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California's Opportunity Zones 2.0 public-comment period is now open and closes August 28, 2026, at 11:59 p.m. Anyone may use the California Department of Finance's OZ 2.0 Public Comment Portal to submit tract-specific input. Each submission must address one census tract and may support or oppose designation or favor a substitution.
This is an important step, but it is not the final map. California plans to submit its final nominations to the U.S. Department of the Treasury by September 28, 2026. After federal certification, the new designations are scheduled to take effect January 1, 2027.
As of this article's review on August 4, California has opened the comment portal and posted its current list of tracts recommended for nomination. The list remains a draft and is subject to change before the Governor submits California's final nominations. Review the official California Opportunity Zones webpage and Department of Finance map and list page for the current materials.
Where California's map-selection process stands today
As of August 4, 2026, the federal government has determined which California census tracts are eligible, California's local-authority recommendation period has closed, and the public-comment period is open. California's published process calls for GO-Biz and the Department of Finance to provide initial evaluations to the Governor's office before final state nominations. Public comments add tract-specific information to that process.
The map-selection picture can be summarized in five facts:
- California has 2,469 federally eligible census tracts under the Opportunity Zones 2.0 criteria.
- The Governor may nominate no more than 618 tracts under the federal 25% limit, which rounds fractional results up to the next whole tract.
- Eligibility does not guarantee selection, and an existing Opportunity Zone 1.0 designation does not automatically carry into Opportunity Zones 2.0.
- California says GO-Biz and the Department of Finance will consider statewide data, local recommendations, geographic equity, and economic-development priorities in their initial evaluations.
- California describes the August map as a draft. Public comments may inform the final nominations, but the Governor makes the final state selections and the U.S. Treasury certifies the designations.
What is California's Opportunity Zones 2.0 public-comment period?
California's Opportunity Zones 2.0 public-comment period is open through August 28. The state's FAQ says anyone may provide tract-specific input through the public-comment portal before the Governor finalizes the state's nominations. The phase follows federal eligibility guidance and recommendations from authorized local authorities. Final nominations and U.S. Treasury certification come later.
Not every eligible tract will become an Opportunity Zone. Federal law generally allows a governor to nominate no more than 25% of the state's eligible low-income census tracts. California therefore must evaluate eligible tracts and choose among them.
The new designations are expected to run from January 1, 2027, through December 31, 2036. Eligibility, draft recommendation, final state nomination, and federal designation are separate statuses.
California Opportunity Zones 2.0 timeline
- July 4, 2025: Federal law makes the Opportunity Zone framework permanent. Public Law 119-21 establishes recurring 10-year designation cycles and new rules beginning in 2027.
- April 6, 2026: Treasury and the IRS release Revenue Procedure 2026-14. The federal government publishes the eligible-tract list and nomination procedure. California has 2,469 eligible tracts and may nominate up to 618.
- May 19, 2026: California holds its first OZ 2.0 webinar covering designation updates and best practices.
- May 26, 2026: California holds its second webinar, focused on attracting and deploying Opportunity Zone investment.
- June 2, 2026: California holds its third webinar, focused on identifying optimal eligible census tracts.
- June 4, 2026: California posts the first state OZ 2.0 FAQ explaining its priorities, local-engagement process, and initial selection framework.
- June 15, 2026: The Local Authority Recommendation Form opens for authorized local and tribal entities.
- June 24, 2026: California holds a tribal communities and partners webinar.
- July 8, 2026: California moves the local recommendation deadline from July 25 to July 20 to create more time for public review.
- July 20, 2026: The local recommendation period closes at 11:59 p.m., and state agencies move into initial evaluation and draft-map preparation.
- July 24, 2026: California posts its public-comment FAQ confirming the dates, one-tract rule, submission format, and accepted comment types.
- August 3, 2026: California opens the public-comment portal and posts the current recommended-tract list for public review.
- August 28, 2026: Public comments close at 11:59 p.m. Submissions received after the deadline will not be accepted.
- September 28, 2026: California plans to submit the Governor's final selections to the U.S. Treasury.
- January 1, 2027: The new designations take effect after federal certification, beginning the first Opportunity Zones 2.0 designation period.
The federal nomination window is governed by IRS Revenue Procedure 2026-14. California's dates and participation process are described in the state's Opportunity Zones 2.0 FAQ and public-comment FAQ.
