The reporting obligation sits with the QOF as a filing matter, and the penalty exposure for a deficient or late filing lands there. The data chain you describe is real, and it gets handled contractually rather than statutorily. In practice a fund that owns a QOZB writes information rights and reporting covenants into the operating agreement or the subscription documents at the project level, with specified delivery dates ahead of the fund's own filing deadline, and often a remedy if delivery slips. Whether your particular documents do that is a question for the lawyer papering them, and the specifics of the current reporting requirements should be confirmed with a tax professional since implementation guidance is still working through.
What that means for you as an operator taking fund capital: expect to be asked for data you may not currently collect. Employee counts and payroll at the project level are the ones operators typically don't have systemized, because a construction phase with subcontracted labor produces headcount numbers that depend entirely on how you define the population. Get the definition agreed in writing before you sign, not at the first reporting cycle.
The thing that tends to bite later is the audit and books-and-records clause traveling alongside the reporting covenant. A fund exposed to penalties will want inspection rights broad enough to verify what you send, and broad inspection rights on an operating asset are an ongoing cost in staff time. I'd also look at whether the fund can withhold a distribution or charge back a penalty to the project if reporting fails. That provision exists in some documents and it converts a paperwork problem into a cash problem at the exact moment you're least able to absorb it.
