Iowa opens its §25F SGO application: a Department of Revenue form, due December 11

Iowa is taking applications. On October 30, 2026, Gov. Kim Reynolds announced the launch of the Iowa Scholarship Granting Organization application, the form a nonprofit files to get on Iowa's 2027 list under the federal Education Freedom Tax Credit (IRC §25F). The Iowa Department of Revenue compiles the list, and applications are due by 11:59 p.m. on Friday, December 11, 2026. Reynolds opted Iowa in on January 5, and the state is on the IRS list of participating states. “Today’s launch of the Iowa Scholarship Granting Organization application is the next step toward making this no-cost investment in Iowa students a reality,” Reynolds said in the release.

Revenue keeps the list; Education gets the reports. When Iowa opted in, the governor's office said it would work with the Iowa Department of Education on SGOs. The list has landed at the Department of Revenue, which hosts the application on a new Federal Education Freedom Tax Credit page and says it will post Iowa's finalized list there after the state submits it to the IRS. The Department of Education still has a role: applicants attest that they'll send it copies of their certifications, audits and other reports the federal rules require, including how many students applied and were awarded scholarships and the minimum, maximum and average award. Questions go to EFTC@iowa.gov.

What the form asks for. You give your legal name, EIN, year established and website, say whether you're Iowa-based, multistate or an existing Iowa School Tuition Organization, and name an authorized representative, a primary compliance contact and your board chair. Then come eight uploads, one file each (zip several together if you need to), and for each you name the document and the pages where the reviewer will find what it asks for. They are your IRS determination letter or proof that recognition is pending; your articles, bylaws or other governing documents, with evidence you meet Iowa's rules for charities; financial policies covering the segregated §25F account and the 90 percent test; your student-eligibility and award policies; your conflict-of-interest and disqualified-person policies; your scholarship application materials; your donor tracking, acknowledgment and IRS reporting procedures; and audit reports if you have them. After that come checkbox attestations that track §25F and a certification under penalty of perjury. Neither Revenue's page nor the form lists a fee.

A pending Form 1023 is fine, with one condition. The form asks whether your exemption is approved or pending and, if pending, your filing date and the effective date you requested. Under Treasury's temporary regulations, a state list can carry an organization whose application is still pending only if its exemption, once granted, reaches back to January 1, 2027 or earlier, and the list must flag it as pending (§ 1.25F-5T(d)(5)). Brand-new organizations can send proposed policies and procedures instead of a track record, Revenue's page says, which matches the transition rule that has a state judge a new organization on its documents (§ 1.25F-5T(d)(4)).

Ask about one box before you check it. One attestation says the organization “has registered with the IRS through the mandatory SGO registration process.” The IRS's FSTC page says SGOs will register and report through an “FSTC SGO Portal,” and as of October 30 that portal hasn't opened (the IRS's portal for states has). If you apply before it opens, email EFTC@iowa.gov and ask how to answer that line. The audit attestation follows the proposed federal rule: an organization with more than $500,000 in annual receipts uses an independent outside auditor, and one at $500,000 or less may use a committee of independent persons (proposed § 1.25F-4(e)(2)).

Iowa's tuition organizations. Iowa already runs a state credit through School Tuition Organizations: donors get a state credit worth 75 percent of the gift, within a $20 million yearly total, for tuition grants at accredited nonpublic schools. An STO can apply for the federal list too (the form has a box for it), but Iowa wants the two kept apart. Applicants attest that qualified contributions won't be commingled with state STO funds and that donor records will separate state-credit gifts from federal qualified contributions. If a single gift does earn both credits, Treasury's proposed ordering rule decides how much of the federal credit survives (how that rule works). Existing STOs formed the Iowa Scholarship Granting Organization in May for exactly this, and now it has a form and a date. On the public-school side, School Administrators of Iowa is converting a foundation into an SGO any district can use, and the governor's release says the scholarships can support students at public schools, public charter schools and nonpublic schools.

When donors can give. The release says the first contributions eligible for the credit can be made after Iowa submits its list to the IRS in early 2027. That fits Treasury's proposed rules, which let a donor rely on an organization's place on the IRS SGO list at the time of the gift; a gift made before the organization is listed doesn't get that protection. The credit is up to $1,700 per taxpayer, or $3,400 on a joint return when each spouse gives, under the proposed regulations, which taxpayers may rely on for 2027. Scholarships go to students whose household income is no more than 300 percent of area median gross income. The release, citing an American Federation for Children fact sheet, estimates that if 20 percent of Iowa taxpayers took part, the credit would generate $528.1 million in scholarships a year, enough to support about 519,553 eligible students.

Located in Iowa. Under Treasury's temporary regulations, which take effect without a comment period and apply from September 1, 2026, an organization is located in Iowa if it is authorized to do business there and complies with the state's charity laws, and the form's attestation uses that same federal definition. No Iowa office is required, and Iowa's list must include every organization located there that asks to be listed and meets the federal requirements. An organization incorporated elsewhere gets a certificate of authority from the Iowa Secretary of State ($25); Iowa registers professional fundraisers, not charities. Scholarships still follow the student: applicants attest they'll verify each student is eligible to enroll in an Iowa public school, so an Iowa-listed SGO's awards go to Iowa students (scholarships follow the student's state). Donors can live anywhere.

For organizations. Six weeks is enough time if your documents already exist and tight if they don't. Write the policies first: four of the eight uploads are written policies and procedures, and each one has to show how you'll meet a specific §25F requirement. Then file well before December 11. Our Iowa application guide has the steps and state fees, our free SGO builder walks through formation and the policies, and our Iowa page and Iowa SGO list page track the state's process. Every state's official list is in one place.