The §25F donor number: how the IRS matches your scholarship tax credit (no SSN to the SGO)

What the donor number is

The Education Freedom Tax Credit (EFTC / §25F) gives donors a dollar-for-dollar federal tax credit of up to $1,700 per taxpayer for cash gifts to a qualifying Scholarship Granting Organization (SGO), and under the proposed regulations a married couple filing jointly can claim up to $3,400 when each spouse makes and designates their own gift. A credit that valuable needs a way for the IRS to confirm that a claimed gift actually happened, to a real SGO, by a real taxpayer. The mechanism Treasury adopted for that is a unique donor number.

After a year in which you make a qualified contribution, the SGO sends you a written acknowledgment, due by January 31 of the following year, that includes a unique number. The SGO creates the number itself, following instructions the IRS gives every registered SGO through its IRS SGO portal so that all numbers share one uniform format. Because each SGO generates its own numbers, a donor who gives to two SGOs gets two different numbers. That number, together with the name and address the SGO reports, is the key the IRS uses to tie your credit to the SGO’s records. Your Social Security number never enters the exchange with the SGO.

Why it exists

Treasury explains its reasoning in the preamble to the proposed regulations, and it names two goals. The first is privacy. Commenters on Notice 2025-70 objected to collecting donors’ taxpayer identification numbers, and Treasury agreed that requiring donors to give SGOs their TINs “would be burdensome, could chill an individual’s desire to make contributions to an SGO, and might result in unnecessary exposure of sensitive taxpayer information.” The donor number removes the need: the SGO can report your gift to the IRS without ever holding your SSN.

The second is matching. Because the SGO reports each contribution to the IRS under the same number the donor reports on their return, the IRS can match claimed credits to real contributions and flag a credit that no SGO ever recorded. It is the same matching logic that makes the W-2 and 1099 systems work, applied to scholarship gifts. Treasury adds that the matched data helps states monitor whether the SGOs on their lists meet the operating requirements, including the requirement to spend 90% of income on scholarships.

How it flows, step by step

1. The SGO registers first. Before it can issue a single number, the organization registers in the IRS SGO portal with its name, EIN, address, phone number, year of formation, taxable year, and a contact person who can bind it (or holds a Form 2848 power of attorney). The IRS checks the submission and sends back the instructions for creating donor numbers in the uniform format.
2. You donate and designate. You make a cash contribution to an SGO on the IRS SGO list and tell the SGO, at the time you give, that it is a §25F qualified contribution. That designation cannot be undone. You do not give the SGO your Social Security number.
3. The SGO issues your number. By January 31 of the next year it sends a written acknowledgment showing its EIN, your total designated contributions for the year, whether you received any goods or services (with a description and a good-faith estimate of their value), and your unique donor number. It can come by email or other electronic delivery if you consent.
4. The SGO reports to the IRS under that number by February 28, through the IRS SGO portal, with your name, address, and annual total, so the government has the SGO’s side of the record.
5. You claim the credit by listing the same number on Form 8525, Federal Scholarship Tax Credit, attached to your federal return, one number for each SGO you gave to.
6. The IRS matches your return to the SGO’s report. The numbers line up, and the credit is substantiated, no SSN ever passed to the SGO.

What it means for donors

• Keep your acknowledgment. The donor number lives on it, and you will need it at tax time. Under the proposed regulations, a donor who leaves an SGO’s number off Form 8525 is presumed not to have made a qualified contribution to that SGO. You can rebut the presumption with the SGO’s timely acknowledgment showing the number, or other evidence the IRS accepts of how much you gave and that you designated it, within the response time the IRS sets in its written request.
• One number per SGO. Give to two SGOs and you get two acknowledgments and two numbers, and Form 8525 asks for each.
• Married? Two donors. A married couple filing jointly can claim up to $3,400 under the proposed regulations when each spouse makes and designates their own gift. In Treasury’s example, each spouse gives $2,000 and each receives their own acknowledgment.
• Check the list when you give. The proposed regulations let you rely on the SGO being on the IRS SGO list (and not shown as removed) at the time of your gift. An SGO has to authorize the IRS to publish its name there, so look for it before you give.
• You control your SSN. A legitimate SGO following the rules does not need your Social Security number to issue a §25F acknowledgment.
• The credit cap still applies. The number documents the gift, but the credit itself is capped at $1,700 per taxpayer, is reduced by any state credit you claim for the same gift (before the cap applies, under the proposed rules), and is non-refundable; see the federal tax credit explained.

What it means for SGO operators

For the organization, the donor number is not a convenience, it is a reporting obligation, and it sits in the temporary regulations, which are binding rules that apply from September 1, 2026. Any organization that plans to solicit qualified contributions must register in the IRS SGO portal “as soon as possible and preferably before” it appears on any state list, since registration is how you get the donor-number format. Treasury describes registration as a step completed before January 1, 2027, when donors can start giving; as of October 1, 2026 the portal is not open. The rule is blunt about the stakes: until you register, you “will not be able to comply with the acknowledgement and reporting requirements,” which are part of substantiating your donors’ credits.

Registration also carries a choice. You must authorize the IRS to disclose your name and identifying information if you want to appear on the IRS SGO list for the year, and that list is what donors are entitled to rely on, so an SGO that withholds authorization leaves its donors without that protection. After registering, you generate a number for every donor who designates at least one gift during the year, place it on each acknowledgment by January 31, report each donor’s name, address, and total to the IRS under it by February 28, and keep your books reconciled so every claimed credit ties back to a recorded gift in your §25F segregated account. Get it wrong and donors’ credits can be questioned, which is the fastest way to lose the donors you worked to win. A failure to report qualified contributions is also one of the grounds on which the IRS may remove an organization from the IRS SGO list, with a right to appeal to the IRS Independent Office of Appeals.

From preview to rule

Treasury first described the donor number in its June 10, 2026 preview, in general terms: SGOs “would” send donors a timely acknowledgment with a number generated under an IRS-provided method and report under it, and taxpayers “generally would” report the number on their returns. The preview also said portal functions might arrive in phases. On October 1, 2026 it became rule text, with specifics the preview did not have: mandatory portal registration before an SGO can issue numbers, a January 31 acknowledgment deadline and its required contents (EIN, designated total, number, goods-or-services statement), a February 28 IRS report through the portal, Form 8525 as the claiming form, and the presumption against a donor who leaves a number off. The SGO side, portal registration, acknowledgments, and IRS reporting, is in the temporary regulations (T.D. 10057), which apply on or after September 1, 2026 and expire October 1, 2029. The donor side, claiming on Form 8525 with each SGO’s number, is in the proposed regulations, which taxpayers may rely on for contributions made on or after January 1, 2027; comments are due December 1, 2026, and final rules could change that part. What is still to come is operational: the IRS has not released Form 8525 or said when the SGO portal opens, and the exact donor-number format arrives through the portal. Build your processes around the rule now and fill in the format when registration opens. Our news report on Form 8525 and the donor number covers the October release in more detail.

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