Short answer: Before January 22, 2027, any central organization—denomination, diocese, conference, network, association, or convention—that held a group letter on January 20, 2026, must make sure every subordinate on the letter is affiliated with it and under its general supervision or control as Rev. Proc. 2026-8 now defines those terms. It must remove any subordinate that is not. Rev. Proc. 2026-8 § 12.02(2)(d), (f).
The date is the end of a grace period, not the start of the rule
Rev. Proc. 2026-8 took effect on January 20, 2026. § 15. The transition period for letters and subordinates that already existed on the publication date ends on January 22, 2027, and the actions “must be completed before” that date. § 12.02(2)(a), (f). Treat January 21, 2027, as the last safe day. Some requirements are suspended for preexisting letters until then. After that, they apply in full.
What the Rev. Proc. requires before January 22, 2027
Section 12.02(2) lists the transition duties. For a preexisting letter, the central organization must:
- Have at least one subordinate, or terminate the letter. § 12.02(2)(b).
- Keep at most one group letter, give the IRS copies of all, and terminate the rest. § 12.02(2)(c).
- Ensure affiliation and general supervision or control for every preexisting subordinate, under the § 4.02 definitions, or remove it. § 12.02(2)(d).
- Remove any subordinate described in a different paragraph of § 501(c) from the one stated in the original group application—for example, a § 501(c)(4) organization on a § 501(c)(3) letter. § 12.02(2)(e).
These actions “are accomplished through SGRI submissions and must be completed before the transition period ends on January 22, 2027.” § 12.02(2)(f).
The IRS’s Example 4 fits the typical church letter: one preexisting § 501(c)(3) letter with preexisting subordinates. That central organization “is not required to make any changes” during the transition period if it has at least one subordinate, all are in the same § 501(c) paragraph, and its relationship with them satisfies § 4.02. § 12.03(4).
The checklist
1. Get the letter and the group exemption number in hand. Confirm which § 501(c) paragraph the letter covers. If the central organization is not itself a church or a convention or association of churches (for example, a network that is not), calendar its annual SGRI. It is due between 30 and 90 days before its fiscal year ends, and late or incomplete SGRI is a ground for terminating the letter. §§ 3.06, 7.01, 7.05, 8.01(1)(d).
2. Preserve a dated roster as of January 20, 2026. Churches on the letter that day are “preexisting subordinate organizations,” spared the new authorization and uniform-purpose requirements. §§ 3.10, 4.06(1) (applies only at inclusion or addition), 12.02(3). A central organization that is a church or a convention or association of churches need not file annual subordinate lists with the IRS (§ 7.05), so its own records may be the only proof of who is grandfathered. Include each church’s legal name, address, and EIN (§ 4.07). Keep it permanently.
3. Send the annual educational notice to every church on the roster, and keep the record. An electronic link to Publication 1828 satisfies general supervision for churches. § 4.02(3)(c), (5)(c). Retain the notice, the date, and the distribution list. See What “general supervision” requires.
4. Inventory every non-church subordinate. Camps, children’s agencies, foundations, and other ministries that file Form 990, 990-EZ, or 990-N need either the full two-part supervision (including annual financial information) or control. § 4.02(3)(a)–(c), (4). The IRS example treats a church school below college level like a church. § 4.02(5)(a), (c). Check each against the IRS automatic-revocation list. An automatically revoked subordinate must come off. §§ 4.04(5), 4.05, 8.02(1)(a)(iii). See Camps, schools, and agencies.
5. Finish pending removals. Any church that has left, closed, merged, or been removed from fellowship needs the § 8.02 procedure: at least 30 days’ notice to the church, then the IRS filing, then a second notice. § 8.02(2)–(3). For a removal that must be complete before January 22, 2027, send the notice by mid-December 2026. See Removing a church.
6. Stop adding churches until you decide how. A church added on or after January 20, 2026, must have an EIN, a signed authorization acknowledging removal “with or without cause,” and a uniform purpose statement in its governing instrument. §§ 4.03(2)(b), 4.06, 4.07, 12.02(1)(c). See Adding a new church for illustrative statements. If your charter or affiliation letter still tells new churches they are covered by the group exemption, revise it.
7. Put the larger decision on the board’s calendar. See below.
What a central organization of churches does not have to do
- File annual SGRI, if the central organization is itself a church or a convention or association of churches. § 7.05. (A removal or termination, however, takes effect only through an SGRI-type submission, §§ 8.01(2), 8.02(2), and the Rev. Proc. describes additions only through one, §§ 10.02, 12.02(2)(b)(i), (f). File Form 15644 for every removal; whether a church can be added without one is unsettled, and the IRS has not addressed it.)
- Collect financial reports from churches. § 4.02(3)(c).
- Claim control over any church that it does not in fact control.
- Ask existing churches to amend anything. § 12.02(3).
The decision every central organization should make on purpose
Compliance is the floor. The governing board should also choose one of three courses:
| Stay | Close | Exit | |
|---|---|---|---|
| What you do | Annual notice; new-church requirements; removal procedure | Annual notice; add no new churches; removal procedure | Terminate the letter; tell every church once |
| Effect on churches | None | New churches lack the group-letter shortcut | Same, for all; existing exemptions unaffected (§ 9.04) |
| Exposure to the next rewrite | Full | Existing roster only | None |
A central organization that terminates its letter should tell each church how to obtain its own recognition or operate without it. § 8.01(2). A church that applies within 27 months, and otherwise qualifies, has its recognition dated back to the termination. § 10.03(2)(b)(ii).
A hierarchical denomination whose governing documents already bind its churches may find staying straightforward. For a body of autonomous congregations, I would close the letter to new churches now, keep the existing roster in compliance through January 22, 2027, and then decide whether a letter that gives churches nothing they need is worth keeping.
Related: Rev. Proc. 2026-8 overview
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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.