For the 2027 map, a census tract qualifies if its median family income is no more than 70 percent of the comparison median, or if its poverty rate is at least 20 percent and its median family income is no more than 125 percent of that median. Metro tracts are measured against their metropolitan area and non-metro tracts against their state. As of October 30, 2026, Treasury's list of tracts that pass is 25,461 long, per its September 23, 2026 eligible-tract file.
Passing the test makes a tract eligible. It becomes a zone only if the governor nominates it and Treasury certifies it, and no state can designate more than about a quarter of its eligible tracts. That process is covered on the 2027 designation round; this page is about the test itself.
The two-prong test
New section 1400Z-1(c)(1), added by P.L. 119-21 sec. 70421(b)(1), defines a low-income community two ways. A tract needs to meet only one.
| Prong | Poverty rate | Median family income |
|---|---|---|
| (A) Income prong | Any | At or below 70% of the comparison median |
| (B) Poverty prong | At least 20% | At or below 125% of the comparison median |
The comparison median depends on where the tract sits. A tract inside a metropolitan area is compared only with the metropolitan area median family income. A tract outside one is compared only with the statewide median. The new text does not use the older "greater of" statewide or metro comparison.
Three tracts, tested
Hypothetical example
Suppose a metropolitan area has a median family income of $80,000. Three tracts inside it are tested against that figure.
- Tract 1: median family income $52,000 (65 percent of $80,000), poverty rate 14 percent. It passes prong (A), since 65 percent is at or below 70 percent.
- Tract 2: median family income $90,000 (112.5 percent), poverty rate 22 percent. It fails prong (A) but passes prong (B): poverty is at least 20 percent and income is under 125 percent.
- Tract 3: median family income $60,000 (75 percent), poverty rate 15 percent. It fails both prongs.
If the same three tracts sat outside any metropolitan area, each would be compared with the statewide median instead, and the results could change.
What changed from the 2018 map
| Rule | 2018 map (2017 law) | 2027 map (2025 law) |
|---|---|---|
| Definition | New Markets Tax Credit low-income community, IRC 45D(e) | New two-prong test in 1400Z-1(c)(1) |
| Comparison median | Set by IRC 45D(e) | Metro median for metro tracts, statewide median for others |
| Contiguous tracts | Up to 5% of a state's zones could be non-low-income tracts next to a zone, with income at or below 125% of the adjacent zone's | Repealed for tracts nominated after July 4, 2025 |
| Puerto Rico | Every low-income tract deemed a zone, effective Dec 22, 2017 | Deemed rule repealed effective Dec 31, 2026; governor nominates up to 25% |
| Tract boundaries | 2010 census tracts | 2020 census tracts, fixed through 2036 |
| How often the map is drawn | One round, listed in Notice 2018-48 | Every 10 years, starting July 1, 2026 |
Commentators, including the Economic Innovation Group, describe the change as lowering the income ceiling from 80 percent to 70 percent of area median family income. We have not re-read IRC 45D(e) to confirm the 80 percent figure, so treat that framing as reported by EIG.
The 2017 law produced 8,764 zones. The new test is applied fresh: a tract that overlaps a 2018 zone is eligible for the 2027 map only if it meets the new definition itself (Rev. Proc. 2026-14, sec. 3.01(2)).
The data behind the list
Treasury applied the test using the 2020–2024 American Community Survey 5-year data. For American Samoa, Guam, the Northern Mariana Islands and the U.S. Virgin Islands, where ACS data are not available, it used the 2020 Decennial Census of Island Areas (Rev. Proc. 2026-14 sec. 3.01(1)). The state caps are also set from these data sets.
The boundaries come with the data. Because the eligible list is built on 2020 tract boundaries, those boundaries control and do not change during the 2027–2036 designation period (sec. 3.01(3)). The 2018 zones use 2010 tracts, so a single property can carry two different tract numbers, one for each map. Our tract checker takes an 11-digit GEOID and shows both.
How many tracts pass
Treasury's September 23, 2026 eligible-tract file lists 25,461 eligible tracts, 8,362 of them rural, which matters for the rural rules on rural Opportunity Zones. That is the 25,332 tracts in the April Rev. Proc. 2026-14 appendix (8,334 rural) plus 129 additions; none was removed. The largest counts on the September list are California (2,479), Texas (2,431), New York (1,716), Florida (1,367) and Ohio (1,040).
