If your organization holds a group exemption, the IRS has something new for you: Form 15644, Supplemental Group Ruling Information. Released in April 2026, this is the designated form for making annual updates to your group exemption and it is long overdue.
Under the old rules, central organizations submitted their annual Supplemental Group Ruling Information as a letter to the IRS. That process worked about as smoothly as you might imagine a freeform letter to a federal agency would. The new form standardizes what the IRS needs and, in theory, should make the whole process less painful for everyone involved.
Here is what you need to know.
What Is Form 15644?
Form 15644 is the form central organizations use to report changes to their group exemption on an ongoing basis. Think of it as the annual maintenance filing that keeps your group exemption current with the IRS.
It is not the form you use to apply for a group exemption in the first place. That is still Form 8940. Form 15644 is specifically for organizations that already have a group exemption letter and need to update, add, or remove subordinates, or to simply confirm that everything is still in order.
Who Needs to File It?
Any central organization holding a group exemption letter needs to file Form 15644 annually to maintain that exemption. This includes organizations that were already holding group exemptions when Rev. Proc. 2026-8 took effect in January 2026. The one notable exception: churches and associations of churches are exempt from the annual SGRI filing requirement.
What Does It Cover?
Form 15644 is how you tell the IRS about:
- Changes to your subordinate list.  Use Form 15644 to add a new subordinate or removing one that has left the group, been dissolved, or lost its eligibility.Â
- Name and address changes.  If a subordinate has been operating under a different name than what appears in the IRS’s records, this is where you update it. Given how often charter schools rebrand, chapters reorganize, and ministries rename themselves, this is likely the most common use case for a lot of organizations.
- Annual compliance certifications.  Under Rev. Proc. 2026-8, the central organization must certify that it has exercised general supervision over its subordinates during the year, meaning it has reviewed each subordinate’s finances and transmitted annual compliance information to each subordinate. Form 15644 is where those certifications are made.
When Does It Need to Be Filed?
Form 15644 must be submitted between 30 and 90 days before the end of the central organization’s fiscal year. This is not an after-the-fact annual report. Rather, it is a pre-fiscal-year-end filing. If your organization operates on a calendar year, that means you are looking at an October through November filing window. If you run on a June 30 fiscal year, you would be filing between April and May.
Mark your calendar now. Missing the window could jeopardize your group exemption.
How Do You File It?
Unlike the old letter-based process, Form 15644 must be submitted electronically. Watch for the IRS to release specific instructions on the submission portal, and check irs.gov for updates as those details are finalized under Rev. Proc. 2026-8.
Why This Matters Right Now
Organizations holding group exemptions have until January 22, 2027 to bring their group structures into compliance with Rev. Proc. 2026-8. That includes updating subordinate authorizations, ensuring governing instruments contain uniform purpose statements, and now, learning and following the Form 15644 filing process.
The introduction of a standardized form is genuinely good news. It tells you exactly what the IRS wants, rather than leaving you to guess what a compliant letter looks like. But it also means there is no longer much ambiguity about what is required. Organizations that skip the annual filing or miss the window will not be able to point to procedural confusion as an excuse.
If you hold a group exemption and have not yet audited your compliance with the new requirements, the release of Form 15644 is a good prompt to start.
Ellis Carter is a nonprofit lawyer and the founder of Caritas Law Group, P.C.. To schedule a consultation with Ellis, call 602-456-0071 or email us through our contact form. This post is for general informational purposes and does not constitute legal advice.