Initial Statement of Beneficial Ownership

This filing details the initial statement of beneficial ownership for Sio Tat Hiang, a director at GDS Holdings Ltd. As of March 17, 2026, Mr. Hiang directly owns 205,208 American Depositary Shares (ADSs). Additionally, he indirectly owns 4,000 ADSs through his spouse. Each ADS represents eight Class A ordinary shares of GDS Holdings Ltd. The filing also notes the settlement of vested Restricted Stock Unit (RSU) awards that contribute to the total number of ADSs owned.