Short answer: On January 20, 2026, the IRS replaced its 1980 group-exemption rules with Revenue Procedure 2026-8. No church loses its tax exemption, but every denomination, diocese, conference, network, association, or convention that holds a group exemption letter for churches must bring that letter into compliance before January 22, 2027.
What a group exemption letter is
A group exemption letter is an IRS letter issued to a “central organization” that recognizes the exemption of the “subordinate organizations” included in it. Its main legal function is to relieve each subordinate from filing its own application for recognition. Rev. Proc. 2026-8 §§ 1, 3.08.
For churches, that relief was never needed. A church is exempt without applying. IRC § 508(c)(1)(A).
What changed on January 20, 2026
For more than 45 years the IRS required subordinates to be “affiliated” with the central organization and under its “general supervision or control,” without defining any of those terms. Notice 2020-36, 2020-21 I.R.B. 840, 842. Rev. Proc. 2026-8 defines all three, and it took effect on publication. Rev. Proc. 2026-8 §§ 4.02, 15.
- Affiliation. The facts and circumstances must show that the church is “a chapter, local, post, or unit of the central organization.” § 4.02(2). For a church, the Rev. Proc.’s example is “the sharing of common religious bonds or convictions with the central organization.” § 4.02(2)(c).
- General supervision. The central organization must (1) annually obtain, review, and retain information on each subordinate’s finances, activities, and filing compliance and (2) annually educate each subordinate about keeping its exemption. § 4.02(3)(a). The first half is optional for a subordinate “not required to file an annual information return or notice,” which includes churches but not a ministry that files Form 990-N. § 4.02(3)(b)–(c).
- Control. Control is an alternative to supervision. It exists when, for example, the central organization appoints the directors holding a majority of the subordinate’s voting power. § 4.02(4)(a).
The IRS’s own example says a church central organization supervises its churches by sending each one an electronic link to Publication 1828 every year. § 4.02(5)(c). For most central organizations of churches, that is the entire ongoing supervision duty.
What did not change
A church’s exemption does not depend on any group letter. The Rev. Proc. says that the tax-exempt status of a church or convention or association of churches “will not be affected” by the termination of a group letter or by the church’s removal from one. § 9.04 (citing IRC § 508(c)(1)(A)).
A central organization that is itself a church or a convention or association of churches also has no new annual IRS filing. The annual “supplemental group ruling information” (SGRI) is optional for it, but any other central organization, including a network that is not itself a convention or association of churches, must file SGRI every year. §§ 3.06, 7.01, 7.05.
Where the new work is
The burden falls mostly on the central organization, not the church, and it falls in four places:
- The transition deadline. Before January 22, 2027, the central organization must make sure every preexisting subordinate meets the new affiliation and supervision-or-control definitions, and must remove any that do not. § 12.02(2)(d), (f). Treat January 21 as the last safe day.
- New churches. A church added on or after January 20, 2026, must have its own EIN, sign a written authorization acknowledging removal “with or without cause,” and carry a uniform purpose statement in its governing instrument. §§ 4.03(2)(b), 4.06, 4.07, 12.02(1)(c).
- Removals. Removing a church from the group letter now takes at least 30 days’ notice to the church, a filing with the IRS, and a second notice to the church. Removal is effective on the IRS filing date, not the date of the vote or decision. § 8.02(2)–(3). It is not entirely clear whether or how removal from the group and removal from the letter differ legally.
- Non-church subordinates. Camps, agencies, colleges, and other ministries that must file annual returns or notices need full two-part supervision or control, and any whose exemption has been automatically revoked after three consecutive years of missed filings must come off. §§ 4.02(3)(a)–(c), (4), 4.04(5), 8.02(1)(a)(iii).
Key dates
| Date | What happens | Source |
|---|---|---|
| June 17, 2020 | IRS stops accepting new group exemption applications | Notice 2020-36; Rev. Proc. 2026-8 § 2.08 |
| January 20, 2026 | Rev. Proc. 2026-8 published and effective; group applications accepted again after this date | §§ 2.08, 12.01, 15 |
| January 20, 2026 | Churches on a letter this day are “preexisting” subordinates | §§ 3.10, 12.02(3) |
| Mid-December 2026 | Practical last time to send a 30-day removal notice if the removal must be filed before the transition ends | § 8.02(3) |
| January 22, 2027 | Transition period ends for preexisting letters and subordinates | § 12.02(2)(a), (f) |
| Every year | Educational notice (such as a Publication 1828 link) to every church on the letter | § 4.02(3)(a)(ii), (5)(c) |
| 27 months after termination or removal | Window in which a church’s own Form 1023 relates back to the termination or removal date | § 10.03(2)(b)(ii) |
One question per page
- Does my church need to stay on a group exemption letter?
- What does “general supervision” require for churches?
- What must a central organization do before January 22, 2027?
- Removing a church from a group letter
- Camps, schools, and agencies on a group letter
- Adding a new church on or after January 20, 2026 Includes illustrative uniform purpose statements.
Our view in brief
A central organization can comply with little more than an annual email and good records. But the direction over 45 years has run from undefined to defined to documented. Every central organization should decide on purpose whether to keep its letter, close it to new churches, or wind it down.
For churches, our general recommendation is to hold their own IRS determination letter when they need one, or simply to rely on the automatic exemption the Code already gives them, rather than depend on group coverage. Circumstances vary, and some churches in some polities will have good reasons to stay. I make the longer case in Would You Tell the IRS that the SBC “Supervises” Your Church?, published by the Center for Baptist Leadership.
Sources
- Rev. Proc. 2026-8, 2026-4 I.R.B. 380 (full text): irs.gov/pub/irs-drop/rp-26-08.pdf
- IRS Publication 1828, Tax Guide for Churches & Religious Organizations: irs.gov/pub/irs-pdf/p1828.pdf
- IRC §§ 508(c)(1)(A), 6033(j)
Questions about your church’s or organization’s group letter? Call 816-398-8305 or book a consultation.
This page is general information about Rev. Proc. 2026-8 as of October 26, 2026. It is not legal advice for any church or organization. Reading it or contacting the firm does not create an attorney-client relationship. Law Offices of Jonathan R. Whitehead LLC, 229 SE Douglas St., Ste. 210, Lee’s Summit, Missouri 64063.