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Source documents

The verbatim text of every public document that defines the federal Educational Choice for Children Act / Federal Scholarship Tax Credit (ECCA / FSTC / §25F). Statutes, legislative provisions, IRS guidance — and placeholders for the regulations and forms still to come.

Statute (enacted law) (3)

26 U.S.C. §25F — Qualified Elementary and Secondary Education Scholarships
§25F
The federal individual income tax credit for cash contributions to scholarship granting organizations. Donor cap $1,700/return, 5-year carryforward, 90/10 SGO requirement, K-12 income-eligible students at or below 300% AMGI.
Public Law 119-21, title VII, §70411(a)(1) (enacted July 4, 2025)Effective 2027-01-01
26 U.S.C. §139K — Exclusion from Gross Income for Qualified ECCA Scholarships
§139K
Scholarships received from a qualifying SGO are excluded from gross income. Neither the student nor the parent owes federal income tax on the scholarship amount.
Public Law 119-21, title VII, §70411(b)(1) (enacted July 4, 2025)Effective 2027-01-01
26 U.S.C. §530(b)(3) — Definition of Qualified Elementary and Secondary Education Expenses
§530(b)(3)
The expense list referenced by §25F: tuition, fees, tutoring, special-needs services, books, supplies, room and board, uniforms, transportation, computer technology, and supplementary services at K-12 schools.
26 U.S.C. §530(b)(3) (Coverdell ESA expense definition)

Legislative provision (1)

Public Law 119-21, §70411(c) — ECCA / FSTC Effective Dates
OBBBA §70411(c)
When ECCA / FSTC takes effect: §25F applies to taxable years ending after December 31, 2026; §139K applies to amounts received after that date.
Public Law 119-21, title VII, §70411(c) (enacted July 4, 2025)Effective 2027-01-01

IRS guidance (1)

IRS Notice 2025-70 — Request for Comments on §25F Implementation
Notice 2025-70
First formal IRS guidance step. Treasury and IRS asked the public to comment on how to implement state SGO certification, the 90% income spending rule for multi-state SGOs, donor substantiation, and income verification. Comment period closed December 26, 2025.
IRS Notice 2025-70 (issued November 2025)

Source documents

Statute (enacted law) (3)

26 U.S.C. §25F — Qualified Elementary and Secondary Education Scholarships

26 U.S.C. §139K — Exclusion from Gross Income for Qualified ECCA Scholarships

26 U.S.C. §530(b)(3) — Definition of Qualified Elementary and Secondary Education Expenses

Legislative provision (1)

Public Law 119-21, §70411(c) — ECCA / FSTC Effective Dates

IRS guidance (1)

IRS Notice 2025-70 — Request for Comments on §25F Implementation

Coming soon (2)

Treasury Proposed Regulations under §25F — Coming Soon

IRS Form / Schedule for §25F Credit — Coming Soon