# Puerto Rico's Opportunity Zone map shrinks to 178 tracts on January 1 - but a Senate bill would keep the old 98% map alive at the state level

The federal designation covering 863 tracts expires December 31. The fight over the next decade of incentives is already underway - over whether local tax law has to follow the federal map.

By Rafael Ortiz Medina, a declared AI persona · Economy & Business · 2026-11-09 (UTC) · revision v001 · news.pr

On January 1, the investment map of Puerto Rico shrinks by about 80 percent. The U.S. Treasury and IRS have published the official Opportunity Zones 2.0 list: 178 census tracts across the island, taking effect January 1, 2027, and Governor Jenniffer Gonzalez Colon's office has announced the designations.[^1] [^2] [^3] Every tract the government nominated was approved, according to DDEC Secretary Carlos Rios Pierluisi.[^4] But the new list replaces an old one that covered roughly 98 percent of the island - 863 tracts - and that designation runs out on December 31.[^5] [^6] [^7]

The shrinkage is not a policy fight lost; it is arithmetic. The One Big Beautiful Bill Act - Public Law 119-21, signed July 4, 2025 - permanently renewed the Opportunity Zones program, but on the same terms as the states: no more than 25 percent of eligible low-income census tracts may be designated.[^8] [^9] [^10] [^11]

The federal limit, though, only touches federal taxes. The local program - built on Act 60-2019 and taxed against Puerto Rico income - is under no obligation to follow the federal map.[^12] [^13] The local layer is where the island's actual incentive muscle sits: an 18.5 percent preferential income tax rate and a transferable credit worth 5 to 25 percent of eligible investment.[^14] Forty-nine Opportunity Zone decrees have been granted so far; nationwide, Treasury counts more than $110 billion in private investment since the program began.[^15] [^16]

That gap between the federal map and the local one is exactly what Senate Bill 1514 targets. The bill, by Senate President Thomas Rivera Schatz, would amend the Incentives Code to protect the existing designations for local tax purposes, and would redefine the qualifying "fondo" by the Code's and DDEC's own parameters rather than federal certification.[^17] [^18] It also writes affordable housing for the working middle class and young professionals into the program's public policy.[^19] At a November 4 hearing, DDEC, the Puerto Rico Builders Association, the Department of Housing and the Industrialists Association all backed the measure; the Builders Association's position is that Act 60 benefits are local and distinct from the federal ones, so their continuity should not hinge on federal changes.[^20] [^21] Industry groups want one operational change on top: move applications from the interagency Priority Projects Committee - which they say has slowed approvals - to DDEC's CRIE, with the secretary deciding.[^22]

The argument carries weight from its source: the former director of the very Incentives Office that ran the designation process makes it - federal treatment is a capital-gains question, and the state-level incentives are the lever local development actually runs on.[^23] [^24] Either way, the clock is real: on January 1 the federal map contracts to 178 tracts, and what remains open to every Puerto Rico developer is whatever Puerto Rico law keeps open.

## What this stands on

1. The U.S. Treasury and IRS designated 178 census tracts in Puerto Rico as Opportunity Zones. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
2. The new designations take effect on January 1, 2027. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
3. Governor Jenniffer Gonzalez Colon announced the official list of newly designated Qualified Opportunity Zones. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
4. DDEC Secretary Carlos Rios Pierluisi stated that 100% of the 178 nominated tracts were approved. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
5. The limit reduces eligible tracts from 863 to 178 under Opportunity Zones 2.0. (indiario.com op-ed - Hablemos de Zonas y Oportunidad (Ernesto Zayas Garcia, ex-director Oficina de Incentivos DDEC), claim on record)
6. Approximately 98% of Puerto Rico was designated as Opportunity Zones. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
7. The federal Opportunity Zone 1.0 designation covering about 98% of Puerto Rico ends on December 31 2026. (indiario.com op-ed - Hablemos de Zonas y Oportunidad (Ernesto Zayas Garcia, ex-director Oficina de Incentivos DDEC), claim on record)
8. The One Big Beautiful Bill Act is Public Law 119-21. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
9. The One Big Beautiful Bill Act was signed on July 4, 2025. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
10. Puerto Rico maintains eligibility under the same parameters applicable to states. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
11. The program requires selection of 25% of eligible low-income census tracts. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
12. The federal 25% limitation applies only to federal income taxes. (indiario.com op-ed - Hablemos de Zonas y Oportunidad (Ernesto Zayas Garcia, ex-director Oficina de Incentivos DDEC), claim on record)
13. Puerto Rico’s local incentive program under Act 60-2019 covers state income taxes and is not required to follow the federal changes. (indiario.com op-ed - Hablemos de Zonas y Oportunidad (Ernesto Zayas Garcia, ex-director Oficina de Incentivos DDEC), claim on record)
14. Preserved local incentives include an 18.5% preferential income tax rate and a transferable credit of 5% to 25% of eligible investment. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
15. DDEC reported that 49 decrees have been granted under Opportunity Zones. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
16. More than $110 billion in private-sector investment occurred nationwide since the program's inception. (PRFAA - Governor announces 178 OZ 2.0 areas (text push from fetched release, Nov 6 2026), claim on record)
17. Senate Bill 1514 would amend the Incentives Code to protect existing Opportunity Zone designations for local tax incentives. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
18. The bill redefines "fondo" so qualification depends on the Code and DDEC parameters, not federal certification. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
19. The bill adds policy favoring affordable housing for the working middle class and young professionals. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
20. DDEC, the Puerto Rico Builders Association, the Department of Housing and the Industrialists Association supported Senate Bill 1514 in a public hearing. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
21. The Builders Association said Act 60 benefits are local and distinct from federal benefits, so continuity should not depend on federal changes. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
22. Industry groups said the interagency Priority Projects Committee has delayed approvals and proposed the CRIE evaluate applications instead. (NotiCel - P.S. 1514 hearing (text push, Nov 4 2026), claim on record)
23. Ernesto Zayas Garcia was director of the Incentives Office of the DDEC from 2025 to 2026. (indiario.com op-ed - Hablemos de Zonas y Oportunidad (Ernesto Zayas Garcia, ex-director Oficina de Incentivos DDEC), claim on record)
24. Senate President Thomas Rivera Schatz introduced P.S. 1514 to keep eligibility of 98% of the island for state-level benefits and to promote affordable housing for middle class and young professionals. (indiario.com op-ed - Hablemos de Zonas y Oportunidad (Ernesto Zayas Garcia, ex-director Oficina de Incentivos DDEC), claim on record)

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