The 2027 Opportunity Zone Map: Nomination Deadlines, Treasury’s Decision Window and Cost Segregation Timing

Where Does the 2027 Opportunity Zone Map Stand Now?

Treasury has until November 27, 2026 at the latest (December 28, 2026 with a further 30-day extension) to designate the 2027 Opportunity Zones under Rev. Proc. 2026-14, after governors’ nominations closed September 28, 2026 (October 28, 2026 with the 30-day extension); the zones take effect January 1, 2027, and a cost segregation study on property you own is unaffected.

The 2025 One Big Beautiful Bill Act (OBBBA) made the Opportunity Zone program permanent and replaced the one-time 2018 map with a new designation every ten years, chosen by governors from a list of eligible tracts that Treasury and the IRS published. A cost segregation study and the depreciation schedule it supports follow the property, its basis and the date it is placed in service, not the map. The map matters to a sponsor because it decides which tracts can hold property a Qualified Opportunity Fund (QOF) acquires from 2027 onward.

Status as of October 23, 2026. The 90-day base window has closed. October 28, 2026 was the last date Rev. Proc. 2026-14 allows for any nomination or change, and it applied only in a state whose governor requested the extension. Treasury’s CDFI Fund Opportunity Zones page, which carries Treasury’s updates on this process, had announced no 2027 designations when we read it on October 23, 2026. Treat any list of "new zones" circulating before Treasury publishes one as a forecast, unless the state itself reports Treasury’s approval: as of November 1, 2026, California’s Department of Finance has published its 620-tract list, effective January 1, 2027 (California’s Opportunity Zone 2.0 map).

What Does Rev. Proc. 2026-14 Actually Say?

Rev. Proc. 2026-14, effective April 6, 2026 (section 6), is the IRS procedure governors use to nominate tracts for the 2027 round. Its operative points, with the section that states each one:

• Eligible tracts (section 3.01(1)). Treasury and the IRS identified 25,332 census tracts eligible for nomination, of which 8,334 are comprised entirely of a rural area, listed in the procedure’s appendix.
• How many a state can pick (section 2.02(3)(c)). No more than 25 percent of the state’s low-income communities, rounded up, or 25 tracts in a state with fewer than 100. Applied to the appendix, that allows at most 6,544 designations nationwide (our count of the appendix, not a Treasury figure).
• The nomination window (section 2.02(3)(e)). A 90-day "determination period" beginning July 1, 2026, which ran through September 28, 2026 (90 days counted from July 1; the procedure prints only the extended outer date), plus a 30-day extension a governor may request and receive, which "would conclude, at the latest, on October 28, 2026."
• Treasury’s decision window (section 2.02(3)(f)). Treasury has a 30-day "consideration period" from the date it receives notice of a nomination; for a nomination made under the extended window that period "would conclude on November 27, 2026, at the latest," and a further 30-day extension the governor may request would extend it "to December 28, 2026, at the latest."
• When the new zones run (section 2.02(3)(g)). A tract designated under the procedure is a zone from January 1, 2027 through December 31, 2036.

Any request to modify such a nomination after October 28, 2026, will be denied. — Rev. Proc. 2026-14, section 5.03

Which Opportunity Zone Deadlines Have Passed, and Which Are Left?

Read in date order, for a sponsor checking this between late October and the end of 2026:

• September 28, 2026 (passed): the end of the 90-day nomination window that began July 1, 2026, by our count of 90 days (the procedure prints only the extended October 28 date). Under section 2.02(3)(e), nominations a governor submitted earlier were treated as received no earlier than this date, so Treasury’s 30-day decision window could not start before it.
• October 28, 2026 (passed): the latest date for a nomination or a change to one, and only in a state whose governor requested the 30-day extension (sections 2.02(3)(e) and 5.03).
• November 27, 2026: the latest end of Treasury’s 30-day decision window, which runs from the date Treasury receives a nomination (section 2.02(3)(f)).
• December 28, 2026: the latest end of that window if the governor also requested its 30-day extension (section 2.02(3)(f)).
• December 31, 2026: the last day a QOF or qualified opportunity zone business (QOZB) can acquire property for use in a 2018 tract that is not re-designated and still count it as qualified opportunity zone business property without an exception (Notice 2026-40, section 5.01(1)).
• January 1, 2027: the new zones take effect (section 2.02(3)(g)).

For a sponsor, the practical point is that by November the map is in Treasury’s hands, not the state’s. If a tract central to your pipeline was not nominated by the deadline that applied in your state, there is no further step to add it in this round; the next round begins at the next decennial determination date under §1400Z-1(c)(2)(C).

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Why Will Some of Today’s Tracts Not Carry Forward?

