Opportunity Zone Funds, From Their Form D Filings: 1,044 Issuers, $18.6 Billion Reported Sold, and the Tax Date Every Pre-2027 Investor Faces on December 31, 2026

What an opportunity zone fund is, and why the Form D is the only common record

A qualified opportunity fund (QOF) is a corporation or partnership organized to invest in property inside designated low-income census tracts, and it must hold at least 90 percent of its assets in that property (26 U.S.C. 1400Z-2(d)(1)). Investors put capital gains into it, not ordinary savings: the statute lets you leave out of income the part of a gain that you invest in a QOF within 180 days of the sale, and later gives a step-up in basis or, after 10 years, a basis equal to fair value.

There is no public register of QOFs. A fund self-certifies to the IRS on its tax return. What almost every fund that raises money from outside investors does file is a Form D, the short SEC notice for a private placement. It carries a handful of comparable numbers: offering amount, amount sold, number of investors, minimum investment, sales commissions, and payments to the sponsor's own people. We pulled every Form D we could tie to an opportunity zone vehicle, from the SEC's quarterly Form D data sets (2018 to June 30, 2026) and EDGAR full-text search (July 1 to October 5, 2026).

Three cautions before the numbers. The count includes property-level vehicles ("QOZB" businesses) and parallel or feeder entities of the same program, so some money may be counted twice. Amounts sold are what the issuer reported on its latest filing, often years old, and some funds never update. And a fund that filed under a name without "opportunity zone", "QOF", "QOZ" or "OZ", and without those words in its text, is missing. Read 1,044 and $18.58 billion as "at least, as reported".

Launches by year: the 2019 rush and the 2025-2026 trickle

Source: SEC Form D data sets and EDGAR filings; grouping by year of each issuer's first filing and totals are our arithmetic. The 2019 row includes CIM Opportunity Zone Fund's $2.22 billion.

The shape follows the tax rule. Before 2027, the deferral always ends on December 31, 2026, so every year of delay meant a shorter deferral and, after 2021, no chance at the 10% step-up. Launches fell every year from 2019. New money has not stopped entirely: Trilogy Edgewater Opportunity Zone Fund, L.P. filed on July 17, 2026 reporting $79,000,000 sold to 5 investors with a $5,000,000 minimum, the largest new filing of the year.

The largest opportunity zone funds by amount sold

Source: each issuer's latest Form D or D/A on EDGAR (accession numbers in the dataset). A minimum of $0 means the filing states no minimum. Amounts sold are as reported on that date and are not updated by funds that stopped filing.

Two things stand out. First, the big numbers are concentrated in a few sponsors who sell through brokers and wealth platforms: CIM, Griffin Capital (four funds, $1.97 billion together), Cantor Silverstein, CV QOZ Partners. Second, most opportunity zone vehicles are small and single-project: the median issuer reporting any sales has sold $4,315,000 to 6 investors (our arithmetic). If you were sold an opportunity zone deal by a local developer, it probably looks like the median, not like CIM. Origin's second fund appears above; we also cover Origin's IncomePlus fund, and Pacific Oak Strategic Opportunity REIT carries the same name as Pacific Oak Opportunity Zone Fund I in the commission table below.

What the broker-sold funds disclose they pay to sell

Source: Item 15 (sales commissions) and Item 13 (offering amount) of each Form D or D/A; percentages are our arithmetic. Item 15 is usually marked as an estimate for the whole offering, so read each as "up to".

The sales commission is paid out of investors' money before anything is built. On a $500,000 gain placed in a fund at 10%, that is up to $50,000 that goes to the selling broker-dealers (our arithmetic). Across the 109 issuers that report a commission and a numeric offering amount, the median is 4.0%, and 32 are at 7% or more. The same pattern shows up in 1031 products: see our 141-filing comparison of DST sales loads. One filing we left out of every average: CV OW Opportunity Zone Fund, LP reports $312,523,200 of sales commissions on a $76,189,494 offering, which can only be a filing error.

