New IRS Form Required for Annual Group Exemption Reporting
The Internal Revenue Service has introduced a new mandatory form for central organizations maintaining group exemption letters. Beginning in 2026, central organizations must use Form 15644, Supplemental Group Ruling Information, to make their annual Supplemental Group Ruling Information (“SGRI”) submission.
The annual reporting obligation itself is not new. However, central organizations may no longer satisfy the requirement through an informal letter or annotated subordinate directory. Form 15644 now provides the standardized format central organizations must use to maintain and update their group exemption records with the IRS.
Updated Group Exemption Procedures
Revenue Procedure 2026-8, effective January 20, 2026, modifies and supersedes Revenue Procedure 80-27, which previously governed the group exemption program.
A group exemption letter allows eligible affiliated organizations to obtain recognition of federal Tax exempt status as subordinate organizations under a central organization’s group exemption. This structure relieves each subordinate organization from having to file its own application for recognition of exemption. In exchange, the central organization must exercise general supervision or control over its subordinate organizations and satisfy continuing reporting obligations designed to keep the IRS’s records current.
Who Must File Form 15644?
Generally, a central organization with one or more subordinate organizations under its group exemption letter must file Form 15644 annually.
A limited exception applies to a central organization described in Section 501(c)(3) that is a church or a convention or association of churches. Such an organization may submit Form 15644, but it is not required to do so.
Importantly, the annual filing obligation applies even when the central organization has no changes to report. In that case, the central organization must still submit Form 15644 and affirmatively indicate that there were no reportable changes during the applicable period.
What Information Must Be Reported?
Form 15644 is used to notify the IRS of changes affecting the central organization’s group exemption letter. This includes changes in a subordinate organization’s purpose, character, or method of operation, as well as changes to a subordinate organization’s legal name or mailing address.
The form must also identify subordinate organizations that are no longer included under the group exemption letter, subordinate organizations whose Tax exempt status has been automatically revoked, and new subordinate organizations being added to the group exemption letter. A central organization may also use the form to terminate its group exemption letter or provide other notices required under Revenue Procedure 2026-8.
For each subordinate organization affected by a reportable change, the central organization must generally provide the organization’s legal name, mailing address, and employer identification number. An annotated directory of subordinate organizations is no longer an acceptable substitute for the required submission.
Additional information is required when adding a new subordinate organization. Among other requirements, the central organization must provide the subordinate organization’s date of formation or incorporation and confirm that the information upon which the group exemption letter was based remains applicable to the new subordinate organization in all material respects. The central organization must also confirm that it has obtained written authorization to include the organization under the group exemption letter.
Additional information may be required when the subordinate organization is a private school, charitable hospital, or Section 501(c)(4) social-welfare organization.
When Is Form 15644 Due?
A central organization must submit Form 15644 annually at least 30 days, but no more than 90 days, before the close of its annual accounting period. This creates a 60-day annual filing window.
The deadline is based on the close of the central organization’s accounting period—not the due date of its Form 990-series information return. Because Form 15644 will generally be due before the organization’s fiscal year ends, central organizations should separately identify and calendar the applicable filing window rather than relying on their ordinary Form 990 preparation schedule.
A central organization may also submit Form 15644 at any time during the year to provide an additional update. For example, the form may be submitted to add a new subordinate organization before the central organization’s annual filing window.
How Is Form 15644 Submitted?
Under the IRS’s current instructions, Form 15644 must be submitted by fax to (833) 312-5228.
The central organization should retain a copy of the completed form, all supporting attachments, and the fax-transmission confirmation as part of its permanent Tax exemption records.
Coordination With Group Returns
A central organization intending to file a group Form 990-series return should update its subordinate organization information before filing the group return. The central organization should also reconcile the list of organizations included under its group exemption letter against the organizations included in the group return.
Form 15644 does not replace the annual Form 990-series filing obligations applicable to the central organization or its subordinate organizations. Each subordinate organization generally must either file its own annual information return or notice or be properly included in a group return filed by the central organization, unless an exception applies.
Why Timely Filing Matters
Revenue Procedure 2026-8 expressly provides that the IRS may terminate a group exemption letter if a central organization—other than a qualifying church or convention or association of churches—fails to submit timely and complete SGRI.
Termination can have substantial consequences. If the group exemption letter is terminated, the IRS generally will no longer recognize the subordinate organizations as exempt under that group exemption letter. The affected organizations may then need to apply for individual recognition of exemption or seek inclusion under another qualifying group exemption letter.
Central organizations should therefore treat Form 15644 as a critical annual compliance filing rather than a routine informational update.
Additional Transition Requirements
Revenue Procedure 2026-8 also establishes a transition period ending January 22, 2027, for central organizations with preexisting group exemption letters.
During this period, central organizations should review their existing group exemption structures to confirm compliance with the new requirements. Depending on the structure, a central organization may need to confirm that it has at least one subordinate organization, terminate additional preexisting group exemption letters, ensure that each subordinate organization is affiliated with and subject to its general supervision or control, or remove subordinate organizations described under a different paragraph of Section 501(c) than the paragraph specified in the original group exemption application.
These transition requirements are separate from the annual Form 15644 filing obligation and may require a broader review of the central organization’s relationship with its subordinate organizations.
Preparing for the New Filing Requirement
Central organizations should identify their annual Form 15644 filing window now and incorporate the filing into their annual compliance calendar. They should also establish a process for subordinate organizations to report legal, operational, and contact changes throughout the year.
Before preparing the form, the central organization should verify the legal name, mailing address, employer identification number, and operational status of each subordinate organization. It should also confirm that it maintains the required written authorization for any new subordinate organization and reconcile its group exemption roster against any planned group Form 990-series return.
Tovella Dowling, PC assists central organizations with maintaining group exemption letters, evaluating subordinate eligibility, preparing annual SGRI submissions, and navigating the updated requirements under Revenue Procedure 2026-8. If your organization maintains a group exemption letter, our attorneys can help evaluate its existing structure and prepare the required Form 15644 filing.