Phase 1: Federal eligibility rules set the field
The map-selection process began at the federal level. On April 6, 2026, the Treasury Department and IRS issued Revenue Procedure 2026-14, identifying the census tracts eligible for the designation period beginning in 2027 and describing how governors must submit nominations.
California has 2,469 eligible census tracts under that federal list. Because the federal 25% limit rounds fractional results up to the next whole tract, California's maximum is 618 tracts. That cap makes the state process a selection among eligible places, not a designation of every qualifying place.
Under the new federal targeting criteria summarized by California, a tract generally must meet one of two low-income tests:
- Median family income below 70% of the applicable metropolitan median, or the statewide median for a non-metropolitan tract; or
- A poverty rate of at least 20%, together with a median-family-income cap of 125% of the applicable median.
Treasury used the 2020-2024 American Community Survey five-year estimates when determining median family income. Two other federal changes materially altered the map-selection pool:
- A current Opportunity Zone 1.0 tract is not automatically eligible for Opportunity Zones 2.0. It must independently satisfy the new criteria.
- The former contiguous-tract option was eliminated. A tract cannot qualify merely because it borders an eligible low-income community.
Appearing on the federal list means a tract may be considered. It does not mean California recommended it, the Governor nominated it, or the Treasury designated it.
The four map statuses are not interchangeable
Understanding the selection process requires keeping four tract statuses separate:
- Eligible: The tract satisfies the federal criteria and may be considered by California.
- Draft recommended: The tract appears on California's preliminary map for public review, but its position can still change.
- Nominated: The Governor includes the tract in California's final submission to the U.S. Treasury.
- Designated: The U.S. Treasury certifies the nomination as a Qualified Opportunity Zone.
As of August 4, the process has not reached final federal designation. Describing a draft-recommended tract as already designated would be premature.
Phase 2: California explained its priorities and gathered local recommendations
California began building its selection framework before the federal nomination window opened. GO-Biz hosted webinars on May 19, May 26, June 2, and June 24 covering designation practices, investment deployment, tract selection, and tribal participation. The state posted the first version of its Opportunity Zones 2.0 FAQ on June 4 and continued updating the document as questions were received.
The formal Local Authority Recommendation Form opened June 15. This initial phase was limited to authorized representatives of:
- Cities and municipalities;
- Counties;
- Special districts;
- Regional joint powers authorities;
- Councils of governments; and
- California-based federally or non-federally recognized tribal governments.
Businesses, nonprofits, chambers, developers, and other community stakeholders could coordinate with those authorized entities, but they could not file the local-authority form in their own name. The later public-comment phase was designed to allow anyone to participate.
The state required one recommendation form per eligible tract. There was no fixed limit on how many tracts a local authority could recommend, but California encouraged jurisdictions to prioritize their strongest candidates. Multiple recommendations for the same tract did not give that tract extra weight, and a city council or other governing-body resolution was not required.
The form asked for tract-specific information such as:
- Committed public investment;
- Housing Element and Regional Housing Needs Allocation connections;
- Shovel-ready or development-ready sites;
- Infrastructure and tax-increment-financing districts;
- Community and regional partners;
- Alignment with California Jobs First sectors; and
- The tract's ability to attract public or private investment.
Supporting files were not accepted during this initial recommendation phase. California instead said letters and other supporting material could be provided during public comment.
On July 8, the state changed the deadline from July 25 to July 20 to create more time for public review in August. The local recommendation period closed July 20 at 11:59 p.m., and GO-Biz subsequently confirmed that it was no longer accepting local-authority forms.
Phase 3: California outlined how it would evaluate the eligible pool
California's FAQ says GO-Biz and the Department of Finance will provide the Governor's office with initial evaluations of all eligible tracts. The state says those evaluations will consider major demographic and socioeconomic indicators alongside local recommendations and economic-development priorities.
California identified the following selection considerations:
- Poverty and median family income;
- Renter occupancy and the share of income spent on rent;
- Household crowding;
- Unemployment;
- Geographic equity across California; and
- Statewide and regional economic-development objectives, including California Jobs First plans and business-ready sites.
