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The rural Opportunity Zone expansion starts January 1, 2027. Potential eligibility does not establish participation—and the incentives do not require job creation.
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Searchlight Institute’s estimate comes from matching project locations against eligible rural census tracts, not from tracking tax claims. Microsoft and Meta said they do not use the incentive, Amazon said it has not claimed it or used it to select sites, and Google did not respond. The distinction matters: the expanded Opportunity Zone benefits may steer capital toward rural data centers, but the program does not require job creation, so local employment gains are not assured.
Searchlight’s database covered fewer than 700 planned or under-construction facilities; other datasets cited by WIRED put the U.S. pipeline near 1,500.
Pew research found rural areas have 13% of operating data centers but about 67% of planned facilities.
Developers must create a specialized investment vehicle to claim the benefits; building in an eligible tract alone is insufficient.
More than 100 rural data-center projects could qualify for federal tax benefits starting January 1, 2027, according to Searchlight Institute research reviewed by WIRED. The finding, published October 4, puts a concrete count on the potential beneficiaries of a rural investment incentive. But qualifying locations are not proof that developers will claim the benefits, and the program does not require projects to create jobs.
Opportunity Zones offer tax benefits for investment in designated low-income census tracts. The One Big Beautiful Bill Act changed the program to attract more investment to rural areas, with the expanded benefits scheduled to begin next year. A developer must create a specialized investment vehicle to pursue them; simply building inside an eligible tract is not enough.
Participation is also difficult to track publicly because claims can be confidential IRS data. WIRED asked Microsoft, Meta, Amazon and Google about data centers they are developing in potentially eligible areas. Their responses distinguish the research’s location-based finding from actual use of the incentive:
Searchlight matched the locations of projects in development against rural census tracts eligible for the expanded program. Its database contained fewer than 700 planned or under-construction data centers. WIRED cited other datasets putting the U.S. development pipeline closer to 1,500, so Searchlight’s finding is not a comprehensive national total.
The incentive arrives as development shifts toward rural locations. Pew research cited by WIRED found that rural areas hold 13 percent of operating data centers but about 67 percent of planned facilities. Those figures describe where projects are headed, not whether tax benefits drove their site choices.
Do you want to use this as a way to get data centers away from population centers? Are they just looking for capital investment, or are they wanting things like jobs?
Emily Kraschel, Searchlight Institute tax policy analyst, speaking to WIRED
Searchlight tax analyst Emily Kraschel told WIRED that capital investment does not necessarily produce jobs or a local economic boost. Data centers can provide construction work, but whether they create a lasting workforce remains contested. The absence of a jobs requirement leaves that outcome outside the program’s conditions.
The federal government estimates the rural Opportunity Zone expansion will cost $40.9 billion over the next decade. That estimate covers the wider rural program, not data centers alone. In September, Senator Josh Hawley introduced legislation to remove Opportunity Zone benefits for data centers, directly challenging their access to this investment incentive.
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