How states join
Explainer · December 12, 2025 · By CEN SGO
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- Where every state stands
Revenue Procedure 2026-6 set the only way a state can opt in for 2027.

Revenue Procedure 2026-6 is short and specific. For 2027, a state opts in by making an advance election on Form 15714, filed on or after January 1, 2026. No other method or altered form counts. (Source: Rev. Proc. 2026-6, §4.01)
Why states have to opt in
The credit is federal, but it only works in states that choose it. The law calls these covered states. A covered state is one that, for a calendar year, elects to take part and identifies the scholarship granting organizations in the state. A donation earns the credit only if the organization uses it for students in a state that has listed it. (Source: §25F(c)(1), (c)(3))
Two steps
Joining has two parts. First, the governor, or an official state law designates, makes the election. Second, the state sends Treasury its list of qualifying organizations, with a certification that the person sending it has the authority to do so. (Source: §25F(g))
The advance election lets a state tell organizations it's taking part before it submits that list. Treasury says the point is to give organizations more time to prepare for 2027. The state then completes the election by sending the list, under guidance Treasury will publish. (Source: Rev. Proc. 2026-6, §1, §2.03)
The list isn't optional. A state that makes the advance election but misses the list deadline won't meet the law, and no organization in that state will qualify for 2027. (Source: Rev. Proc. 2026-6, §3.02)
What goes on a state's list
Treasury's earlier notice described what it expects a state to certify about each organization. That it's a 501(c)(3) public charity. That it keeps federal-credit donations in a separate account. That it spends at least 90% of its income on scholarships, serves ten or more students who don't all attend one school, and checks each family's income. States would also tell the IRS promptly if they remove an organization. These are proposals, not final rules. (Source: Notice 2025-70, §3.03)
Organizations in more than one state
CEN SGO works in several states. Treasury has said it expects organizations like ours to ask each donor which state the donation is for, and to match those donations to scholarships in that state. We'll build that into how you donate. (Source: Notice 2025-70, §3.03(5))
One year at a time
A state's choice covers one calendar year. A state that stays out for 2027 can join later. A state that's in has to send a new list each year. (Source: §25F(c)(1), (g)(1))
What it means for families and schools
Scholarships can only reach students in a covered state. If you're a family or a school, your state's decision matters more than anything else on this page. Donors aren't limited the same way. They can donate from any state, as long as the organization uses the money in a state that has listed it. (Source: §25F(c)(3))
What happens next
From January 1, 2026, governors can file Form 15714. Comments on Notice 2025-70 close on December 26, 2025. Treasury has said more guidance is coming on how states submit their lists and certifications. (Source: Rev. Proc. 2026-6, §2.03)
What this means for you
Watch for your governor's filing, and then for your state's list. Once your state is in and has listed CEN, scholarships can reach families there from January 1, 2027.