The Department of Finance already held the core demographic data for eligible tracts, so local submitters were told to keep their narrative responses focused on the specific questions in the form rather than reproduce statewide data.
California says the Local Authority Recommendation Form did not use a point system. The state also did not promise any jurisdiction a minimum or maximum number of nominations. State materials say GO-Biz and the Department of Finance will provide initial evaluations, but the Governor's office determines which tracts appear in the final state nomination.
The announced framework is not simply a count of local endorsements. A local recommendation does not guarantee draft inclusion, duplicate recommendations do not add weight, and the absence of a governing-body resolution does not create a penalty. California says it will consider tract conditions, local context, statewide priorities, geographic distribution, and the federal cap of 618 nominations.
On July 24, California published a separate public-comment FAQ explaining how the preliminary map could be reviewed before final nominations. The state then opened its public, tract-by-tract comment phase on August 3.
Phase 4: Open public comment adds tract-specific context
The open public-comment phase gives residents, businesses, nonprofits, public agencies, and other stakeholders an opportunity to add local evidence to the state's analysis. According to California's official public-comment FAQ and portal:
- The period is open and closes August 28, 2026, at 11:59 p.m.;
- Anyone may submit a comment;
- Each submission must address one census tract;
- There is no limit on the number of separate comments a person may submit;
- A comment may support or oppose a tract or favor a substitution;
- The portal accepts written text and one optional PDF of up to 10 MB per submission;
- Comments should be addressed to the Governor; and
- A confirmation email should come from OZComments@dof.ca.gov after submission.
The state will review comments alongside demographic and socioeconomic indicators, local recommendations, and other factors. A recommended tract is not penalized merely because it receives no supporting comments, and a tract does not need comments to be nominated.
Comments also cannot turn an ineligible tract into an eligible tract. Before submitting, commenters should confirm the exact 11-digit census tract GEOID and its current status on the state's map.
Practical checklist for a tract-specific comment
California requires each comment to address one tract, and it accepts comments supporting or opposing a tract or favoring a substitution. The published public-comment FAQ does not provide a scoring formula. Based on the state's required fields and announced evaluation factors, a commenter can organize a submission around:
- The exact 11-digit census tract GEOID;
- A direct statement of the requested action;
- Current housing needs and affordability pressures;
- Committed public investment and infrastructure;
- Entitled, shovel-ready, or near-term projects;
- Access to jobs, transit, education, and community services;
- Alignment with adopted local and regional plans;
- Potential to support priority industries and quality jobs; and
- Named public, private, nonprofit, or community partners.
These are practical organizational suggestions, not additional state requirements. Factual statements should be supported with available records or source links.
What this means for San Jose and Santa Clara County
A count of the U.S. Treasury's March 2026 eligible-LIC dataset identifies 95 eligible tracts in the San Jose-Sunnyvale-Santa Clara core-based statistical area, including 89 in Santa Clara County. Those figures describe the eligible pool, not the final map. Each tract still must compete for a place within California's 618-tract maximum.
The stricter rules matter locally because current Opportunity Zone 1.0 status does not automatically carry forward. Some existing zones qualified under the former contiguous-tract provision, which is no longer available. The 2027 map may therefore preserve some current zones, omit others, and add eligible tracts that were not part of the original map.
For San Jose and Santa Clara County, the practical sequence has been:
- Identify which local tracts appear on Treasury's federal eligibility list.
- Distinguish eligible tracts from current Opportunity Zone 1.0 boundaries.
- Follow local-authority recommendations and California's selection criteria.
- Compare California's draft recommended map with the eligible local pool.
- Use tract-specific public comments to support a recommended tract, oppose a recommendation, or advocate for an eligible substitute.
- Wait for the Governor's final nominations and Treasury certification before describing any tract as designated.
Urban Catalyst has tracked federal eligibility and California's published deadlines and guidance and is evaluating how the draft-map process may affect downtown San Jose.
California's announced factors include housing conditions, committed public investment, infrastructure and development readiness, access to jobs, and alignment with state and regional plans. Any local evidence should be documented for the exact census tract under review.
There is no assurance that any particular San Jose or Santa Clara County tract will be nominated by the Governor or certified by the Treasury. A draft-map recommendation is not a final designation, and an omitted tract should not be called ineligible unless the federal list confirms that status.
What happens after the public-comment period?
