The efforts to embed a Circular Economy (CE) within every organization in the Netherlands have taken both, scholars and practitioners, to look into the design of Circular Business Models (CBMs) that allow to make this transition possible; one of the Dutch industries taking this approach is the real estate development sector. Different business modelling tools have been proposed to design CBMs, however, to this date no academic research has been performed on their implementation process within real estate development firms. This study can be seen as the next step on the current developments on CBMs within real estate organizations and through a qualitative analysis of nine in-depth semi-structured interviews taken from people involved in the development of real estate assets in the student housing private sector, investigates the process of CBMs implementation and proposes a conceptual framework that encompassed it. The resulting framework includes 19 elements that emerged from the analysis grouped into 5 categories that represent the relationship of these elements to a core category. These categories and relationships are seen as the first conceptualization of the process within a real estate development firm and foster further studies to investigate and evaluate the validity of these arguments.