- Treasury and the IRS designated 6,576 census tracts as qualified opportunity zones on Nov. 5, effective Jan. 1, 2027 and running for 10 years, with 2,594 of them rural.
- The new map is about 25% smaller than the 2018 round, and the original zones stay in effect through Dec. 31, 2028, so the two overlap for two years.
- Rural funds get a 30% basis step-up after five years versus 10% for other funds, which is already shaping how sponsors build metro and rural products.
On Nov. 5, Treasury and the IRS locked in 6,576 tracts as the new opportunity zones, fixing the map for opportunity fund investment through 2036, according to AltsWire.
They kick in Jan. 1, 2027 for a 10-year run, and 2,594 of them, or 39%, sit in rural areas.
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A Smaller Map
That is about a quarter fewer than the 2018 round, when the first round certified over 8,700 zones. The original zones stay live until Dec. 31, 2028.
That creates a two-year overlap. AltsWire reports that opportunity fund raising cooled in late 2025 ahead of a gap year between the old and new schedules.
How Tracts Were Chosen
Every nominated tract made the cut. Governors and the D.C. mayor picked from a pool of 25,332 eligible tracts released in April, of which 8,334 were rural.
By state, California tops the list at 620 tracts, then Texas (608), New York (430), Florida (342) and Ohio (260), AltsWire’s tally of Treasury’s data shows.
Why the Rural Split Matters
The 2025 tax law gives qualified rural opportunity funds a bigger break: a 30% step-up in basis on deferred gains after a five-year hold, versus 10% elsewhere.
Sponsors are already building around it. Peakline Real Estate Funds aims to raise $1.3 billion in its fourth program, which pairs a metro fund with a rural fund. The Wyoming Reserve now offers an escrow route for investors who want to commit before the rules start.
Why It Matters
Texas’ 608 designations compare with the 605 tracts Gov. Greg Abbott nominated in September, when we noted that most original-program zones were not renominated and only four of Dallas’ original tracts made the list.
Per Treasury, more than $110 billion has flowed into these zones since 2017. With the list final, sponsors and the advisers vetting their offerings can check which properties qualify.
What’s Next
The new rules apply to qualifying investments made after Dec. 31, 2026, which we broke down in our guide to Opportunity Zones 2.0. Expect sponsors to start rolling out funds tied to the final map as the Jan. 1 start date approaches.
