Internal Revenue Service · 2026-02 I.R.B. · released December 12, 2025
Rev. Proc. 2026-6, Advance Election to Participate Under §25F for 2027
Update, October 1, 2026: Treasury’s temporary regulations (T.D. 10057) now govern the 2027 election. For calendar year 2027 only, a state must file its advance election on Form 15714 on or before January 1, 2027 (§ 1.25F-5T(c)(3)(i)(B)(1)) and perfect it by submitting its SGO list on or before February 15, 2027 (§ 1.25F-5T(c)(3)(ii)(B)). A state in its first year cannot elect just by sending a list (§ 1.25F-5T(c)(4)), and a state that does not perfect its election has no qualifying SGOs for 2027 (§ 1.25F-5T(c)(3)(ii)(C)). The temporary regulations take effect without a comment period and apply from September 1, 2026. The summary below describes Rev. Proc. 2026-6 as issued in December 2025.
(purpose)Purpose
Revenue Procedure 2026-6 sets forth the exclusive procedure for a State to make an “Advance Election” to participate in the §25F Federal Scholarship Tax Credit (FSTC) for calendar year 2027. A State that makes the election signals, ahead of submitting its full list of Scholarship Granting Organizations (SGOs), that it intends to be a “covered State” for the program’s first year.
“This revenue procedure provides the exclusive procedures for a State to make an Advance Election to participate… for the 2027 calendar year.”
(covered-state)What a “covered State” is
Under §25F(g), a contribution generates the federal credit only if it goes to an SGO in a covered State, and only K-12 students in a covered State are eligible for the scholarships. A State becomes a covered State by both (1) electing to participate and (2) identifying its qualifying SGOs to the Treasury. The Advance Election addresses the first step.
(how)How a State makes the Advance Election
(1)Use Form 15714
The State must submit Form 15714, Advance Election to Participate Under Section 25F for 2027, in accordance with the form’s instructions.
(2)Filing window
The form may be filed on or after January 1, 2026 and before the final date on which the State is permitted to submit the list identifying its SGOs.
(3)No alternatives for 2027
No alternative method of making an Advance Election, and no alteration of Form 15714, will be accepted for calendar year 2027. Procedures for 2028 and later years will be addressed in future guidance.
Since addressed: under the temporary regulations, for years after 2027 a state may file an advance election through the IRS State section 25F portal from January 2 through September 30 of the prior year and perfect it with its SGO list from October 1 through January 1, or elect by submitting its list in that October 1 to January 1 window. A state making its first election in a later year follows future guidance (§ 1.25F-5T(c)(3) and (c)(4)).
(sgo-list)The SGO list still controls eligibility
The Advance Election does not, by itself, make an organization an SGO. A State must still submit its list identifying qualifying SGOs by the applicable deadline. (When this revenue procedure issued, a State could also elect by submitting its list. For 2027, the temporary regulations make the Form 15714 advance election the only route for a State in its first year.) If a State fails to submit that list on time, no organization in that State qualifies as an SGO under §25F for that calendar year, and donations to organizations in that State would not generate the credit.
Rev. Proc. 2026-6 governs only the advance-election mechanics. The broader substantive rules (donor substantiation, the 90% spending requirement for multi-state SGOs, and income verification) were the subject of Notice 2025-70 and are now addressed in the proposed regulations issued October 1, 2026, which are not final. The state election and SGO list procedures are in the companion temporary regulations (T.D. 10057).
