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State guide · Research 2026-09-08

Kansas SGO Requirements

Scholarship Granting Organization (SGO)

State + FederalKS
Informational only, not legal or tax advice. Requirements and program availability may change. Revalidate for the applicable program year. SGOone uses “SGO” broadly; each state's official terminology and separate program rules still matter.

State Overview

Onboarding status
State + Federal — dated snapshot
State program type
Traditional tax-credit scholarship
Program name(s)
Tax Credit for Low Income Students Scholarship Program
Official terminology
Scholarship Granting Organization (SGO)
Administering agency/agencies
Kansas State Board/KSDE; Kansas Department of Revenue

Established TCS program; federal §25F advance election confirmed.

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: Kansas 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.

Original state implementation research — 2026-09-08

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.

Kansas State Program Requirements

According to the supplied research snapshot. Program-specific exceptions, current forms and annual guidance must be checked.

Organization Requirements

§501(c)(3) organization; notification/qualification with the state.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

State Approval

Notify the Secretary/State Board and operate under the statutory SGO requirements.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

Financial Requirements

If contributions exceed/are expected to exceed $50,000, bonding or approved financial assurance applies; other-service nonprofits must segregate program funds.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

Donation Requirements

If the SGO limits scholarships to a set of schools, it must disclose the school names in writing to contributors and its board.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

Student & Family Eligibility

Low-income eligibility plus statutory school/pathway criteria; current official materials use 250% of federal poverty guidelines.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

School / Provider Requirements

Participating schools annually certify compliance; conflict and disclosure controls apply.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

Important Deadlines

Annual audit/reporting cycle; 36-month scholarship spending window is a critical rolling deadline.

State research dated 2026-09-08 — revalidate for the applicable program year. K.S.A. 72-4351–4357 · State source

Established TCS program; federal §25F advance election confirmed.

Federal §25F Pathway

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

Treasury and IRS issued temporary and proposed rules on October 1, 2026. The federal notes below distinguish updated guidance from the original 2026-09-08 snapshot. Read the October 2026 Section 25F regulatory update. Completing a checklist does not implement these controls in SGOone.

State listing

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

Original September research wording — historical

Organization must be included on the participating state's annual SGO list for the applicable calendar year.

Statutory baseline + IRS administration · Original source

Funds / accounting

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

Original September research wording — historical

Maintain one or more separate accounts used exclusively for qualified contributions; qualified contributions may not be commingled with other funds.

Statutory baseline · Original source

Financial ratio

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

Original September research wording — historical

Spend not less than 90% of the organization's income on scholarships for eligible students.

Statutory baseline; measurement details pending regulations · Original source

Scholarship expenses

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

Award priority

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

Original September research wording — historical

After prior recipients, give priority to siblings of prior-year recipients.

Statutory baseline · Original source

Eligibility evidence

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

Original September research wording — historical

SGO must verify annual household income and family size for each scholarship student.

Statutory baseline · Original source

Income threshold

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

Original September research wording — historical

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

State restriction

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

State certification

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

Original September research wording — historical

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

Multistate operations

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

Original September research wording — historical

Treasury has previewed state-designation/tracking expectations for SGOs listed in multiple states.

Treasury preview — not final regulation · Original source

Regulatory status

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

Original September research wording — historical

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

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.

Federal §25F

  • Organization must be described in IRC §501(c)(3), exempt under §501(a), and not a private foundation.
  • Organization must be included on the participating state's annual SGO list for the applicable calendar year.
  • Maintain one or more separate accounts used exclusively for qualified contributions; qualified contributions may not be commingled with other funds.
  • Provide scholarships to at least 10 students who do not all attend the same school.
  • Spend not less than 90% of the organization's income on scholarships for eligible students. — September research flag — review October guidance
  • Scholarships must be for qualified elementary and secondary education expenses under §25F.
  • Give priority to students who received an SGO scholarship in the preceding school year.
  • A qualified contribution cannot be earmarked for a particular student.
  • SGO must verify annual household income and family size for each scholarship student.
  • Eligible student's household income cannot exceed 300% of area median gross income as defined by the federal statute. — September research flag — review October guidance
  • Scholarships may not be provided to disqualified persons under the federal related-party rule.
  • Qualified contributions associated with a state listing must fund scholarships solely within that state.
  • Participating state must annually submit its SGO list and state certification to IRS; 2027 list by Jan. 1, 2027 or as early as practicable.
  • Treasury has previewed state-designation/tracking expectations for SGOs listed in multiple states. — September research flag — review October guidance

State program

  • Verify §501(c)(3) status and complete state SGO notification.
  • At/above the $50,000 contribution threshold, obtain required bond or approved financial assurance.
  • If organization provides other nonprofit services, segregate SGO funds from other funds.
  • Disburse at least 90% of contributions as scholarships within 36 months; halt new contributions if out of compliance.
  • Complete annual calendar-year CPA audit.
  • Enforce statutory school/staff/board related-party conflict restrictions.

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.

Preview of Forthcoming Section 25F Guidance

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

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.