Colorado opens its §25F SGO application: an online portal and a November 30 deadline

Colorado is taking applications. “Organizations seeking to be listed on Colorado’s SGO list may now apply through the Colorado SGO Application Portal,” the Colorado Department of Revenue's Scholarship Granting Organizations page now says. The portal, at sgo.colorado.gov, is an online version of Form DR 1998, and the deadline is firm enough to plan around: “To guarantee inclusion on Colorado’s 2027 SGO list, applications must be submitted in the portal by November 30, 2026.” Earlier this month the same page offered only an email sign-up and an interest survey. That makes Colorado the eighth state to start taking organizations for its 2027 list, after Kentucky, Alaska, Montana, Idaho, Wyoming, South Carolina and Oklahoma. It's the step Gov. Jared Polis's office promised on October 1, when it said the Department was updating its form and would open the process “in the near future” (our October 1 report).

What you'll need. The Department says the application takes about 30 minutes once you've gathered your materials, and you can save it and come back. The attachments: your IRS 501(c)(3) determination letter, or, if your exemption is still pending, a copy of your Form 1023 with proof of submission through Pay.gov (a pending organization can be listed if its exemption, once granted, is effective by January 1 of the list year); a Certificate of Good Standing and a Certificate of Registration under the Colorado Charitable Solicitations Act, both from the Colorado Secretary of State and issued within 90 days of your application; and evidence that you've opened a §25F segregated account for Colorado, such as a bank statement (the portal says you can black out the account number). A first-time applicant also uploads its governing documents or bylaws and its written policies and procedures.

Your policies have to name the rules. This is the part to get right. A new SGO has no IRS filings yet, so Treasury's temporary regulations, which take effect without a comment period and apply from September 1, 2026, let a state list it based on its documents, as long as they “expressly require (beyond a general requirement to comply with applicable law)” that it meet §25F's operating rules (§ 1.25F-5T(d)(4)). Colorado's application puts it plainly: your policies “must expressly require the organization to satisfy the operational requirements for an SGO,” and “A general requirement to comply with applicable laws and regulations will not suffice.” Write the 10-student rule, the 90 percent spending test, income verification, the priority for prior recipients and their siblings, and the bar on scholarships for disqualified persons into your policies in so many words.

What you certify. Section 5 is a checklist of the federal operating rules, and nothing on it goes past them: scholarships to 10 or more students who don't all attend the same school; at least 90 percent of income spent on scholarships, computed under the proposed regulations' method; qualified education expenses only; no earmarking for a particular student; verified household income and family size, with a short description of how you verify; households at or below 300 percent of area median gross income; recipients who are eligible to enroll in a public school; the priority order for prior recipients and siblings; and no scholarships to disqualified persons. One box asks you to verify that students are “solely within Colorado,” which under the proposed regulations means they live in Colorado, with exceptions for military and tribal families. None of it is a Colorado add-on, and that matters, because Treasury's temporary regulations bar a state from making SGOs operate more restrictively than §25F (one national standard).

Located in Colorado, and single-state or multistate. You certify that you're authorized to do business in Colorado and registered under its charitable solicitations law, which is the federal “located in” test (no Colorado headquarters required), and that you'll award scholarships to eligible Colorado students. You also choose single-state or multistate. A multistate SGO keeps a §25F account solely for gifts donors direct to Colorado. The portal adds that “Any approved single-state SGO or multi-state SGO can accept donations and assign tax credits from out-of-state donors,” so a Colorado-listed SGO can raise money from donors anywhere in the country.

After you're listed. Section 7 commits you to give the state whatever it or the IRS needs to check compliance, including the annual certifications and the annual financial and programmatic audit in the proposed regulations, and to file an annual report with Colorado covering total qualified contributions received, total scholarships awarded, the number of students served, the percentage of income spent on scholarships, a certification of continued compliance, and each organization that received your scholarship payments, with the number of students per organization. Treasury's temporary regulations require states to set reporting like this, tailored in part to catch duplicate awards (§ 1.25F-5T(e)(1)(ii)), so set up your records to capture which organization received every award, starting with the first one. An authorized officer, director, trustee or other official signs the application under penalty of perjury, and Colorado warns that misrepresentation can mean removal from the list and referral to federal authorities.

The IRS portal can wait, donations can't. You can apply to Colorado before you've registered in the IRS SGO portal, which hasn't opened yet, the application says, “but you must register with the IRS SGO portal before accepting donations for the 25F tax credits.” Signing in to Colorado's portal takes the Google Authenticator app; “IRS guidance requires the SGO Application Portal to be secured by multifactor authentication,” the Department says. Help with the portal is at DOR_SGOApplications@state.co.us. The Department acknowledges each application by email and sends its decision by email if you opt in, or by mail if you don't.

The calendar. Applications are due November 30, 2026; the Department “may not be able to consider applications received after this date.” Colorado will send its list to the IRS by January 1, 2027, ahead of the February 15, 2027 federal deadline for 2027 lists (the full calendar). Under the temporary regulations, filing that list is also what completes Colorado's 2027 election. After 2027 the federal deadline moves to January 1 each year, and Colorado says future application cycles will run October through December of the year before.

For organizations. That leaves six weeks, including for the public-school SGOs the governor's office named on October 1. Order your Secretary of State certificates, open the Colorado §25F account, and write §25F-specific policies before you start the form. Our free SGO Builder walks through each step, the Colorado page and Colorado SGO list page track the state's process, and every state's official list is in one place.