It is thought that the company has appointed advisors to oversee the sale of the sites, which are spread across the UK.
M&C Report understands that first round bids for the package were due in Monday of this week, with trade buyers and private equity showing an interest.
Last month, Punch said that its disposal programme was ahead of target at £57m and had been revised up to £80m for the full year.
The company reiterated its belief that the inclusion of the market rent only option in the pubs code is unlawful. It said it was taking steps to mitigate the impact pf the regulatory changes, including a review of new managed and franchised operating format-trials: new agreements including commercial free-of-tie leases and deferral of some capital investment projects.