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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.
Statute (enacted law) (3)
26 U.S.C. §25F — Qualified Elementary and Secondary Education Scholarships
§25FThe 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)Effective 2027-01-0126 U.S.C. §139K — Exclusion from Gross Income for Qualified ECCA Scholarships
§139KScholarships 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)Effective 2027-01-0126 U.S.C. §530(b)(3) — Definition of Qualified Elementary and Secondary Education Expenses
§530(b)(3)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)
Legislative provision (1)
IRS guidance (3)
IRS Notice 2025-70 — Request for Comments on §25F Implementation
Notice 2025-70First 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)IRS Revenue Procedure 2026-6 — Advance Election Procedure for §25F Covered States
Rev. Proc. 2026-6The 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 Federal Scholarship Tax Credit (FSTC) — Official Program Page
IRS FSTC pageThe 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 page
Coming soon (2)
Treasury Proposed Regulations under §25F — Coming Soon
Proposed RegsAfter Notice 2025-70's comment period, Treasury will publish proposed regulations specifying donor substantiation, joint-filer cap treatment, AMT coordination, SGO certification process, and income verification.
Treasury Department / IRS — anticipated 2026Coming soonIRS Form / Schedule for §25F Credit — Coming Soon
IRS Form (TBD)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.
Internal Revenue Service — anticipated 2026Coming soon