The federal government has drawn the second Opportunity Zone map, and it is smaller than the first. The Treasury Department and the IRS on Nov. 5, 2026, designated 6,576 census tracts as Qualified Opportunity Zones in all 50 states, the territories and the District of Columbia. The zones take effect Jan. 1, 2027, and keep the designation for 10 years.
For developers, fund sponsors and investors who use the program to put capital gains into real estate in low-income areas, the list settles which neighborhoods will carry the tax benefit for the next decade. Of the new zones, 2,594 are entirely rural, a category the law now favors with larger incentives.
About 25% fewer Opportunity Zones than in 2018
The first round, designated in 2018 under the Tax Cuts and Jobs Act, covered 8,764 tracts, according to the CDFI Fund’s list of 2018 designations. The 2027 map therefore has about 2,190 fewer zones, a drop of roughly 25%.
Treasury’s tract-level designation file shows how the new map is distributed. By our count from that file:
- California has the most zones, 620, down from 879 in 2018.
- Texas follows with 608 (628 in 2018), including 184 rural zones, the most of any state.
- New York has 430 (514 in 2018) and Florida 342 (427).
- The next largest are Ohio (260), Illinois (240), Georgia (238), Pennsylvania (218), Michigan (215) and North Carolina (204). North Carolina has the second-most rural zones, 126.
- Puerto Rico has the sharpest cut: 178 zones, against 863 in the 2018 list.
At the county level, Los Angeles County has the most zones, 201, followed by Cook County, Ill. (84); Kings County, N.Y., which is Brooklyn (67); Wayne County, Mich. (65); and Dallas County, Texas (60). Maricopa County, Ariz., has 59; the Bronx 57; and Miami-Dade, Harris County, Texas, and Hidalgo County, Texas, 51 each. The District of Columbia has 25.
How the tracts were chosen
The new map comes out of the 2025 tax law, which the administration calls the Working Families Tax Cuts and Treasury’s own data page identifies as the One, Big, Beautiful Bill Act (Pub. L. 119-21). The law made the Opportunity Zone incentive permanent, added larger benefits for investment in rural zones, and set up a redesignation every 10 years, according to the IRS announcement (IR-2026-132).
Treasury and the IRS published 25,332 eligible tracts on April 6, of which 8,334 were rural. Governors, and the mayor of the District of Columbia, began submitting nominations on July 1 under Revenue Procedure 2026-14. The agencies said 6,576 eligible tracts had been nominated by the end of the statutory window and that every one was designated. The release also says 130 more eligible tracts, 28 of them rural, were nominated during that window; it does not explain how those relate to the 25,332.
Like the first round, the program defers and can reduce capital gains taxes for investors who put gains into qualified opportunity funds that invest in the zones, with the largest benefit going to investments held at least 10 years. Real estate has been one of its main uses. Treasury and the IRS credit the incentive with “more than $110 billion in private-sector investment” since 2017, a figure from the government’s own release.
What officials said
“Today’s announcement of the new designations will help direct private investment to communities that stand to benefit most,” Treasury Secretary Scott Bessent said in the release. IRS Chief Executive Officer Frank J. Bisignano said designating the zones enables “targeted investment and growth in communities where it is needed the most.”
The release does not say what happens to 2018 zones that were left off the new map, which is the open question for investors with projects in those tracts.
On our reading, the smaller map pushes the program toward rural areas. Rural tracts make up about 39% of the new zones, up from 33% of the tracts eligible for nomination. The zones were picked by governors from Treasury’s eligibility list, so how the map lines up with where developers already want to build will vary by state. With investor sentiment already soft, as Deloitte’s 2027 commercial real estate outlook found, the 10-year designation at least gives sponsors a known map to raise new funds around. More coverage of development and investment is on our commercial real estate page.
