The federal SGO list: which organizations qualify and how donors verify one

This article is the companion to our SGO overview and governor opt-in explainer. Everything below traces to IRC §25F and the state-by-state record we track.

Why the list is what makes a donation creditable

§25F is a federal credit, but it only reaches families through a state-mediated gate. A Scholarship Granting Organization can be a well-run, fully compliant nonprofit and still not generate a creditable donation, if it isn’t on the list its state submits to the U.S. Treasury for that year. The organization’s own compliance and its state’s participation are two separate conditions, and a donor needs both to be true before giving.

That two-part structure is deliberate. §25F gives states control over which organizations count in their jurisdiction (a form of gatekeeping meant to let states apply their own oversight), while the federal statute sets the floor every listed organization must clear regardless of state. For the mechanics of the state side, see how governors opt states in.

How an organization gets on the list

Getting from “a nonprofit that awards scholarships” to “a qualifying SGO whose donations earn the §25F credit” runs through several steps:

1. The organization meets §25F’s federal operating rules. Tax-exempt nonprofit status, the 90/10 spending rule, serving 10 or more students who don’t all attend the same school, renewal-then-sibling award priority, no earmarking, no self-dealing, separate accounts, and income verification against the 300% area-median-gross-income ceiling. See our SGO guide for the full rundown of these requirements.
2. The organization’s state has opted in. A governor (or the state-designated authority) has to have made the advance election and, ultimately, submitted a qualifying-SGO list to Treasury for that year. An organization in a state that hasn’t opted in cannot be listed, no matter how compliant it is.
3. The state includes the organization on its submitted list. States have discretion in how they certify or designate organizations for that list, some run a light federal pass-through, others layer on additional application steps, nondiscrimination provisions, or reporting requirements, modeled on how existing state tax-credit-scholarship programs already certify organizations (Arizona’s Department of Revenue, Ohio’s Attorney General, Indiana’s Department of Education, and others).

For an organization walking through this process itself, our how-to-start-an-SGO guide covers it step by step, including where the state-listing step sits relative to incorporation, the EIN, and 501(c)(3) approval.

What makes an organization a qualifying SGO

Being on the list isn’t just a paperwork event, it certifies that the organization meets the substantive federal bar. When a governor submits a state’s list, the certification carries weight: the listed organizations are represented as meeting §25F’s requirements, including:

• Tax-exempt nonprofit status
• The 90/10 rule, at least 90% of income spent on scholarships, no more than 10% on administration
• Serving 10 or more students who don’t all attend the same school
• Verified household income at or below 300% of area median gross income
• No earmarking of contributions for a particular student
• No awards to disqualified persons (insiders and their families)
• Separate accounts that prevent co-mingling of qualified contributions

A state can add its own oversight on top of this floor, but it cannot weaken it. Treasury’s June 2026 guidance preview indicated that states may not impose SGO-specific requirements stricter than §25F’s own, though the exact contours are still being finalized in the proposed regulations expected by the end of September 2026.

Why the IRS’s published list can run behind a state’s roster

Participation happens in two distinct steps, and they don’t happen at the same time. First, a state can make an advance election under Rev. Proc. 2026-6, filing IRS Form 15714 to signal it intends to participate for 2027. Second, and separately, the state has to submit its actual list of qualifying SGOs to Treasury. The advance election is a commitment; the SGO list is what actually makes specific organizations creditable.

That gap between commitment and final listing is exactly why you will sometimes see a state reported as having “opted in” or “advanced” §25F in the news, in legislative records, or on our own state-by-state status map, while the IRS’s own published roster hasn’t yet caught up to reflect it. A governor can sign an advance election, and a legislature can pass and even enact implementing legislation, before the federal paperwork transmitting the state’s full SGO list is complete. Neither step is fake or premature, they’re just different stages of the same pipeline, and the lag between them is a normal feature of a new federal program ramping up, not an error.

How a donor verifies an SGO before giving

As of mid-2026, there is no single searchable federal database of every qualifying SGO, Treasury’s June 2026 guidance preview left the list-submission mechanics and reporting format to the forthcoming proposed regulations. Until that exists, verification is a three-step check:

1. Confirm the state has opted in. Check our state-by-state status map for the SGO’s state (participation is annual, a state can opt in one year and not the next).
2. Confirm the organization is on that state’s current list. Reputable SGOs publish their designation status, award criteria, and financials. Our SGO directory catalogs organizations already running today’s state tax-credit-scholarship programs, the same organizations expected to carry that track record into §25F designation, though it is not itself the federal designation list.
3. Ask the SGO directly for proof of listing and substantiation. A donor needs documentation from the SGO to claim the credit. If an organization can’t point to its state listing or can’t explain how it substantiates donations, treat that as a red flag before giving.

Remember, too, that a donor doesn’t have to live in a participating state to claim the credit, only the SGO’s state has to be opted in. A donor in a non-participating state can still give to a listed SGO elsewhere and claim §25F, though the scholarship dollars flow to students in the SGO’s own state.

For SGO operators: staying on the list

For an organization, appearing on the list once isn’t permanent. Participation is annual on both the state and organization side, a state resubmits its list each year, and an organization that drifts out of compliance (the 90/10 ratio, income verification, anti-earmarking) risks falling off it. Operators who manage listings, donor substantiation, and per-state compliance across the year typically use dedicated systems rather than spreadsheets to keep the underlying ratios auditable; SGO Software is built around exactly this kind of ongoing, per-state §25F compliance tracking.

For the full operating-rule checklist an organization has to hold to stay listed, see our SGO guide, and for state-by-state opt-in mechanics, see how governors opt in.

Frequently asked questions