The 2027 calendar: January 1, February 15 and the dates after

Treasury's rules of October 1, 2026 turned this fall into dates. Here's the calendar, from the comment deadline this year to the first filing season in 2028. (Source: Prop. Reg.; T.D. 10057)

2026

December 1, 2026. Comments on the proposed regulations are due, 60 days after they appear in the Federal Register on October 2. Requests to speak at the hearing are due the same day. Comments go to regulations.gov, docket REG-117199-25. (Source: Prop. Reg., preamble)

December 15, 2026. Public hearing at the IRS building in Washington, 10 a.m. Eastern. Requests to attend are due by 5 p.m. on December 10. If no one asks to speak, the hearing is cancelled. (Source: Prop. Reg., preamble)

Before the year ends. Organizations that want to be on a state's 2027 list register in the IRS SGO portal as soon as it opens, and in any case before they appear on a list. A new organization needs to exist by January 1, 2027. A state can list one whose 501(c)(3) application is still pending, but only if its exemption will date back to January 1 or earlier. (Source: Prop. Reg. §1.25F-4(b); T.D. 10057, §1.25F-5T)

2027

January 1, 2027. The first day a donation earns the federal credit. Also the last day for a state to file its advance election on Form 15714 for 2027. Thirty states have already filed. (Source: P.L. 119-21 §70411(c); T.D. 10057, §1.25F-5T)

February 15, 2027. The deadline for a state that filed its advance election to send the IRS its list of scholarship granting organizations. A state that filed the election but misses this date has no qualifying organizations for 2027. After this date no organization can be added to a 2027 list. (Source: T.D. 10057, §1.25F-5T)

Through 2027. Organizations award scholarships and pay schools. Each must spend at least 90% of its income on scholarships, and each year's money has to be spent by the end of the following year. (Source: Prop. Reg. §1.25F-3(c)(4))

December 31, 2027. The last day to donate for the 2027 return. There's no lookback into the new year. (Source: §25F(a))

2028

January 31, 2028. Every organization sends each donor a written acknowledgment for 2027: the organization's EIN, the donor's total designated donations, the donor's unique donor number, and any goods or services received. (Source: Prop. Reg. §1.25F-4(c))

February 28, 2028. Every organization reports each donor's name, address, total and donor number to the IRS through the portal. (Source: Prop. Reg. §1.25F-4(c))

Filing season 2028. Donors claim the credit on Form 8525 with their 2027 return, listing each organization's donor number. The form itself hasn't been published yet. Organizations attach their annual certification to their Form 990. (Source: Prop. Reg. §1.25F-2(g), §1.25F-4(d))

The cycle after 2027

For 2028 and later, a state files its advance election between January 2 and September 30 of the year before, and sends its list between October 1 and January 1 of the year itself. January 1 means up to 11:59 p.m., so a newly inaugurated governor can act on inauguration day. A state's election covers one calendar year and can't be withdrawn once the list is in. A state that wants out simply doesn't file for the next year. (Source: Prop. Reg. §1.25F-5; T.D. 10057)

What it means for schools

CEN handles certification in each state, and the deadline that matters is February 15, 2027. Your school's part is to register with CEN, run your pledge campaign this fall, and confirm enrollment before payments start. Register your school