Commercial real estate (CRE) lending is entering a period of heightened complexity. Market volatility, shifting interest rates, and evolving state-level regulations are creating new challenges for banks and credit unions. Understanding these risks is essential to protecting your institution and supporting borrowers through successful, compliant transactions.
In this post, we highlight five major risks shaping the 2026 CRE debt landscape. Our insights draw from newly published outlooks from Deloitte, U.S. Bank, and other industry reports, as well as practical guidance from GoDocs specialists who work with commercial lenders every day.
1. Refinancing Risk on Legacy Loans
Many legacy loans originated during previous low-interest-rate cycles are now approaching maturity. As Deloitte notes, “Loan maturity pressures and rising borrowing costs pose refinancing challenges.” This creates potential stress for both borrowers and lenders, highlighting the importance of careful monitoring of upcoming maturities and their associated risks.
“We’ve seen lenders come under pressure when borrowers face unexpected rate changes at renewal,” says a GoDocs document specialist. “Having visibility into these loans early and understanding the associated documentation is critical for managing exposure.”
2. Rising Cost of Capital and Interest-Rate Volatility
Interest rates have begun to ease after a period of historically high borrowing costs, and the cost of capital remains sensitive to market expectations about future rate moves. Recent rate cuts and the anticipation of further easing have helped alleviate some pressure on borrower affordability, but volatility in overall financing costs still affects lender underwriting assumptions and creates uncertainty for both new originations and refinancings. Deloitte’s report emphasizes that, while overall sentiment is cautiously optimistic, “CRE recovery is delayed due to volatility, though overall sentiment remains cautiously optimistic.”
“Even modest swings in financing costs can impact borrower capacity and deal viability,” notes a GoDocs senior counsel member. “Keeping documentation accurate and workflows consistent helps lenders adjust without introducing unnecessary risk.”
3. Regulatory and Policy Uncertainty
CRE lenders must navigate evolving federal, state, and local regulations. Deloitte highlights that, “Trade and regulatory uncertainties have complicated decision-making, prompting some leaders in the CRE industry to rethink their approach.”
“Built-in compliance guardrails in document workflows are essential when regulations change,” says another GoDocs document specialist. “Using structured checklists, automated validations, and centralized oversight can help ensure your documents always meet current requirements, reducing risk and keeping your closings on track.”
4. Complexity of Capital Structures
Modern CRE transactions often involve multiple layers of capital, such as private credit, joint ventures, or mezzanine financing. These structures add complexity to loan agreements, increase coordination demands, and create potential exposure if not carefully managed. Deloitte recommends that “Commercial real estate leaders should proactively stress‑test portfolios, implement consistent standards, and keep agility central to strategy,” highlighting the importance of operational control when managing complex deals.
“With complex loan structures, it really helps to have a process that keeps everyone on the same page,” advises a GoDocs customer success manager. “Reducing manual data entry, making collaboration easier, and keeping documents consistent can prevent mistakes and keep the transaction moving smoothly.”
5. Documentation Errors and Legal Risk from Manual Processes
Manual document preparation and review remain a source of risk. Errors, omissions, or inconsistencies in loan documents can lead to delays, compliance issues, or legal exposure, particularly in a highly regulated market. U.S. Bank highlights that CRE leaders are increasingly turning to technology to drive operational efficiency and replace paper-based, manual processes.
“Careful documentation and consistent processes go a long way in minimizing exposure,” remarks a GoDocs senior counsel member.
Further Reading & Industry Resources
The following reports and articles provide deeper context on the trends and risks shaping today’s CRE debt market and may be helpful for lenders looking to explore these topics further.
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