As of November 2026, Treasury's final list has 260 Ohio census tracts as Opportunity Zones from January 1, 2027, 96 of them rural. What sets Ohio apart is its own state credit: under Ohio Revised Code 122.84, investors in an Ohio qualified opportunity fund can receive a nonrefundable state tax credit of 10 percent of the amount the fund invested in Ohio Opportunity Zone projects.
This page uses OZ 1.0 for federal Qualified Opportunity Fund (QOF) investments made on or before December 31, 2026, under the 2017 rules, and OZ 2.0 for investments made after that date, under the rules rewritten by Public Law 119-21, sec. 70421. Tract counts and maps are on the Ohio Opportunity Zone data page.
- 2027 status
- 260 tracts designated
- State credit
- 10% (ORC 122.84)
- Per-applicant cap
- $2M per biennium
- 2018 zones end
- Dec 31, 2028
Ohio's 2027 designations
Each governor had 90 days from July 1, 2026 to nominate up to 25 percent of the state's eligible tracts, with one 30-day extension, so the latest possible deadline was October 28, 2026.
Treasury's November 5, 2026 release announced the national designations, and Treasury's list has 260 Ohio tracts. The 2027 designations page and the Ohio data page show the counts.
A 2018 Ohio zone does not carry over. Any area on the new map must meet the new test on its own: median family income at most 70 percent of the metro (or statewide, outside metro areas) median, or poverty of at least 20 percent with median family income at most 125 percent of that median. The 2027 map also uses 2020 tract boundaries.
Ohio's state Opportunity Zone tax credit
Ohio created a separate state incentive that rewards investment in Ohio zones. The terms below are from the current text of ORC 122.84, in the version effective September 23, 2026 (amended by House Bill 479 of the 136th General Assembly).
| Term | Rule |
|---|---|
| Credit amount | 10% of the person's investment in an Ohio qualified opportunity fund, limited to amounts the fund invested in Ohio Opportunity Zone projects during the preceding investment period |
| Per-applicant limit | $2 million of credit certificates per fiscal biennium |
| Program limit | $50 million for each of fiscal years 2026 and 2027 |
| After fiscal year 2027 | No new credits unless the General Assembly authorizes them |
| Refundable? | No |
| Taxes it offsets | Taxes under ORC 5725.18, 5726.02, 5729.03 and 5747.02, which includes the personal income tax |
The Ohio Department of Development runs the application rounds. The state credit is separate from the federal deferral; whether an investor or fund qualifies for both is a question for an Ohio tax adviser. How Ohio's income tax treats the federal deferral and exclusion was not verified from an official source for this page; see state tax conformity.
Projects in Ohio's 2018 zones
Property bought after December 31, 2026 for use in a 2018 zone generally cannot be Opportunity Zone business property under Notice 2026-40 sec. 5.01, unless the tract is on the new map or an exception applies:
- A written working capital plan adopted by December 31, 2026, with at least 10 percent of the planned capital received and 5 percent spent by that date.
- Replacement or modernization of existing property in the ordinary course (not expansion).
- For property acquired before the zone expires, continued treatment as zone property for the use test through December 31, 2047.
See the transition rules.
Federal benefits for Ohio investors
Older Ohio guides described deferral "until December 31st, 2026" with 10 and 15 percent step-ups. That is OZ 1.0: gain invested by December 31, 2026 is included in income for the tax year that includes that date, and the step-ups required 5 or 7 years of holding by then, so new money cannot earn them.
For OZ 2.0 money, invested after December 31, 2026 within 180 days of the gain, deferral runs until the earlier of a sale or 5 years. A 5-year hold excludes 10 percent of the deferred gain, or 30 percent in a qualified rural opportunity fund, which matters in rural Ohio. A 10-year hold lets appreciation go untaxed on a sale before the 30th anniversary. See capital gains tax benefits.
Investing through an Ohio Opportunity Fund
To get the federal benefits, money goes into an Opportunity Fund: a corporation or partnership that holds at least 90 percent of its assets in Opportunity Zone property, tested twice a year, and self-certifies on Form 8996. Eligible investments include:
- Real estate in a zone that is newly built, or substantially improved by doubling the building's basis within 30 months (50 percent in a zone made up entirely of rural area).
- Stock or partnership interests in a business that holds at least 70 percent of its tangible property in the zone, earns at least half its gross income from active business there, and is not a golf course, country club, massage parlor, hot tub or suntan facility, racetrack or gambling facility, or liquor store.
Other credits Ohio projects pair with Opportunity Zones
Ohio investors interested in affordable housing can combine an Opportunity Zone investment with the Low Income Housing Tax Credit (LIHTC), which is claimed over a 10-year credit period with a 15-year compliance period under 26 U.S.C. 42.
The New Markets Tax Credit (NMTC) under 26 U.S.C. 45D totals 39 percent of a qualified equity investment, claimed over seven years: 5 percent for each of the first three years and 6 percent for each of the next four. See NMTCs in Opportunity Zones.
The federal Historic Tax Credit (HTC) under 26 U.S.C. 47 is 20 percent of qualified rehabilitation expenditures, taken ratably over five years. It applies to certified historic structures, which can include buildings in registered historic districts.
For loans on the underlying real estate, see Opportunity Zone financing. Other state guides: California, Florida and Texas.
Common questions
Has Ohio chosen its 2027 Opportunity Zones?
Yes. Treasury's final list, published November 5, 2026, has 260 Ohio census tracts, 96 of them rural, effective January 1, 2027 through December 31, 2036.
What is the Ohio Opportunity Zone tax credit?
Under Ohio Revised Code 122.84, an investor in an Ohio qualified opportunity fund can receive a nonrefundable state tax credit equal to 10 percent of the investment that the fund placed in projects in Ohio Opportunity Zones. Certificates to one applicant cannot exceed $2 million per fiscal biennium, and total credits are capped at $50 million for each of fiscal years 2026 and 2027.
Can new credits be issued under the Ohio Opportunity Zone program after 2027?
Under the current text of ORC 122.84, no new credits may be issued after fiscal year 2027 unless the General Assembly authorizes them. Check with the Ohio Department of Development for the current application round.
Are the federal Opportunity Zone benefits different in Ohio?
No. For money invested after December 31, 2026, every state gets the same federal rules: up to 5 years of deferral, a 10 percent step-up after 5 years (30 percent in a qualified rural opportunity fund), and the 10-year exclusion for sales before the 30th anniversary.
Do Ohio's 2018 Opportunity Zones still count?
Yes, until December 31, 2028. Property bought after December 31, 2026 for use in a 2018 zone generally does not qualify unless the tract is on the new map or a Notice 2026-40 transition exception applies.
Sources
- U.S. Treasury, press release sb0682 (Nov. 5, 2026)
- IRS News Release IR-2026-132 (Nov. 5, 2026)
- CDFI Fund, full list of designated Qualified Opportunity Zones (xlsx)
- Ohio Revised Code 122.84
- Public Law 119-21, sec. 70421 (enrolled text)
- Rev. Proc. 2026-14
- IRS Notice 2026-40
- IRS News Release IR-2026-45
- 26 U.S.C. 45D (Cornell LII)
- 26 U.S.C. 47 (Cornell LII)
- 26 U.S.C. 42 (Cornell LII)