Inside The CRE Recovery: Faster, Pickier, Less Forgiving

by | Jun 17, 2026

A Mid-Year Read for CRE Decision-Makers

Through the first half of 2026, capital came back to commercial real estate, but on tougher terms. Here’s what we’ve seen across thousands of CRE projects so far this year, and what we’re anticipating for the second half.

BY
Nolan Previte | President, Real Estate | EBI Consulting

FOR
CRE Owners, Investors, Lenders & Developers

About This Read
EBI Consulting has supported environmental, engineering, and energy due diligence for U.S. commercial real estate since 1989. This is the mid-year follow-up to our CRE Outlook 2026. The observations below reflect what we’ve seen across our work in the first half of 2026 and where we see the back half heading.

The Question We Keep Hearing

“Is the deal market actually back, or are we still in wait-and-see?”
The answer is both, and that’s the story. Capital is moving. The Mortgage Bankers Association forecasts $805 billion in commercial mortgage originations for 2026, a 27% jump. But as Altus Group put it, “selectivity, not exuberance, defines the moment.” That selectivity is what we’ve watched play out for six months. Going into H2, the question isn’t whether the recovery is real. It’s who’s prepared to participate in it.

What The Book Is Telling Us

The First Half Set The Pattern. The Second Half Will Test It.

H1 2026 Activity Trajectory

UP

CRE due diligence activity built through the first half of 2026, outpacing the same period last year on both volume and dollar value. The recovery has held.
Diligence-Linked Service Lines

UP

Acquisition-related diligence and agency due diligence are pacing well above their early-2026 baseline. This isn’t projected pipeline. It’s signed, scheduled work.
Core CRE Diligence in H1

3,400+

Phase I ESAs, acquisition services, and agency due diligence engagements delivered for CRE clients in the first half of 2026, supporting 640+ unique owners, investors, and lenders nationally.
The lens

4,500+

CRE engagements in the first half of 2026, spanning 850+ unique owners, investors, lenders, and developers in all 50 states. National coverage; aggregate signal only.
Three Signals

Three Things The Market Is Telling Us.

Aggregate growth headlines hide the real story. Where demand is moving, and what underwriting it now demands, matters more than the size of the move itself.

Signal 01

Capital Is Moving Again, Across A Wider Field.

Office investment volume jumped 20% in Q1 2026, and industrial leasing climbed 14% YoY [1]. Inside our CRE work, deal flow has built steadily through H1: more owners, investors, and lenders running diligence in parallel, more deals heading into LOI. The transaction recovery isn’t theoretical.
Signal 02

Capital Is Coming From New Places.

The biggest shift in CRE finance heading into 2026 isn’t rates. It’s who’s writing the checks. Alternative lenders — debt funds and mortgage REITs — captured roughly 37% of non-agency CRE loan closings in 2025, surpassing banks (~31%) and dwarfing life companies (~16%, down from 43% the year before) [2]. Debt funds alone saw origination volumes climb 68% year-over-year in Q3 2025 [3]. The Mortgage Bankers Association forecasts $805 billion in commercial mortgage originations for 2026, a 27% increase over 2025 [4]. Meanwhile, the 30-year fixed mortgage rate climbed back to roughly 6.4% in early Q2, with markets pricing only one Fed cut for all of 2026 [9]. The source of capital fundamentally changed. Borrowers transacting now stopped waiting for traditional bank relief and started underwriting to whichever capital partner could actually move.
Signal 03

The Diligence Threshold Has Moved.

Tariffs on steel, aluminum, and copper at 50% — restructured in April 2026 to apply to full customs value rather than just metal content — pushed nonresidential construction input prices to a 12.6% annualized rate in early 2026, the fastest pace since 2022 [5]. Cushman & Wakefield estimates current tariffs add roughly 6% to materials costs and 3% to total project costs relative to the pre-tariff era [6]. An AGC-NCCER survey found 43% of contractors reported at least one project canceled, postponed, or scaled back in the past six months due to higher costs [7]. Inside our work, capex-sensitive scopes — acquisition due diligence, property condition assessments, energy retrofits — ran well above their early-2026 pace through H1. Reserves modeled on pre-tariff prices may face increased scrutiny in committee.
H1 Snapshot

The Lending Environment, Visualized.

Why the financing case looks materially different than it did 12 months ago.

CRE Lending Volume Forecast

Annual originations, $ billions

Source: Mortgage Bankers Association CREF Forecast, February 2026.

Construction Input Cost Pressure

Annualized growth rate, nonresidential
Source: Industry data citing Section 232 tariff restructure, April 2026; consistent with BLS Producer Price Index data and AGC analysis.
The market isn’t waiting for the Fed. It’s already moving. But the deals that close are the ones whose owners can prove they’ve underwritten to today’s standard, not yesterday’s. Diligence isn’t the last step before closing anymore. It’s the gate.
What This Means For Underwriting

Risk Is Being Repriced.
The ESA Is The Tell.

