Nearly 92% of American schoolchildren qualify for a §25F scholarship. The first state-by-state numbers are out.

Anyone planning around the Education Freedom Tax Credit has been working without a basic number: how many children can actually receive one of these scholarships. The statute sets the test at 300% of area median income, but nobody had run that test against real population data state by state, so operators sizing a program, schools deciding whether to participate, and governors weighing an opt-in have all been guessing. On July 28 the American Federation for Children published the first estimates, by senior fellow Patrick Graff, built from Census population estimates, the American Community Survey, HUD income limits, and 2026 Household Pulse data.

The headline figure is 51.7 million eligible students, which is 91.7% of the country's school-age children. That is not a rounding artifact, it is what a 300%-of-area-median-income ceiling does. AFC puts the resulting income limit for a family of four somewhere between roughly $234,000 and nearly $500,000 depending on where that family lives. The state-level range is narrow at the top: from 85.9% in the District of Columbia to 96.2% in Maine. In other words, §25F is not means-tested the way most people assume when they hear the words “scholarship” and “income limit.” In practice it excludes the top slice of earners in expensive metros and almost nobody else. Our explainer on who qualifies for a §25F scholarship walks through how the AMI test is applied to a single household.

The half of the analysis that matters politically is the split. AFC counts 31 states as in or committed as of July 2026, home to 30.9 million eligible students, which is 59.8% of the national total. That leaves 20.8 million eligible children in the states and the District of Columbia that have not joined. AFC's 31 lines up with our own participation map: 30 states have completed the federal advance election and appear on the IRS roster, and New York has announced its intent without filing. AFC also flags that for 20.5 million of those students the credit would be the first private-school-choice program their state has ever had, because 18 states run no ESA, voucher, or tax-credit scholarship of their own.

Two honest caveats before anyone quotes the number. First, eligible is not funded. Every donor is capped at $1,700 per taxpayer per year, so the binding constraint on how many children get a scholarship is donor dollars raised, not how many qualify, which is the same point we made about uptake being the real risk. An operator who reads 51.7 million as a market is reading it wrong; the number tells you your outreach is not limited by an income screen, not that the money is there. Second, AFC's counts assume homeschool rules will defer to each state's law on the legal status of homeschool students. That assumption is doing real work in some states and it is not settled yet, so treat the homeschool share of any state's figure as provisional until the federal rules land.

The practical use of this data is narrower and more useful than the headline. If you are forming an SGO, the question is not the national total, it is your own state's eligible population set against whether your state is in, because a large eligible population in a state that has not opted in is not a market until the governor files. Check your state on the participation map, see who is already organizing in the SGO directory, and if you are starting from nothing, our free SGO builder walks the formation and compliance steps. The eligibility ceiling being this high changes who you can credibly ask for applications, which changes how you should be recruiting donors between now and January 1, 2027.