Short answer: No. A church is tax-exempt without any IRS letter, and Rev. Proc. 2026-8 says that a church’s exempt status “will not be affected” by its removal from a group letter or by the letter’s termination. Rev. Proc. 2026-8 § 9.04; IRC § 508(c)(1)(A).
Why a church never needed the letter
Most charities must notify the IRS that they are applying for recognition of § 501(c)(3) status. IRC § 508(a). Churches, their integrated auxiliaries, and conventions or associations of churches are excepted from that requirement. IRC § 508(c)(1)(A). A church that meets the requirements of § 501(c)(3) is exempt whether or not it appears on anyone’s letter, and gifts to it are deductible on the same terms. IRC §§ 170(b)(1)(A)(i), (c)(2), 508(d)(2)(B).
A group exemption letter’s main legal function is to relieve each subordinate on the letter—whether the central organization is a denomination, diocese, conference, network, association, or convention—from filing its own application. Rev. Proc. 2026-8 § 1. For a church, that relief duplicates what the Code already gives.
What the 2026 rule says about churches that leave
The Rev. Proc. answers the question directly. The status of a church that is removed from a group letter, or whose central organization terminates its letter, “will not be affected.” § 9.04. A church in that position may apply for its own recognition, but “is not required to do so.” § 9.05(3). It may also simply continue as an exempt church without recognition. § 9.06.
If a church does apply within 27 months after its removal or the letter’s termination, its recognized exemption runs back to the date of the removal or termination. § 10.03(2)(b)(ii). There is no gap, provided the church otherwise qualifies.
What a church gives up by leaving
A convenience. Some banks, grantors, and state tax offices have accepted a central organization’s group-letter confirmation in place of an IRS determination letter. Church plants have used it to open their first bank account.
A church that needs paper can get its own determination letter by filing Form 1023. As of October 2026, the IRS user fee for Form 1023 is $600. (IRS, “Form 1023 and 1023-EZ: Amount of user fee,” irs.gov, updated October 9, 2026.) Churches cannot use the shorter Form 1023-EZ: the IRS eligibility worksheet asks, “Are you a church or a convention or association of churches described in section 170(b)(1)(A)(i)?”, and a “yes” makes the organization ineligible. (Instructions for Form 1023-EZ (Rev. January 2025), Eligibility Worksheet, question 12.) For most churches it is a one-time cost, and many will never need it.
What staying costs a church already on the letter
Very little in the short run. A church that was on a letter on January 20, 2026, is a “preexisting subordinate organization.” § 3.10. It does not have to sign a new authorization or amend its governing documents. §§ 4.06(1) (applies only at inclusion or addition), 12.02(3)(a), (d). Its central organization’s ongoing duty can be met with an annual educational notice, such as an emailed link to IRS Publication 1828. § 4.02(3)(c), (5)(c). Every church on the letter must have its own EIN, and the central organization should keep it on file. § 4.07.
What staying costs a church added now
More. A church added to a letter on or after January 20, 2026, 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. §§ 4.03(2)(b), 4.06, 12.02(1)(c). See Adding a new church on or after January 20, 2026.
The polity question
How much this matters depends on polity. In a hierarchical church, the denomination’s authority over the congregation is real, and a group letter describes something true. In a congregational church—Baptist, independent, many networks—the church answers to no one above the congregation, yet a group letter rests on the premise that the central organization exercises “general supervision or control” over it, at least for IRS purposes. Rev. Proc. 2026-8 § 3.05.
The IRS’s version of supervision is light. But for a congregational church added on or after January 20, 2026, a plaintiff looking to reach a central organization’s pockets for a church’s acts, or a church’s pockets for the central organization’s acts, now has three ready exhibits: a group letter covering the church as under the central organization’s “general supervision or control,” a signed paper conceding it can remove the church from the letter “with or without cause,” and uniform language in the church’s governing documents. Churches should win that argument: the Rev. Proc. says that “affiliated,” “general supervision,” and “control” “apply only for purposes of this revenue procedure and § 1.6033-2(d).” § 4.02(1). They should not have to keep making it.
Our general recommendation
Our general recommendation is that a church hold its own IRS determination letter if it needs one, or rely on its automatic exemption under § 508(c)(1)(A) if it does not, rather than depend on a group letter. Circumstances vary, and a church in a hierarchical polity may have good reasons to stay. In practice:
- A church already on a letter need not rush to leave. It should know which letter it is on and should expect an annual notice from the central organization.
- A church that needs a determination letter for a lender, donor, or tax office should consider getting its own. That concedes supervision or control to no one.
- A new church or church plant should weigh carefully before accepting group coverage, and can apply on its own if and when it needs paper.
Questions to ask this month
- Is our church on a group exemption letter? Whose, and since when?
- Were we added before or after January 20, 2026?
- Has anyone asked us to sign an authorization or change our governing documents?
- What is the central organization’s procedure for removing a church from the letter?
- If a lender or grantor has ever asked for our IRS letter, what did we send?
Related: Removing a church from a group letter · 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.