Six months to launch, and not one state has opened SGO certification. Here is why, and what to do with the wait.

There is a gap in the middle of the federal Education Freedom Tax Credit (FSTC / ECCA / §25F) that the roster counts hide. Twenty-eight states have completed the formal advance election and appear on the IRS's official list of participating states; our own participation map counts 30, because Kansas and Kentucky joined by overriding their governors' vetoes but their executive branches have not yet filed the formal Form 15714 with the IRS, and New York has announced it will participate without yet electing in (the roster catches up as each files). Either way the program goes live January 1, 2027. Yet as of early July 2026, with roughly six months on the clock, a donor in any of those states still cannot make a credited donation and a family still cannot receive a scholarship, for one concrete reason: no state has opened the process to certify a Scholarship Granting Organization (SGO). Not one. The election put states on the map; it did not switch the program on, because the machine that turns donations into scholarships, the certified-SGO list, does not exist yet anywhere.

The reason is a deliberate sequencing choice at Treasury, and it is worth stating plainly so operators stop refreshing state websites waiting for an application form that is not coming this summer. The only part of §25F the IRS has fully built out is the state advance election, the Form 15714 filing a governor or designated official uses to opt a state in. The rules that govern SGO certification itself, who qualifies, how a state builds and submits its list, the deadline mechanics for the first year, were expressly deferred to the proposed regulations Treasury previewed on June 10 and said it expects to issue no later than the end of September 2026. Until those land, states have nothing final to certify against, and they are saying so, in writing, on their own pages.

The state agencies are unusually candid about the hold. Alabama's Department of Revenue has already published the six criteria an organization must meet to be certified, 501(c)(3) status, scholarships to ten or more students at more than one school, at least 90% of income spent on scholarships, no earmarking for named students, Alabama students only, and ALDOR certification, then states directly that it is “awaiting additional guidance from the Treasury Department” before finalizing deadlines. Nebraska's §25F page says flatly that it will post SGO forms and procedures only “after the final federal guidance has been published.” Mississippi's governor said the state would designate eligible SGOs “in the coming months.” Tennessee has assigned its Department of Education to certify organizations and submit the list, but has not opened a window. The pattern is identical across every participating state we checked: authorized, staffed, and frozen, all waiting on the same September document.

That turns a vague “sometime before 2027” into a sharp and predictable calendar. If the proposed regulations publish at the end of September and carry reliance for the 2027 tax year, as Treasury signaled they will, then the real certification sprint is the fourth quarter of 2026: states open applications, organizations apply and get listed, and each state submits its roster to Treasury, all compressed into the weeks before the January 1 launch. The states that did their homework early, Alabama pre-publishing criteria, Nebraska standing up an information page, Tennessee naming its certifying agency, are the ones positioned to open fastest once the gun sounds. The states still deciding who even administers the list (West Virginia adjourned without designating an officer) will be slower. For an operator, the state you organize in may determine whether you are certified in October or scrambling in December.

The mistake would be to read “certification is closed” as “nothing to do yet.” The wait is the build window, and almost everything an SGO needs is within an operator's control right now, independent of the September rules. The 501(c)(3) determination, the segregated account that will carry the 90%-of-income test, the annual-audit relationship, and above all the donor pipeline can all be assembled now, and the donor side is the one that decides whether a new SGO survives, because acquiring donors can cost more than the 10% administrative cap allows, a squeeze we covered in our look at §25F marketing costs. An operator who spends the third quarter building an audience it does not have to buy, and picking software that keeps intake, income verification, receipting, and disbursement inside the cap, walks into the fourth-quarter certification window ready to file rather than starting from zero. Our guide to starting an SGO lays out exactly what can be done before the rules finalize.

So the honest status of the program at the halfway mark is this: the yes votes are in, the plumbing is not connected, and the connection date is now legible. The end-of-September proposed regulations are the event that starts the certification race in every opted-in state at once; the first state to actually open SGO applications after that will be a genuine first worth marking. Until then, the work is preparation, not paperwork. Operators can track which states have opted in on the national participation map, see the current field in the SGO directory, and use the runway rather than wait it out.