Ohio Already Runs an SGO Regime: How Its Attorney General Certification Coordinates With the New Federal $1,700 Credit

Ohio enters the federal §25F era with something most states lack: a Scholarship Granting Organization regime that has been running since 2021. Under Ohio Revised Code 5747.73, the state offers a dollar-for-dollar nonrefundable income-tax credit for cash donations to certified SGOs, worth up to $750 for a single taxpayer and up to $1,500 for a married couple filing jointly. What makes Ohio distinctive is not that it has a tax-credit-scholarship program (many states do) but where the certification authority sits: the Ohio Attorney General's Office, through its Charitable Law Section, certifies SGOs and publishes the official certified-organization list at charitable.ohioago.gov. That is an unusual home for a school-choice function, which in most states lives with the department of revenue or education. The new federal Education Freedom Tax Credit, a one-for-one credit of up to $1,700 per taxpayer for cash SGO contributions, arrives on top of this existing structure when it launches January 1, 2027.

The word to watch is “coordinates,” not “stacks.” The federal §25F credit does not simply layer on top of Ohio's $750/$1,500 credit so that a donor pockets both in full on the same gift. Under the federal rules, if a taxpayer claims a state credit on a qualifying SGO contribution, the §25F credit is reduced dollar-for-dollar by the amount of that state credit, and the same dollars cannot also be taken as a §170 charitable deduction. In practice, an Ohio donor who claims the full $1,500 state credit on a contribution would see the available federal credit on that gift reduced accordingly. Donors who want to maximize the federal $1,700 may need to structure separate contributions, or weigh which credit delivers more value given that the Ohio credit is nonrefundable and capped well below the federal figure. We walk through the federal cap itself, and why it is $1,700 rather than $3,400, in our explainer on what the §25F statute already settles.

There is also a divergence in who and what qualifies. The federal program requires a state to opt in by filing an advance election on IRS Form 15714 under Rev. Proc. 2026-6, the executive route the IRS laid out when it published Form 15714 in December 2025. Federal §25F also limits scholarships to students whose family income is below 300% of area median income, an eligibility test that Ohio's own statute does not impose in the same terms. So an organization certified by the Ohio Attorney General as an SGO under ORC 5747.73 is not automatically a qualified SGO for federal §25F purposes, and a scholarship that satisfies Ohio's program may not satisfy the federal income ceiling. Operators will be running two overlapping but non-identical rulebooks, and the certification page that confirms Ohio's federal participation is the same Attorney General resource that lists state-certified SGOs. Ohio's status and the broader national picture are tracked on our Ohio state page and the national participation map.

For SGO operators, the takeaway is that Ohio is fertile ground but procedurally dense. The certification function belongs to the Ohio Attorney General's Office as an institution, which persists regardless of who holds the office, so organizations should not pin their planning to any individual office-holder. The practical work is compliance: tracking which donors claim the state credit versus the federal credit, verifying the federal 300%-of-area-median-income eligibility, and keeping the §170 interaction straight so donors are not double-counting the same dollars. None of that has to be built by hand. There is software designed specifically for the §25F workflow, including the donor-credit coordination and eligibility verification that Ohio's dual regime makes especially fiddly, and existing organizations are listed in the SGO directory. How the credit works, who can found an SGO, and what certification entails are covered in our explainers.

Looking ahead, Ohio is a useful preview of a question every opt-in state will face: how a pre-existing state scholarship credit coordinates with the federal one. The mechanics that reduce the federal credit when a state credit is claimed will shape donor behavior in every state that already runs its own program, not just in states fighting over whether to participate at all. Ohio's experience, layering a 2021 state statute under a 2027 federal credit administered through an Attorney General's charitable division, will be watched by operators and donors well beyond its borders as the first full year of §25F donations approaches.