Oklahoma opens its §25F SGO application: one Tax Commission form for the state and federal lists, due December 15

Oklahoma is taking applications. This week the Oklahoma Tax Commission (OTC) posted a Scholarship Granting Organizations page and a revised Form 80002 (“Revised 10-2026”) that lets a nonprofit apply for Oklahoma's own SGO tax credit program, for the state's list under the federal Education Freedom Tax Credit (IRC §25F), or for both on one application. The application “must be submitted by December 15th, 2026 with all required documentation in order to participate for tax year 2027,” the page says. That makes Oklahoma the seventh state to start taking organizations for its 2027 list, after Kentucky, Alaska, Montana, Idaho, Wyoming and South Carolina. It's the agency HB 3704 put in charge of registering SGOs and sending Oklahoma's list, and it built the federal list into the application its state program already uses.

Three ways in. Section D of the form has three boxes: Oklahoma SGO registration only, federal SGO registration only, or both. The two lists stay separate. “Federal IRC § 25F listing by itself does not make a contribution eligible for the Oklahoma credit,” the Commission's FAQ says, and Oklahoma registration “by itself does not make a contribution eligible for the federal credit.” An organization that only wants to be on the federal list doesn't have to join the state program. Section E covers the state program's own requirements under 68 O.S. § 2357.206, which apply to organizations that register for it.

What the federal list takes. Section F lists eight documents, all due with the application. You send the full set in your first year; after that you file the annual application, confirm the documentation on file is still accurate, and add anything new. The eight: your IRS determination letter as a 501(c)(3), or proof that you've applied (Treasury's temporary regulations, which take effect without a comment period and apply from September 1, 2026, let a state list an organization whose exemption is pending if, once granted, it's effective by January 1 of the list year, § 1.25F-5T(d)(5)); your incorporation and Oklahoma Secretary of State registration, showing you're authorized to do business in Oklahoma and comply with its charity laws, which is the federal “located in” test (no Oklahoma headquarters needed); a written description of your eligibility criteria and methodology, which must affirm that you fund 10 or more students who don't all attend the same school and spell out the qualifying expenses and your household-income test; your scholarship payment procedures; your recordkeeping procedures, including how you prevent commingling of funds; written procedures for the 90 percent spending test (the form phrases it as spending no more than 10 percent of annual revenue on anything other than scholarships; the federal test is that at least 90 percent of the organization's income goes to scholarships); a continuity procedure, discussed below; and “a copy of all information the SGO is required to provide to the IRS as part of the Federal SGO program.” You also check whether you're a single-state or multistate SGO.

One item to ask about. Item 7 asks for written procedures ensuring that once a student receives a scholarship, “they and any sibling remain eligible until they graduate high school or reach 21 years of age.” The same promise appears in Section E as a requirement of Oklahoma's own program. §25F asks for something narrower: a priority for students awarded a scholarship the previous school year and then for their siblings (§25F(d)(1)(D)), and Treasury's proposed regulations give an SGO flexibility in how it applies that priority (proposed § 1.25F-3(c)(8)). Every federal award must also go to a student whose household is within the income limit. Oklahoma wrote its participation law to stay at the federal floor: HB 3704 bars any state agency, the Commission included, from adopting rules that “exceed requirements of the applicable federal law,” and the temporary regulations bar a state from making SGOs operate more restrictively than §25F (§ 1.25F-5T(e)(2), one national standard). If you're applying for the federal list only, answer item 7 with your §25F priority policy, and if you want certainty, ask the Commission how it reads that item before you mail.

Paper, by mail. There's no online or email option. You complete the form, print it, have an officer sign it (certifying that every required document is attached), keep a copy, and mail the original with your documents to the Oklahoma Tax Commission, Oklahoma City, OK 73194. Section B asks for the Social Security number of the officer completing the form. The Commission's page notes that federal implementation requirements are still developing, so check it again before you send your package. Approved organizations will be listed on that page under three headings (Oklahoma program, federal program, both), and we'll carry them on our Oklahoma SGO list page.

The calendar. HB 3704 takes effect November 1, 2026. Applications are due December 15, 2026. Oklahoma's list is due to the IRS by February 15, 2027, the federal deadline for 2027 state lists (the full calendar), and after that the state can't add organizations for the year (§ 1.25F-5T(d)(7)(ii)). A new organization that hasn't reported to the IRS yet can be listed on its governing documents and written policies (§ 1.25F-5T(d)(4)), so write the 90 percent test, the 10-student rule, income verification, the priority for prior recipients and the bar on scholarships for disqualified persons into those documents in so many words before you mail them.

Why the both box matters to Oklahoma donors. Oklahoma's state credit is 50 percent of a gift to a registered Oklahoma SGO (75 percent with a written commitment to give the same amount the next year), up to $1,000 for a single filer and $2,000 on a joint return. The federal credit is reduced by a state credit claimed for the same qualified contributions, but under Treasury's proposed regulations, which taxpayers may rely on for 2027 contributions, that reduction comes off the gift before the $1,700 cap, not after (how the ordering works). So a single Oklahoman who gives $2,700 in cash to an SGO on both lists and designates it all for §25F gets a $1,000 state credit, and $2,700 minus $1,000 still fills the $1,700 federal cap: $2,700 in credits on a $2,700 gift. Oklahoma's statewide cap can scale the state credit down, joint filers work through different numbers, and both credits depend on having tax to offset (the federal one carries forward five years). Donors in any state can give to an Oklahoma-listed SGO for the federal credit; only Oklahoma taxpayers get the state one.

For organizations. Decide which list you want, get your 501(c)(3) letter (or pending application), your Oklahoma Secretary of State registration, a segregated §25F account and §25F-compliant written policies in place, and mail Form 80002 well before December 15. Our free SGO builder walks through each step, our Oklahoma page and Oklahoma SGO list page track the state's process, and every state's official list is in one place.