Tax Planning & Advisory

Qualified Opportunity Zones 2.0: The 2026 Nomination Window Explained

Qualified Opportunity Zones 2.0: The 2026 Nomination Window Explained

States began nominating new Qualified Opportunity Zone (QOZ) census tracts on July 1, 2026, opening a 90-day window under the One, Big, Beautiful Bill (OBBB) that a state may extend once by 30 days. The IRS and Treasury laid out the process in Revenue Procedure 2026-14, which also lists the 25,332 low-income census tracts eligible for nomination, including 8,334 tracts made up entirely of rural areas. State CEOs decide which tracts get nominated, not individual taxpayers or their advisors. The new QOZ designations take effect January 1, 2027. Firms with clients sitting on unrealized capital gains or weighing real estate and business investment should flag this now, while the nomination window is still open.

## What is happening with Qualified Opportunity Zones right now?

State governors and other state CEOs are nominating which low-income census tracts in their states should become Qualified Opportunity Zones under the next designation round. The OBBB made the QOZ tax incentive permanent and set up a new round of designations every 10 years, replacing the one-time 2018 designation that has run for years. This is the first round under the new permanent structure.

## How many census tracts are eligible, and how many can a state nominate?

Revenue Procedure 2026-14 identifies 25,332 population census tracts nationwide that qualify as low-income communities and are eligible for nomination. Of those, 8,334 tracts are comprised entirely of a rural area, which carries additional tax benefits under the OBBB.

| QOZ nomination rule | Detail |

|---|---|

| Eligible low-income community tracts (nationwide) | 25,332 |

| Of those, entirely rural | 8,334 |

| State cap, if the state has 25-99 eligible tracts | Up to 25 tracts |

| State cap, if the state has fewer than 25 eligible tracts | All eligible tracts |

| State cap, general rule | No more than 25% of the state's eligible low-income-community tracts |

A state cannot designate more than 25% of its eligible low-income-community tracts as QOZs, with a floor that lets smaller states nominate all of theirs.

## When does the nomination window close?

The nomination window opened July 1, 2026, and runs 90 days, which puts the base deadline around late September 2026. A state may take a single 30-day extension, pushing its own deadline into late October 2026. The Treasury Department and the IRS have said they expect to issue guidance identifying the final designated QOZs after the nomination and certification process wraps up, before January 1, 2027.

## What changed for Opportunity Zones under the OBBB?

Before the OBBB, Opportunity Zones came from a single 2018 designation round with no built-in renewal. The OBBB made the QOZ incentive permanent and put a new designation round on a 10-year cycle, with the first new round taking effect January 1, 2027. The OBBB also added tax benefits specific to investments in QOZ tracts that are entirely rural, covered separately in Treasury and IRS guidance (Notice 2025-50).

## What should a firm do with this?

The nomination itself is a state-government process, so there's no client filing or election tied to this specific window. The work for a firm is watching and timing. Track which states your clients are in and whether those states' nominated tracts get finalized, since the designated map won't be final until closer to January 1, 2027. For clients with large unrealized capital gains, business sale proceeds, or real estate they're considering redeploying, this is the moment to start the conversation about Qualified Opportunity Fund investment planning for 2027, rather than waiting until the designations are final and the window to act feels rushed. Don't tell a client a 2026 investment qualifies under the new-round rules; the new designations aren't effective until January 1, 2027, so a QOF investment made now would need to rely on whatever prior-round QOZ tracts remain in effect, not the tracts being nominated in this window. See how [SignalsHQ structures multi-document tax prep](https://signalshq.io/blog) for where a planning check like this fits into a firm's advisory workflow.

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*Sources: IRS news release IR-2026-45, "Treasury, IRS provide guidance to States for nominating census tracts as qualified opportunity zones under the One, Big, Beautiful Bill" (irs.gov/newsroom/treasury-irs-provide-guidance-to-states-for-nominating-census-tracts-as-qualified-opportunity-zones-under-the-one-big-beautiful-bill), April 6, 2026, revised April 8, 2026; Revenue Procedure 2026-14 (irs.gov/pub/irs-drop/rp-26-14.pdf). Nomination-window dates confirmed current via direct IRS.gov fetch, 2026-07-28.*

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