Short answer: A church added to a group letter on or after January 20, 2026, must have its own EIN, must sign a written authorization acknowledging that the central organization may remove it “with or without cause,” and must carry a uniform purpose statement in its governing instrument. Churches already on the letter that day are excused from the last two. Rev. Proc. 2026-8 §§ 4.03(2)(b), 4.06, 4.07, 12.02(1)(c), (3).
Who counts as “new”
The full rule applies to “subordinate organizations added to preexisting group exemption letters on or after the publication date,” January 20, 2026. § 12.02(1)(c). That includes a new church or church plant; an established church joining a denomination, network, association, or convention, or moving from another group letter; and a church that was removed and is added back, which loses its preexisting status. §§ 3.10, 12.03(2), (4)–(5).
Requirement 1: an EIN before the church is added
Each subordinate (or the central organization on its behalf) “must obtain an EIN prior to its . . . subsequent addition to a group exemption letter.” § 4.07.
Requirement 2: a signed written authorization
The church must authorize its addition in writing, signed “by an officer of the subordinate organization with personal knowledge of the facts and with authority to legally bind” it. § 4.06(1). The authorization “must acknowledge that the central organization may remove the subordinate organization from the group exemption letter with or without cause.” § 4.06(2).
Requirement 3: a uniform purpose statement
“Subordinate organizations that share the same purpose must have a uniform purpose statement in their governing instruments (for example, a charter, trust indenture, articles of association, etc.).” § 4.03(2)(b). The statement “must generally describe the purpose of the subordinate organizations.” Id. Where purposes on a letter differ, those that share one “must include the same uniform purpose statement.” Id. Use identical wording. It belongs in the governing instrument. Id.; § 3.12. It sits alongside the church’s other purpose language, and the church must still meet the § 501(c)(3) organizational test.
Who sets the statement depends on polity
Section 4.03(2)(b) requires a uniform statement. It does not say who writes it. That leaves room for different polities to reach the same result in different ways:
- In a hierarchical denomination, the statement may already sit in the denomination’s governing documents that bind local churches.
- A network may set it in a covenant that member churches sign and then adopt.
- In other bodies, the churches may agree on the language and each adopt it by its own action.
In a Baptist convention, as a practical matter, I see no way around the convention supplying the language. No other body can set a uniform statement for autonomous churches, and a sentence each church writes for itself will not match the next church’s. That is one reason our general recommendation is that churches hold their own determination letters, or rely on their automatic exemption, rather than group coverage.
Example uniform purpose statements (illustrations, not model forms)
Each would have to be used identically by every church that shares the purpose.
- Broad religious purpose. “This church is organized and operated exclusively for religious purposes within the meaning of section 501(c)(3) of the Internal Revenue Code.”
- Worship and ministry. “This church is organized exclusively for religious, charitable, and educational purposes, including public worship, the teaching of the Scriptures, the observance of the ordinances, and ministry to its members and community.”
- Statement of faith by reference. “This church is organized exclusively for religious purposes, to worship and serve God in accordance with the statement of faith adopted by the church, and to carry on ministries consistent with it.”
- Network or association. “This church is organized exclusively for religious purposes as a local congregation cooperating with other churches in worship, evangelism, church planting, and missions.”
- Ecumenical or generic. “This congregation is organized exclusively for religious and charitable purposes, including worship, religious instruction, and service to its neighbors.”
Caution: a purpose statement must fit what each church actually does. Have a lawyer review it, and the church’s whole governing document, before adoption.
Requirement 4: the relationship tests apply at once
A church added now must meet the § 4.02 affiliation and supervision-or-control tests from the start, with no transition period. §§ 4.02, 12.02(1)(c). See What “general supervision” requires.
Reporting is optional for church central organizations; the requirements are not
A central organization that is a church or a convention or association of churches is not required to submit SGRI, including the information on added subordinates. § 7.05. But whether a church is added to the letter without a Form 15644 filing is unsettled. The Rev. Proc. does not say, and as of October 2026 the IRS has not addressed the question. The Rev. Proc.’s structure points toward filing: it ties an unrecognized added organization’s effective date of exemption to “the submission date of the SGRI adding the organization to the group exemption letter” (§ 10.02), and Examples 2 and 4 describe each addition through an SGRI (§ 12.03(2), (4)). Filing Form 15644 for each addition avoids the question. The §§ 4.02–4.07 requirements are conditions of being added to and staying on the letter, not filing requirements. §§ 4.05–4.07. If a church is added without them, the IRS “may” remove it (§ 8.02(1)(b)), and may terminate the letter if more than half the subordinates fail the uniform-purpose or matching requirement (§ 8.01(1)(h)). A charter or affiliation letter telling a new church it is “covered by the group exemption” would make a representation the rule does not support.
The choices
- Close the letter to new churches. Confirm affiliation without promising group coverage. A church that needs IRS paper files Form 1023; as of October 2026 the IRS user fee is $600 (IRS, “Form 1023 and 1023-EZ: Amount of user fee,” updated October 9, 2026).
- Offer coverage by opt-in, with the authorization, the removal acknowledgment, and the uniform statement set by whatever means the polity allows.
- Continue as before. I do not recommend it. A church added without the § 4 items is on the letter without meeting the rule.
For bodies of autonomous congregations, I recommend the first. A new church is exempt without the letter. IRC § 508(c)(1)(A).
Related: Does my church need to stay on a group letter? · Checklist for January 22, 2027 · Rev. Proc. 2026-8 overview
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.