Across our work in the first half of 2026, the role of the Phase I ESA shifted. What used to land late in the closing process now shows up earlier, as a financing input. Three forces are reshaping how environmental and structural risk gets priced into a CRE transaction. The first is tariff exposure on building materials, where the 50% steel, aluminum, and copper duties are flowing through to capex reserves. The second is insurance market volatility. The third is institutional capital that has grown more selective on physical and operational risk, including energy performance and contamination exposure.

There’s also a fourth factor worth naming: the lender behind a deal is increasingly a different lender than it was three years ago. With debt funds, mortgage REITs, and private credit now writing more than a third of non-agency CRE loans, diligence requirements are evolving too. Alternative lenders often underwrite to asset-level cash flow and structural specifics rather than borrower balance sheet — which means a defensible ESA, a current PCA, and a clean environmental record have become more important to closing, not less. The borrower whose diligence package can satisfy both a bank credit committee and a debt fund’s investment committee is the borrower closing first.

The downstream effect: ASTM E1527-21 compliance, current EPA and state-level vapor intrusion guidance, and PFAS-aware site investigations aren’t differentiators anymore. They’re the price of admission. The properties closing fastest in H2 will be the ones whose diligence package was built for the underwriter that exists today.

Stay Ahead Of The Next Update
Regulatory shifts are moving fast — ASTM updates, PFAS guidance, ENERGY STAR rule changes, state-level emissions disclosure. EBI’s Quarterly Regulatory Bulletin tracks what’s changing and what it means for CRE diligence. Free, no pitch, four issues a year.

Looking Forward

Three Things We’re Anticipating For The Back Half Of 2026.

H1 established the pattern. H2 will test how durable it is. Three areas where we expect the back half of the year to land, based on what the first half has already put on paper.

Anticipating 01

Originations Will Keep Pressuring Diligence Capacity.

With H1 already running ahead of pace and full-year originations on track for their largest jump since 2021 [8], the constraint heading into H2 isn’t capital. It’s how fast diligence comes back. Buyers and lenders working Q3 and Q4 deals should start environmental, structural, and energy reads earlier than they did in 2024.

For Owners & Investors

If your closing window is under 60 days, get diligence started before LOI, not after. The deals that actually close on schedule are the ones whose buyers stopped treating diligence as a sequential step.

Anticipating 02

Phase I And Core Diligence Will Stay Elevated.

Phase I ESA volume and core acquisition diligence climbed consistently across H1. More deals heading into LOI, more lenders ordering reports earlier, more parallel streams on the same property. We expect that pace to hold or grow through H2, particularly as maturing 2022-era loans push refinancing into the queue.

For Lenders

The borrower packages clearing credit committee fastest are the ones with current ASTM E1527-21 ESAs and defensible PCAs already in hand. Pre-LOI diligence is becoming a screening criterion, not just a closing condition.

Anticipating 03

The Bid-Ask Spread: Closing On Quality, Widening On Everything Else.

The recovery isn’t uniform. CMBS office delinquency rates remain above 12% [10], even as Sun Belt growth markets and well-leased income properties see competitive bids again. Vacant office, weak retail, and value-add deals are also transacting, but at wider spreads and deeper diligence asks. Both ends of the market need better-prepared diligence to close. The gap between them is likely to keep growing through H2.

For Developers & Repositioning

Capex reserves modeled on 2024 input prices may not hold up against today’s committee scrutiny. Reprice your reserves yourself, before the buyer’s consultant does it for you.

Practical Application

Five Questions Before
Your Next Move In H2.

The H2 2026 CRE Due Diligence Pre-Flight

If you’re acquiring, refinancing, developing, or disposing in the back half of 2026, start here.

How current is your environmental baseline?
A Phase I ESA pre-dating mid-2024 likely doesn’t reflect current ASTM E1527-21 vapor intrusion guidance, evolving PFAS scrutiny, or what underwriting is asking for today.

Have you stress-tested capex reserves against materials inflation?
Steel, aluminum, and copper at 50% duties are pushing input prices at a 12.6% annualized clip — the fastest pace since 2022. Pre-tariff 2024 reserves may not survive committee.

Is your physical asset story defensible to your next buyer?
Documented building condition, capex plans, and operational data are increasingly part of how institutional capital prices bids.

Do you know which assets carry latent environmental liability?
Site investigation and remediation are among the most under-reserved line items in failed deals. Identify the exposure before the buyer’s consultant does.

Can your diligence partner move at deal speed?
As originations volume climbs through the year, qualified diligence capacity is becoming a constraint. Turnaround time is part of the conversation now, not an assumption.

An H2 Move On Your Desk?

Talk To Someone Already Inside The Pattern.

EBI works with owners, investors, lenders, and developers across the full property lifecycle: acquisition due diligence, remediation, energy strategy, capital improvement planning, and exit verification. If you’re underwriting, refinancing, building, or repositioning in H2, our team is happy to share what we’re seeing in the market.

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