Proposed resolution:

In [ostreambuf.iter.cons]:

Move the current paragraph 1, which reads "Requires: s is not null.", from the first constructor to the second constructor.

Insert a new paragraph 1 Requires clause for the first constructor reading:

Requires: s.rdbuf() is not null.

The requires clause for ostreambuf_iterator's constructor from an ostream_type (24.5.4.1, paragraph 1) reads "s is not null". However, s is a reference, and references can't be null.