The IRS roster reaches 30 states, and for the first time the official count matches our map

The federal roster has caught up. On July 27, 2026 the IRS updated its Federal Scholarship Tax Credit (FSTC / ECCA / §25F) page with a participating-states list current as of July 24, and Kentucky now appears on it. That brings the official count of completed advance elections to 30 states, up from the 29 the page showed after Kansas filed on July 7, and it lands five days after Secretary of State Michael Adams signed Kentucky’s election in Frankfort on July 22. The roster has now moved 27 to 28 to 29 to 30 in seven weeks.

The more useful fact for anyone tracking this program is what the update does to the arithmetic. All year there have been two accurate counts in circulation, and we have been careful to publish both: the IRS’s official list of completed federal filings, and our own participation map, which also counted states that were in by state law but whose executive branch had not yet filed the federal paperwork. Kentucky was the last state sitting in that gap, having joined in March when the legislature overrode Gov. Andy Beshear’s veto of House Bill 1. With its filing recorded, the two lists have converged: the IRS names 30 states, our map names 30 states, and the two sets are identical, state for state.

One state remains outside both counts and is worth naming precisely. New York has announced that it will participate, but no advance election has been filed, so it appears on neither the federal roster nor our opted-in tally; we track it as committed. If and when New York files, the count goes to 31. Every other movement from here has to come from a state that has not yet decided, which is why the governors still weighing the question are the group to watch between now and the January 1, 2027 launch.

It is also worth being clear about what a roster entry does and does not buy. A completed advance election means the state has told the IRS it is in for 2027; it does not mean the state has certified a single Scholarship Granting Organization. Every participating state still owes Treasury a list of qualifying SGOs, and no state has opened federal SGO certification, because the rules governing who qualifies arrive with the proposed §25F regulations Treasury expects to issue by the end of September. Kentucky is furthest along on the state side, having opened its own SGO declaration process on July 22, and North Carolina has named NCSEAA as its certifying office in statute. The rest of the roster is a list of states that have committed to a program whose plumbing is still being drawn.

For donors and families, the practical read is simple: in 30 states, a 2027 contribution to a qualifying SGO is on track to earn the dollar-for-dollar federal credit of up to $1,700, and the federal record now says so without a footnote. For operators, the roster is the map of where demand will be legal on day one, and the September regulations are the gun that starts the certification race. Check your state on the participation map, start with our guide to starting an SGO if you are building one, and see who is already organizing in the SGO directory.