Exactly what to do
- Everything stage 5 has you keep, the annual audit, the annual §25F certification and report, the live 90/10 number, award and verification records, is what re-listing will ask for. Once you’ve filed your first certification and audit, your state reviews those (and must investigate any that are missing) rather than relying on your documents alone. Know your state’s cycle: under the temporary regulations each year’s list goes to the IRS between October 1 and January 1 (2027 only: by February 15, 2027), and we alert account holders when your state’s re-listing window opens.
Questions people actually ask
What if our state doesn't re-elect next year, or drops us from the list?
The organization survives; the credit pauses. Donors who gave while you were on the IRS SGO list can generally rely on that listing (unless they knew you didn’t qualify or had a hand in the problem), but new gifts stop generating the federal credit the year your state (or your listing) lapses, so tell donors promptly and plainly: their gifts remain deductible charitable contributions, the credit is what's paused. A state can remove you only through a procedure that gives you due process, and an IRS removal for noncompliance can be appealed to the IRS Independent Office of Appeals. Operationally you keep running as a scholarship charity, keep the compliance records current (they're your re-application), and pursue listing in another participating state where you’re located, remembering that its §25F scholarships can fund only its own residents. Never keep marketing the credit after a lapse; that's the fastest way to burn donor trust.
The final regulations changed a rule we already built on. Now what?
Today’s SGO rules are Treasury’s proposed regulations (October 2026): SGOs may rely on them for 2027 contributions, and they could change when finalized (comments are due December 1, 2026, with a hearing set for December 15). The documents amend the same way they were adopted: bylaws by your amendment vote (the template's two-thirds), the award policy by board vote recorded in minutes, articles by a certificate of amendment with the state if the regulations ever touch that layer (unlikely: our articles provision lets the regulations as amended control). We re-verify every proposed-rule item the week final regulations publish and email account holders exactly what changed; the fixes are typically an evening of board work, not a rebuild.
