Back in April, we wrote about the IRS lifting its six-year moratorium on new group exemption applications. That post covered the basics. Revenue Procedure 2026-8 has now been finalized, and it includes detailed mechanics that every central organization, not just new applicants, needs to work through before a firm deadline.

The Deadline That Matters: January 22, 2027

If your organization already holds a group exemption letter issued before January 20, 2026, you have until January 22, 2027 to confirm that every subordinate organization covered by that letter satisfies the affiliation and supervision or control tests under the new rules. This is more than a formality. The IRS is giving existing group rulings a transition window to clean up their subordinate rosters, and organizations that don’t use it will be maintaining a group exemption letter that no longer matches what the subordinates on file can support.

Five Subordinates Is Still the Bar, But Only for New Applicants

Revenue Procedure 2026-8 keeps the longstanding requirement that a central organization have at least five subordinate organizations to obtain a new group exemption letter. The IRS considered lowering that number and decided against it, concluding that five subordinates strikes the right balance between the burden on the agency and the burden on organizations seeking the benefit.

Existing group rulings are treated differently. An organization with a group exemption letter issued before the new rules took effect is not required to have five subordinates to keep it; it can maintain the ruling with fewer, as long as it satisfies the other requirements. New applicants don’t get that benefit.

One requirement is new for everyone. Subordinate organizations that share the same purpose now have to use the same uniform purpose statement in their governing documents. If a group exemption covers subordinates with different purposes, each purpose group needs its own uniform statement. It is worth pulling your subordinates’ articles of incorporation and comparing them side by side rather than assuming they are consistent because they were all approved at one time.

Form 15644 Replaces the Old Annual Letter

Central organizations used to satisfy their annual reporting obligation with a letter. That is gone. Central organizations with one or more subordinates now use Form 15644, Supplemental Group Ruling Information, and it has to be filed every year, no earlier than 90 days and no later than 30 days before the close of the central organization’s annual accounting period. It currently must be submitted by fax, as the IRS has specified. Beyond the annual filing, a central organization can also submit Form 15644 during the year to report changes to its subordinate list, including additions, removals, or name and address changes, without waiting for the annual cycle.

Churches and conventions or associations of churches are the one exception. They’re permitted to file Form 15644 but not required to, which tracks the general pattern of relaxed reporting rules for religious organizations elsewhere in the tax code.

What Central Organizations Should Do Now

If your organization holds an existing group exemption, don’t wait until late 2026 to start this. Pull the current list of subordinates and confirm each one still meets the affiliation and supervision or control tests, since that’s the specific thing due by January 22, 2027. Compare governing documents across subordinates that share a purpose and fix any inconsistency in the purpose statement now, while there’s time to amend articles or bylaws if needed. And build the Form 15644 filing window, 30 to 90 days before your fiscal year-end, into your compliance calendar so it doesn’t get missed the way the old annual letter sometimes did.

Organizations considering a new group exemption should plan around the five-subordinate minimum from the outset. If you’re close to that number but not quite there, it may be worth waiting until you clear it rather than applying and being turned away.

Ellis Carter is a nonprofit lawyer with Caritas Law Group, P.C. licensed to practice in Washington and Arizona. Ellis advises nonprofit and socially responsible businesses on federal tax and fundraising regulations nationwide. Ellis also advises donors concerning major gifts. 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.