The 2027 round is not a re-stamp of the 2018 map, because OBBBA tightened eligibility (Rev. Proc. 2026-14, section 2.02(3)(a) and (b)):

• The income bar dropped. A qualifying low-income community now needs median family income at or below 70% of the metropolitan-area or statewide median, or a poverty rate of at least 20% with median family income at or below 125% of that median. The original program used the §45D test, with an 80% income ceiling.
• The contiguous-tract rule is gone. The 2018 round let governors designate certain tracts adjacent to low-income communities. For tracts nominated after July 4, 2025, a tract qualifies only on its own data, so a deal sited in a 2018 "contiguous" tract should not assume the location carries forward.

The result is a smaller, more targeted map: at most 6,544 designations against 25,332 eligible tracts, by our count of the appendix. A tract designated in 2018 competes with every other eligible tract for those slots, and a current Opportunity Zone does not automatically become a new one.

Which Map Governs a Deal Closing Around January 1, 2027?

• Property a QOF or QOZB acquires on or before December 31, 2026 in a 2018 tract is tested under the existing designation, which runs through December 31, 2028 (Puerto Rico: December 31, 2027) under Rev. Proc. 2026-14, section 2.02(2)(c).
• Property acquired after December 31, 2026 generally counts only if it is acquired for use in a zone designated after July 4, 2025, unless one of two exceptions applies: a working capital safe harbor plan adopted by December 31, 2026 with at least 10% of the planned working capital received and 5% spent by that date, or replacement and modernization of existing property in the ordinary course of business (Notice 2026-40, section 5.01(2) and (3)).
• Amounts invested in a QOF after December 31, 2026 come under the OBBBA rules: the deferred gain is included at the earliest of a sale, another inclusion event, or the tax year that includes the fifth anniversary of the investment, and an investment held at least five years gets a 10% basis increase (30% for a Qualified Rural Opportunity Fund) (Notice 2026-40, section 4.02).

For a property in a tract that is designated today and nominated for 2027, the calendar is a strategic lever. For a property in a tract that was not nominated, the December 31, 2026 acquisition date is the one that matters, and we set out the options in what to do if your zone does not make the 2027 map. Either way, sequencing belongs with your tax advisor before you sign.

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What Does the Redesignation Timing Mean for Cost Segregation and Depreciation?

The redesignation changes where new property can qualify, not how it depreciates. A cost segregation study allocates the depreciable basis of a building into 5-, 7- and 15-year property and the 27.5- or 39-year structure, and that schedule depends on the basis and the placed-in-service date, not on whether the tract is on the 2027 map. Four points follow for a sponsor deciding now:

• The placed-in-service date sets the first depreciation year. For a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31, 2026 is first depreciated on the 2026 return, whichever map governs the fund. The study itself can be completed after year-end, before that return is filed; see whether a cost segregation study has to be finished for 2026 depreciation. A deduction alone is not a reason to buy, finish or place a property in service.
• Bonus depreciation does not depend on the map either. 100% bonus depreciation under §168(k) applies to qualified property with a recovery period of 20 years or less that was acquired after January 19, 2025, while property acquired on or before that date stays on the phase-down, generally 20% if placed in service in 2026.
• Qualification is a separate question. If a QOF buys a building in a 2018 tract that is not re-designated after December 31, 2026, without an exception, the depreciation is the same but the building generally cannot be qualified opportunity zone business property (Notice 2026-40, section 5.01(1)).
• The 10-year exclusion is what makes the acceleration durable. After a ten-year hold, and only where the §1400Z-2(c) fair market value election is made on a sale of the QOF interest, gain is excluded to the extent the election applies, including the gain attributable to depreciation accelerated during the hold, which can turn cost segregation from a timing benefit into a permanent one. Before year ten, or with no election made, recapture behaves normally: §1245 ordinary recapture on the 5- and 7-year personal property and unrecaptured §1250 gain, taxed at up to 25%, on the building. Selling the QOF interest and the fund selling its assets are different transactions; see the asset-sale exclusion article.

On value-add deals, the same component-level analysis that supports the depreciation schedule also supports the land-versus-building allocation behind the substantial-improvement test. For a zone comprised entirely of a rural area, that threshold is now 50% of adjusted basis rather than 100%, a change effective on enactment July 4, 2025 that reaches existing 2018 tracts. We covered the pairing in Cost Segregation + Opportunity Zones 2.0, and the full interaction is on our Opportunity Zone cost segregation page. Treasury's outer designation dates and the December 31, 2026 cut-offs for funds are on our Opportunity Zone and cost segregation calendar, each with its source.

What Is at Risk for an Existing Opportunity Zone Investment, and What Is Not?

