managed to complete the process entirely online. For an ordinary sale, that friction is an inconvenience. For a REIT, which depends on thousands of dispersed investors trusting a prospectus they cannot independently verify, it’s closer to disqualifying. This problem, and what it would actually take to fix it, is worth its own examination, but the short version is that registry modernisation has narrowed the risk without eliminating it. Thus, the most REIT-suitable assets still sit disproportionately in the urban areas where old paperwork is thickest.
Compounding this is a shortage of people who have done this before. Structuring a REIT requires valuers trained to institutional standards, licensed fund managers, lawyers versed in trust law as applied to listed securities, and auditors comfortable certifying property income to capital-markets standards. Uganda has professionals in each field individually, but almost none with REIT transaction experience, because none has yet happened, a chicken-and-egg problem common to any market’s first structured-finance product. Regional firms with Kenyan or South African transaction experience are, in effect, importing that missing expertise, which may prove more durable than waiting for local talent to catch up organically.
What ‘REIT-ready’ actually means
Moses Lutalo, who runs Broll, a property management firm which manages a property portfolio worth more than $200m, argues the test is more commercial than legal. Does the asset behave the way institutional money expects it to? ‘Every time we have had a conversation with property owners, it has boiled down to: are they ready for the sort of scrutiny that capital-markets expectations look out for?’ he says. Importantly, he says, developers must be ready for questions like: are your cash flows underwritten properly, do you have audited financial books, and are you ready for disclosure expected within the listed property market.
This is echoed by Matthew Rukaari, who manages a $400m real estate portfolio at National Social Security Fund (NSSF), the country’s most obvious anchor investor for any future REIT. ‘The first thing I would like to see, assuming a REIT is being proposed, is the quality of the underlying assets. They have to be what you would want to call institutional grade with a clean title, in fantastic locations that have prospects for appreciation’
But beyond this is the issue of governance, which Rukaari says must ensure there is an independent trustee, experienced management, transparent reporting, credible valuation, and a clear alignment between the sponsors and investors. None of this is unusual by global standards. Yet Uganda’s property owners have, on the whole, run their projects as private businesses, not as regulated investment products. Converting one into the other is a cultural exercise more than a legal one.
The tax that kills deals
If there is a single obstacle worth watching, it’s tax.
Moving a property into a REIT trust currently triggers a stamp duty of 1.5 percent of the asset’s value under the Stamp Duty Act. Government grants targeted stamp-duty exemptions, but only in strategic cases such as large-scale industrial park developers meeting a $50m investment threshold. Fredrick Murimi Ngari, managing partner at Centum Capital Partners, points out that Kenya and South Africa both built their REIT markets on exactly this kind of exemption. Ssembuya confirms the issue is under active discussion between CMA, Uganda Revenue Authority and Ministry of Finance, but no resolution has been reached.
Who might actually go first?
Two candidates stand out, for different reasons. The first is NSSF, which occupies an unusual dual position. NSSF manages roughly Shs26 trillion (about $7.4b) in total assets, of which real estate accounts for around 7 percent. The Fund, in its 2024 annual report, indicated that more than 40 percent of its real estate allocation, such as 469 acres at Temangalo and 423.6 acres at Nsimbe, is undeveloped land, held partly for future development and capital appreciation.
That land, packaged into a development REIT, could bring in outside capital rather than tying up the fund’s own balance sheet for years before a project generates returns. NSSF’s real estate portfolio has, by its own disclosures, delivered underwhelming returns of around 5.6 percent in recent years, sharpening the case for a more capital-efficient use of that land. Whether NSSF’s dual role as both prospective anchor investor and issuer creates a genuine governance problem is a separate question worth its own scrutiny.
The second candidate is the private sector, involving developers already active in high-end residential and mixed-use projects who have watched Kenya’s REIT market mature and are beginning to ask whether their own unbuilt phases could be financed the same way. However, none of these point to a single fix, and that may be the real lesson. Kenya needed a decade, and a redesigned product before its REIT market found investors who wanted in. Rwanda has cleaner land records than either country and still has nothing listed. Uganda, meanwhile, has spent years narrowing its own list of obstacles like the valuation standards, lease enforceability, and registry risk, without producing an issuer.