A new, once-in-a-decade window is opening for the designation of federal Opportunity Zones (OZs), which creates a significant and time-sensitive opportunity for developers, investors, businesses, and community stakeholders to shape where federal tax-advantaged capital will flow over the next decade.

Under recently issued guidance from the U.S. Department of the Treasury and Internal Revenue Service (IRS), governors in all 50 states will have just 90 days, beginning July 1, 2026, to nominate eligible census tracts for Opportunity Zone designation, with new zones taking effect January 1, 2027.

By law, governors may designate no more than 25% of eligible low-income census tracts, making this a highly competitive process with long-term implications for economic development and capital formation.

For clients with current or planned projects, the stakes are significant: Designation can materially enhance project feasibility, attract new sources of equity, and improve long-term returns. Equally important, this is a rare opportunity to influence state decision-making in a way that shapes investment patterns for the next decade.

Cozen O’Connor Public Strategies is well-positioned to help clients navigate this process by developing targeted advocacy strategies and executing coordinated engagement to maximize the likelihood of securing favorable designations and achieving meaningful results.

Key Timeline and Process

• July 1, 2026: Governor nomination window opens
• 90-Day Selection Period: States evaluate and submit nominations (subject to limited extension)
• Late 2026: U.S. Treasury reviews and certifies designations
• January 1, 2027: New Opportunity Zones take effect

Importantly, the nomination period is iterative and deliberative, allowing stakeholders to engage with state decision-makers and provide input throughout the full 90-day window. But states do not have to wait for July 1 to start receiving proposals. We know that many states are already actively reviewing requests for designations and could submit selections early in the window that opens on July 1.

Why Opportunity Zone Designation Matters

Opportunity Zones provide one of the most powerful federal incentives to drive private investment into targeted areas. Investments made through Qualified Opportunity Funds (QOFs) can unlock:

• Deferral of capital gains taxes on reinvested gains
• Reduction of deferred gains through basis step-up after a holding period
• Elimination of taxes on new appreciation for investments held at least 10 years

Since the program’s inception, tens of billions of dollars in private capital have been deployed into designated communities, demonstrating the program’s ability to catalyze large-scale investment.

For developers and businesses, these incentives translate into:

• Improved access to equity capital
• Lower cost of capital and increased project competitiveness
• Accelerated timelines for development and financing
• Enhanced long-term asset value

However, these benefits are only available within designated census tracts, making the nomination process critically important.

Who Should Be Paying Attention

Opportunity Zone designation creates meaningful advantages for a broad set of stakeholders, particularly those who can either deploy capital or attract it into designated areas. The most important groups include:

Developers and Operating Businesses

Benefit from improved access to equity, lower cost of capital, and accelerated timelines—particularly for capital-intensive real estate, infrastructure, and growth-oriented projects.

Communities and Local Leaders

Can leverage designation to attract private investment, advance long-planned development initiatives, and drive job creation and economic revitalization.

Investors with Significant Capital Gains

Including individuals, family offices, and investment platforms that can access favorable tax treatment by committing long-term capital to qualifying projects.

Bottom Line

Opportunity Zone designation is most impactful where investment-ready projects, supportive community leadership, and patient investment capital intersect, making early and coordinated engagement critical to capturing the program’s full benefits.

Why Advocacy Matters

Not all eligible census tracts will receive designation, and competition is expected to be intense due to:

• The 25% cap on eligible tracts
• Stricter eligibility criteria, reducing the total number of qualifying areas
• Increased emphasis on projects that demonstrate clear economic impact and investment readiness

Governors are expected to prioritize tracts that align with statewide priorities, show strong potential to attract private capital, and present credible development opportunities. As a result, proactive, coordinated engagement by developers, investors, and community stakeholders can be decisive in influencing outcomes.

How Cozen O’Connor Public Strategies Can Help

Cozen O’Connor Public Strategies is actively supporting clients in navigating the Opportunity Zone designation process and engaging with state leadership and key federal officials during this critical window. Our team has a strong presence and established relationships in New York, Pennsylvania, Illinois, Minnesota, Virginia, and New Jersey, positioning us to provide targeted, state-specific advocacy along with a robust federal practice to provide strong support at the federal level.

We can assist with:

• Identifying and evaluating eligible census tracts aligned with your priorities
• Developing clear, data-driven advocacy strategies
• Engaging with key decision-makers in Governor’s offices and state agencies
• Coordinating multi-state efforts for national clients
• Integrating policy, tax, and economic development considerations into a cohesive strategy

Next Steps

The July 1 nomination window presents a time-sensitive and highly strategic opportunity to position projects, investments, and communities for long-term success.

If you have current or planned projects that may benefit from Opportunity Zone designation, or would like to explore advocacy strategies, please contact Cozen O’Connor Public Strategies to learn more.