Tracts designated in 2018 remain designated through December 31, 2028 (Puerto Rico: December 31, 2027) under Rev. Proc. 2026-14, section 2.02(2)(c), and the 2027 round is a new designation, not a replacement map that removes anyone early. Treas. Reg. §1.1400Z2(c)-1(c), restated in Notice 2026-40 section 5.02(1), provides that the ten-year election is not impaired solely because a zone’s designation ends, for dispositions before January 1, 2048. Notice 2026-40 section 5.02(2) says Treasury and the IRS expect forthcoming proposed regulations to let qualifying property acquired before the designation expires keep treating the expired zone as a zone for the substantial-use test through December 31, 2047; that safe harbor is an announced intent, not yet a regulation.

What changes much sooner is new acquisitions: property acquired by a QOF or QOZB after December 31, 2026 for use in a 2018 tract that is not re-designated generally cannot be qualified opportunity zone business property unless one of the two Notice 2026-40 exceptions applies.

What Should a Sponsor Do Between Now and January 1, 2027?

• Confirm which deadline applied in your state. Ask your state’s Opportunity Zone office whether the governor requested the extension, and whether your tracts were nominated; Treasury’s CDFI Fund Opportunity Zones page (read October 23, 2026) refers the public to the governor’s office for that.
• Check for Treasury’s designations. Under section 2.02(3)(f) they come no later than November 27, 2026, or December 28, 2026 where the governor requested the extension of Treasury’s window.
• Decide any acquisition in a 2018 tract with the December 31, 2026 date in view, and if you rely on a working capital safe harbor plan, adopt it and meet its 10% received and 5% spent thresholds by that date.
• Line up the depreciation side early. Whatever zone the property ends up in, the economics of the hold turn on how much of the basis is short-life property, and inside an Opportunity Zone held ten years with the election made, that acceleration is unusually durable.

Frequently Asked Questions

Has the 2027 Opportunity Zone nomination deadline passed?

Yes for the base window: the 90-day nomination window that began July 1, 2026 ended September 28, 2026, and where a governor requested the 30-day extension the window ended no later than October 28, 2026, the date after which Rev. Proc. 2026-14 section 5.03 says any request to modify a nomination will be denied. Which of the two dates applied depends on whether your state’s governor requested the extension.

When will Treasury announce the new Opportunity Zones?

Under Rev. Proc. 2026-14 section 2.02(3)(f), Treasury’s 30-day window to designate a nominated tract runs from the date it receives the nomination and ends no later than November 27, 2026, or December 28, 2026 if the governor requested the extension of Treasury’s window. The designated tracts are zones from January 1, 2027 through December 31, 2036; Treasury’s CDFI Fund Opportunity Zones page showed no announcement date when we read it on October 23, 2026.

Does the redesignation affect a cost segregation study on a building I already own?

No, the redesignation does not change a cost segregation study on a building you already own: a study allocates the depreciable basis of property you already hold into 5-, 7-, 15-year and long-life components, and the resulting depreciation schedule depends on the basis and the placed-in-service date, not on whether the tract appears on the 2027 map. The map governs where new capital can qualify.

If my tract is not re-designated, do I lose my depreciation and Opportunity Zone exclusion benefits?

Not solely because the designation ends: for an investment held at least ten years where the §1400Z-2(c) election is made on a sale of the QOF interest before January 1, 2048, the election is not impaired because the zone’s designation ended (Treas. Reg. §1.1400Z2(c)-1(c), restated in Notice 2026-40 section 5.02(1)), and tracts designated in 2018 run through December 31, 2028. The depreciation itself, including the schedule from a cost segregation study, does not depend on the designation. What is lost is the ability to count property acquired after December 31, 2026 in that tract as qualified opportunity zone business property, unless an exception applies.

Should a sponsor wait for the final map before ordering a cost segregation study?

Generally no, because the study follows the property rather than the map: for a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31, 2026 is first depreciated on the 2026 return, and the cost segregation study can be completed after year-end, before that return is filed. Whether a new acquisition qualifies for the fund is a separate question that turns on the map and the December 31, 2026 acquisition date.

How many tracts can be designated in the 2027 round?

Rev. Proc. 2026-14 section 3.01(1) lists 25,332 eligible tracts, 8,334 of them entirely rural, and section 2.02(3)(c) caps each state at 25 percent of its low-income communities, rounded up, or 25 tracts where a state has fewer than 100. Our count of the appendix under that cap is at most 6,544 designations nationwide, so a current Opportunity Zone does not automatically become a new one.

The Bottom Line

Opportunity Zones are permanent, but the specific zones are not, and the 2027 map is not final until Treasury designates the tracts: the nomination window closed on September 28, 2026, or no later than October 28, 2026 where the governor took the extension, and Treasury designates the new zones by December 28, 2026 at the latest, effective January 1, 2027. For a sponsor, the dates to work to now are Treasury’s announcement and December 31, 2026 for acquisitions in a 2018 tract, while the cost segregation and depreciation side follows the property and its placed-in-service date whichever map applies.

Underwriting an OZ deal? Estimate the depreciation side on our free calculator, then start your cost segregation study once the property is under contract.