Form 8525: how donors will claim §25F with a donor number, not a Social Security number

How do you prove a $1,700 credit without handing a charity your Social Security number? The §25F rules Treasury and the IRS released on October 1, 2026 answer with a number of their own. Every SGO will issue each donor a unique donor number, and donors will claim the credit on a new IRS form, Form 8525, Federal Scholarship Tax Credit, by listing the number from each SGO they gave to.

Why not a Social Security number. Many commenters objected to SGOs collecting taxpayer identification numbers, and Treasury agreed. The preamble says requiring donors to hand over their TINs "would be burdensome, could chill an individual's desire to make contributions to an SGO, and might result in unnecessary exposure of sensitive taxpayer information." The IRS still needs to match what SGOs report against what donors claim, so the donor number does that job. Because each SGO generates its own numbers, a donor who gives to two SGOs gets two different numbers.

Step one is the SGO's, and it starts now. The temporary regulations, which apply from September 1, 2026, require every organization to register in a new IRS SGO portal with its name, EIN, address, phone number, year of formation, a contact person, and its taxable year. Registration is how the SGO receives the IRS's instructions for creating donor numbers "in a uniform format to be used by all SGOs," and it is also where the SGO authorizes the IRS to publish its name on the IRS SGO list. Treasury asks organizations to register "as soon as possible and preferably before the organization appears on any State SGO list," since an SGO that has not registered cannot issue the numbers its donors need.

Two deadlines after each year of giving. By January 31, the SGO sends each donor a written acknowledgment showing the SGO's EIN, the donor's total designated contributions for the year, the donor's unique number, and a statement of whether the SGO gave anything in return, with a good faith estimate of its value. It can go by email if the donor consents. By February 28, the SGO reports to the IRS, through the portal, each donor number with the donor's name, address, and total. For gifts made in 2027, those dates fall in early 2028. Both requirements are in the temporary regulations, which apply from September 1, 2026, so they do not wait for final rules. Our donor number explainer walks through the mechanics.

Then the donor files. Under the proposed rule, a donor substantiates the credit on Form 8525 (or a successor form) and lists the unique donor number for each SGO. Leave a number off and the IRS presumes there was no qualified contribution to that SGO. The presumption can be rebutted with the SGO's acknowledgment showing the number, or other evidence of the amount and the fact that it was designated, within the time the IRS allows in a written request. The form itself has not been released yet; we track it on our Form 8525 document page.

What counts as a qualifying gift. The donor has to designate the gift as a §25F contribution when making it, and under the temporary regulations that designation, once made, is irrevocable. The gift has to be cash, which the rules define as "physical currency, check, money order, electronic transfer, after-tax payroll deduction, or other similar method, in each case all in U.S. dollars," and which "does not mean any digital asset." Card payments count as electronic transfers. If the SGO gives anything back, its value comes off the qualified amount. And the gift has to come from the individual: under the proposed rule, a partner's or S corporation shareholder's share of a gift made by the business does not count toward that person's credit.

How a donor knows the SGO is real. The IRS will publish an IRS SGO list, and under the proposed rule a donor "may rely on the fact that an organization is listed on the IRS SGO list (and not listed as removed from that list) at the time a contribution is made." Removed organizations stay on the list in strike-through text with the removal date. Reliance is lost only if the donor knew the organization did not qualify, or was responsible for or aware of what got it removed. One catch for SGOs: an organization that does not authorize the IRS to publish its information leaves its donors without that reliance. More on the list is in our federal SGO list guide.

The proposed pieces are not final, but Treasury says donors, SGOs, and states may rely on them for contributions made on or after January 1, 2027. The full text is in our archives of the temporary regulations and the proposed regulations. If you are setting up an SGO, portal registration, a segregated §25F account, and a January acknowledgment run belong on your launch checklist; the free SGO Builder covers formation, and the SGO directory shows who is already operating.