The Healey-Driscoll Administration nominated 104 census tracts across 46 Massachusetts municipalities to the U.S. Treasury on October 2, 2026, according to the Commonwealth's 2026 Opportunity Zone program page. Mass.gov says the state could nominate up to 104 of 414 eligible tracts under the tighter federal criteria, down from 138 tracts designated in 2018. The eligible-tract appendix to IRS Rev. Proc. 2026-14 lists 410 Massachusetts tracts and a cap of 103, so Treasury certification will settle the final count. The EOED and EOHLC picked tracts on project readiness, local support and priorities such as housing production, transit-oriented development, downtown revitalization and job creation. The slate covers innovation districts, working waterfronts, MBTA Communities districts and rural hubs. The state expects Treasury to certify the designations later this fall, and certified zones take effect January 1, 2027 through December 31, 2036.
The filing. The Commonwealth’s 2026 Massachusetts Opportunity Zone Program page says that on October 2, 2026, the Healey-Driscoll Administration nominated 104 census tracts across 46 municipalities to the U.S. Department of the Treasury. The page says Treasury is expected to certify the designations “over the next several weeks” and, in another section, “later this fall.” Until Treasury certifies them, these are nominations, not designated Opportunity Zones.
The numbers. Mass.gov says that under the updated federal eligibility criteria the Commonwealth could nominate up to 104 of 414 eligible census tracts, and that it nominated the full 104. That compares with 138 tracts designated in Massachusetts in 2018. The eligible-tract appendix to IRS Rev. Proc. 2026-14, which our Massachusetts zone page and tracker use, lists 410 eligible Massachusetts tracts, for a 25% cap of 103. Mass.gov does not explain the difference. Treasury certification will settle the final count.
Why the map shrank. The state page attributes the smaller slate to the tighter eligibility rules in the 2025 One Big Beautiful Bill Act. A tract now qualifies if its median family income is at or below 70% of the area median (down from 80%), or if it has a poverty rate of at least 20% and a median family income at or below 125% of the area median. Contiguous tracts, which governors could nominate in 2018, are no longer eligible.
How the tracts were chosen. According to Mass.gov, the Executive Office of Economic Development (EOED) and the Executive Office of Housing and Livable Communities (EOHLC) worked with municipalities and other stakeholders and scored proposed tracts on project readiness, local support and fit with Administration priorities: housing production, transit-oriented development, downtown revitalization and job creation. The Administration says it favored tracts with projects in the pipeline, demonstrated developer interest, supportive local zoning and the chance to leverage existing or planned public investment.
Where the zones are. The state page names several groups of places on the slate. It lists innovation districts in Amherst, Boston, Cambridge, Lowell and Worcester, and working waterfronts “from New Bedford to Gloucester” aimed at maritime industries, ocean technology and marine science. On housing, it cites public housing revitalization in Boston and “more than a dozen” MBTA Communities districts, naming Fall River, Framingham and Haverhill. It also names smaller hubs in Central and Western Massachusetts: Athol, Gardner, Greenfield, Montague, North Adams and Southbridge. The page has an interactive map and a searchable table of the 104 nominated tracts, which can be downloaded as a CSV.
Timing. Massachusetts filed four days after the 90-day federal nomination window closed on September 28, 2026. Under Rev. Proc. 2026-14, a governor may get one 30-day extension, which ends no later than October 28, 2026. Treasury’s 30-day period to certify nominations ends by November 27, 2026 at the latest, and an extension can push that to December 28, 2026. Mass.gov does not say whether the Commonwealth requested an extension. Massachusetts had told stakeholders it was aiming for an early-September submission, as we reported in August.
What comes next. The state page says that once Treasury certifies them, the designations take effect January 1, 2027 and remain in place through December 31, 2036, and it will post updates when certifications are official. Massachusetts is the tenth state on our tracker with a filing confirmed by an official source, alongside the U.S. Virgin Islands. Together they account for 1,299 nominated tracts by their own counts; see the OZ 2.0 nomination tracker for the full list.
For investors. The state page notes that investments through Qualified Rural Opportunity Funds in rural zones get a 30% basis step-up after five years, against 10% for other investments, and a 50% substantial-improvement threshold instead of 100%. Our guide to investing in Opportunity Zones starting January 1, 2027 covers how the new rules apply to investments made on or after that date. Until certification, treat the 104 Massachusetts tracts as proposed, not final.
Original reporting by Sarah Whitfield for Opportunity Zone Invest, an independent OZ 2.0 research site. Facts are drawn from the primary sources cited above per our editorial standards. Nothing here is tax, legal, or investment advice.
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