These are the Opportunity Zone deadlines that matter between now and January 1, 2027. The last two months of 2026 are the busiest the program has ever had. The original deferral ends, the new map gets certified, and a new set of rules starts on New Year’s Day. Here is the calendar in one place, and what each date means for you.
Opportunity Zone deadlines at a glance
| Date (2026 unless noted) | What happens | Who it affects |
|---|---|---|
| November 23 | Comments due to the IRS on Notices 2026-40 and 2026-55 | Funds, developers, advisors |
| Late November | Treasury expected to certify the states that filed on time | Anyone tracking the new map |
| December 4 | Last day OZPros takes on new year-end fund setup clients | Investors forming their own fund for 2026 |
| December 11 | Expedited fund setups end | Same |
| December 18 | No new fund formations. A shelf fund is the route after this | Same |
| Late December | Treasury expected to finish certifying the October 28 filers | Anyone tracking the new map |
| December 31 | Original deferred gains are recognized. Working capital plan deadline the IRS intends to propose for original zones not on the new map | OZ 1.0 investors, projects in original zones |
| January 1, 2027 | OZ 2.0 begins and the new map takes effect | Anyone with a 2026 or 2027 gain |
| January 4, 2027 | Day 180 for a sale on July 9, 2026 | Second-half 2026 sellers |
November: comments and working capital plans
November 23 is the last day to send the IRS comments on Notice 2026-40 and Notice 2026-55. Notice 2026-55 asks for input on single-family housing, working capital plans, operating businesses, the 10-year election, and more. If something in either notice doesn’t fit how real deals work, this is the window to say so. You can read the request in IRS Notice 2026-55.
November is also when working capital plans should get written. Under Notice 2026-40, the IRS intends to propose that a business in an original zone that did not make the new map needs a written plan by December 31, 2026, with at least 10% of the planned money received and 5% spent or under a binding contract by then. See how the working capital plan works.
“That’s a November project, folks, not a December one.”
Ashley Tison
December Opportunity Zone deadlines
December is where Opportunity Zone deadlines stack up, so here they are in order.
Our fund setup cutoffs: December 4, 11 and 18
Setting up your own Qualified Opportunity Fund takes time: the entity, the bank account, the paperwork, and getting the money in. So we set hard dates.
“December 4th is the last day we take on new year-end clients for fund creation. After that, it’s expedited pricing through the 11th, and we’re done with new QOF formations completely on the 18th.”
Ashley Tison
After the 18th, a shelf fund, one that is already formed and ready, is the usual route.
December 31: the original deferral ends
Every gain deferred under the original program is recognized on December 31, 2026, whether or not you sell. It goes on your 2026 return, due in April 2027. The amount is the smaller of the gain you deferred or what your fund interest is worth that day, so a fair valuation matters. See what is due on December 31.
January: OZ 2.0 begins
January 1, 2027 is day one of OZ 2.0. The new map takes effect. New investments get a rolling five-year deferral and a 10% step-up in basis, or 30% in a qualified rural fund.
January 4, 2027 is day 180 for a sale on July 9, 2026, counting the sale date as day one. It is the last of this year’s Opportunity Zone deadlines, and it is why any sale on or after July 9 can wait and invest under the new rules. Sales from July 6 to 8 are close calls. See can a 2026 gain use OZ 2.0.
Opportunity Zone deadlines FAQ
Which Opportunity Zone deadlines matter most in 2026?
December 31, 2026 matters most. Every gain deferred under the original program is recognized that day and goes on your 2026 return, due in April 2027. It is also the date the IRS intends to use for written working capital plans in original zones that are not on the new map.
Is it too late to start an Opportunity Zone fund in 2026?
Not yet. December 4 is our last day to take on new year-end clients for fund setup, expedited setups run through December 11, and we stop forming new funds on December 18. After that, a shelf fund is the usual route.
What changes on January 1, 2027?
OZ 2.0 begins. The new map takes effect, and new investments get a rolling five-year deferral with a 10% step-up in basis, or 30% in a qualified rural fund.
I sold something in the second half of 2026. Which program can I use?
Count 180 days with the sale date as day one. A sale on or after July 9, 2026 reaches January 4, 2027 or later, so you can wait and invest under OZ 2.0. Earlier sales have to go in under the original rules by the end of their window.
Sources
If one of these Opportunity Zone deadlines lands in your window, don’t wait on it. Book a free 15-minute call and we will tell you which dates apply to you.
General information, not tax or legal advice. Rules change, and your facts change the answer.