Opportunity Zone Reporting Requirements Expand
Published Oct 26, 2026 · Insights Brief
The IRS and Treasury have proposed expanded information reporting requirements for Qualified Opportunity Funds (QOFs) and certain Qualified Opportunity Zone Businesses (QOZBs).
Under REG-116506-25, the proposed rules would expand Form 8996 reporting, require QOZBs to furnish additional information to participating funds, and establish procedures for investor reporting and fund certification.
The changes extend beyond tax return preparation.
Funds and underlying businesses would need to maintain detailed records supporting property valuations, qualifying investments, business activity, and compliance with Opportunity Zone requirements.
The proposal also addresses penalties under IRC § 6726, including a statutory $500 daily penalty for certain QOF reporting failures, subject to applicable limitations and relief.
The regulations remain proposed, but the underlying statutory reporting requirements were enacted in 2025.
Source: U.S. Treasury and IRS, REG-116506-25, September 11, 2026.
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