Office of Management and Budget · Office of Information and Regulatory Affairs · 2026 Unified Agenda, published July 3, 2026
Tax Credit for Contributions of Individuals to Scholarship Granting Organizations
The Unified Agenda is the semiannual inventory of the rules every federal agency plans to issue. Treasury filed two entries for the §25F rulemaking, both under regulation number REG-117199-25. The fields below are reproduced verbatim from each entry; the only additions are our headings. We read these entries on July 29, 2026 and wrote up what they show in our report on the interim final rule.
(rin-1545-bs17)RIN 1545-BS17, temporary regulations
- Title
- Tax Credit for Contributions of Individuals to Scholarship Granting Organizations
- Abstract
- “The temporary regulations would accompany proposed regulations that provide guidance on the new tax credit for contributions by individuals to scholarship granting organizations (SGOs), as added to the Internal Revenue Code by the enactment of section 70411 of Public Law 119-21 (July 4, 2025), commonly referred to as the One Big Beautiful Bill Act. Temporary regulations are necessary to provide the procedure for States to make an Election, and to submit the State’s SGO List in the Fall of 2026 to complete an Election or perfect an Advance Election, before Final regulations will be published. Temporary regulations are also needed to require SGOs to track contributions made starting January 1, 2027, and capture the elements that SGOs will need to report.”
- Agency
- Department of the Treasury (TREAS) / IRS
- Priority
- Other Significant
- RIN status
- First time published in the Unified Agenda
- Agenda stage of rulemaking
- Final Rule Stage
- CFR citation
- 26 CFR 1
- Legal authority
- 26 U.S.C. 25F(h); 26 U.S.C. 7805; Pub. L. 119-21
- Legal deadline
- None
- Timetable
- Interim Final Rule, 07/00/2026 (no Federal Register citation)
- Government levels affected
- State
- Additional information
- REG number: REG-117199-25
(rin-1545-br97)RIN 1545-BR97, proposed regulations
- Title
- Tax Credit for Contributions of Individuals to Scholarship Granting Organizations
- Abstract
- “The proposed regulations would provide guidance on the new tax credit for contributions by individuals to scholarship granting organizations, as added to the Internal Revenue Code by the enactment of section 70411 of Public Law 119-21 (July 4, 2025), commonly referred to as the One Big Beautiful Bill Act. The new regulations will implement IRC 25F by providing for enforcement of the requirements for scholarship granting organizations and State elections to participate under IRC 25F, as well as recordkeeping and information reporting requirements for purposes of administering the requirements of IRC 25F.”
- Agency
- Department of the Treasury (TREAS) / IRS
- Priority
- Other Significant
- RIN status
- First time published in the Unified Agenda
- Agenda stage of rulemaking
- Final Rule Stage
- CFR citation
- 26 CFR 1
- Legal authority
- 26 U.S.C. 25F(h); 26 U.S.C. 7805; Pub. L. 119-21
- Legal deadline
- None
- Timetable
- Interim Final Rule, 07/00/2026 (no Federal Register citation)
- Government levels affected
- State
- Additional information
- REG-117199-25
(how-to-read-this)How to read this document
Three things in the text above carry the weight, and one common misreading is worth heading off.
The timetable action. An interim final rule takes legal effect on the day it publishes, with comments collected afterward. That is the reverse of a proposed rule, which binds nobody until the agency has answered comments and issued a final version. Treasury’s public statements, including its June 2026 guidance preview, describe proposed regulations by the end of September 2026. These entries describe a different instrument.
The stated purpose of the temporary rules. They exist so states can make an election and file their SGO lists in the fall of 2026 without waiting for final regulations. That timing is not an early start to the program: §25F(g)(1)(A) has always required a participating state to give Treasury its list “not later than January 1 of each calendar year (or, with respect to the first calendar year for which this section applies, as early as practicable).” The credit itself is available for contributions beginning January 1, 2027, and not before.
“Legal Deadline: None.” A Unified Agenda entry states an agency’s intent, not a commitment, and the 07/00/2026 date on both entries passed with nothing published. Agenda text is also often drafted weeks or months before OIRA posts it, so these entries may predate the June 2026 preview, and Treasury could still choose to publish a conventional proposed rule. The tell will be the label on the rule when it reaches OIRA for review, which is the step that precedes publication. Both RINs arrived there on September 10, 2026, and the record below shows what they carried.
(oira-review-record)OIRA review record, received September 10, 2026
Both rules are now under Executive Order 12866 review at the Office of Information and Regulatory Affairs, the last step before publication in the Federal Register. The two filings were received the same day and carry different stages, which answers the question the agenda entries above left open. We reported what the split means in our report on the rules reaching OIRA.
- RIN 1545-BS17
- Temporary regulations. Received 09/10/2026. Status: Pending Review. Stage: Interim Final Rule. Economically Significant: Yes. Legal Deadline: None. Agency: TREAS / IRS. Review record
- RIN 1545-BR97
- Proposed regulations. Received 09/10/2026. Status: Pending Review. Stage: Proposed Rule. Economically Significant: Yes. Legal Deadline: None. Agency: TREAS / IRS. Review record
- EO 12866 meetings
- Zero requests logged on either RIN as of September 11, 2026. While a rule is under review, any affected member of the public may request a meeting on it: request form for 1545-BS17, request form for 1545-BR97.
Two notes on reading this. First, the agenda entries above put both RINs at Final Rule Stage with an Interim Final Rule timetable. The review records separate them, and the separation follows the abstracts rather than the timetable: the temporary regulations, which carry the state election and SGO list procedures, are the interim final rule, while the substantive regulations on enforcement and recordkeeping are a proposed rule. Second, Economically Significant: Yes is new information. It is the government’s designation for a rule with an annual effect of at least $100 million, and the agenda entries had left the equivalent field undetermined.
