D.C. sits out the §25F roster: a mayor's call, not a legislature's, and Bowser is on her way out

When the IRS published its first official roster of jurisdictions participating in the federal Scholarship Tax Credit (FSTC / §25F) on June 8, 2026, in news release IR-2026-76, the District of Columbia was not on it. The list named 27 participating jurisdictions, all of them states: Alabama, Alaska, Arkansas, Colorado, Florida, Georgia, Idaho, Indiana, Iowa, Louisiana, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, Utah, Virginia, West Virginia, and Wyoming. The §25F credit lets a taxpayer claim a one-for-one federal credit of up to $1,700 for donations to qualified Scholarship Granting Organizations, and it becomes available January 1, 2027. D.C.'s absence from the 27-jurisdiction roster means residents of the nation's capital will not have access to the credit when the program launches unless that changes.

The mechanism here is what makes the District distinctive. Revenue Procedure 2026-6 explicitly names D.C. as eligible to participate, referring to the jurisdictions “including the District of Columbia, to make an Advance Election.” The election is made on Form 15714, “Advance Election to Participate Under Section 25F for 2027.” For the 50 states, that election is the governor's to make. The District has no governor, so under §25F(g)(2) the authority falls to the Mayor in lieu of a governor, exercised as an executive Advance Election rather than through a separate statute. The District does have a legislature in the D.C. Council, but the participation decision does not run through it: per the IRS guidance and analysis of Rev. Proc. 2026-6 by Current Federal Tax Developments, this is the mayor's call. To date, Mayor Muriel Bowser has filed no advance election.

Timing complicates the picture. Bowser announced on November 25, 2025, that she will not seek re-election, and the next D.C. mayoral election is set for November 3, 2026. That leaves the §25F decision in limbo: a lame-duck mayor who has shown no inclination to opt in, and a successor who will not take office until after the program has already launched. The dynamic resembles the lame-duck inheritance seen elsewhere, such as Virginia, where Glenn Youngkin opted in before handing the program to his successor, except that in the District no election has been made at all. The contrast with the states that moved early, like Florida and Colorado, is stark: each had a sitting executive willing to sign on, and the District has neither acted nor signaled it intends to.

For donors and prospective SGO founders, the practical consequence is straightforward. Without an advance election on file, no §25F credit flows to D.C. taxpayers and no qualified Scholarship Granting Organization can receive credit-eligible donations in the District for the 2027 launch. That does not mean the door is closed permanently, because a future mayor could file the election in a later cycle, but it does mean the capital starts behind the 27 states already on the roster. Operators eyeing the District should track whether any 2026 mayoral candidate adopts a §25F position, since the decision is now effectively a campaign question. How the credit works for families and the organizations that administer it is laid out in our explainers, and the current national landscape is detailed alongside every jurisdiction's status on the District of Columbia page and the national participation map.

The forward question is whether §25F becomes a live issue in the 2026 D.C. mayoral race. With Bowser stepping aside and the program launching just weeks after the new mayor is sworn in, the next executive will face an early, concrete choice: file the Form 15714 advance election and stand up an SGO framework, or leave the District out while neighboring states route credit-eligible donations to scholarships. SGO operators who do want to be ready can run a program on software built for §25F from day one, and founders can review how the organizations function in our explainers and scan the existing SGO directory. For now, the District remains the conspicuous blank on a map where more than half the states have already said yes.