After comments close on August 28, GO-Biz, the Department of Finance, and the Governor's office will consider the public record alongside state analysis and local recommendations. California currently plans to submit final nominations to the U.S. Treasury by September 28, 2026.
The Treasury then certifies and designates qualifying nominated tracts. The new map is scheduled to take effect January 1, 2027. Until that federal process is complete, any August draft map remains preliminary, and no public comment guarantees that a tract will be added, removed, or ultimately designated.
Frequently asked questions
How many California census tracts are eligible, and how many can be selected?
California has 2,469 federally eligible census tracts for Opportunity Zones 2.0. Under the federal 25% limit and its required rounding rule, the Governor may nominate no more than 618 tracts.
How is California developing its draft Opportunity Zones 2.0 map?
California says GO-Biz and the Department of Finance will use demographic and socioeconomic data, local-authority recommendations, geographic equity, housing conditions, unemployment, and statewide and regional economic-development priorities. The Local Authority Recommendation Form did not use a point system, and the Governor's office makes the final state selections.
Does a local recommendation guarantee that a tract appears on the map?
No. A local-authority recommendation is one input into the state's review. California also considers statewide data, economic-development priorities, geographic equity, public comments, and the federal limit on how many tracts may be nominated.
Are current Opportunity Zone 1.0 tracts automatically eligible for Opportunity Zones 2.0?
No. Every tract must independently satisfy the new federal eligibility criteria. The contiguous-tract option used in the original program has been eliminated, so some current zones may not qualify for the new round.
What is the difference between an eligible, recommended, nominated, and designated tract?
An eligible tract may be considered under the federal rules. A recommended tract appears on California's draft map. A nominated tract is included in the Governor's final Treasury submission. A designated tract has been certified by the U.S. Treasury.
When is California's Opportunity Zones 2.0 public-comment period?
California's public-comment period is open through August 28, 2026. The submission deadline is August 28, 2026, at 11:59 p.m.
Who can submit a public comment?
Anyone may submit a comment. A person commenting for a government entity, business, or nonprofit should use contact information associated with that organization.
Can one comment cover several census tracts?
No. Each submission must address one census tract. A person may comment on multiple tracts by filing a separate submission for each tract, and there is no overall submission limit.
Is California's current August 2026 draft map final?
No. California's public-comment map identifies eligible tracts and tracts currently recommended for nomination. Recommended tracts remain subject to change before the Governor submits California's final nominations.
Can a public comment make an ineligible tract eligible?
No. California says comments on an ineligible or off-list census tract do not change its federal eligibility.
What can be attached to a public comment?
Each comment may include text entered in the state portal and one optional PDF of up to 10 MB. A submitter who needs to provide another PDF may make an additional submission.
When will the new California Opportunity Zones take effect?
After the Governor's nominations are certified by the U.S. Treasury, the new Opportunity Zones 2.0 designations are scheduled to take effect January 1, 2027.
Stay informed
California's 2026 map-selection process is still underway, and dates, FAQs, and tract recommendations may change. Review the official California Opportunity Zones webpage, Department of Finance map and list page, and public-comment portal before relying on a draft map or submitting a comment.
To follow California Opportunity Zone policy and downtown San Jose development news, visit the Urban Catalyst blog.
This article is for educational and informational purposes only. It is not a research report or investment recommendation, does not provide tax, legal, accounting, investment, or securities advice, and is not an offer to sell or a solicitation of an offer to buy any security. No indication of interest or investment commitment is being solicited or accepted through this article. Opportunity Zone rules and designations remain subject to federal and state action. Consult qualified advisors about your circumstances.
Official sources
- California GO-Biz: Opportunity Zones in California
- California Department of Finance: Opportunity Zones 2.0 map, recommended-tract list, and portal
- California Department of Finance: OZ 2.0 Public Comment Portal
- California Opportunity Zones 2.0 Public Comment Period FAQ
- California Opportunity Zones 2.0 FAQ
- California Local Authority Recommendation Form Instructions
- U.S. Treasury: Eligible LICs for Nomination as 2027 QOZs
- IRS Revenue Procedure 2026-14
Important Disclosurs
The contents of this communication: (i) do not constitute an offer of securities or a solicitation of an offer to buy securities, (ii) offers can be made only by the confidential Private Placement Memorandum (the “PPM”) which is available upon request, (iii) do not and cannot replace the PPM and is qualified in its entirety by the PPM, and (iv) may not be relied upon in making an investment decision related to any investment offering by an issuer, or any affiliate, or partner thereof ("Issuer").
