State guide · Research 2026-09-08
Scholarship Granting Organization
Absence here means no current state SGO-administered tax-credit education program was identified in the two NCSL scans; it does not mean the state has no other school-choice program.
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: Colorado appears 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.
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.
State implementation / status checked: 2026-10-23 · Verified and page revised October 23, 2026. Colorado Department of Revenue · Colorado SGO Application Portal.
IRS advance election confirmed. Annual state SGO list is still required; monitor state guidance and forthcoming Treasury/IRS regulations.
Historical IRS source date: 2026-07-24. References to forthcoming federal regulations predate the October 1 release.
No state-level SGO-administered tax-credit education program found in the NCSL TCS/ESA scans used for this workbook.
This is not a finding that the state has no school-choice programs. Other education programs may use different funding or organizational models.
This separate federal pathway begins in 2027. State-program rules above are not substituted for the federal baseline.
State process — September research: State implementation agency/process not confirmed in enacted guidance located
Organization must be described in IRC §501(c)(3), exempt under §501(a), and not a private foundation.
Research authority status: Statutory baseline
Any organization seeking §25F SGO status · U.S. Congress — Public Law 119-21 (workbook direct citation)
An organization needs the applicable state SGO listing and must meet federal qualification requirements. Temporary regulations establish state certification and IRS SGO registration procedures; nonprofit formation, exemption recognition, state listing and portal registration are separate steps.
Statute + October 2026 temporary procedures · Primary source
Organization must be included on the participating state's annual SGO list for the applicable calendar year.
Statutory baseline + IRS administration · Original source
Maintain segregated Section 25F accounts for qualified contributions and their earnings, separate from other funds. Proposed operational rules address account-level testing and separate accounts for multistate SGOs.
Statute + temporary account definition; operational details proposed · Primary source
Maintain one or more separate accounts used exclusively for qualified contributions; qualified contributions may not be commingled with other funds.
Statutory baseline · Original source
Provide scholarships to at least 10 students who do not all attend the same school.
Research authority status: Statutory baseline
Federal SGO qualification/operation · Notice 2025-70 / Internal Revenue Bulletin 2025-50
The statutory minimum remains 90% of income spent on eligible scholarships. October's proposal defines cash-basis measurement, spending by the end of the following taxable year, oldest-income-first treatment and special segregated-account rules. The separate 85% activity safe harbor does not replace this spending minimum.
Statutory minimum; October 2026 measurement rules proposed · Primary source
Spend not less than 90% of the organization's income on scholarships for eligible students.
Statutory baseline; measurement details pending regulations · Original source
Scholarships must be for qualified elementary and secondary education expenses under §25F.
Research authority status: Statutory baseline
Every federal scholarship/disbursement · Notice 2025-70 / Internal Revenue Bulletin 2025-50
Give priority to students who received an SGO scholarship in the preceding school year.
Research authority status: Statutory baseline
When selecting eligible applicants · Notice 2025-70 / Internal Revenue Bulletin 2025-50
After returning-recipient priority, the statute prioritizes eligible students whose sibling was awarded a scholarship from the same SGO. The October proposal supplies timing details; do not limit this rule to the workbook's disputed prior-year-sibling wording.
Statutory priority; October 2026 timing details proposed · Primary source
After prior recipients, give priority to siblings of prior-year recipients.
Statutory baseline · Original source
A qualified contribution cannot be earmarked for a particular student.
Research authority status: Statutory baseline
Every federal-credit contribution · Notice 2025-70 / Internal Revenue Bulletin 2025-50
Verify household-income and family-size eligibility. The October 2026 proposal details household definitions, verification and certain safe harbors; those proposed provisions are not universal waivers of eligibility evidence.
Statutory requirement; October 2026 verification details proposed · Primary source
SGO must verify annual household income and family size for each scholarship student.
Statutory baseline · Original source
The statutory household-income ceiling remains 300% of applicable area median gross income. The October proposal details the income measure and verification safe harbors. Review those conditions and current IRS data instructions rather than treating every student as eligible.
Statutory threshold; October 2026 implementation details proposed · Primary source
Eligible student's household income cannot exceed 300% of area median gross income as defined by the federal statute.
Statutory baseline; data-source mechanics pending regulations · Original source
Scholarships may not be provided to disqualified persons under the federal related-party rule.
Research authority status: Statutory baseline
Every applicant/award · Notice 2025-70 / Internal Revenue Bulletin 2025-50
Qualified contributions associated with a state listing must fund scholarships solely within that state.
Research authority status: Statutory baseline
Each federal qualified contribution/award · Notice 2025-70 / Internal Revenue Bulletin 2025-50
Temporary regulations establish electronic state elections and SGO-list certifications. For 2027, an advance election is due by January 1, 2027, with a transition deadline of February 15, 2027 for the initial SGO list. The IRS portal instructions checked October 23 instead say January 1 for the 2027 list; states should resolve this discrepancy with the IRS. Individual organizations must confirm their own state's application process; a state election does not approve an SGO.
October 2026 temporary state procedures · Primary source
Participating state must annually submit its SGO list and state certification to IRS; 2027 list by Jan. 1, 2027 or as early as practicable.
IRS administration · Original source
The October 2026 proposal would require multistate SGOs to have at least 85% scholarship-granting activities, separate Section 25F accounts and books for each covered state, donor state-allocation designations and separate operational testing. These operating provisions are proposed, not final.
October 2026 proposed multistate framework · Primary source
Treasury has previewed state-designation/tracking expectations for SGOs listed in multiple states.
Treasury preview — not final regulation · Original source
Treasury and IRS released temporary and proposed Section 25F regulations on October 1, 2026. Temporary rules cover registration, acknowledgements, contribution reporting and state procedures. Other operating rules are proposed; reliance requires consistent use of all applicable portions. The September research statement that regulations were forthcoming is historical.
Updated October 2, 2026; temporary and proposed rules distinguished · Primary source
Treasury/IRS proposed §25F regulations were still forthcoming as of 2026-09-08; Treasury said they expect issuance by end of September 2026.
Current guidance status · Original source
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.
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 SGOoneThis 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.
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
U.S. Congress — Public Law 119-21, §70411 / IRC §25F · Direct citation in Federal Baseline and Checklist Seeds; absent from the workbook's Sources tab.
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.