Source documents
The verbatim text of every public document that defines the federal Educational Choice for Children Act / Federal Scholarship Tax Credit (ECCA / FSTC / §25F). Statutes, legislative provisions, IRS guidance, and placeholders for the regulations and forms still to come.
§25F 26 U.S.C. §25F, Qualified Elementary and Secondary Education Scholarships
The federal individual income tax credit for cash contributions to scholarship granting organizations. Donor cap $1,700/return, 5-year carryforward, 90/10 SGO requirement, K-12 income-eligible students at or below 300% AMGI.
Public Law 119-21, title VII, §70411(a)(1) (enacted July 4, 2025)§139K 26 U.S.C. §139K, Exclusion from Gross Income for Qualified ECCA Scholarships
Scholarships received from a qualifying SGO are excluded from gross income. Neither the student nor the parent owes federal income tax on the scholarship amount.
Public Law 119-21, title VII, §70411(b)(1) (enacted July 4, 2025)§530(b)(3) 26 U.S.C. §530(b)(3), Definition of Qualified Elementary and Secondary Education Expenses
The expense list referenced by §25F: tuition, fees, tutoring, special-needs services, books, supplies, room and board, uniforms, transportation, computer technology, and supplementary services at K-12 schools.
26 U.S.C. §530(b)(3) (Coverdell ESA expense definition)
Notice 2025-70 IRS Notice 2025-70, Request for Comments on §25F Implementation
First formal IRS guidance step. Treasury and IRS asked the public to comment on how to implement state SGO certification, the 90% income spending rule for multi-state SGOs, donor substantiation, and income verification. Comment period closed December 26, 2025.
IRS Notice 2025-70 (issued November 2025)Rev. Proc. 2026-6 IRS Revenue Procedure 2026-6, Advance Election Procedure for §25F Covered States
The exclusive method for a state to make an Advance Election to be a “covered State” for calendar year 2027. States must use Form 15714, filed on or after January 1, 2026 and before the state's SGO-list deadline. No alternative method or altered form is accepted for 2027, and a state that misses its SGO-list deadline has no qualifying SGOs that year.
Rev. Proc. 2026-6, 2026-02 I.R.B. (released December 12, 2025)IRS FSTC page IRS Federal Scholarship Tax Credit (FSTC), Official Program Page
The IRS's official hub for the §25F credit. It explains that states must opt in and submit an SGO list before donors can claim the credit, links Form 15714 (the state advance election), and is where the IRS will post the donor claim form and instructions when released ahead of the 2028 filing season.
Internal Revenue Service, Federal Scholarship Tax Credit (FSTC) program pageGuidance Preview Treasury Preview of Forthcoming §25F Guidance, Remarks by DAS Kevin Salinger (June 9, 2026)
Treasury's official preview of the §25F proposed regulations, expected no later than the end of September 2026 and reliable for tax year 2027. Covers the 90% test and its segregated-account safe harbor, the “located in” standard, the multistate SGO path, the §530-based definition of school, income-verification safe harbors, annual audits, the unique-donor-number system, and a planned IRS SGO portal.
U.S. Department of the Treasury, Office of Tax Policy, remarks delivered June 9, 2026; published June 10, 2026Treasury PR 6/10 Treasury Press Release, Treasury Previews Education Freedom Tax Credit Guidance (June 10, 2026)
The press release in which Treasury officially branded the §25F program the “Education Freedom Tax Credit,” committed to proposed regulations by the end of September 2026, and confirmed states, SGOs, and taxpayers can rely on them for tax year 2027. Includes Secretary Bessent's statement.
U.S. Department of the Treasury press release (June 10, 2026)EFTC Fact Sheet Treasury Fact Sheet, President Trump Delivers Affordable School Choice Options Through the Education Freedom Tax Credit
Treasury's plain-English fact sheet on the Education Freedom Tax Credit: a $1,700 federal credit (dollar-for-dollar, 5-year carryforward) for cash gifts to SGOs, the four-step state opt-in → SGO list → contribution → claim flow, 300% AMGI student eligibility, the 90% SGO income test, eligible §530 expenses, and impact estimates ($24B/year; 77,000 tuition or 300,000+ tutoring scholarships per $1B).
U.S. Department of the Treasury, Education Freedom Tax Credit Fact Sheet (Working Families Tax Cuts), released with the June 10, 2026 guidance preview
Proposed Regs Treasury Proposed Regulations under §25F, Expected by End of September 2026
After Notice 2025-70's comment period, Treasury will publish proposed regulations covering the 90% spending test, multistate SGOs, income verification, audits, and donor reporting. Treasury previewed the framework on June 10, 2026, see the Guidance Preview document, leaving joint-filer cap treatment and AMT coordination among the items still to be settled in the published rule.
Coming soonIRS Form (TBD) IRS Form / Schedule for §25F Credit, Coming Soon
The IRS has not yet published the specific form or schedule donors will use to claim the §25F credit. Donors will need a written acknowledgment from the SGO and should follow IRS instructions when published.
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