South Carolina opens its §25F SGO applications: McMaster's order sends them to the Department of Revenue

South Carolina is taking applications. On October 13, 2026, Gov. Henry McMaster signed Executive Order 2026-23, which directs the South Carolina Department of Revenue (SCDOR) to create and receive the application a nonprofit must submit to be considered a scholarship granting organization (SGO) under the federal Education Freedom Tax Credit, IRC §25F, for the 2027 tax year. “Scholarship granting organizations interested in participating may apply by emailing SGOapplication@dor.sc.gov,” the governor's office said in its release. That makes South Carolina the sixth state to start taking organizations for its 2027 list, after Kentucky, Alaska, Montana, Idaho and, one day earlier, Wyoming.

What the order does. Section 1 has three parts. The Department of Revenue is “an appropriate agency to assist” the governor “by creating and receiving an application that an entity must submit to be considered a scholarship granting organization.” The department “shall compile a list of organizations who have submitted complete applications.” And it must give the Office of the Governor that list of complete applicants by February 1, 2027. The order also explains why the governor's office stays at the center. §25F lets a state's governor, or whoever state law designates, make the election and send the SGO list, and the order finds that “no individual, agency, or entity other than the undersigned has been designated under South Carolina law” to do either. So SCDOR runs intake, and the governor's office files South Carolina's list with the IRS. The order doesn't publish a form, a document checklist or a review standard. It does authorize the governor's office to issue further guidance without another order.

The election date, settled. The order puts the state's own date on its opt-in: McMaster submitted Form 15714, South Carolina's advance election, to the IRS on January 13, 2026. When we first reported South Carolina's decision, the public record was a spokesman's confirmation in the Post and Courier on January 28. We've updated our South Carolina page to the filing date. South Carolina has been on the IRS's list of participating states since its first edition on June 8, 2026.

The calendar that matters. February 1, 2027 is when the department's list reaches the governor's office. The federal deadline comes two weeks later. Under Treasury's temporary regulations, which take effect without a comment period and apply from September 1, 2026, states have until February 15, 2027 to send their 2027 SGO lists to the IRS (the full calendar). After that deadline a state can't add organizations to its list for the year; any addition waits for the next year's list (§ 1.25F-5T(d)(7)(ii)). SCDOR hasn't posted an application deadline of its own. The order counts only complete applications, so if you want to serve South Carolina families in 2027, get a complete one to the department well before February 1.

What South Carolina has to certify. The order is short, but the federal rules spell out what the state vouches for when it files. For every organization on its list, the state certifies that the organization is located in South Carolina, keeps a segregated §25F account holding only qualified contributions and their earnings, and meets §25F's operating requirements, and it decides whether each one is a single-state or multistate SGO (§ 1.25F-5T(d)(3)). The list must include every organization located in South Carolina that asks to be on it and qualifies, and a state may not make SGOs operate more restrictively than §25F (one national standard). Being located in South Carolina means being authorized to do business there and complying with its charity laws. No in-state headquarters is required. A new organization that hasn't reported to the IRS yet can be listed on its governing documents, bylaws and written policies (§ 1.25F-5T(d)(4)), so write the 90 percent spending 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 email the department.

A second track. The order doesn't mention it, but South Carolina is also studying how the federal credit fits with its own programs. The 2026-27 budget (proviso 1.127) has the state Department of Education convene a seven-member study committee, chaired by a governor's appointee, to recommend how the federal credit should line up with the Educational Credit for Exceptional Needs Children and the Education Scholarship Trust Fund. Its recommendations are due by December 1, 2026, or 60 days after federal guidance is published, whichever is later. That committee only advises. The executive order is the route onto South Carolina's 2027 list.

For organizations and donors. A South Carolina-listed SGO funds scholarships for students who live in South Carolina, and under the proposed regulations donors in any state can give to it and claim up to $1,700 per taxpayer, or $3,400 on a joint return when each spouse gives. Get your 501(c)(3) letter, your authorization to do business in South Carolina, a segregated §25F account and §25F-compliant written policies in place, then email SGOapplication@dor.sc.gov. Our free SGO builder walks through each step, our South Carolina page and South Carolina SGO list page track the state's process, and every state's official list is in one place.