How to become an SGO in Oklahoma

1.Be a 501(c)(3) public charity

The IRS has to recognize you as a 501(c)(3), and you can't be a private foundation. Oklahoma accepts nonprofits whose Form 1023 is still pending. Under Treasury's temporary regulations, a state can list a nonprofit whose Form 1023 is still pending only if the exemption, once granted, takes effect by January 1 of the list year. For 2027, that means the nonprofit has to be incorporated by December 31, 2026. (An exemption reaches back to the date you incorporated if you file Form 1023 within 27 months.)

2.Register in Oklahoma

Treasury's rules count you as "located in" Oklahoma if you're authorized to do business there and follow its charity laws. You don't need an office or staff there. If you're incorporated in another state, you register with the Oklahoma Secretary of State ($300) and for charitable solicitation with the same office ($15). You'll also need a registered agent with a Oklahoma address.

3.Open a separate bank account for Oklahoma

Gifts for the credit go into an account that holds nothing else. If you're on more than one state's list, you keep one account per state and donors pick the state.

4.Put the §25F rules in your bylaws and policies

A new nonprofit has no track record, so the state reads its documents, and a promise to "follow the law" isn't enough. They have to require each rule: at least 90% of your income goes to scholarships, scholarships go to at least 10 students who aren't all at the same school, you verify household income, past recipients come first and then their siblings, no donor can earmark a gift for a particular student, and no scholarships go to insiders.

5.Register in the IRS SGO portal when it opens

Treasury asks every SGO to register in the IRS portal, ideally before a state lists it. The portal gives you the donor-number format your receipts use. It hasn't opened yet.

6.Apply to Oklahoma by December 15, 2026

Complete Form 80002 (Revised 10-2026) and check the box for the federal list only, or for both the federal list and Oklahoma's own SGO program. For the federal list, attach the eight documents in Section F: your 501(c)(3) determination letter or proof you've applied, your Oklahoma Secretary of State registration, your written scholarship criteria (10+ students not all at one school, qualifying expenses, the household-income test), payment procedures, recordkeeping procedures that prevent commingling, written procedures for the 90% spending test, the continuity procedure in item 7, and copies of what you give the IRS. Section F also asks you to check whether you are a single-state or multi-state SGO. An officer signs the paper form, and you mail the original package to the Oklahoma Tax Commission, Oklahoma City, OK 73194, by December 15, 2026. The application is annual: in later years you re-file the form, confirm the documents on file are still accurate, and add new ones only if needed.

7.After you're listed

Send each donor a written acknowledgment by January 31 and report the gifts to the IRS by February 28. Under Treasury's proposed regulations, which you can rely on for 2027, you also file a yearly certification and report (with a copy to every state that lists you), get a yearly audit, and spend at least 90% of each year's income on scholarships by the end of the next year.