December 31, 2026: what the statute says happens to money already in a fund

For every gain deferred into a QOF before 2027, 26 U.S.C. 1400Z-2(b)(1) says the gain “shall be included in income in the taxable year which includes the earlier of” the date the investment “is sold or exchanged” or “December 31, 2026.” For an individual on a calendar year, that is the 2026 return, filed in 2027, whether or not the fund has paid anything out.

How much is included is the deferred gain (or, if lower, the investment's fair market value on that date) minus your basis. Basis starts at zero, rises 10% of the deferred gain after a 5-year hold and another 5% after 7 years. Because the measuring date is fixed, only investments made by December 31, 2021 reach five years in time, and only those made by December 31, 2019 reach seven (our arithmetic from the statute's dates).

Our arithmetic from 26 U.S.C. 1400Z-2(b)(2), as in effect for investments made before January 1, 2027. Not tax advice: partnership-level events, earlier sales and state rules can change the result.

The last row is the one fund statements matter for: if the fund's value has fallen, the amount you include is capped by that value. Ask the sponsor now how it will value your interest at December 31, 2026, and when you will get the figure. Separately, the 10-year rule in 1400Z-2(c) still lets an investor who holds 10 years elect a basis equal to fair market value on sale, which is where most of the promised benefit of the 2019-2021 funds lies.

From January 1, 2027: the new rules, side by side

The tax law signed on July 4, 2025 (Public Law 119-21, section 70421) rewrote the program and made it permanent. The changes apply, in the statute's words, “to amounts invested in qualified opportunity funds after December 31, 2026.”

Source: 26 U.S.C. 1400Z-2 and 1400Z-1 as amended by Pub. L. 119-21, sec. 70421, text and effective-date notes as published by the Legal Information Institute.

A qualified rural opportunity fund must hold at least 90% of its assets in property in zones made up entirely of rural areas, meaning outside cities or towns of more than 50,000 people and the urbanized areas next to them. Rural projects also need only 50% of the building's basis in improvements, instead of 100%, to count as "substantially improved" (a change that took effect on July 4, 2025). States may designate up to 25% of their low-income tracts.

One practical reading for anyone selling an asset in the second half of 2026 (our reading, to confirm with a tax adviser): the old rule bars elections for sales after December 31, 2026, but the amended election rule applies by investment date, not sale date. A gain realized in, say, August 2026 and invested in a QOF in January 2027, inside the 180-day window, would fall under the new 5-year rules rather than being taxed at the end of 2026.

What a holder can do with this

• If you are already in a QOF, put the December 31, 2026 inclusion in your 2026 tax estimate now. Work out your holding date (2019, 2020-2021, or 2022 and later decide the step-up), ask the sponsor for the year-end value it will report, and plan the cash: most funds will not distribute enough to pay the tax.
• Check the fund's own Form D on EDGAR (search the fund's name) for the amount sold, investors and commissions. A fund whose latest filing is from 2021 has simply stopped updating; ask for current figures.
• If you have a 2026 gain, the timing of the investment, not only the sale, now decides which rules apply.
• If you are being pitched a new 2027 fund, compare the load (Item 15) and the payments to the sponsor's people (Item 16) with the table above before you look at projected returns. Our guide to real estate crowdfunding taxes covers K-1 timing for partnership funds.

FAQ

Sources: SEC Form D data sets for 2018Q1 to 2026Q2 and individual Form D and D/A filings on EDGAR through October 5, 2026 (accession numbers in the dataset); 26 U.S.C. 1400Z-1 and 1400Z-2 with the amendments of Pub. L. 119-21, sec. 70421, as published by the Legal Information Institute, read October 5, 2026. Totals, medians, percentages, the grouping by year and the worked examples are our arithmetic. Issuers were identified by name and by full-text search, and hedge funds and unrelated "OZ" names were removed. This is analysis of public documents, not investment, legal or tax advice.