Initial Statement of Beneficial Ownership

Lim Ah Doo, a director at GDS Holdings Ltd, has filed an initial statement of beneficial ownership reporting direct ownership of 1,687,647 Class A ordinary shares and 73,580 American Depositary Shares (ADSs). The ADSs represent 588,640 Class A ordinary shares. The filing, dated March 17, 2026, indicates no securities were owned prior to this transaction. The ownership is reported following the settlement of fully vested Restricted Stock Unit (RSU) awards, with each RSU settling into one ADS.