121.5 million taxpayers can claim the §25F credit in 2027, and more than 100 million can use all $1,700

In July the American Federation for Children published the first estimate of how many students can receive a §25F scholarship: 51.7 million. That number describes demand. On September 9 the same analyst, AFC Growth Fund senior fellow Patrick Graff, published the other side of the ledger in a report titled “Who Can Fund a Scholarship Under the EFTC?” It counts the people who can actually claim the credit, using IRS Statistics of Income data released at the end of August.

The test for a donor is simpler than the test for a student. The credit is nonrefundable, so what matters is whether a filer owes federal income tax. AFC counts 121.5 million filers with federal tax liability, which is 74.2% of all tax filers, or nearly three in four. More than 60% of all filers, 100.5 million tax units, owe enough to give $1,700 and receive the maximum credit. The rest could still give and claim a credit, just a smaller one, capped at what they owe (with any unused amount carrying forward under the statute).

The funding figures follow from that count. AFC says that for every 5% of eligible taxpayers who participate, K-12 scholarship funding rises by $9.4 billion, which puts 10% participation at $18.8 billion and 20% at $37.6 billion. Some rough arithmetic: 5% of 121.5 million is about 6.1 million filers, so $9.4 billion works out to roughly $1,550 per participant, a bit under the $1,700 cap. The report sets these amounts against familiar benchmarks. At 10%, it says, the total would exceed the tax deductions and credits generated each year by charitable gifts to all schools, colleges, and universities. At 20%, it would exceed current federal spending on Title I and IDEA special education combined.

Two caveats matter before anyone repeats these numbers. First, the report itself calls its totals theoretical upper limits on available credits, not projections, and eligible donors are not participating donors. Whether 5% of filers ever give is the uptake question that decides whether §25F becomes a large program or a small one. Second, AFC assumes $1,700 per return throughout and says directly that Treasury has not ruled on whether married couples filing jointly may claim $3,400. We read the statute the same conservative way (here is why), and a Senate bill introduced in August would settle it by amendment instead.

For anyone building an SGO, the donor count matters in a way the student count does not. The donor pool is national. A filer does not have to live in a participating state to give, because the statute places the in-state requirement on how an SGO spends the money, not on where the donor lives (we explained that split in August). An SGO's donor pool is therefore every one of those 121.5 million filers who can be reached and asked. Turning them into gifts takes work, and our guide to recruiting donors for your SGO and the donor number explainer are good places to start. If you are still forming the organization, the free SGO builder walks through each step before the credit opens on January 1, 2027.