LEGAL ALERT

The Future of Capital Markets: Unlocking REITs in Uganda (Part 1)

Article Series By Joshua T. Byabashaija (Partner), Hosea Barlow (Senior Associate), and Christopher Percy Mpindi (Associate).

Why REITs matter, and why Uganda should care

Everyone wants to own real estate and income generating infrastructure, but far fewer are willing or able to manage such assets directly. It is within this gap that Real Estate Investment Trusts (“REITs”) find their purpose. In this article, the first in a series, we explore the concept of REITs in Uganda.

A REIT is a structured investment arrangement involving real estate or interests in real estate, set up in accordance with regulatory requirements, which allows participants to invest in property, whether directly or indirectly, and share in the income or profits generated from its acquisition, ownership, management or eventual disposal.

Instead of buying an entire apartment block, office building or shopping centre, an investor can buy an interest in a professionally managed vehicle that owns income-producing property. In that sense, REITs make property and infrastructure ownership more accessible to ordinary people who would be able to invest in toll roads, data centres and other regulated infrastructure such as telecom towers. REIT’s turn real estate from a market traditionally reserved for developers, banks and a small group of wealthy investors into something that can, in principle, be opened to a much wider public.

This model is already gaining traction across Africa. In Kenya, for example, the Vuka platform allows investors to participate in portfolios backed by Acorn’s income-generating and development REITs with relatively modest entry amounts, thereby widening access to institutional-grade real estate investments that would otherwise remain out of reach for most individuals.

That is why REITs are often described as a way of democratising real estate.

From Bricks and Mortar to the digital economy

Around the world, the REIT structuring has moved from traditional property to what observers have called the “mission-critical digital infrastructure”.

REITs still own office blocks, malls and residential developments. But the market has evolved. Newer REIT platforms now hold telecom towers, data centres, toll roads, and other non-traditional assets that sit at the heart of the digital economy. 

South Africa has already shown what a deeper REIT market can look like. Kenya has also pushed ahead, with a growing REIT ecosystem and five REITs in existence as of March 2026, with a combined market capitalisation of just over KES 30.3 billion. That is still modest by global standards, but it signals the adoption of REITs in the East African region.

Uganda’s REIT Legal Framework

REITs in Uganda are governed by the Collective Investment Schemes Act, Cap. 65 and the Collective Investment Schemes (Real Estate Investment Trusts) Regulations, 2017 (the “REIT Regulations”). The REIT Regulations establish the core legal architecture for REITs in Uganda. In broad terms, Uganda’s legal framework mirrors Kenya’s Capital Markets (Real Estate Investment Trusts) (Collective Investment Schemes) Regulations, which have been in force since June 2013 and were subsequently revised in December 2022 and October 2023.

Under Uganda’s REIT framework, a REIT must be established as an unincorporated trust divided into units, managed by a licensed REIT manager and overseen by an independent trustee. In practical terms, this means the law already treats REITs as a recognised collective investment product, with a structure designed to support professional management, investor participation and regulatory supervision.

Importantly, REIT units are intended to operate within the broader capital markets ecosystem. Once listed, investors are able to buy and sell REIT units through a securities exchange in much the same way as shares of a public company are traded.

The REIT Regulations recognise two distinct REIT models.

Income REIT (I-REIT)

An I-REIT is designed for completed, income-producing property. These are assets already generating returns, such as office buildings, shopping centres, residential developments or other properties producing rental income.

Development REIT (D-REIT)

A D-REIT is intended for projects still under development. It allows capital to be pooled for land acquisition, construction and project delivery, with the possibility of transitioning into an income-generating REIT once the development is complete.

On paper, the framework is comprehensive. It provides the legal structure, the oversight mechanisms and the categories through which REITs can operate. But, as we will highlight in this series, creating a reliable and attractive REIT framework in Uganda remains a case of so little done, so much to do.

Authors

Copying is disabled. Please respect the creators' work. Contact us for permission to use our content.