Analysis
Where the money comes from, who is allowed to be paid, and what the rules leave open.
Every one of these programs runs on a document: a statute, a regulation, an administrator’s handbook. This page collects what those documents say, and what follows from them for a company selling into the programs they govern.
A Second Funding Layer: What the Federal Scholarship Tax Credit Pays For
Treasury published the Section 25F rules on October 2, 2026. What the scholarships may buy is not tuition alone, which puts the companies already selling into the twenty-four state programs in front of a second funding source in thirty states. Read it.
What is in the window.
The federal credit is the live one. These are the dates it turns on.
December 1, 2026. Comments close on the proposed federal regulations. A request to speak at the hearing runs to the same date, and a request only to attend is due by 5 p.m. Eastern on December 10.
December 15, 2026. The public hearing is at 10 a.m. Eastern.
January 1, 2027. The credit begins, and a state has to have made its election by this date.
February 15, 2027. Each participating state files its list of scholarship granting organizations. An organization that is not on the list cannot receive credit-eligible contributions.
2027-28. The first school year a federal scholarship is realistically spent against. My read from the sequence, not a date anyone has published.
