Private Real Estate Funds in Saudi Arabia: SAR 380.7bn

Private real estate funds in Saudi Arabia hold SAR 380.67 billion across 965 funds and 130,232 subscribers at the end of Q1 2026, which makes them the largest private fund class in the Kingdom and the least disclosed vehicle in it (CMA, Quarterly Statistical Bulletin, 47th issue, pages 51 to 53). Three years earlier, at Q1 2023, those same cells read SAR 129.35 billion, 309 funds and 56,113 subscribers. Every listed Tadawul REIT put together holds SAR 30,838 million at the same date, and none raised new capital in either half of 2025. For the private universe the Capital Market Authority publishes three aggregates a quarter and nothing else: no fund names, no cities, no asset types, no leverage, no returns.

Key figures at a glance

How big are private real estate funds in Saudi Arabia?

SAR 380.67 billion across 965 funds at the end of Q1 2026, against SAR 129.35 billion across 309 funds at Q1 2023. Real estate is the largest private class on all three of CMA's measures at once: assets, fund count and subscribers. Equities, the next class down, holds SAR 212,653.01 million across 222 funds at the same date (CMA, pp.51-52).

CMA says it itself: private funds are 75.0% of all investment-fund assets at end-2025, and the chairman attributes the industry's expansion to "a significant rise in private real estate fund assets, which grew by 53% to reach SAR 356 billion" (Annual Report 2025, pages 16 and 100). Its Q3 2020 bulletin carries the identical column back to SAR 17,733.25 million across 68 funds in the first half of 2013 (CMA), which is as far back as the private-fund tables run.

Omran computation, from CMA's own cells. Real estate is 54.3% of private-fund assets (380,674.64 of 700,693.61) and 67.9% of private-fund subscribers, and it produced 75.3% of the three-year increase (SAR 251,326.64 million of a SAR 333,572.90 million rise). These funds hold 12.3 times the assets of all twenty Tadawul REITs combined, and 21.5 times what the class itself held in first-half 2013 (380,674.64 against 17,733.25). Only the "Real Estates" column survives that second comparison, because the 2020 edition sorts private funds into nine classes and the 2026 edition into twelve, and nine quarters between the two files, Q4 2020 to Q4 2022, are published nowhere. Inputs: CMA bulletin, pages 44 and 51 to 53; CMA Q3 2020 bulletin, sheets 25 and 26.

The SAR 500 million that does not apply to them

The number quoted most often as the price of entry to a Saudi private real-estate fund is a listing condition belonging to somebody else. Article 47(a)(2) of the Real Estate Investment Funds Regulations requires SAR 500 million of total assets on establishment to offer units on the Main Market, SAR 100 million on the Parallel Market. Those Regulations cover publicly offered funds only, and Part 5 of the private rulebook sets no minimum at all.

Article 1(a) says as much: they regulate funds "the units of which are offered publicly in the Kingdom" (Regulations, amended 24 Nov 2025). The rest of that book is what a listed REIT carries: 75% of assets in developed income-producing property, 90% of net profit distributed (47(b)), borrowing capped at 50% (41(b)), revaluation by two accredited valuers every six months with the report published within 15 days (37(c)). A second misreading sits in that list. The last two are public-offering rules, not REIT rules: 41(b) caps borrowing for "the Fund -including a REIT fund on the Main Market-". They pass for REIT rules because the whole publicly offered non-traded real-estate class is three funds holding SAR 174 million at Q1 2026 (CMA, p.44). The publication duty in 37(c) is what builds the asset-level REIT disclosure record.

Private funds live in Part 5 of the Investment Funds Regulations, where Article 82(d) removes the choice of structure: "If the units are offered in a private real estate fund, the fund must be a closed-ended investment fund." Hence the Arabic term for the class, الصناديق العقارية المغلقة, closed-ended real-estate funds, rather than any word meaning private. Valuation bites at the transaction and nowhere else: two valuers holding the Saudi Authority for Accredited Valuers fellowship, independent of every related party including any 5% unitholder, report under three months old, before a purchase or a sale (Article 92). No periodic revaluation, and no publication duty at all. Reporting runs inward: unitholders get audited accounts within 90 days and an interim report every six months, CMA gets them within five days of asking (95 and 96).

