Group exemptions · Rev. Proc. 2026-8

IRS Form 15644 (Supplemental Group Ruling Information): who files it, when, and how

Short answer: Form 15644 is the IRS form a central organization uses to report supplemental group ruling information (SGRI)—additions, removals, name and address changes, and changes in purpose—for the subordinates on its group exemption letter. Most central organizations must file it every year, 30 to 90 days before their accounting year ends. A central organization that is a church or a convention or association of churches is excused from the annual filing, but it still uses Form 15644 to remove a subordinate. The form is filed electronically on irs.gov or by fax, not by mail. Rev. Proc. 2026-8 §§ 7.01, 7.05, 8.02(2); Form 15644 (Rev. 10-2026).


What the form is for

Rev. Proc. 2026-8 requires a central organization to keep the IRS informed about the subordinates on its group letter. § 7. The IRS’s vehicle for that information is Form 15644, Supplemental Group Ruling Information, revised October 2026. The form’s own title uses the Rev. Proc.’s term, SGRI.

Each filing is one of three types: an annual update, an interim update (permitted “at any time,” § 7.01), or a termination of the group exemption by the central organization.

What it reports

Under § 7.02, a central organization reports:

  • Changes in purpose, character, or method of operation of any subordinate. § 7.02(1).
  • Separate lists of subordinates that (i) changed their name or mailing address, (ii) are no longer included in the letter, (iii) had their exemption automatically revoked, and (iv) are being added. § 7.02(2)(a). Each list gives each subordinate’s name, mailing address, and EIN. § 7.02(2)(b). An annotated directory will not do. § 7.02(2)(c).
  • For each subordinate being added: its date of formation, and statements that the information supporting the group letter applies to it in all material respects, that the central organization has the subordinate’s written authorization, and (if the central organization files a group return) the subordinate’s accounting period. § 7.02(3).
  • No change: if nothing reportable happened, a statement saying so. § 7.02(5).

The form also asks each subordinate’s foundation code; code 10 is a church or a convention or association of churches.

When to file

Annually, at least 30 days but no more than 90 days before the close of the central organization’s accounting year. § 7.01. For a calendar-year central organization, that window runs from early October to early December.

For a removal, only after the subordinate has had at least 30 days’ notice. § 8.02(2)–(3). The removal takes effect on the date the IRS is notified. § 8.02(2). See Removing a church from a group exemption.

Churches and conventions: the exception and its limit

A central organization that is a church, or a convention or association of churches, “may, but is not required to,” submit the § 7 information. § 7.05. So a denomination, association, or convention of churches does not owe the annual Form 15644.

The exception does not reach removals. A subordinate leaves the letter only when the central organization notifies the IRS “through an SGRI submission.” §§ 7.02(2)(a)(ii), 8.02(2). A church central organization that removes a church and never files Form 15644 has not removed the church from its letter.

Whether a church central organization must file Form 15644 to add a church is unsettled. See Adding a new church after January 20, 2026.

Where and how to file

Form 15644 “must be submitted electronically on irs.gov/forms-pubs/mobile-friendly-forms or by fax at (833) 312-5228.” Form 15644 (Rev. 10-2026), Where to File. The form says the mobile-friendly version became available September 28, 2026. It gives no mailing address. (Section 7.03 of the Rev. Proc. provides an Ogden, Utah mailing address only for the period before the IRS published electronic procedures.)

Check the current form on irs.gov before filing; the IRS can change the procedure by posting on irs.gov. § 7.03.

Practical points

  • Keep the confirmation. For a removal, the filing date is the effective date. Save the electronic-submission confirmation or the fax transmission report with the minutes.
  • Calendar the window. A calendar-year central organization that owes the annual filing should calendar October 2 through December 1.
  • Collect EINs now. Every list requires each subordinate’s EIN. § 7.02(2)(b). Churches without one should get one before they are added.
  • Before January 22, 2027: see the transition checklist.

Filing this year? For a calendar-year central organization, the annual window closes December 1. Questions about your church’s or organization’s group letter? Call 816-398-8305 or book a consultation.

This page is general information as of November 3, 2026. It is not legal advice and 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.