Formation is a project; compliance is a rhythm. The duties below are the recurring ones, and they split into ordinary nonprofit hygiene (settled law) and the §25F-specific obligations in Treasury’s October 2026 regulations. Some of those are temporary regulations, binding rules that apply from September 1, 2026 (donor acknowledgments by January 31 and IRS reporting by February 28); others are proposed and may still change (the annual certification filed with your Form 990, and the annual audit). The companion piece with the cadence table is our SGO compliance calendar.

Some of these rules are proposed, not final. Treasury released the §25F regulations on October 1, 2026, in two parts. The temporary regulations are binding rules, not proposals, and apply from September 1, 2026: registering in the IRS SGO portal, donor acknowledgments and IRS reporting, and how states build their SGO lists. Most of the rest, including the 85% safe harbor, the details of the 90% test, income verification, payment rules, disqualified persons, and the annual certification and audit, comes from the proposed regulations. Taxpayers, SGOs, and states may rely on those for 2027 contributions if they follow them in full, but comments are open until December 1, 2026 (hearing December 15) and the final rules could change them. Items tagged Proposed rule rest on that part; we re-verify each one when the final regulations publish, and our news feed tracks every change.

The duties

  1. The once-a-year machine: the right Form 990 by the 15th day of the 5th month after fiscal year end (three missed years = automatic revocation), with the §25F annual certification and report attached under Treasury's proposed regulations and a copy to each state that lists you; the annual financial and programmatic audit, with results to each listing state (receipts over $500,000: an independent outside professional; $500,000 or less: may instead use a committee of independent people unrelated to management, report signed under penalties of perjury); corporate + solicitation renewals; and re-qualifying for each state's list.

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    The audit and certification rules

  2. The continuous duties: track the 90% test as a live number (90% of each year's income must be paid out by the end of the next tax year, and multistate SGOs track each state account separately); keep your disqualified-person list current (substantial-contributor status is tested at each year end); deposit every designated gift in the segregated account and record it with the donor's number for the step 3 acknowledgments; never double-promise credit and deduction (the credited amount cannot also be deducted); and keep records while honoring public disclosure of your 990s and exemption application.

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    90/10 calculator

  3. Treasury's temporary regulations (binding rules that apply from September 1, 2026): by January 31, send every donor who designated a gift the previous year a written acknowledgment with your EIN, their total designated amount, their unique donor number, and whether you gave any goods or services (if so, a description and good-faith value); email works if the donor consents. Then, by February 28, report each donor number's name, address, and annual total to the IRS through the SGO portal. You never collect donors' Social Security numbers. The first deadlines are January 31 and February 28, 2028, for 2027 gifts.

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    Form 8525 and donor numbers

The §25F calendar

  • As soon as the IRS opens it: register in the IRS SGO portal, preferably before you appear on any state list (temporary regulations; the portal is not open yet).
  • January 31 each year: written acknowledgment to every donor who designated a gift the year before: your EIN, their total, their unique donor number, and any goods or services provided (temporary regulations). The first one is due January 31, 2028, for 2027 gifts.
  • February 28 each year: each donor number’s name, address, and annual total reported to the IRS through the SGO portal (temporary regulations). First due February 28, 2028.
  • With your Form 990: the annual §25F certification and scholarship report, with a copy to each state that lists you (proposed regulations).
  • Every year: the financial and programmatic audit, results to each listing state; receipts over $500,000 require an independent outside professional (proposed regulations).
  • By the end of the following tax year: 90% of each year’s income paid out on scholarships (proposed regulations).

The primary text is on our temporary regulations and proposed regulations pages.

Coming with builder accounts: tell us your fiscal year end and your states, and we compute your organization’s personal deadline calendar and keep it current as the rules finalize. Free, like the rest of the builder.