Why the count exploded while the average fund shrank

The class added SAR 251.33 billion and 656 funds between Q1 2023 and Q1 2026, and the average fund inside it got smaller over the same span, from SAR 418.6 million to SAR 394.5 million. Both halves of that are ours, divided out of CMA's own numerator and denominator. One quarter, the one ending Q4 2025, produced 147 of the new funds.

Omran computation, the shape of the growth. SAR 380,674.64 million over 965 funds is SAR 394.5 million per fund at Q1 2026, against SAR 418.6 million (129,348.00 over 309) at Q1 2023: average size down 5.8% while total assets rose 194.3%, a 43.3% compound annual rate. Subscribers per fund fell from 181.6 to 135.0. Year on year the class grew 40.7%, from SAR 270,596.18 million at Q1 2025. Inputs: CMA bulletin, pages 51 to 53.

SAMA sees it from outside the CMA tables: the average value per private fund "declined 1.8 percent in 2024", a year when the number of real-estate funds rose 36.4% (Financial Stability Report 2025, page 63).

The tax code explains that shape better than investor appetite does. A Saudi fund has no legal personality, so a custody company is incorporated to hold title. Contributing a building in kind escapes the 5% real-estate transaction tax if the units stay put for five years, and selling units of an unlisted fund is exempt below 50%, taxed at 5% at or above (ZATCA, RETT guideline v6, sections 5.1.11, 5.1.23 and 5.1.24). Selling the building itself is a 5% event on the whole price. An average vehicle of SAR 394.5 million with 135 subscribers is not a diversified portfolio; it reads as a wrapper around one asset, and the tax code pays for the wrapper. That reading is ours: CMA publishes no size distribution and no asset list, so the averages are the only evidence either way.

Who may buy in, and who signs off on the launch

Institutional and qualified clients, with retail money capped at SAR 200,000 an investor (Article 82(a)) and at half the fund's cash subscriptions, tested at the offer under 82(b) and again on every later transfer under 98(b). Nobody approves the launch: CMA is notified in writing at least 15 days before the offer and may object. It logged 709 private-placement notifications in 2025 against the single listed real-estate fund it approved that year (Annual Report 2025, page 96), in twelve months when net subscriptions into the whole public REIT class were SAR 0.00 and the listed REIT count did not move off 20, where it has sat in every quarter since Q1 2024 (bulletin, pages 45 and 56). Primary capital formation in Saudi real estate has moved into the structure that files nothing publicly.

What the 965 funds never have to tell you

Three aggregates per class per quarter is the whole public record here, and it has never been more than that: CMA's 2013 tables count the same three things and stop. No register, no manager names, no fund names, no launch or termination dates, no size distribution. The SAR 380.67 billion behind those 965 funds is anonymous at Q1 2026 and in every quarter before it. One filing does reach the public and it has nothing to do with property: Article 97 makes the manager notify the Exchange within three trading days when the fund crosses 5% of a listed issuer's voting shares (Investment Funds Regulations). The buildings, the valuations, the borrowing and the returns never travel that way.

Each hole is a decision an investment committee takes blind. No geography, not even a domestic-versus-foreign split, though CMA publishes exactly that for public funds on page 54 of the same bulletin. No land against built, no development against income-producing. No returns, no distributions, no NAV history, which is why the closest published comparator is a neighbourhood gross yield rebuilt from REGA files and why yield on cost against cap rate has to be argued from first principles here. CMA never defines the "Real Estates" class either, and a footnote adds that these figures include funds still in their offering period, so part of the SAR 380.67 billion has bought nothing yet. The design shows in the rulebook: the Instructions for Investment Funds Announcements set out 21 announcement types for public funds and 19 more for public real-estate funds, and the word "private" appears zero times across its 73 pages (CMA).

Omran estimate: a ceiling on private-fund leverage, because the real number is filed and never published. Part 5 sets no borrowing limit and no aggregate leverage figure exists anywhere, but the cap itself is not missing. Annex (11) of the Investment Funds Regulations requires each fund's terms and conditions to state its borrowing powers and "the statement of borrowing cap", and Article 83(a)(3) files those terms with CMA at notification. It exists 965 times over, the regulator holds every one, and only the public is outside the room. The bound we can build from published cells: corporate real-estate credit at Saudi banks was SAR 227,389.94 million at Q1 2026 (SAMA, table 12e), so even if every riyal had gone to these funds, their domestic bank borrowing could not exceed 227,389.94 over 380,674.64, or 59.7% of assets. That covers Saudi bank debt only, not sukuk and not offshore lenders, and the true share sits far below it: a roof, not a measurement of what these funds owe.

