The compliance calendar

Updated September 28, 2026 · 5 min read

Related guides:: What CEN does and what your school does What is a scholarship granting organization?How scholarships are awarded and paid
Tool:: State tracker

What CEN does through the year, so your board knows the program is run to the statute.

In brief

CEN runs the program to the statute all year. This guide shows what happens when, so your board can see it.
By January 1 each year, each state that joins gives the IRS its SGO list. (Source: §25F(g)(1))
Donations sit in separate accounts, get an acknowledgment within one business day and are reported to the IRS under donor numbers.
After year end, CEN files reports and completes an annual audit, available to your board on request.

The year at a glance

Fall, before each year
CEN applies to or renews with each state that joins, for the coming year.
By January 1
Each state gives the IRS its SGO list for the year.
All year
Donations go into separate accounts. Each donor gets an acknowledgment within one business day.
Your application window
CEN checks income and awards under the priority order.
Before each payment
Your school confirms enrollment. CEN pays your school.
December 31
Last day to donate for that year's return.
After year end
Reports to the IRS and states. The annual audit.

What CEN does, and where your school comes in.

The calendar in detail

When	What CEN does	Your school's part	Source
By January 1 each year	Confirms CEN SGO is on each state's list submitted to the IRS	Nothing	§25F(g)(1)
All year	Holds qualified contributions in separate accounts and tracks the 90/10 ratio	Nothing	§25F(c)(5)(B), §25F(d)(1)(B)
Within one business day of each donation	Sends the acknowledgment with the donor number	Nothing	Treasury guidance preview, June 2026
Application windows	Verifies income and family size. Awards under the priority order	Tells families when to apply	§25F(d)(1)(D), §25F(d)(1)(F)
Payment dates	Pays schools and records each payment to a student	Confirms enrollment first, then credits accounts	§25F(d)(1)(C)
As changes happen	Updates awards and records	Reports withdrawals, transfers and grade changes	§25F(d)(1)(C)
After year end	Reports donations to the IRS under donor numbers. Files state reports. Completes the annual financial and programmatic audit and gives it to each listing state	Nothing	Treasury guidance preview, June 2026
Each year	Keeps its Ohio certification current. Publishes the 90/10 ratio on the Compliance page	Nothing	Ohio R.C. 5747.73

State list

Each state that joins gives the IRS a list of SGOs by January 1 of each year, with a certification that the person sending it has authority to do so. (Source: §25F(g)) Treasury expects states to check each SGO themselves, including its tax status and separate accounts. (Source: Notice 2025-70) The list is renewed every year, so CEN applies again each year in every state where it works.

Separate accounts

Qualified contributions sit in accounts kept only for them, never mixed with other money. (Source: §25F(c)(5)(B)) CEN tracks each school's fund and each state's donations inside those accounts, because money raised through one state's list funds students in that state only. (Source: §25F(c)(3))

Receipts

Each donor gets a written acknowledgment within one business day. It shows CEN SGO's legal name and EIN, the donor's name, the date, the amount, the school the donor chose, a statement that it's a qualified contribution under §25F and that no goods or services were provided, and the donor number. (Source: Treasury guidance preview, June 2026)

Reporting

After year end, CEN reports donations to the IRS under donor numbers so the IRS can match each donor's claim. It also files the reports each listing state asks for. Your enrollment confirmations are part of the record behind them. (Source: §25F(h); Treasury guidance preview, June 2026)

Audit

CEN's financials are audited every fiscal year, and the audited statements are available on request. Treasury's preview adds an annual financial and programmatic audit for SGOs, given to each state that lists them. (Source: Treasury guidance preview, June 2026)

Renewals

State lists. Every year, in every state. (Source: §25F(g)(1))
Family income. Checked again every year for every applicant. (Source: §25F(d)(1)(F))
Ohio. CEN keeps its Ohio certification with the Attorney General current for the state credit. (Source: Ohio R.C. 5747.73(C))
The 90/10 ratio. Published on the Compliance page each year.

What your board can ask for

CEN SGO's IRS determination letter.
Its Form 990.
Its audited financials.
The 90/10 ratio for the last year.
Its listing status in your state.

Ask your CEN contact, or email compliance@censgo.org. How CEN SGO is run

Common mistakes

Treating the state list as permanent. It's renewed every year.
Missing the enrollment confirmation before a payment date.
Reporting student changes only at year end.
Assuming a returning student's award carries over without a new income check.

What's still pending. Treasury's proposed rules, the final acknowledgment format, the IRS SGO portal and the IRS claim form, expected before the 2028 filing season. We'll update this calendar within a week of each.

Next step

Questions about this guide? See them on the FAQ page

Sources: §25F(g)(1); §25F(g); Notice 2025-70; §25F(c)(5)(B); §25F(c)(3); Treasury guidance preview, June 2026; §25F(h); §25F(d)(1)(F); Ohio R.C. 5747.73(C); §25F(c)(5)(D); §25F(d)(1)(D); Ohio R.C. 5747.73