Initial Statement of Beneficial Ownership

Bruno Lopez, a director at GDS Holdings Ltd, has filed an initial statement of beneficial ownership reporting 105,594 American Depositary Shares (ADSs). These shares represent a direct ownership interest. The filing also notes that the total number of shares includes those from settled Restricted Stock Unit (RSU) awards that met both time and performance conditions. Each ADS represents eight Class A ordinary shares, and each RSU represents one ADS. The reporting date for this transaction is March 16, 2026.