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Updates / Current Guidance

SGO & Section 25F Updates

Important developments, useful deadlines, and sources to help you take the next step.

Sources checked October 23, 2026. Dates identify official events or source updates; entries labeled “status checked” use our verification date when no official publication date is shown. Follow the official source for later changes.

· Federal / portal status checked

IRS State Portal access instructions are available

The IRS now provides a State Portal sign-in and access instructions for designated state officials managing elections and annual SGO lists. Access uses Business Tax Account, ID.me, a dedicated state EIN and a mailed activation PIN. This is not the separate SGO registration portal. Status rechecked October 23; no launch date is asserted. The portal page’s January 1 list deadline differs from the temporary rule’s 2027 February 15 transition; see the regulatory guide before relying on either date.

IRS State Portal instructions · State procedures and deadline distinction

· State implementation / status checked

Colorado SGO applications open; November 30 deadline

Colorado Revenue is accepting applications through its SGO Application Portal. It identifies November 30, 2026 as the submission deadline for guaranteed inclusion on the 2027 list, subject to eligibility review. Prepare the required nonprofit, state-registration and segregated-account documents. Submission alone is not approval. The agency page has no displayed publication date; this is an October 23 status check.

Colorado Department of Revenue · Colorado application guidance

· Federal participation

IRS refreshes its 2027 advance-election list: 30 states

The IRS list dated October 22 still contains 30 states. New York’s October 9 announcement is not yet reflected in that list. The existing federal classifications remain unchanged. A state election is separate from an individual SGO’s approval, listing and ongoing federal and state obligations.

IRS participating-state list · State Information Hub

IRS participating-state list

· State agency page updated

Oklahoma Form 80002 applications due December 15

Oklahoma Tax Commission has revised Form 80002 for state, federal or combined SGO participation. Submit the application and required documentation by December 15, 2026 for tax year 2027. Approval under one framework does not automatically qualify the organization under the other. The agency page was updated October 22.

Oklahoma Tax Commission · Oklahoma application guidance

· Federal reporting / comment deadline

IRS seeks reporting-burden comments by December 21

The October 21 notice seeks comments on extending the existing Section 25F information collection, OMB 1545-2335, by December 21, 2026. It covers state elections, SGO registration, contribution records and donor acknowledgments and states that the approved collection is unchanged. This is a paperwork-comment deadline, separate from December 1 comments on the proposed regulations; it does not finalize those operating rules.

Federal Register information-collection notice · October regulatory guide

· State agency page updated

Indiana requires 2027 federal SGO approval by December 31

Indiana Education provides a State + Federal SGO application. For the 2027 federal program, organizations must have applied and been approved by December 31, 2026; do not treat that as a last-day submission allowance. Indiana lists no application deadline for its separate state SGO program. The agency page was updated October 21; both frameworks retain their own requirements.

Indiana Department of Education · Indiana state and federal pathways

· State implementation

South Carolina establishes federal SGO application intake

Executive Order 2026-23 directs the South Carolina Department of Revenue to receive applications for the 2027 federal program. The Governor identifies [email protected] as the application channel. Contact SCDOR for submission instructions; sending an application does not establish approval or replace federal qualification requirements.

South Carolina Governor’s October 13 announcement · South Carolina state guide

· State implementation

Tennessee opens preliminary SGO interest form

Tennessee Education announced an initial interest form for organizations seeking a place on its federal SGO list. This is a preliminary step, not certification or a completed formal application. Use the department’s linked form and contact [email protected] for current next steps.

Tennessee Department of Education announcement · Tennessee state guide

· Proposed rules / deadlines

Section 25F comments due December 1; hearing scheduled December 15

The proposed-rule notice sets December 1, 2026 for comments and requests to speak with topic outlines. A hearing is scheduled for December 15 at 10 a.m. Eastern; it may be cancelled if no outlines are received. Attendance requests are due December 10 at 5 p.m. Eastern. These are proposed rules, distinct from the accompanying temporary regulations.

Federal Register notice · October regulatory guide

· State implementation

Alaska approves its first 20 SGOs

Alaska Education announced the first 20 state-approved SGOs on October 2 and continuing rolling application review. The state expects to submit its 2027 list by December 1; that is a state submission target, not a published universal application cutoff. State approval and the applicable IRS listing remain distinct. Contributions before January 1, 2027 do not qualify for the new federal credit.

Alaska Department of Education announcement · Alaska state guide

SGOone Update

Stay current on the SGO landscape.

Important Section 25F developments, state implementation updates, SGO operating guidance, and new SGOone resources. No noise—just useful updates.