Short answer: One educational notice a year. A central organization satisfies “general supervision” over its churches by annually sending each church written information about keeping its exemption—the IRS’s own example is an electronic link to Publication 1828. Rev. Proc. 2026-8 § 4.02(3)(a)(ii), (3)(c), (5)(c). Keep a record that it went out.
Who this applies to
Every central organization that holds a group letter covering churches: a denomination, diocese, conference, network, association, or convention. The Rev. Proc. uses one term for all of them: “central organization.” § 3.05. Its definitions draw no line by polity.
The two-part definition
Rev. Proc. 2026-8 defines general supervision. A central organization exercises it if it:
- “Annually obtains, reviews, and retains information on the subordinate organization’s finances, activities, and compliance with annual filing requirements”; and
- “Annually transmits (including electronically) written information to, or otherwise educates, the subordinate organization about the requirements to maintain tax-exempt status under the applicable paragraph of § 501(c), including, but not limited to, annual filing requirements, if applicable.”
§ 4.02(3)(a)(i)–(ii).
The first half is optional for churches
If a subordinate is not required to file an annual information return or notice, the central organization “may, but is not required to,” satisfy the financial half. § 4.02(3)(c). Churches file no Form 990, 990-EZ, or 990-N. IRC §§ 6033(a)(3)(A)(i), 6033(i). So for churches, only the educational half remains.
The IRS’s own example
The Rev. Proc. illustrates the rule with a church central organization whose subordinates are churches, schools below college level, and hospitals. It supervises the hospitals by annually obtaining, reviewing, and retaining their annual information returns and sending each a link to Publication 557. It supervises the churches and schools “by annually providing each church and school an electronic link to the current version of Publication 1828, Tax Guide for Churches & Religious Organizations.” § 4.02(5)(a)–(c).
That example is the most useful sentence in the Rev. Proc. for anyone holding a letter for churches. Follow it closely.
Affiliation is the other half of the relationship
Supervision is not enough by itself; each church must also be “affiliated” with the central organization. § 4.02(1). Affiliation rests on facts and circumstances showing 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). An annually updated directory of subordinates is another example. § 4.02(2)(b). Keep one.
Control is an alternative
The rule is supervision or control, not both. Control means, for example, that the central organization appoints the directors holding a majority of the subordinate’s voting power or a majority of its officers, or that a written agreement evidences its control over the subordinate’s activities and operations. § 4.02(4)(a)–(e).
Whether control fits churches depends on polity. Some hierarchical bodies may meet one of the control tests. A central organization of autonomous congregations does not, and should never represent to the IRS, or to anyone else, that it controls them. Supervision through the annual notice is the route for those churches. Control remains the natural route for an institution whose trustees the central organization elects.
What the annual notice must cover
The Rev. Proc. requires information about “the requirements to maintain tax-exempt status,” including annual filing requirements “if applicable.” § 4.02(3)(a)(ii). The IRS example shows that a link to the current Publication 1828 does that for churches.
The same mailing can remind churches that their exemption does not depend on the group letter (§ 9.04) and that they may seek their own determination letter (§ 9.05(3)), and confirm each church’s legal name, EIN (§ 4.07), and addresses. None of this is required for supervision.
Send it to every church on the roster. Email is enough; the rule says “including electronically.” § 4.02(3)(a)(ii). The standard is that the central organization transmits the information, not that every church reads it.
Keep the record
Retain the notice, the date it went out, and the list of churches it went to. If the IRS ever examines the letter, that file is the proof of supervision. Failing to exercise general supervision or control over even one subordinate is a listed ground for terminating the letter. § 8.01(1)(f).
When it is due
For a letter that existed on January 20, 2026, the central organization must “ensure” that each preexisting church is affiliated and under general supervision or control before the transition period ends on January 22, 2027. § 12.02(2)(d), (f). In practice, that means one documented notice to every church on the roster before that date, and one every year after.
A church the central organization cannot bring within the definition—for example, one that no longer shares religious bonds or convictions with it—must be removed under the § 8.02 procedure. § 12.02(2)(d). See Removing a church from a group letter.
What the notice does not require
- No financial reports from churches. § 4.02(3)(c).
- No annual SGRI filing with the IRS for a central organization that is itself a church or a convention or association of churches. § 7.05.
- No change to the governing documents of churches already on the letter. § 12.02(3)(a).
Related: 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.