Initial Statement of Beneficial Ownership

This filing reports an initial statement of beneficial ownership for GDS Holdings Ltd by Liu Chee Ming, who is a director. The filing indicates that Liu Chee Ming directly owns 28,290 American Depositary Shares (ADSs). Each ADS represents eight Class A ordinary shares. The total number of ADSs includes those from the settlement of fully vested Restricted Stock Unit (RSU) awards that were subject to both time and performance conditions, with each RSU representing one ADS.