Five things about the scholarship credit the IRS has not decided yet

A law can exist without being operable. §25F exists. Congress passed it and roughly thirty states have opted in. The first qualifying gift can be made on January 1, 2027. What does not exist yet is the machinery.

That gap is uncomfortable for anyone building in this space, and the temptation is to fill it with a confident guess. Here is what is actually missing.

How will donors get an IRS identification number?

Treasury has signalled that organizations will acknowledge gifts using a unique donor identification number issued by the IRS, so nobody has to hand a Social Security number to a small nonprofit. That is the single most donor-friendly thing in the guidance so far.

Nobody has said how the number gets issued. An API? A portal? Something derived? Until that lands, no acknowledgment anywhere can carry a real one. Any product showing you a donor number today invented it.

How will organizations report contributions?

Organizations are expected to report to the IRS so it can match what a taxpayer claims against what was actually given. Format and channel are both open, and so is how often it has to happen. Comments were requested in Notice 2025-70 and closed in December 2025.

Practically, this means no scholarship organization can finish its compliance workflow yet, however organized it is.

What will a receipt have to say?

The exact required language for a contribution acknowledgment is not published. We issue receipts now carrying the facts that cannot change: the organization’s legal name and EIN, your own name and address, and what you gave and when. When the language is settled, receipts get reissued and the original version stays on file.

Is the ceiling per return or per taxpayer?

This one has real money attached. The statute is not explicit. Most practitioners reading it expect the $1,700 limit to apply per return, so a married couple filing jointly shares one ceiling instead of getting two.

If that is right, a couple who each give the maximum has substantially overshot. If it is wrong, they have left a credit unclaimed. We show the meter per account and put the uncertainty on the dashboard. Of everything outstanding, this is the one we would actively wait on.

How are third-party fees treated?

§25F requires organizations to keep qualified contributions in a segregated account and spend at least 90% of income on scholarships. Take a platform fee out of a gift before it lands and you have an unanswered question: is the qualifying contribution what the donor gave, or what arrived?

We ship with fees switched off entirely. If the answer lands badly, every donor on a platform that charged a fee is holding a misstated credit. That is not something you apologise your way out of.

Should you wait to give?

No gift can qualify before January 1, 2027 anyway, so there is nothing to rush. Proposed regulations were anticipated around the end of September 2026, which leaves a reasonable runway before the 2027 window opens.

What you can usefully do now is find organizations you actually want to support and check they are in a participating state. The directory is open, and every listing shows where its information came from and whether anyone has verified it.