State Overview
- Onboarding status
- State Program Only — dated snapshot
- State program type
- Traditional tax-credit scholarship
- Program name(s)
- Individual Income Tax Credit; Switcher Individual; Low-Income Corporate; Disabled/Displaced Corporate STO programs
- Official terminology
- School Tuition Organization (STO)
- Administering agency/agencies
- Arizona Department of Revenue
Four mature STO tax-credit programs. Arizona was not on the IRS §25F advance-election list dated 2026-07-24.
October 2026 federal regulatory update · Temporary state procedures and proposed SGO operating rules; current participation must be checked with the IRS.
Federal participation — verified October 23, 2026: Arizona does not appear on the IRS advance-election list for 2027.
IRS list dated October 22, 2026. Neither an advance election nor this guide establishes that an individual organization is listed. View IRS source.
Original state implementation research — 2026-09-08
No IRS advance election shown as of 2026-07-24. Arizona has mature state STO programs, but it was not on the IRS advance-election list dated 2026-07-24.
Historical IRS source date: 2026-07-24. References to forthcoming federal regulations predate the October 1 release.
Arizona State Program Requirements
According to the supplied research snapshot. Program-specific exceptions, current forms and annual guidance must be checked.
Organization Requirements
Arizona nonprofit that is exempt, or has applied for exemption, under IRC §501(c)(3).
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
State Approval
Apply to ADOR for certification before receiving tax-credit contributions under the applicable STO program(s).
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Governance
Maintain nonprofit status and comply with program-specific statutory conditions.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source · Additional sources and caveats
Financial Requirements
Track tax-credit contributions by program and preserve records necessary for ADOR verification.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Scholarship Use / Administrative Limits
Allocate at least 90% of annual tax-credit contributions to scholarships.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source · Additional sources and caveats
Donation Requirements
Individual programs prohibit donor designation of a student as a condition of the gift and prohibit beneficiary swapping. Recommendations may be permitted but awards cannot be based solely on donor recommendations.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Student & Family Eligibility
Eligibility varies by the four STO programs: some are broad individual-credit programs, while corporate programs include low-income and disabled/displaced eligibility conditions.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
School / Provider Requirements
May not limit scholarship availability to students of one school; must use qualified schools and follow program-specific restrictions.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Reporting
ADOR certification/reporting requirements; certain scholarship distribution disclosures must appear on an STO website if it has one.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Audit / Financial Review
Maintain records sufficient for ADOR verification and statutory compliance; confirm current annual filing/audit forms for each STO program.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Important Deadlines
Certification and program-specific contribution/preapproval deadlines vary by STO program.
State research dated 2026-09-08 — revalidate for the applicable program year. A.R.S. Title 43, Chapters 15–16; §§43-1089 et seq. · State source
Four mature STO tax-credit programs. Arizona was not on the IRS §25F advance-election list dated 2026-07-24.
Optional Checklist Preview
These are manual organizational tasks, not automated regulatory checks. State tracks use the 2026 research snapshot; federal tracks concern the 2027 pathway. Review the October update before using older federal checklist wording; these tasks are planning aids, not a current legal determination.
State program
- Confirm Arizona nonprofit status and §501(c)(3) exempt or applied-for status.
- Select applicable STO program(s) and obtain ADOR certification.
- Monitor minimum 90% allocation of annual tax-credit contributions to scholarships.
- Block contributions conditioned on designation of a specific student; block beneficiary swapping.
- Ensure scholarship availability is not limited to students of one school.
- If organization has a website, capture and publish required scholarship distribution disclosures.
Turn this guide into your SGO checklist
SGOone organizations can add this optional checklist to their account, track progress, add notes, and work toward a State Readiness badge.
Use This Checklist in SGOone This badge indicates that the organization has completed SGOone's optional state readiness checklist. It does not represent certification, approval, or a compliance determination by the state or SGOone.
Sources & References
Links and currentness notes come from the supplied workbook. Secondary mirrors are labeled; not every current annual form or primary instruction has been independently revalidated.
Internal Revenue Service · Primary official
Current page; participating-state list dated 2026-07-24 · Federal opt-in status; annual state list requirement; $1,700 credit overview
Internal Revenue Service · Primary official
2025-11 / still operative pending regulations · Statutory §25F SGO requirements and requested-guidance topics
U.S. Department of the Treasury · Primary official
2026-06-09; proposed regulations still forthcoming as of 2026-09-08 · Previewed implementation mechanics; pending/not-final items
IRS · Primary official
Current · General federal nonprofit/filing context
National Conference of State Legislatures · Secondary authoritative policy scan
Updated 2026-08-31 · 18 traditional TCS states / 22 programs; program/statutory inventory
National Conference of State Legislatures · Secondary authoritative policy scan
Current 2026 · Florida, Missouri, Utah tax-credit ESA programs administered by nonprofit organizations
National Conference of State Legislatures · Secondary authoritative policy tracker
Updated 2026-08-28 · State legislation implementing or conditioning §25F participation
Arizona Department of Revenue · Primary official/state source
Current source reviewed for workbook as of 2026-09-08 · State program qualification, operating, reporting and/or statutory requirements
Reference release 2026.1 · SGOone_50_State_Requirements_Hub_2026-09-08.xlsx. Some workbook source IDs are duplicated; citations here are bound by actual URL and state, not legacy ID prefixes.