The additions came from two methods. 128 tracts have no published median family income, and they qualify when the upper bound of the tract's income distribution is used instead and comes out at or below 70 percent of the comparison median. One tract in Lahaina, Maui qualifies because of extraordinary temporary population displacement. The OpportunityZones.com tracker reported the 128 as an "Alternate Framework"; Treasury's file does not use that name.
The list may not be complete. The Rev. Proc. says some qualifying tracts may not appear on it, and Treasury will consider a governor's nomination of an unlisted tract if it comes with a detailed analysis, using current tract-level data, showing the tract meets the test (sec. 5.04).
Reading the official list
The appendix to Rev. Proc. 2026-14 is a spreadsheet with one row per eligible tract, identified by its 2020 census tract number, and a column marking each tract "Rural" or "Non-rural." Of the 25,332 rows, 8,334 are marked rural and 16,998 non-rural. Treasury also said it would publish the list as an online resource with mapping and demographic data for each tract (sec. 3.02). Its September 23, 2026 data transparency file is the current list: it covers all 85,529 tracts, flags the 25,461 that are eligible, and publishes the inputs Treasury used to test each one. Our data page offers the list in other formats.
Eligible is not designated
A state may designate no more than 25 percent of its eligible tracts in a designation period, rounded up; states with 25 to 99 eligible tracts may designate 25, and those with fewer may designate all. California's 2,479 eligible tracts on the September list, for example, give a computed cap of 620, the number its Department of Finance list shows as certified. Most eligible tracts will not become zones.
The CDFI Fund does not confirm whether a particular investment is in a zone. It points users to the Census Geocoder and the official map or list. Treasury had not published a national certified 2027 list as of October 30, 2026. Until it does, each state page at /opportunity-zones/<state>/ (see the state index) carries the current status and sources for that state, and the map shows both maps; see for communities for how local groups engage with the process.
Common questions
What makes a census tract eligible to be an Opportunity Zone?
Under the 2025 law, a tract is a low-income community if its median family income is no more than 70 percent of the comparison median, or if its poverty rate is at least 20 percent and its median family income is no more than 125 percent of that median. Metro tracts are compared with their metropolitan area median and non-metro tracts with the statewide median.
Can a tract next to an Opportunity Zone be designated even if it is not low-income?
Not anymore. The 2017 law let up to 5 percent of a state's zones be contiguous tracts that were not low-income. The 2025 law removed that rule, so any tract nominated after July 4, 2025 must qualify on its own.
Does a 2018 Opportunity Zone automatically stay a zone in 2027?
No. A tract that overlaps a 2018 zone is eligible for the 2027 map only if it meets the new low-income test itself, and it still has to be nominated by the governor and certified by Treasury.
What data did Treasury use to decide which tracts are eligible?
Rev. Proc. 2026-14 used the 2020-2024 American Community Survey 5-year data, plus the 2020 Decennial Census of Island Areas for American Samoa, Guam, the Northern Mariana Islands and the U.S. Virgin Islands. The new zones use 2020 census tract boundaries, fixed for 2027 through 2036.
How many census tracts qualify?
Treasury's September 23, 2026 file lists 25,461 eligible tracts, 8,362 of them rural: the 25,332 in the April Rev. Proc. 2026-14 appendix plus 129 added in September. Only up to about a quarter of each state's eligible tracts can actually be designated.
Sources
- Public Law 119-21, sec. 70421(a) and (b)
- 26 U.S.C. 1400Z-1 (2024 edition, pre-2025 text)
- Rev. Proc. 2026-14 (2026-20 I.R.B. 910)
- Rev. Proc. 2026-14 Appendix (eligible tract list, xlsx)
- U.S. Treasury, OZ 2.0 Eligible Tracts Data Transparency file (Sept. 23, 2026)
- California Department of Finance, OZ 2.0 certified tracts (xlsx)
- IRS Notice 2025-50
- IRS Notice 2026-40
- CDFI Fund, Opportunity Zones