Consistent with changes made by Revenue Procedure 2026-8 (see Tax Alert 2026-0280) to longstanding guidance on group exemption letters, the IRS has released Form 15644, Supplemental Group Ruling Information (SGRI), to standardize the annual reporting of information related to subordinate organizations in group exemptions.

Background

On January 20, 2026, the IRS published Revenue Procedure 2026-8, which supersedes longstanding guidance on group exemption letters under Revenue Procedure 80-27 and finalizes, with modifications, the proposed revenue procedure outlined in Notice 2020-36 (see Tax Alert 2020-1256). The revenue procedure represents the first comprehensive update to the group exemption framework in more than 45 years and modernizes the rules for obtaining and maintaining group exemption letters for affiliated organizations described in IRC Section 501(c).

Annual filing required to maintain a group exemption

Beginning in 2026, central organizations must annually submit Form 15644 to the IRS to provide the information on their subordinate organizations required by Revenue Procedure 2026-8 as a condition of maintaining their group exemption letters. Central organizations must use Form 15644 to:

• Add or remove subordinate organizations under a group exemption
• Confirm that each new subordinate:
• Authorized in writing its inclusion in the group exemption
• Acknowledged that the central organization may remove the subordinate upon 30 days' written notice, with or without cause
• Is organized and operated consistently with the information provided by the central organization in its group exemption application (as updated by its annual group exemption updates to the IRS)
• Complies with IRS standards for schools, hospitals and IRC Section 501(c)(4) organizations, as applicable
• Provide notice to the IRS of any changes to the purpose, character or method of operation of any subordinate organization, as required under Revenue Procedure 2026-8
• Attest that the group exemption meets certain requirements of Revenue Procedure 2026-8, including that:
• All subordinates are described in the same paragraph of IRC Section 501(c) and are eligible for inclusion in the group exemption
• All subordinates with the same purpose have a uniform purpose statement in their governing documents
• Terminate a group exemption

A central organization must annually submit Form 15644 at least 30 days, but not more than 90 days, before the close of the central organization's tax year. A central organization may submit Form 15644 at any time to provide updates, such as adding or removing a subordinate organization from its group exemption.

Implications

Before Form 15644, central organizations of group exemptions were required to annually mail updated SGRI information on their subordinate organizations to the IRS, without IRS guidance on the format in which the updates should be submitted. With the release of Form 15644, the IRS has standardized the annual SGRI group exemption reporting process to comply with Revenue Procedure 2026-8 to specify the format (i.e., Form 15644) and means (i.e., via fax) of submitting the information. Central organizations should familiarize themselves with the updated group exemption requirements of Revenue Procedure 2026-8, as Form 15644 requires them to attest their compliance with certain requirements of that revenue procedure.

Under Revenue Procedure 2026-8, central organizations have a limited window to annually submit Form 15644. Central organizations that were previously required to submit their annual SGRI updates at least 90 days before the close of each tax year must now submit Form 15644 at least 30 days, but no more than 90 days, before the close of their tax year. If a central organization fails to submit Form 15644 within this window in a given tax year, the IRS could revoke its group exemption, which would effectively revoke the federal income tax exemptions of all subordinates within that group.