Insights

What Rev. Proc. 2026-8 asks of your group by January 22, 2027

October 13, 2026 · 5 minute read

For a parent organization with an existing group letter, four checks decide whether anything has to change before the transition period ends. Here they are in plain words, with the section of the revenue procedure under each.

Why January 22, 2027

The IRS published Rev. Proc. 2026-8 on January 20, 2026. It replaced Rev. Proc. 80-27, the rules group exemptions had run on since 1980. For letters that already existed on that date, four of the new requirements wait until a transition period ends on January 22, 2027 (s. 12.02(2)(a)). After that, they apply in full.

Commenters asked for a three-year transition. The IRS declined, saying it would have to run two group exemption programs side by side (Notice 2026-8). As of October 13, 2026 we found no notice moving the date.

The four checks

1. At least one chapter

A group letter now needs at least one subordinate organization to stay alive. If yours covers none, you must add one or terminate the letter before January 22 (s. 12.02(2)(b)). A chapter added now is not a "preexisting" chapter, so it must meet the full new rules from day one, including a written authorization that says you may remove it with or without cause (s. 12.03, Example 2; s. 4.06).

2. Only one letter

A parent may keep one group letter. If you hold more than one, choose the one to keep, send the IRS copies of all of them, and terminate the rest (s. 12.02(2)(c)). You, not the IRS, tell the chapters under the letters you end how they can get recognition on their own (s. 12.03, Example 1).

3. Every chapter affiliated and under your general supervision or control

Each chapter must be affiliated with you and subject to your general supervision or control (s. 12.02(2)(d)). The revenue procedure defines both terms:

• Affiliated: the facts show it is your chapter, local, post or unit. Being on your group return, or in a chapter directory you update every year, are the examples given (s. 4.02(2)).
• General supervision: every year you obtain, review and keep information on each chapter's finances, activities and filing compliance, and every year you send chapters written information, or otherwise educate them, on what they must do to keep their exemption (s. 4.02(3)). A copy of a chapter's Form 990 or 990-EZ covers the first part. A copy of its Form 990-N e-Postcard does not.
• Control: for example, you appoint a majority of its directors or officers, a majority of its directors or officers are yours, or a written agreement gives you control over its activities (s. 4.02(4)).

If you cannot make sure a chapter meets this test, the rule says you must remove it.

4. Every chapter in your group's 501(c) paragraph

All chapters must be described in the paragraph of section 501(c) your group application named. Chapters in any other paragraph must be removed (s. 12.02(2)(e); s. 12.03, Example 3). In the IRS master file we downloaded on October 13, 2026, 321 of 3,957 parent organizations show chapters under more than one paragraph.

How the changes are filed

All four are done through supplemental group ruling information, or SGRI, submissions (s. 12.02(2)(f)). Since July 14, 2026 the IRS takes SGRI only on Form 15644, sent by fax to 833-312-5228. Each list of changes gives the name, mailing address and EIN of every chapter on it (s. 7.02(2)).

You do not have to wait for your annual window. The revenue procedure and the IRS announcement both say a central organization may send updates at any time (s. 7.01). Form 15644 has boxes for an annual update, an interim update and ending the group.

Your officer signs the form under a penalties of perjury declaration. There is no paid-preparer block, and the form goes in under your organization's name.

If you already meet all four

Then nothing has to change by January 22. The revenue procedure says so directly: a parent with at least one chapter, all chapters in the same paragraph, and a relationship with them that meets s. 4.02 "is not required to make any changes" during the transition period (s. 12.03, Example 4). Your annual Form 15644 is still due 30 to 90 days before your fiscal year ends, and any chapter you add later follows the full new rules.

If you do not

The IRS may terminate a group letter if, among other grounds, the parent has no chapters, fails to exercise general supervision or control over one or more chapters, fails to send timely and complete SGRI, or otherwise fails the revenue procedure (s. 8.01(1)). It will remove a chapter it finds in a different 501(c) paragraph from the one your application named (s. 8.02(1)(a)(iv)).

After a termination or removal, the IRS does not recognize the chapter's exemption until the chapter gets recognition another way, for example by applying on its own (s. 9.02, 9.03 and 9.05). For a church chapter, exempt status is not affected (s. 9.04).