OMB approves the §25F paperwork: state SGO lists, SGO portal registration and donor reports are cleared

The paperwork side of §25F is cleared. On October 15, 2026, the Office of Information and Regulatory Affairs (OIRA), the part of the White House Office of Management and Budget that reviews federal paperwork, approved the information collections in Treasury's temporary regulations for the Education Freedom Tax Credit (the Federal Scholarship Tax Credit, FSTC, or §25F). The approval covers what a state or an SGO will send the IRS under those rules, all under one OMB control number, 1545-2335. The IRS submitted the request on October 2, the day the rules were published in the Federal Register, and asked for emergency review. OIRA cleared it in 13 days.

Why it matters. Under the Paperwork Reduction Act, the IRS can't require anyone to fill out a form or file a report until OMB approves it. The temporary regulations put it this way: “An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid control number.” When Treasury published those rules, each state and SGO requirement carried the same future-tense line: it “will be approved by OMB under control number 1545-2335 pursuant to the emergency procedures in 5 CFR 1320.13.” As of October 15, it is. That gives the IRS State §25F portal, where states register, elect and file their SGO lists, and the IRS SGO portal, where organizations register and report their donors, the paperwork approval they need. It doesn't switch them on. The IRS hasn't announced when either portal opens.

What's covered. OMB's notice lists ten collections. For states: Form 15714, the advance election (OMB had already cleared it on September 23 in a separate review); registration in the State §25F portal (§ 1.25F-5T(b)); the election itself (§ 1.25F-5T(c)(1)-(4)); compiling and submitting the SGO list (§ 1.25F-5T(d)(2) and (3)); the state's certifications, including its policies for deciding which organizations qualify (§ 1.25F-5T(c)(5) and (d)(6)); and reporting an SGO's removal from the list (§ 1.25F-5T(d)(7)(iii)). For SGOs: registration in the SGO portal (§ 1.25F-4T(b)); a one-time setup of an acknowledgment template and a process for generating unique donor numbers; the written acknowledgment each donor receives (both under § 1.25F-4T(c)(1)); and the annual report of each donor's information to the IRS (§ 1.25F-4T(c)(2)).

How long the IRS thinks it takes. The approved figures come from burden tables in the temporary regulations, and they make a decent planning guide. The IRS puts an SGO's portal registration at 1 hour 20 minutes, done once, and building the acknowledgment template and donor-number process at 2 hours, also once. It calls that a “one-time startup burden” because it expects SGOs already have procedures for sending donors acknowledgments. After that, the work scales with donors. Each written acknowledgment is estimated at 15 minutes, a blend of “less than 1 minute to send electronically” and up to 30 minutes for a paper one, and the IRS expects fewer than 1 percent to go out on paper. Each donor's entry in the annual report is estimated at 30 minutes. Acknowledgments are due to donors by January 31 and the report to the IRS by February 28, both covering the prior year's gifts (how the donor number works).

The numbers behind the estimate. The tables assume 650 SGOs, the midpoint of the 600 to 700 Treasury projects, and 11 million donors a year, or about 16,923 donors per organization. That adds up to 22,002,210 responses and 8,258,885 hours a year. Nearly all of it is the two per-donor items: 2.75 million hours of acknowledgments and 5.5 million hours of reporting, against 8,885 hours for everything else combined. For states, the IRS assumes about 13 SGOs each and 10 hours to review and certify each one, plus about three hours for registration, the election and the certifications. It expects only about 8 states to pull an organization off a list partway through a year.

A short approval, with a renewal ahead. The IRS asked for six months, and OMB set the expiration at April 30, 2027. That's before the first acknowledgments (January 31, 2028) and reports (February 28, 2028) for 2027 gifts come due, so the approval has to be renewed first, and the proposed regulations say it will be: these collections “will be renewed under the PRA procedures in 5 CFR 1320.10,” the regular route, which runs through Federal Register notices that invite public comment on the burden estimates. For SGOs that's a second chance to tell the IRS what the paperwork really takes, separate from the December 1 deadline for comments on the proposed rules (how to comment).

Not in this approval. Form 8525, the form donors will use to claim the credit, is cleared separately. Under the proposed regulations it will be approved with the Form 1040 collection, OMB control number 1545-0074. The form hasn't been released yet, and our Form 8525 page tracks it.

For organizations. There's nothing to file today, but the order of steps is set. Register in the SGO portal when the IRS opens it: Treasury asks organizations to register “as soon as possible and preferably before the organization appears on any State SGO list,” and registration is how you get the IRS's uniform format for donor numbers. Build your acknowledgment template around that format before your first 2027 gift, and keep records with one entry per donor from day one, since that's where nearly all the federal paperwork lands. Our donor number explainer and SGO compliance calendar cover the dates, the free SGO Builder walks through formation, and every state's official SGO list is tracked in one place.