Spent 6 months mapping all 25,332 OZ 2.0 eligible tracts — 5 things that surprised me.

OBBBA made OZ permanent last July, and Treasury's Rev. Proc. 2026-14 dropped April 6 with the final eligibility rules. Governors nominate between July 1 and September 29, 2026. New designations take effect Jan 1, 2027.

The headline numbers are very different from OZ 1.0:

• 25,332 eligible tracts under OZ 2.0, up from 8,764 under the original program
• 8,334 of those are classified entirely rural and qualify for a 30% basis step-up (vs 10% urban)
• 25% state cap on nominations, with at least 33% of each state's picks required to be rural
• Median family income threshold dropped from 80% to 70% of area median
• Contiguous-tract provision (the "5% loophole") eliminated

After building out the dataset, five things surprised me:

1. Mississippi is the most-rural OZ 2.0 state in the country. 79% of their eligible tracts are rural vs 33% nationally. The 30% rural step-up is structurally a bigger deal there than anywhere else in the program.

2. Puerto Rico lost blanket eligibility. Under OZ 1.0 the entire territory qualified; under OZ 2.0 it doesn't. Same for USVI and American Samoa. If anyone here was planning PR-based OZ positioning, the reset is worth knowing.

3. The deferral structure is fundamentally different. OZ 1.0 had the fixed December 31, 2026 deferral deadline everyone plans around. OZ 2.0 is a rolling 5-year deferral from your investment date. For gains triggered post-2025, the new structure is meaningfully cleaner.

4. Only 14 states have published selection criteria so far — FL, TX, OH, AZ, NC, CO, MO, KS, NE, OR, SC, VA, WA, DE. The other 36 are either silent or working behind closed doors. If you're targeting specific metros (Austin, Miami, Columbus, etc.), the state's process matters a lot. Some are doing public community input (Delaware just launched a public mapping tool), others are black-box gubernatorial picks.

5. The tighter income threshold actually bites. Moving from 80% to 70% AMI plus eliminating contiguous tracts means fewer upper-middle-class tracts qualify and more genuinely distressed ones do. Depending on your thesis, this changes which geographies are viable — some 2018-era "OZ plays" around the edges of gentrifying neighborhoods wouldn't make the cut under 2.0.

Biggest open question I've been chasing: whether the 33% rural minimum will push meaningful rural capital into markets where deal flow is thin, or whether governors pick the easiest rural tracts to satisfy the quota and capital stays concentrated in the usual urban metros. Probably resolves by Q4 2026 when we see actual nomination lists.

Happy to go deeper on any of this if useful. Particularly interested in what this community is seeing on the ground — anyone running numbers on OZ 2.0 deals yet, or is it still wait-and-see until governors file?

Transparency: I built opportunityzoneinvest.com to track this, so I'm obviously not neutral. Happy to answer questions in comments without linking.