Compliance

Opportunity Zone compliance calendar, 2026 to 2047

The dates that matter most are December 31, 2026, when deferred gain from every investment made through that day comes due, and January 1, 2027, when OZ 2.0 and the first new zones begin. As of October 30, 2026, this calendar lists every dated deadline we could tie to a primary source, from the remaining 2026 rulemaking dates through December 31, 2047.

"OZ 1.0" means investments made through December 31, 2026, and "OZ 2.0" means investments made after that date. Filing dates below assume a calendar tax year. Dates marked proposed come from REG-116506-25, which is not final and would apply only to statements due after final regulations are published.

November and December 2026

  1. Telephone public hearing on proposed reporting regulations REG-116506-25 scheduled for 10:00 a.m. ET, to be cancelled if no outlines of topics were received by October 13, 2026. The comment period closed October 16, 2026. See reporting penalties and decertification.

  2. Written comments due on IRS Notice 2026-55, which asks for comments on all aspects of implementing the amended section 1400Z-2. It changes no rules.

  3. Latest end of Treasury's 30-day window to certify governors' nominations of 2027 zones, or December 28, 2026 if the governor requested a further extension (Rev. Proc. 2026-14, sec. 2.02(3)(f)). Treasury and the IRS expect to publish the list of designated zones before January 1, 2027; as of October 30, 2026 no national list had been published.

  4. OZ 1.0 inclusion. Gain deferred through an investment made on or before this date must be included no later than the tax year that includes it (Notice 2026-40, sec. 4.01). Gain included because the investment was still held on this date cannot be deferred again. Last day an investment counts as OZ 1.0. See the December 31, 2026 inclusion.

  5. Working capital transition deadline. For a business to keep buying qualifying property for a 2018 zone after 2026 under a working capital plan, the plan must be adopted by this date and the business must have received at least 10 percent of the planned working capital and spent at least 5 percent, with amounts owed under binding agreements signed before January 1, 2027 counted as spent (Notice 2026-40, sec. 5.01(2)(b)). See the Notice 2026-40 transition rules.

  6. Year-end 90 percent asset test date for calendar-year funds. The repeal of Puerto Rico's automatic designation rule takes effect.

2027

  1. OZ 2.0 begins. Amounts invested after December 31, 2026 get the 5-year rolling deferral, the 10 or 30 percent step-up and the 30-year cap. Tracts certified during 2026 become Opportunity Zones through December 31, 2036. Eligible gain from 2026 whose 180-day window is still open can be invested on or after this date and deferred under the new rules (Notice 2026-40, sec. 4.02(2)). New acquisition-date rules apply to property acquired after December 31, 2026.

  2. Proposed: investor statements due to brokers that are holders of record, for dispositions in the prior calendar year, if the rule is final before then.

  3. Proposed: statements from calendar-year qualified opportunity zone businesses to their funds, due the first day of the second month after the business's year end. Applies only if the rule is final before the statements are due.

  4. Proposed: fund statements to investors who disposed of an investment in the prior calendar year, if the rule is final before then.

  5. 2026 returns due for calendar-year partnerships, under section 6072(b) as described in the REG-116506-25 preamble. A partnership fund attaches Form 8996, and a partnership investor attaches Form 8997.

  6. 2026 returns due for calendar-year individuals and corporations. This is the return that reports the December 31, 2026 inclusion for most OZ 1.0 individual investors, with Form 8997. A corporate fund attaches Form 8996. See how to report an Opportunity Zone investment.

  7. First semiannual 90 percent asset test date of 2027 for calendar-year funds. The second is December 31, 2027. See the 90 percent asset test.

  8. Extended due date for calendar-year partnership returns, after the automatic 6-month extension (26 CFR 1.6081-2).

  9. Extended due date for calendar-year individual and corporate returns, after the automatic 6-month extension (26 CFR 1.6081-4; 1.6081-3). Form 8997 must be filed with a timely return, including extensions.

  10. The Puerto Rico zones automatically designated under the 2018 Budget Act expire.

2028 to 2047

  1. The $15 million appropriated for the IRS to produce Treasury's annual public reports on Qualified Opportunity Funds is available until this date.

  2. The 2018 Opportunity Zones expire (Notice 2026-40, sec. 2.04(2)(c)(ii)). Property bought after December 31, 2026 for use in a 2018 zone generally cannot qualify unless a transition exception applies; see the transition rules.

  3. Earliest 5-year date for an OZ 2.0 investment, reached by an investment made January 1, 2027. Deferred gain is included in the tax year that includes the earlier of a sale or the date 5 years after the investment, so each investment has its own date.

  4. The first round of new Opportunity Zones, effective January 1, 2027, ends.

  5. Last date for a disposition that can use the 10-year election on an OZ 1.0 investment after its zone designation has expired (26 CFR 1.1400Z2(c)-1(c)). Funds and businesses that acquired property before a 2018 zone expired, or under a transition exception, may treat that zone as an Opportunity Zone for the property-use, gross income and intangible property tests through this date.

Recurring dates

  • 180 days from each gain. Each eligible gain has its own 180-day investment window, which generally begins the day the gain would otherwise be recognized. Use the 180-day deadline calculator.
  • Two fund test dates a year. The last day of the first 6 months of the fund's tax year and the last day of the tax year.
  • Form 8997 every year held. With the investor's timely federal return, including extensions.
  • Form 8996 every year. With the fund's return today; as a separate, electronically filed information return under the proposed rules once final.

Fiscal-year taxpayers shift the filing dates by their own year end. A tax adviser can map these dates to a specific fund or return.

Common questions

What is the most important Opportunity Zone date in 2026?

December 31, 2026. Deferred gain from an investment made on or before that date must be included in income no later than the tax year that includes it, and it is the last day an investment counts as OZ 1.0. It is also the deadline for the working capital transition test under Notice 2026-40.

When are 2026 returns that report Opportunity Zone gains due?

For calendar-year taxpayers, partnership returns are due March 15, 2027 and individual and corporate returns April 15, 2027. Automatic 6-month extensions move those to September 15 and October 15, 2027. Form 8997 and Form 8996 go with the timely filed return, including extensions.

When does OZ 2.0 start?

January 1, 2027. Amounts invested after December 31, 2026 get the new rules, and tracts certified during 2026 are Opportunity Zones from January 1, 2027 through December 31, 2036.

When do the 2018 Opportunity Zones expire?

December 31, 2028. The Puerto Rico zones that were automatically designated under the 2018 Budget Act expire earlier, on December 31, 2027. Funds and businesses that acquired property in time may keep treating an expired zone as a zone for certain tests through December 31, 2047.

Is there an Opportunity Zone calendar I can add to my own calendar?

Yes. A downloadable calendar file (.ics) with these dates is on the data page. Dates marked proposed depend on final regulations and may change.

Sources

  1. IRS Notice 2026-40
  2. IRS Notice 2026-55
  3. Rev. Proc. 2026-14
  4. REG-116506-25, 91 FR 57968 (Sept. 11, 2026)
  5. REG-116506-25, public inspection copy (return due dates under section 6072)
  6. 26 CFR 1.6081-2, 1.6081-3, 1.6081-4, automatic extensions (LII)
  7. 26 CFR 1.1400Z2(a)-1 (eCFR)
  8. 26 CFR 1.1400Z2(c)-1 (eCFR)
  9. Public Law 119-21, sec. 70421

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