Every SGO starts life as an ordinary nonprofit corporation. Nothing in this stage is §25F-specific except the forethought: under Treasury’s temporary regulations, a state listing a new SGO checks that its governing documents expressly require the SGO rules, so you write them in now rather than amending later. The sequence below is fixed by how the IRS process works: the state creates the corporation, the corporation gets its EIN, and only then can it apply for exemption.
The steps
Nothing gets filed here; this is the shopping list. Four decisions the articles form will demand: your home state, an available organization name, a registered agent, and your initial board. Collect them once and every later step just uses them.
0/4 insideStep-by-step guide →Take your name, agent, and board from step 1 and file with your state's Secretary of State. The articles must limit your purposes to 501(c)(3) exempt purposes and dedicate assets to exempt purposes on dissolution; an express dissolution clause is the safe path even where state law can substitute.
0/3 insideStep-by-step guide →Apply online with the IRS after the state accepts your articles. Never pay a third party for an EIN.
0/1 insideStep-by-step guide →For an SGO these are not boilerplate. Under Treasury's temporary regulations (binding rules that apply from September 1, 2026), until a new SGO files its first annual certification, a state can list it only after determining that its governing documents, policies, and procedures EXPRESSLY require each §25F operating rule; a general promise to follow the law does not count. So the operating rules from the next stage belong in these documents from day one.
0/2 insideStep-by-step guide →Elect officers, adopt the bylaws and conflict-of-interest policy, authorize the bank account and the exemption application. Keep minutes; your 1023 and later state vetting both lean on them.
0/3 insideStep-by-step guide →File within 27 months of formation and exemption is generally retroactive to your formation date. 1023-EZ ($275) is available only if you pass the IRS Eligibility Worksheet, including projected gross receipts of $50,000 or less in each of the next 3 years and total assets of $250,000 or less; otherwise the full Form 1023 ($600). An SGO expecting real §25F volume in 2027 should think hard before assuming it stays under $50,000. Aiming at a 2027 state list? Under the temporary regulations a state may list an organization whose application is still pending only if its exemption, once granted, takes effect on or before January 1, 2027, so be incorporated by that date.
0/3 insideStep-by-step guide →Form 1023-EZ instructions + Eligibility Worksheet ↗The 2027 calendar
Three errands with everything above in hand: open the operating account plus a segregated §25F account (the statute requires qualified contributions in separate accounts; under Treasury's proposed regulations every gift a donor designates for the credit goes into it, nothing else but its earnings does, and an SGO on more than one state's list keeps one per state), claim whatever state tax exemptions your state doesn't grant automatically, and put your email on your own .org domain.
0/4 insideStep-by-step guide →
What this costs
State incorporation fees vary (commonly $30 to $125), the EIN is free, and the IRS user fee is $275 for Form 1023-EZ or $600 for the full Form 1023. Our startup-cost estimator puts the whole picture together, and the deeper narrative walkthrough lives in how to start an SGO.
