IRS Requires New Annual Filing for Group-Exemption Leaders
The Internal Revenue Service is adding a new annual reporting step for most central organizations that maintain group exemption letters covering subordinate nonprofits.
Beginning with the 2026 filing cycle, those organizations generally must use Form 15644, Supplemental Group Ruling Information, to update the IRS about the organizations included in the group. The IRS announced the form requirement on July 14, 2026, after issuing Revenue Procedure 2026-8 on January 20, 2026.
The change does not require every nonprofit to file Form 15644. It generally applies to a central organization with one or more subordinate organizations covered by a group exemption letter. The form also does not replace separate Form 990-series returns, Form 990-N notices or other annual filing requirements that may apply.
What Form 15644 reports
The form is designed to keep IRS records current. A central organization can use it to add or remove subordinate organizations, report changes in names or mailing addresses, and notify the IRS about changes in a subordinate organization’s purpose, character or method of operation.
The annual submission also covers subordinate organizations that have been removed from the group, organizations being added, and subordinates whose tax exemptions were automatically revoked. The required lists include each organization’s name, mailing address and employer identification number.
A central organization may submit additional updates outside its annual filing window, including an update to add a new subordinate organization. Form 15644 can also be used to terminate a group exemption.
When the filing is due
The deadline is tied to the central organization’s annual accounting period, not necessarily the calendar year. The annual Supplemental Group Ruling Information submission generally must be made at least 30 days, but no more than 90 days, before the close of that accounting period.
For a central organization with a December 31 year-end, the practical filing window is October 2 through December 1, subject to the organization’s applicable accounting-period calculation.
The IRS’s current Form 15644 instructions say the form must be submitted by fax at 833-312-5228. Revenue Procedure 2026-8 uses broader language saying the required information must be submitted electronically and allows the IRS to change submission procedures through later guidance. Because the specific form instructions and the broader procedure use different wording, compliance teams should check the latest IRS instructions before filing.
Which churches are excepted
A central organization described in section 501(c)(3) that is a church, or a convention or association of churches, and that maintains a group exemption letter may submit the annual information but is not required to do so under the stated exception.
The exception applies to the qualifying central organization. It should not be read as a blanket exemption for every nonprofit connected to a religious group.
What existing groups must review by January 22, 2027
Revenue Procedure 2026-8 establishes a transition period for existing group exemption letters and preexisting subordinate organizations. Required actions under the applicable transition provisions must be completed by January 22, 2027.
For affected groups, the review can include whether the central organization has more than one group ruling, whether subordinate organizations meet the revised affiliation and general supervision or control standards, whether a subordinate’s section 501(c) classification matches the group exemption letter, and whether the group still has at least one subordinate organization.
Some organizations continuously included in the same group ruling as of January 20, 2026, may qualify for grandfather provisions affecting particular requirements. The transition rules are detailed, so central organizations should determine which provisions apply to their group rather than assume that every subordinate must immediately satisfy every new standard.
What nonprofit teams should do now
Central organizations should first confirm whether they maintain a group exemption letter and identify every subordinate organization covered by it. They should then calculate the annual filing window by working backward from the close of the central organization’s annual accounting period.
Before submitting Form 15644, teams should assemble current names, mailing addresses and EINs; review additions and removals; check for automatically revoked subordinates; and document changes in purposes or operations. They should also review the group’s affiliation, supervision and control structure ahead of the January 22, 2027, transition deadline.
The procedure lists failure to submit timely and complete Supplemental Group Ruling Information as one possible basis for IRS termination of a group exemption in applicable cases. That does not mean a late Form 15644 automatically revokes every organization’s tax-exempt status. Separate annual filing obligations continue to apply where required.
Sources
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