Tax Insight

Proposed regulations address expanded Opportunity Zone reporting and updated QOF certification procedures

Insight
7 minute read
September 18, 2026

What happened?

Treasury and the IRS on September 11, 2026 published proposed regulations to implement new Qualified Opportunity Zone (QOZ) information-reporting requirements enacted by the One Big Beautiful Bill Act (OBBBA). The proposal would require qualified opportunity funds (QOFs) to file expanded annual information returns and furnish statements to investors that experience disposition events. It also would require applicable qualified opportunity zone businesses (QOZBs) to provide annual information statements to their QOF investors.

The proposed regulations also would clarify QOF self-certification, create procedures for revoking an inadvertent certification and voluntarily decertifying, coordinate broker reporting for certain QOF disposition events, and address penalties for incomplete, incorrect, or late reporting.

The proposed regulations focus on reporting, certification, and decertification, and do not address the broader post-2026 transition rules or other substantive changes to the QOZ regime enacted by the OBBBA.

Why is it relevant?

If finalized, the rules would materially increase reporting requirements for QOFs and QOZBs by significantly expanding the scope of information that QOZBs must provide to QOFs, and that QOFs must provide to their investors and the IRS. The proposed reporting extends beyond asset values and census tract data to include employee and residential-unit information, NAICS codes, property acquisition and improvement dates, working capital safe harbor information, QOZB compliance attestations, and detailed investor acquisition and disposition data. Once the regulations become applicable, the new requirements would apply to both existing and future QOFs and QOZBs.

Actions to consider

QOF sponsors and QOZBs should begin assessing whether current governance, accounting, investor-recordkeeping, payroll, property, and compliance systems can produce the proposed information on the required testing dates and deadlines. Sponsors also should identify data owners, establish annual QOZB-to-QOF reporting protocols, review investor and broker reporting processes, and consider whether fund and QOZB agreements provide sufficient information rights and remedies. Entities considering QOF decertification should evaluate the proposed documentation, filing, and investor-notification rules before taking action.