By the end of 2024, Opportunity Funds held about $112 billion of investment in designated Opportunity Zones, according to a June 2026 working paper from Treasury's Office of Tax Analysis. That's up from $44 billion at the end of 2020. On January 1, 2027, the program starts over with a new map, new rules and, for the first time, a requirement that Treasury publish what the money produces.

The deal, in brief

The basic trade hasn't changed. An investor who sells something at a profit can roll that capital gain into an Opportunity Fund that invests in designated lower-income areas. Tax on the original gain is deferred, and if the investment is held at least ten years, the fund's own appreciation can be sold free of federal capital gains tax. The tax benefit depends on time, not timing. I covered the mechanics, and why ten years is the part to take seriously, in Qualified Opportunity Zone Funds Require Ten Years.

What changed in 2025 is the program's lifespan. The original version had end dates built in. Any gain still deferred under it is included in income at the end of 2026, and the first-round zones expire at the end of 2028. The 2025 tax law made the incentive permanent. A new map of zones takes effect January 1, 2027, runs through 2036, and is redrawn every ten years after that.

The new map is also narrower. To qualify, a tract's median family income now has to be at or below 70 percent of the area median, down from 80 percent, and the old allowance for higher-income tracts next to qualifying ones is gone. The Treasury paper counts about 29 percent of US census tracts as eligible this time, compared with 42 percent of tracts that qualified as low-income in the first round.

What the first round built

The money spread out over time. By 2024, about 77 percent of designated zones had received some investment, up from 48 percent in 2020, according to the Treasury paper.

Much of it went into real estate. Among businesses that Opportunity Funds invested in, 77 percent of the investment was in real estate, the paper finds. That fits the incentive. Housing takes years to build and years to pay back, the kind of long project a ten-year holding period is designed to reward.

The best-known estimate of the housing effect comes from the Economic Innovation Group, the think tank that first proposed Opportunity Zones, a point its researchers disclose in the paper. Using Postal Service address data, they estimate that designation added about 416,000 residential addresses through early 2025, beyond what those tracts would otherwise have gained. They also found little sign that the growth was simply pulled from neighboring areas. An address count isn't a count of finished, occupied homes, but the authors treat it as a measure of new housing supply, and it's the broadest one available.

Other researchers, summarized in the Treasury paper, see the effect too, with some caveats. One team found that construction starts rose in the zones after designation, but that about two-thirds of the increase reflected governors choosing tracts where projects were already being planned. After adjusting for that, they still estimate starts rose 13 to 23 percent.

Who it reached

This is where the record gets less flattering. The Treasury paper finds that investment flowed more heavily into zones with less economic distress and into tracts already trending toward growth: higher incomes, lower poverty, rising home values. The poorest zones, the ones the program's name suggests it was built for, received a smaller share.

The evidence on residents is thinner and more mixed. One study the paper summarizes found that jobs located in the zones rose about 1.3 percent after designation, compared with similar tracts that weren't chosen. But more than three-quarters of those jobs went to people living in nearby, higher-income tracts, fewer than one in eight went to zone residents, and most of the gain was offset by job losses in nearby low-income areas.

My read is that the first round proved a tax incentive tied to patience can move a lot of private money and get things built. It didn't prove the money reaches the people who live there. That depends on where it lands, and the program left that mostly to investors.

What the reset lets us see

The first round wasn't a black box. Funds filed tax forms, and those forms are the reason the Treasury paper exists at all. But nothing required Treasury to publish regular results, and the paper's authors note that investors didn't always fill the forms out completely.

The 2025 law changes that. According to the Economic Innovation Group's summary, Treasury must now publish annual reports on the number of funds and their assets, which zones received investment, which industries, how many housing units were created, and employment effects. In the sixth and eleventh years after enactment, it must also compare designated tracts with similar tracts that weren't designated, on jobs, poverty, income, housing and new businesses. Funds face new reporting requirements and penalties for incomplete filings. Proposed rules for the new reporting were published in September 2026, so the details aren't final.

Where these places sit

The reset makes one more thing easier to see. Opportunity Zones are drawn on an economic map. Whether a tract qualifies depends on income and poverty, not on whether it floods, burns, or is getting hotter. Some of the new zones will sit on comparatively stable ground. Others will sit in floodplains or wildfire country. When the 2027 map is published, those two maps can be laid over each other for the first time in a decade. That's a comparison the designation process itself doesn't make.

An observation

The first round of Opportunity Zones answered one question clearly: a tax reward tied to time can draw patient money, and some of that money builds housing. It left a second question mostly open: who ends up better off. The second round is the first with a legal obligation to report the answer.

Sources

Figures current as of October 2026.