316 local governments opted out of Georgia's new property tax cap. Here's the full scorecard, the rewritten 299c freeze rules, and what pending legislation could change everything.
# HB 581 and Georgia Property Tax Appeals: What Changed, Who Opted Out, and What Comes Next
Last Updated: March 2026
Georgia voters approved Amendment 1 in November 2024 by a 63% margin, giving HB 581 the constitutional foundation to cap annual homestead assessment increases at the rate of inflation. Then 316 local government entities opted out. Counties representing 83% of Georgia's population now have at least one taxing authority that rejected the cap. That disconnect between voter intent and local government action is reshaping property tax appeals, school funding, and the 2026 legislative session in ways that touch every Georgia homeowner.
This article breaks down what HB 581 actually changed in Georgia law, which jurisdictions opted out (and why), how the 299c appeal freeze was rewritten, and what pending legislation could override local opt-outs entirely.
Georgia's property tax system didn't arrive at HB 581 overnight. The legislative history spans 25+ years of reforms, recessions, and political shifts.
Rep. Shaw Blackmon (R-146th) sponsored both HB 581 and HB 92, making him the central legislative architect of Georgia's property tax overhaul.
Signed by Governor Kemp on April 18, 2024, HB 581 has three distinct components that operate independently.
The floating homestead exemption caps annual assessed value increases at CPI-U for jurisdictions that didn't opt out. The base year is the 2024 digest value (frozen for 2025), with the first CPI adjustment applying in 2026 at 2.7%. The cap resets when the home is sold or the homestead exemption lapses.
The 299c freeze reform is the change that most directly affects appeals. You must now win an actual reduction to trigger a value freeze, and the freeze is shorter. (Full details in the next section.)
The Property Tax Relief Local Option Sales Tax (PTRLOST/FLOST) authorized counties to levy up to a 1-cent sales tax dedicated to property tax relief. HB 92 later adjusted eligibility and accelerated refund timelines.
This is the most consequential change for anyone considering a property tax appeal. The amendment to O.C.G.A. 48-5-299(c) fundamentally rewrote how value freezes work after an appeal. For a deeper look at the freeze changes, see How the 299c Freeze Law Changed in 2025.
(c) When the value of real property is reduced or is unchanged from the value on the initial annual notice of assessment or a corrected annual notice of assessment issued by the board of tax assessors and such valuation has been established as the result of an appeal decision rendered by the board of equalization, hearing officer, arbitrator, or superior court pursuant to Code Section 48-5-311...the new valuation so established by appeal decision or agreement may not be increased by the board of tax assessors during the next two successive years...
(c) When the value of real property is reduced from the value on the initial annual notice of assessment or a corrected annual notice of assessment issued by the board of tax assessors and such reduced valuation has been established as the result of an appeal decision rendered by the board of equalization, hearing officer, arbitrator, or superior court pursuant to Code Section 48-5-311...the new valuation so established by appeal decision or agreement may not be increased by the board of tax assessors during the next two successive years...
Two words were deleted. Those two words changed everything.
Under the old system, Georgia property owners could file an appeal with no evidence, show up to the Board of Equalization hearing, receive the same assessed value back, and still walk away with a 3-year freeze. That freeze prevented the assessor from raising the value during those three years regardless of market conditions.
A Georgia Tech study of Fulton County found that commercial property owners exploited this mechanism systematically. Over 12 years (2011-2022), 31,587 commercial appeals generated a 62% success rate, and the 299c freeze ensured values stayed suppressed even when appeals didn't succeed. In Paulding County alone, over 54% of 2022 appeals were filed by a single entity, costing the county $1.2 million in property tax revenue.
The 299c reform applies statewide. There's no opt-out. Every Georgia appeal filed from 2025 forward operates under the new rules.
Even a successful appeal won't trigger the freeze if:
The opt-out provision was supposed to be a safety valve. It became the default. According to data from the Georgia Secretary of State's office, 316 entities opted out by the March 1, 2025 deadline.
316 local government entities opted out of the HB 581 floating homestead exemption, including ~68% of school districts, ~30% of counties, and ~26% of cities.
Source: Tax Foundation and GSU Center for State and Local Finance
Counties representing ~83% of Georgia's population have at least one taxing authority that opted out of the HB 581 CPI cap.
Three patterns explain the mass opt-out.
First, several large jurisdictions already had local floating homestead exemptions that were more protective than HB 581's CPI cap. Gwinnett County, Cobb County, and the City of Atlanta all fell into this category. Atlanta's HB 820 cap (2.6%) was more restrictive than the 2.7% CPI rate published for 2026.
Second, school districts faced the steepest revenue projections. Property taxes fund 72% of local school revenues in Georgia, and K-12 education receives about $11.1 billion annually from property taxes statewide. Cherokee County Schools estimated an $11 million loss in the first year and $68 million over five years. When 65% of your budget depends on property tax revenue, a CPI cap changes the math quickly.
