Nebraska's SGO application opens November 16: the Department of Revenue takes filings through January 15

Nebraska has its dates. In an email bulletin on November 12, the Nebraska Department of Revenue told subscribers that scholarship granting organizations may apply for its 2027 list “beginning Monday, November 16, 2026, at 9:00 a.m. Central Time,” and that for 2027 only, applications “will be accepted on or before January 15, 2027.” The same day the department posted a one-page SGO Application Guide and filled in its Federal Scholarship Tax Credit page. Filing goes through the state's ShareFile system and nowhere else, and a Form 1023 still pending with the IRS is accepted. It's the step Nebraska organizations have waited on since Gov. Jim Pillen made Nebraska the first state to commit, by executive order in September 2025. Until now the department's page said only that forms would follow.

How you file. You send Form FSGO-A, the Nebraska Federal Scholarship Tax Credit SGO Application, and all your supporting documents together through ShareFile, the State of Nebraska's secure file sharing system. The department will post the ShareFile link and the form on its page when the window opens; until then the upload button is marked “coming on November 16, 2026.” Don't email or mail anything. The department “will not accept Form FSGO-A or supporting documentation via email or mail,” and the guide warns that filing any other way “may result in the delay or denial of the application.” An authorized representative of the organization signs the form; if someone else signs, a Power of Attorney (Form 33) goes in with it. Label every document with the organization's name and the document's title. Neither the page nor the guide mentions an application fee. If you check the page before Monday, it still says applications open at “(TIME) Central Time.” The bulletin gives the time as 9:00 a.m. The bulletin came through the department's email subscriptions, where its SGO list sits under Tax Credits and sends notice when new information is posted.

What goes in. The guide lists eight items, and one document can cover more than one. Besides the signed form, you send your IRS determination letter (or your Form 1023, below); your articles of incorporation filed with the Nebraska Secretary of State or, if you're incorporated elsewhere, the Secretary of State's approved Application for Certificate of Authority to Transact Business; a Certificate of Good Standing from the Nebraska Secretary of State; proof of an established §25F segregated account for Nebraska, such as a bank statement with the account number redacted; and your procedures for keeping qualified contributions from being commingled. The last two items are your written §25F policies (next paragraph) and, if you have them, your most recent certifications and financial and program audits, which the guide says generally applies to renewals. A new organization sends documentation showing prospective compliance instead, where the federal transition rules allow it. The account has to be established when you file, so open it first.

The policies. Item seven is the longest. Your procedures, policies or bylaws have to show how you'll meet §25F and Treasury's temporary regulations, and the documentation “must go beyond stating that the organization will comply in general with the applicable laws and regulations and specifically address how the organization will meet requirements.” The guide names five areas: financial recordkeeping, keeping federal contributions apart from other funds, and the 90% scholarship spending requirement; student eligibility, selection, prioritization, awards and verification; prohibited awards, disqualified persons, donor earmarking and conflicts of interest; your scholarship application materials and how you'll verify qualified expenses; and contribution tracking, donor acknowledgments, recordkeeping and IRS reporting. That follows Treasury's rule for organizations that haven't reported to the IRS yet: a state may rely on their documents only if they expressly require the SGO to meet §25F's operating rules, “beyond a general requirement to comply with applicable law” (§ 1.25F-5T(d)(4)). The guide also says “Newly established organizations may submit prospective policies and procedures where permitted under applicable federal requirements,” so a group that hasn't awarded a scholarship yet can still apply.

If your Form 1023 is pending. Nebraska takes you. Its page opens the list to 501(c)(3) organizations and to those “who have applied for tax-exempt status with the IRS,” and the guide asks for the determination letter or, “if determination is pending with the IRS, a copy of the IRS Form 1023” you filed. Private foundations can't apply. Treasury's temporary regulations, which take effect without a comment period and apply from September 1, 2026, let a state list pending organizations if it lists every pending applicant that asks and certifies that the exemption, if granted, reaches back to January 1 of the list year or earlier (§ 1.25F-5T(d)(5)). For 2027 that means a nonprofit incorporated by December 31, 2026. Nebraska now joins the states that take a pending Form 1023.

Register in Nebraska first. Nebraska asks that you be registered to do business in the state and in compliance with its nonprofit laws, “including provisions for transparency, accountability, and fraud prevention.” Those are the words Treasury uses to define where an SGO is located (§ 1.25F-1T(a)(10)). A Nebraska corporation already has its filed articles. An organization incorporated elsewhere needs two things from the Secretary of State before it can file with the Department of Revenue: an approved Application for Certificate of Authority, and then a Nebraska Certificate of Good Standing. The application costs $25 online plus a small processing charge, or $30 on paper, and wants a certificate of good standing from your home state no more than 60 days old. The state's nonprofit biennial report is due April 1 in odd-numbered years. There's no charity registration to add, since Nebraska stopped registering charitable solicitors in 1996. Two timing notes from the Secretary of State: its online filing page says review is taking about a week, and online filing moves to a new system on December 7, 2026 that needs a login at business.nebraska.gov. Our Nebraska apply page has each step and fee.

Why sooner beats January 15. The department processes completed applications in the order received and asks you to allow at least four weeks for its review. It may also ask for clarification or more documents “reasonably necessary to verify federal eligibility or to prevent fraud and abuse,” and the guide adds that such requests “will not impose additional substantive eligibility requirements beyond those authorized by applicable law.” Count it out: four weeks from January 15 is February 12, three days before the federal deadline for state lists, with no room for a follow-up question. The department encourages SGOs to apply as early as possible and says it “may not be able to consider applications received after January 15, 2027, for the 2027 certification list.” A complete package in November or December is the safe plan.

After 2027, the cutoff is November 30. The January 15 date is for the 2027 list only. For later years, the page says applications are due by November 30 of the year before, because “IRS rules do not permit the DOR to add SGOs after January 1 for lists submitted for calendar years after 2027.” An organization that wants to be on Nebraska's 2028 list applies by November 30, 2027.

The calendar. The window opens at 9:00 a.m. Central on November 16 and closes January 15, 2027. That's one of the later state cutoffs: Colorado's is November 30, Iowa's December 11 and Oklahoma's December 15, while Nevada's also runs to January 15. The department hasn't said when it will send Nebraska's list to the IRS. February 15, 2027 is the federal deadline for 2027 lists, and after it a state can't add organizations for that year (§ 1.25F-5T(d)(7)(ii)). The department will tell each applicant whether it's approved or denied, and its page already has a heading for Nebraska's certified SGO list, with no names under it yet. Questions go to Julie Schuur (402-471-1445, julie.schuur@nebraska.gov) or Kyle Doyen (402-595-1929, kyle.doyen@nebraska.gov) in the department's Policy Section. Nebraska's dates now sit with every other state's, and the Nebraska SGO page and Nebraska state page track what happens next.