IRS Requires Central Nonprofits to Use New Annual Group-Ruling Form
The Internal Revenue Service is requiring central organizations covered by group exemption rulings to use a new form for annual submissions about their affiliated subordinate organizations, creating a standardized reporting process for national religious denominations, nonprofit networks and other organizations operating under group exemptions.
The IRS announced the change in its Exempt Organizations Update on July 14, 2026. Beginning in 2026, central organizations must use Form 15644, “Supplemental Group Ruling Information,” to provide the required annual information unless an exception applies.
What the new filing changes
A group exemption letter can apply to a group of affiliated organizations and has the same effect as an individual exemption letter for those organizations, according to the IRS. The arrangement allows subordinate organizations to rely on the central organization’s group ruling rather than filing separate exemption applications.
Under the updated procedure, central organizations must submit information about subordinate organizations annually. The requirement gives the IRS a formal, standardized way to receive updates about the organizations covered by a group exemption arrangement.
The annual submission is due at least 30 days, but no more than 90 days, before the close of the central organization’s accounting period. The form must be submitted by fax at 833-312-5228.
A central organization may also submit additional updates at any time. That includes adding a subordinate organization before the annual filing deadline, according to the IRS.
Updated rules replace earlier procedures
The change is part of Revenue Procedure 2026-8, which modifies and supersedes Revenue Procedure 80-27, as modified by Revenue Procedure 96-40. The updated procedure establishes current rules for group exemption letter requests and related exempt-organization administration.
The IRS’s January 2026 materials also said organizations may request group exemption letters through Form 8940 on Pay.gov. The request carries a $3,500 user fee.
That fee applies to requests for group exemption letters. It is separate from the new annual Form 15644 reporting requirement described in the July announcement.
Who is affected
The requirement applies to central organizations that maintain group exemption arrangements, not to every nonprofit organization. Potentially affected organizations include religious denominations, nonprofit networks and other central organizations whose affiliated entities rely on a group ruling.
The available IRS material does not identify a specific denomination or nonprofit network that has already filed Form 15644. It also does not quantify how many central organizations or subordinate organizations will be affected.
The change is a procedural and reporting requirement. The IRS material does not describe Form 15644 as a new tax, and the announcement does not say that affiliated organizations lose tax-exempt status merely because the form is being introduced.
What organizations should watch next
Central organizations using group exemptions will need to determine when their accounting periods close and work backward from the 30-to-90-day filing window. They will also need to use the specified form and fax submission method for the annual filing.
The IRS has not stated in the available announcement whether it will impose penalties specifically for late or incomplete Form 15644 submissions. The agency’s notice likewise does not characterize the change as an enforcement action or identify a specific investigation.
For religious and nonprofit networks, the immediate consequence is a new recurring administrative step: maintaining current information about subordinate organizations and transmitting that information to the IRS through the group-ruling process. Additional updates remain available at any time when an organization needs to report a change before its annual deadline.
Sources
- Exempt Organizations Update, Internal Revenue Service
- Internal Revenue Bulletin 2026-04, Internal Revenue Service
- Exempt Organization — Exemption Application, Internal Revenue Service
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