Here is an interesting fact: the Education Freedom Tax Credit (EFTC) launches in under six months, thirty states have joined, and not one of them has certified a Scholarship Granting Organization (SGO) to receive donations. Some may see this as a worrying headline about the tax credit.
But the current certification list isn’t a failure of the system. It is the system and its deliberate sequencing decision that says a lot about how carefully this program is being built. Understanding it will make you a smarter donor in October.
Why the List Is Empty
The short version? States can’t certify organizations against rules that haven’t been published. The only piece of federal machinery fully built so far is the state opt-in itself which is the form governors used to put their states on the map. The rules governing certification and exactly who qualifies as an SGO, how states build and submit their official lists, and how the first-year deadlines work were deliberately held for the proposed regulations Treasury previewed on June 10 and has promised by the end of September.
Rather than let 50 states improvise fifty different certification systems this summer and force organizations to redo their paperwork when federal rules arrived, Treasury chose one authoritative rulebook, once. States get a single standard to certify against. Organizations apply once, correctly. Donors get lists they can rely on.
Staged, Not Stalled
Look closer at the states and you don’t see idleness. You see runners in their blocks.
Alabama has already published the criteria an organization will need to meet, including 501(c)(3) status, scholarships to ten or more students at more than one school, and the 90% scholarship-spending floor, while noting it’s awaiting Treasury’s final word before setting deadlines.
Nebraska has said it will post its forms as soon as federal guidance is final. Tennessee has named its Department of Education as the certifying agency. Virginia has gone furthest, submitting an early roster of organizations to Treasury.
Authorized, staffed, and waiting on one document — everywhere.
Be the First to Know
Get notified when the Education Freedom Tax Credit launches so you don’t miss the opportunity to support K–12 students while benefiting from a federal tax credit.
What the Fall Actually Looks Like
The September regulations are the starting gun. When they publish, certification opens in every participating state at roughly the same time, and the fourth quarter becomes a sprint: applications filed, organizations vetted, official lists submitted to the federal government, all before January 1. Treasury has said the rules can be relied on for the 2027 tax year, which is what makes the compressed timeline workable.
For SGOs, the summer is the build window. Everything that makes an SGO worth your donation is being assembled right now, before any state opens its doors: the nonprofit status, the segregated account that will carry the 90% test, the audit relationship, the school and family networks, the systems that verify income and move money efficiently.
The organizations doing that work now will be certified in October. The ones waiting for the starting gun to begin building will be scrambling in December.
What It Means for You
If you’re a donor: nothing is required of you yet, except attention.
The moment that matters is this fall, when your state publishes its certified list, and you choose where your $1,700 will go.
If you’re a family: the scholarships are coming on schedule, and applications will follow certification. The dates to circle are the end of September, when the rules land, and January 1, 2027, when the first donations flow.
The AFC Scholarship Fund is spending the waiting room months exactly the way you’d hope, including building the accounts, the audits, the school network, and the donor community that day one requires.
Certification rules are contained in Treasury’s proposed regulations, expected by the end of September 2026. States are deliberately waiting for that single federal rulebook before opening applications.
This fall, after states open certification and publish their official lists of qualified Scholarship Granting Organizations — expected in the fourth quarter of 2026.
Confirm your state has opted in, plan for a January 2027 gift, and sign up for updates so you know the moment your state’s certified list is published.
