The US Treasury and the IRS will propose regulations on how Scholarship Granting Organizations can conduct their business. They are seeking public comment. Specifically, Notice 2025-70 requests comments on the following issues:
- A State required “annual certification of SGOs” that meets the statutory requirements to qualify;
- Policies and procedures implemented by States to ensure that the required certification is accurate and complete;
- Issues involving all three of these options: single-State organizations, organizations that may fundraise and award scholarships in more than one State, and organizations operating under other fact patterns that may wish to qualify as an SGO;
- SGOs’ reporting and recordkeeping policies.
Please ask your accrediting organization, Diocese, or other affiliate leader if you need guidance on your comments, or contact WFIS for more information. There are strong opinions about the best way forward. We are happy to talk through scenarios to help hone your messaging.
Comments are due by December 26, 2025
Commenters are encouraged to use the Federal e-Rulemaking portal to submit comments.
- Indicate “IRS-2025-0466” in the portal search engine to access Notice 2025-70.
