$26 billion a year: Treasury's forecast for §25F scholarships by 2030

The rules Treasury and the IRS released on October 1 come with a forecast. In the economic analysis attached to the proposed regulations, the agencies estimate that by 2030 "more than 11 million taxpayers will make qualified contributions totaling $26 billion" a year to scholarship granting organizations. Treasury's announcement put the headline as "nearly $26 billion in qualified contributions annually" funding "as many as 2.2 million scholarships each year." These are agency projections, not results. The credit opens January 1, 2027, and nothing has been given under it yet.

The full set of numbers. The analysis starts from the roster: "As of August 2026, 30 States have elected to participate." In those states Treasury and the IRS project 600 to 700 SGOs by 2030, more than 11 million donors, and $26 billion a year in qualified contributions. The analysis translates that into either 2 million full-time scholarships at $12,000 each or 5 million part-time scholarships at $4,500. The press release's "as many as 2.2 million" sits a little above the analysis's 2 million; $26 billion divided by $12,000 comes to about 2.2 million.

How Treasury built the forecast. The footnotes show the assumptions. The donor and dollar figures are "produced using a 10% take-up rate," based on the 2023 Panel Study of Income Dynamics and research finding that people give more when they get to direct where their tax dollars go. The $12,000 is "a rounded average of the cost to attend one year of private elementary or secondary school in the states which have opted in." And the 600 to 700 SGOs come from the average number of SGOs operating in states that already run tax-credit scholarship programs, applied to each state that opts in. That last assumption makes the SGO count a per-state number: it describes the 30 states that had elected as of August 2026, at roughly 20 to 23 organizations per state.

Why the forecast is in the rule at all. The White House Office of Information and Regulatory Affairs designated the proposed rules "economically significant," which requires a full cost-benefit analysis. Treasury's case for the benefits rests on outcomes: "Research shows that educational choice can lead to increases in college enrollment and test scores, particularly for students from economically disadvantaged backgrounds." Because each additional year of schooling returns roughly 10% in earnings, the analysis says scholarship recipients "are expected to experience a significant increase in lifetime earnings."

A conservative take-up assumption. Treasury's 11 million donors rest on 10% participation. The American Federation for Children counted 121.5 million federal filers with enough tax liability to claim the credit, so the forecast assumes most eligible taxpayers never use it. That makes take-up the number to watch, a point AEI's Rick Hess made in July when he argued that the biggest risk to the credit is whether people claim it. Every point of participation above Treasury's assumption means more scholarships than the forecast shows, and the same rules that produced it also make the credit easier to use: married couples can claim up to $3,400, and donors can give to an SGO in any participating state.

The roster can still grow. The forecast covers the 30 states on the IRS list. States still deciding have until January 1, 2027 to file an advance election for the first year, and each added state brings its own students and, under Treasury's method, its own share of SGOs. Where every state stands is on the states page.

For anyone building an SGO, the forecast is a sizing exercise: 600 to 700 organizations sharing $26 billion a year, with a donor pool that is national because donors can give across state lines. The full estimates and their footnotes are in the proposed regulations archive, and our plain-English read of the rules covers what changed. If you are forming an organization, the free SGO Builder walks through each step, and the SGO directory shows who is already operating.