New Reporting Requirements under OBBB Act
The One, Big, Beautiful Bill Act introduced new information reporting obligations for employers and payors:
- Cash tips and qualified overtime compensation must be separately reported to employees, with payee statements; employers/payors must also file correct information returns. (irs.gov)
- Car loan interest interest received from individuals on qualified passenger vehicle loans (≥ $600/year) must be reported under the new section 6050AA. (irs.gov)
These duties began applying in 2025 — the tax year currently in process. (irs.gov)
IRS’s Transition Relief: Staying Compliant Without Penalties
Recognizing implementation challenges, the IRS provided transition relief in recent notices:
- Notice 2025-62 grants penalty relief for 2025 for those who don’t strictly comply with the new reporting for tips/overtime. Employers won’t face penalties for failures to separately provide occupation codes or tip amounts, or total qualified overtime, as long as complete and correct returns are otherwise filed. (irs.gov)
- Notice 2025-57 gives lenders and others transition relief under section 6050AA for 2025. If, by Jan 31, 2026, they make a statement to the individual showing total interest received, the IRS won’t penalize incomplete information returns/statements. (irs.gov)
Compliance Checklist for Employers and Lenders
| Requirement | 2025 Minimum | Ideal Practice |
|---|---|---|
| Tips & Overtime Reporting | File information returns; provide payee statements with totals, occupation codes somewhat optional during transition; avoid major errors. | By 2026, ensure systems capture cash tips, employee occupations, qualified overtime amounts correctly. |
| Car Loan Interest (Sec 6050AA) | Make statement indicating total interest for 2025 to borrower by Jan 31, 2026; penalties waived if statement provided. | Establish process to collect vehicle loan metadata (VIN, model/year) when required; prepare to file return forms. |
| Internal Training/Systems | Educate payroll, HR, finance teams about new definitions and thresholds. | Update payroll software & reporting templates; audit existing data flows. |
Example Scenario
An employer runs a restaurant where servers receive cash tips and standard overtime. In 2025, under penalty relief, separate amounts of cash tips or overtime do not need separate occupation codes if the employer still files overall W-2s with total compensation and overtime reported elsewhere properly. Come 2026, the employer must include occupation codes, tip amounts separately.
A car dealership that finances vehicle loans and receives interest ≥ $600/year from an individual must make a statement available (as online portal or annual document) showing total interest received for 2025. If they do so, no penalties under new reporting rules.
Action Steps for Employers/Lenders
- Review current payroll/reporting systems for ability to segregate tips, overtime, and cash tip amounts.
- Communicate with lenders about what statements will look like for car loan interest reporting.
- Document election of relief for 2025; keep records proving statements provided, returns filed.
- Prepare for full compliance by 2026: occupation codes, detailed statements, updated tax forms/forms W-2/1099.
Conclusion: While the OBBB Act brings compliance requirements that may feel heavy, the IRS is giving businesses room to adjust. Use 2025 as a transition year: avoid penalties by providing minimal statements now, and plan stronger data systems and reporting to meet the full standard in 2026.