All potential investors must read the PPM and no person may invest without acknowledging receipt and complete review of the PPM.
With respect to any performance levels outlined herein, these do not constitute a promise of performance, nor is there any assurance that the investment objectives of any program will be attained. All investments carry the risk of loss of some or all of the principal invested. Assumptions are more fully outlined in the Offering Documents/ PPM for the respective offering. Consult the PPM for investment conditions, risk factors, minimum requirements, fees and expenses and other pertinent information with respect to any investment.
These investment opportunities have not been registered under the Securities Act of 1933 and are being offered pursuant to an exemption therefrom and from applicable state securities laws. All offerings are intended only for accredited investors unless otherwise specified.
Past performance are no guarantee of future results. All information is subject to change. You should always consult a tax professional prior to investing. Investment offerings and investment decisions may only be made on the basis of a confidential private placement memorandum issued by Issuer, or one of its partner/issuers. Issuer does not warrant the accuracy or completeness of the information contained herein. Thank you for your cooperation.
Real Estate Risk Disclosure:
- There is no guarantee that any strategy will be successful or achieve investment objectives including, among other things, profits, distributions, tax benefits, exit strategy, etc.;
- Potential for property value loss – All real estate investments have the potential to lose value during the life of the investments;
- Change of tax status – The income stream and depreciation schedule for any investment property may affect the property owner’s income bracket and/or tax status. An unfavorable tax ruling may cancel deferral of capital gains and result in immediate tax liabilities;
- Potential for foreclosure – All financed real estate investments have potential for foreclosure;
- Illiquidity – These assets are commonly offered through private placement offerings and are illiquid securities. There is no secondary market for these investments.
- Reduction or Elimination of Monthly Cash Flow Distributions – Like any investment in real estate, if a property unexpectedly loses tenants or sustains substantial damage, there is potential for suspension of cash flow distributions;
- Impact of fees/expenses – Costs associated with the transaction may impact investors’ returns and may outweigh the tax benefits
- Stated tax benefits – Any stated tax benefits are not guaranteed and are subject to changes in the tax code. Speak to your tax professional prior to investing.
Opportunity Zone Disclosures
- Investing in opportunity zones is speculative. Opportunity zones are newly formed entities with no operating history. There is no assurance of investment return, property appreciation, or profits. The ability to resell the fund’s underlying investment properties or businesses is not guaranteed. Investing in opportunity zone funds may involve a higher level of risk than investing in other established real estate offerings.
- Long-term investment. Opportunity zone funds have illiquid underlying investments that may not be easy to sell and the return of capital and realization of gains, if any, from an investment will generally occur only upon the partial or complete disposition or refinancing of such investments.
- Limited secondary market for redemption. Although secondary markets may provide a liquidity option in limited circumstances, the amount you will receive typically is discounted to current valuations.
- Difficult valuation assessment. The portfolio holdings in opportunity zone funds may be difficult to value because financial markets or exchanges do not usually quote or trade the holdings. As such, market prices for most of a fund’s holdings will not be readily available.
- Capital call default consequences. Meeting capital calls to provide managers with the pledged capital is a contractual obligation of each investor. Failure to meet this requirement in a timely manner could elicit significant adverse consequences, including, without limitation, the forfeiture of your interest in the fund.
- Opportunity zone funds may use leverage in connection with certain investments or participate in investments with highly leveraged capital structures. Leverage involves a high degree of financial risk and may increase the exposure of such investments to factors such as rising interest rates, downturns in the economy or deterioration in the condition of the assets underlying such investments.
- Unregistered investment. As with other unregistered investments, the regulatory protections of the Investment Company Act of 1940 are not available with unregistered securities.
- It is possible, due to tax, regulatory, or investment decisions, that a fund, or its investors, are unable realize any tax benefits. You should evaluate the merits of the underlying investment and not solely invest in an opportunity zone fund for any potential tax advantage.
The above material cannot be altered, revised, and/or modified without the express written consent of Urban Catalyst.
