Wells Fargo Securities, LLC
500 West 33rd Street, 14th Floor
New York, New York 10001

Bank of America, N.A.
One Bryant Park
New York, New York 10036

JPMorgan Chase Bank, National Association
270 Park Avenue
New York, New York 10017

The Toronto-Dominion Bank

c/o TD Securities (USA) LLC

1 Vanderbilt Avenue

New York, New York 10017

Truist Bank

50 Hudson Yards, 70th Floor

New York, New York 10001

Wells Fargo Bank, National Association

500 West 33rd Street, 14th Floor

New York, New York 10001

Re: Tax Opinions

Ladies and Gentlemen:

We have acted as tax counsel to Acadia Realty Trust, a Maryland real estate investment trust (the “Company”), in connection with the preparation of the Registration Statement on Form S-3 filed with the Securities and Exchange Commission (the “SEC”) on November 3, 2026 (the “Registration Statement”) and the base prospectus included as a part of the Registration Statement (the “Prospectus”), as supplemented by the prospectus supplement dated November 3, 2026 (the ”Prospectus Supplement”), including the discussion under the caption “Certain U.S. Federal Income Tax Considerations” contained in the Prospectus in the Registration Statement (the “Tax Disclosure”), and the offering (the “Offering”) of up to $500,000,000 of shares of the Company’s common shares of beneficial interest, par value $0.001 per shares, pursuant to Amendment No. 1, dated November 3, 2026, to the ATM Equity Offering Sales Agreement, dated as of February 14, 2025 by and among the Company, Acadia Realty Limited Partnership, a Delaware limited partnership (the “Partnership”), and BofA Securities, Inc., Barclays Capital Inc., Citizens JMP Securities, LLC, Goldman Sachs & Co. LLC, Jefferies LLC, J.P. Morgan Securities LLC, TD Securities (USA) LLC, Truist Securities, Inc. and Wells Fargo Securities, LLC, each as sales agent, principal and/or forward seller, and Bank of America, N.A., Citizens JMP Securities, LLC, Goldman Sachs & Co. LLC, Jefferies LLC, JPMorgan Chase Bank, National Association, The Toronto-Dominion Bank, Truist Bank and Wells Fargo Bank, National Association, each as forward purchaser. You have requested our opinions as to certain United States federal income tax matters in connection with the Offering.

The Company is the sole general partner of the Partnership, and all of the Company’s assets are held by, and all of its operations are conducted through, the Partnership. The Partnership owns equity interests in existing retail real property (and certain other real property) and associated personal property (the “Properties”). The Partnership owns some of the Properties directly and

owns the remaining Properties through limited liability companies or subsidiary partnerships (individually or collectively, the “Subsidiary Partnerships”).

In connection with the opinions rendered below, we have examined the following:

In connection with the opinions rendered below, we have assumed that:

For purposes of rendering our opinions, we have made such factual and legal inquiries, including by examination of the documents set forth above and discussions with certain Company personnel, including the Company’s tax director, as we have deemed necessary or appropriate for purposes of our opinions. However, we have not made any independent investigation of the facts contained in the documents or assumptions set forth above or the representations set forth in the Officers’ Certificate. We consequently have relied upon the representations in the Officers’ Certificate that the information presented in such documents or otherwise furnished to us is accurate and complete in all material respects relevant to our opinions. We are not aware of any facts inconsistent with the facts contained in the documents and assumptions set forth above or representations set forth in the Officers’ Certificate.

In addition, to the extent that any of the representations provided to us in the Officers’ Certificate are with respect to matters set forth in the Code or the Treasury Regulations promulgated thereunder, we have reviewed with the individual making such representations the relevant provisions of the Code and the applicable Treasury Regulations and are reasonably satisfied that such individual understands such provisions and is capable of making such representations.

Based on the documents and assumptions set forth above and the representations set forth in the Officers’ Certificate, we are of the opinion that:

We undertake no obligation to advise you of any changes in our opinions subsequent to the delivery of this letter. The Company’s qualification and taxation as a REIT under the Code depends upon the Company’s ability to meet on a continuing basis, through actual operating and other results, the various requirements under the Code with regard to, among other things, the sources of its gross income, the composition of its assets, the level of its distributions to stockholders, and the diversity of its stock ownership. We will not review on a continuing basis the Company’s compliance with the documents or assumptions set forth above, or the representations set forth in the Officers’ Certificate. Accordingly, no assurance can be given that the actual results of the Company’s operations, the sources of its gross income, the composition of its assets, the level of the Company’s distributions to its stockholders and the diversity of the

Company’s stock ownership for any given taxable year will satisfy the requirements for qualification and taxation as a REIT under the Code.

The foregoing opinions are based on current provisions of the Code and the Treasury Regulations, published administrative interpretations thereof, and published court decisions, any of which could be changed at any time, possibly on a retroactive basis. The Internal Revenue Service has not issued Treasury Regulations or administrative interpretations with respect to various provisions of the Code relating to REIT qualification under the Code. No assurance can be given that the law will not change in a manner that will prevent the Company from qualifying as a REIT under the Code, or the Partnership from being classified as a partnership for federal income tax purposes.

The foregoing opinions are limited to the United States federal income tax matters addressed herein, and no other opinions are rendered with respect to any other United States federal tax matters or to any issues arising under the tax laws of any state or locality or foreign jurisdiction. We undertake no obligation to update the opinions expressed herein after the date of this letter.