IRS opens the FSTC State Portal, where states file their §25F election and SGO list

The IRS has put the last piece of state-side plumbing for the Education Freedom Tax Credit (§25F) online. On October 22, 2026, it rebuilt its Federal Scholarship Tax Credit (FSTC) page around a new FSTC State Portal, the system a state uses to “make the election for your state to participate” and to “submit and manage your state's annual list of scholarship granting organizations (SGOs).” The portal page, dated October 22, carries a sign-in link for state officials. The same update moved the list of participating states to a page of its own, now dated “as of October 22, 2026.” It still names 30 states.

Who can sign in. Only a state's designated officials. Each one registers in IRS Business Tax Account: sign in with ID.me, choose the Designated Official role, enter the state's information and request a PIN. The IRS mails the PIN in 5 to 10 days, and the account works once it's entered. Before starting, an official needs an ID.me account, the state's FSTC State Portal employer identification number (EIN), and “a document that shows your authority to act on behalf of the state (delegation order on official letterhead, for example).” For a government entity, a designated official has to be an elected official, the Director of Taxation or an appointed official. Those are the same three categories in Treasury's temporary regulations, which let the governor, or whoever state law designates, authorize up to two (§ 1.25F-5T(b)(2)). Officials revalidate every year, in a six-week window that opens June 15.

The EIN comes from Form 15714. A state gets its portal EIN by filing Form 15714, the advance election for 2027, and the IRS sends the number to the point of contact named on the form. The page tells states not to use any other EIN, “even if it's affiliated with the state,” and tells any state that hasn't filed the form to “submit it as soon as possible.” That line matters most for New York. Gov. Kathy Hochul announced on October 9 that New York will take part in 2027, and it isn't on the October 22 list yet. Its Form 15714 is due by January 1, 2027.

One date to read closely. The portal page says every participating state must submit its SGO list by January 1 each year, and that for 2027 “States must submit their list of qualifying SGOs by January 1, 2027. This includes participating states that made advance elections.” Treasury's temporary regulations, which apply from September 1, 2026, give the first year more room: “For calendar year 2027 only, a State may provide its State SGO list on or before February 15, 2027” (§ 1.25F-5T(c)(3)(ii)(B)). The page doesn't mention that grace period. A state that files by January 1 is on time either way, and the states that have published a timeline are aiming there or sooner: Alaska by December 1, Colorado and Kentucky by January 1. For an organization, the date that counts comes earlier still: your state's own application cutoff.

What the IRS now tells SGOs and donors. The rebuilt main page has a section for each. To qualify, an SGO must be a 501(c)(3) public charity (“private foundations are not eligible”), meet the requirements for awarding scholarships, managing contributions and verifying student eligibility, ask to be included on a participating state's list, and give the state what it needs to establish eligibility. The IRS says it “will assist states” in checking the public-charity requirement. Once qualified, SGOs owe financial, recordkeeping, donor-acknowledgment and reporting work, “including registering and reporting through the FSTC SGO Portal.” That portal has no page or sign-in yet. For donors, the page lays out two steps: tell the SGO “your payment is a qualified Section 25F contribution,” then file Form 8525 listing the SGO and your donor number. It now says married couples filing jointly “may each be able to claim a $1,700 credit, for a total credit of $3,400 on the joint return,” matching the proposed rule. Form 8525 itself hasn't been released.

For organizations. Nothing changes on your side today, but the route your state will use to list you now exists. Apply to your state by its cutoff (every participating state's application, deadline and checklist), and watch for the SGO portal: the temporary regulations ask organizations to register “as soon as possible and preferably before” they appear on any state list, and registration is how you get the IRS's uniform format for donor numbers. Our guide to how a state opts in covers the state side, the donor number explainer covers acknowledgments, every state's official SGO list is tracked in one place, and the free SGO Builder walks through formation.