Third, local government associations (the Association County Commissioners of Georgia and Georgia Municipal Association) provided opt-out guidance, model resolutions, and clear financial impact analyses. That infrastructure made opting out the path of least resistance.
Only one jurisdiction used the HB 92 rescission window to reverse course. Bryan County Schools voted unanimously in April 2025 to rescind their opt-out, calling HB 92's construction materials sales tax exemption a "win-win." With $300 million in building needs over the next decade, the tax savings on construction outweighed the revenue impact of the CPI cap.
No other jurisdiction has publicly reversed its opt-out.
For jurisdictions that stayed in, the Georgia DOR published the first inflation index rate in January 2026: 2.7%, based on CPI-U (All Urban Consumers) as required by Rule 560-11-2-.32.
The 2026 CPI cap rate is 2.7%, based on CPI-U (All Urban Consumers). A home assessed at $300,000 can't exceed $308,100 in opted-in jurisdictions.
At a typical 30-mill rate, that $15,900 in protected assessed value translates to about $477 in annual tax savings. But the cap applies only to assessed value. Millage rates are set independently by each taxing authority and can still increase, potentially offsetting part of the benefit.
Georgia's HB 581 places it in a growing group of states with assessment cap provisions, but the details vary enormously.
Georgia and Illinois are the only two major states where a homeowner faces meaningful risk of an assessment increase after filing an appeal. But Georgia's combination of free filing and assessor burden of proof is unusually favorable. The tradeoff is real: your appeal body can raise your value, which doesn't happen in Texas, Florida, or New York.
The Homeowner Tax Relief Grant is Georgia's primary mechanism for direct property tax relief. It works by reducing each homestead's assessed value, with the state reimbursing local governments for the lost revenue. The program has been funded exactly twice since the Great Recession.
$850 million in Homeowner Tax Relief Grants was signed into law on March 3, 2026, the first HTRG appropriation since the $950 million one-time grant in 2023.
The 14-year gap between 2008 and 2023 wasn't an oversight. HB 143 (2009) created a revenue trigger requiring state revenues to grow at least 3% plus CPI inflation before HTRG could be refunded. That threshold wasn't met until the post-pandemic revenue surge.
Between 2023 and 2026, the state has now appropriated $1.8 billion in direct homeowner tax relief through HTRG alone, not counting the HB 581 CPI cap or the separate $1.2 billion income tax rebate included in the 2026 budget.
$1.8 billion in cumulative HTRG funding has been appropriated since 2023, making it the largest direct property tax relief program in Georgia history.
The 2026 HTRG is explicitly one-time. There's no guarantee of future funding, and the per-homestead reduction amount hasn't been officially published by the Georgia DOR yet. News reports estimate approximately $500 per homestead.
The 2026 Georgia legislative session (ending around April 2, 2026) has produced competing visions for property tax reform. The House and Senate each passed their own bill, and reconciliation will determine which approach (if either) becomes law.
If SB 382 passes, every jurisdiction that opted out would be forced back in. The 316 opt-outs would become irrelevant overnight. If HB 1116 passes instead, the 3% hard cap would replace the CPI-based approach. The session ends around April 2, 2026.
The HB 581 opt-out map creates a two-track system for Georgia homeowners.
The 299c freeze reform applies everywhere in Georgia, regardless of opt-out status. That's the change no jurisdiction can escape.
For the ~83% of Georgians living in a county with at least one opt-out, the incentive to appeal with solid evidence has never been higher. You can't rely on the old strategy of filing to trigger a freeze. You need comparable sales, market data, and a persuasive case.
Official government sources: HB 581 bill page and full text; House Budget & Research Office HB 581 policy brief; Georgia DOR 2026 Inflationary Index Bulletin; DOR 2025 Property Tax Administration Annual Report; Secretary of State HB 581 opt-out list; Governor Kemp FY 2026 budget signing; O.C.G.A. 48-5-299: pre-HB 581 and post-HB 581
Research and analysis: Tax Foundation opt-out analysis (May 2025); GSU Center for State and Local Finance (July 2025); Georgia Budget and Policy Institute; Georgia Tech / Atlanta Civic Circle commercial appeal study (2011-2022 data)
Association guidance: ACCG HB 581 FAQs; Georgia Municipal Association HB 581 & HB 92
Opt-out counts come from Tax Foundation analysis of Georgia Secretary of State data. The "83% of Georgia's population" figure reflects Tax Foundation's county-level population analysis of jurisdictions with at least one opt-out. Individual jurisdiction statuses were verified against official county/city websites and news reports. No single comprehensive tracker exists; the Secretary of State's list is the closest official record. Pending legislation status is current as of March 20, 2026.