The rest of that SAMA sheet is worth reading whole. Bank real-estate loans stood at SAR 967,894.69 million at Q1 2026, split SAR 740,504.75 million to individuals and SAR 227,389.94 million to corporates, the corporate half growing 7.7% year on year against 6.0% for households (SAMA, June 2026 bulletin, table 12e; the series sits in full in our Saudi real-estate lending data).

Omran computation, the funds set against the corporate loan book. SAR 380,674.64 million of fund assets over SAR 227,389.94 million of corporate real-estate credit is 1.67 times, both at Q1 2026. Household mortgages, the other SAR 740,504.75 million, finance buyers rather than vehicles. Fund leverage is unpublished, so part of the 380.67 may be borrowed from part of the 227.39: size the two against each other and never add them. Inputs: CMA bulletin, page 51; SAMA, table 12e.

Every figure on this page was read off the regulator's own file, never off a summary of it, with both language editions of the bulletin open side by side and every cell carrying its page and its date. That is the whole of our Saudi public data sources method. Ask for the assembled fund and credit series if you want it quarter by quarter rather than as a headline.

FAQ

How big are private real estate funds in Saudi Arabia, and who publishes the number? SAR 380.67 billion across 965 funds and 130,232 subscribers at the end of Q1 2026, on pages 51 to 53 of CMA's 47th quarterly statistical bulletin. Divide it by the SAR 700.69 billion private-fund total on the same page and real estate is 54.3% of all Saudi private-placement assets. Two cautions when quoting it: cite by page and table title, because the index and the printed table numbers disagree from there on, and avoid the Q3 2025 row, which differs between CMA's English and Arabic editions with no erratum saying which governs.

What is the difference between a private closed-ended real estate fund and a listed REIT? Different rulebooks. A REIT falls under the Real Estate Investment Funds Regulations: SAR 500 million of assets to list on the Main Market, 75% in income-producing property, 90% of net profit distributed, borrowing capped at 50%, revaluation every six months with the report published within 15 days. The last two bind every publicly offered real-estate fund, not listed REITs alone. A private fund falls under Part 5 of the Investment Funds Regulations, must be closed-ended (82(d)), and carries none of it.

Does CMA approve a private real estate fund before it launches? No. Article 83 is a notification regime: the manager notifies CMA at least 15 days before the offer, filing the terms and conditions, a declaration and a compliance programme, and CMA may object. In 2025 it logged 709 private-placement notifications and approved one listed closed-ended real-estate fund.

Who can invest, and can units be sold before the fund terminates? Institutional and qualified clients: net assets of at least SAR 5 million for an individual, SAR 10 million to SAR 50 million for a company, above SAR 50 million to count as institutional (CMA Glossary, 2026). Retail investors are capped at SAR 200,000 each and at half the fund's cash subscriptions. Units transfer only within those categories (98(a)), and a transfer of 50% or more of a fund is taxed at 5% as a real-estate transaction, where less is exempt.

Sources

• CMA, Quarterly Statistical Bulletin Q1 2026, 47th issue (fund AUM, counts, subscribers, net subscriptions, pages 44 to 56): link
• CMA, Quarterly Statistical Bulletin Q3 2020 (the same class back to first half 2013): link
• CMA, Annual Report 2025 (75.0% private share p.100, chairman's statement p.16, 709 notifications p.96): link
• CMA, Investment Funds Regulations as amended 24 Nov 2025 (Part 5, Articles 80 to 98, Annex 11): link
• CMA, Real Estate Investment Funds Regulations as amended 24 Nov 2025 (Articles 1, 37, 41, 47): link
• CMA, Instructions for Investment Funds Announcements (no private-fund announcement regime): link
• CMA, Glossary of Defined Terms 2026 (Qualified Client, Institutional Client): link
• SAMA, Monthly Statistical Bulletin June 2026, table 12e (real-estate loans, individuals and corporates): link
• SAMA, Financial Stability Report 2025 (private-fund and real-estate fund growth): link
• ZATCA, RETT Detailed Guideline Version 6, May 2026 (sections 5.1.11, 5.1.23, 5.1.24): link