Analysis and guidance on Section 25F
In-depth posts on regulatory developments, formation strategy, state news, and operational guidance for organizations building and running scholarship programs.
Why Most SGOs Get Scholarship Disbursement Wrong — And What a Compliant System Actually Looks Like
Approving a scholarship is the easy part. Getting the funds to families in a way that creates an airtight compliance record is where most SGOs accumulate serious liability. The default approach — bank transfer plus receipt collection — breaks at scale. Here is what compliant disbursement actually requires, and why the answer is not a single payment method.
Faith Communities and Section 25F: The Compliance Tensions Unique to Religious Organizations
Faith communities are among the most active SGO organizers — and the ones who face the most distinctive compliance challenges. The earmarking tension, single-school concentration, and governance independence questions all hit harder in a congregation context than anywhere else in the program.
How to Form a Scholarship Granting Organization: A Step-by-Step Guide
Forming a Section 25F SGO requires clearing several sequential hurdles — legal structure, IRS recognition, state approval, and operational setup. Here is what each step actually involves and how long it takes.
The SGO Compliance Calendar: What Your Organization Must Do Every Month and Year
Compliance for a Section 25F SGO is not a once-a-year filing exercise. It is an ongoing operational discipline. Here is what your organization needs to do monthly, quarterly, and annually to stay compliant and keep your approved status.
The Section 25F Tax Credit: A Complete Guide for Donors
The Section 25F scholarship tax credit is a dollar-for-dollar reduction in your federal income tax bill — not a deduction. Here is exactly how it works, what you need to claim it, and what the $1,700 limit means in practice.
SGO Scholarship Eligibility: How the 300% AMI Requirement Works in Practice
Section 25F scholarships are restricted to students from households earning at or below 300% of area median gross income. The rule sounds simple. Applying it correctly requires understanding what AMI means, how it varies by location, and what documentation your SGO needs to collect.
Section 25F Proposed Rules: What SGOs Need to Know Before Finalizing Their Structures
The IRS has signaled its intent to issue proposed regulations under Section 25F. Here is what the current statutory text requires, where the regulatory gaps are, and what SGOs should be doing now rather than waiting.
What Can Section 25F SGO Scholarships Pay For? A Guide to Qualified Expenses
Section 25F scholarships can only be used for qualified educational expenses as defined by the Coverdell Education Savings Account rules. The list is broader than tuition — but it has real limits. Here is what qualifies, what does not, and where the gray areas are.
Form Your Own SGO or Partner With an Existing One? A Framework for the Decision
The decision to form a new SGO versus partner with an existing one is strategic, not just operational. Here is the framework we use with organizations that are evaluating their options.
SGOs, ESAs, and Vouchers: Understanding the Three Models of School Choice
Section 25F SGOs are one of three major structures used to fund private K-12 education with public dollars or tax benefits. Understanding how SGOs compare to Education Savings Accounts and traditional vouchers clarifies when each model makes sense and what makes Section 25F distinctive.
How to Run a Compliant Scholarship Award Process Under Section 25F
The no-earmarking rule and the arm's-length award requirement are the most operationally demanding compliance requirements in Section 25F. Here is what a compliant award process actually looks like.
State SGO Opt-In Status: What We Know As of Spring 2026
Which states have enacted qualifying Section 25F opt-in legislation, which are actively considering it, and what organizations in non-opted states should be doing right now.
The 90/10 Rule: How to Maintain Compliance From Your First Scholarship Cycle
Section 25F requires that SGOs spend at least 90% of their annual revenue on qualified scholarships. The rule sounds simple. The operational implications are not.
Know the moment your state moves.
Opt-in legislation is moving through statehouses right now. Tell us your state and we’ll send a short email when its status changes — plus formation deadlines and program guidance as January 1, 2027 approaches.
See the platform live. Then decide.
Tell us about your organization and we’ll set up a live demo — the real product, loaded with sample data — alongside a consultation on your formation path, state, and timeline.
What happens next
We review your submission and respond within one business day
Live platform demo — the actual product on sample data, typically 45–60 minutes
Diagnostic consultation on your formation path, state requirements, and timeline
You leave with a clear scope and recommendation — even if the answer is to partner rather than form