IRS puts its new group exemption form online as nonprofit networks face a January 2027 deadline

The IRS has made Form 15644, the annual report that central organizations, such as national bodies with local chapters, file to keep their group exemptions, available as an online form. In its Exempt Organizations Update on October 30, 2026, the agency said the form is now a mobile-friendly form that can be completed and submitted from a computer, phone or tablet. Filers need an IRS Online Account for mobile-friendly forms that require signatures. When the IRS introduced Form 15644 in July, it said the form had to be submitted by fax.

A group exemption lets a central organization obtain recognition of tax exemption for its chapters, locals, posts or units as a group, so that each of these subordinate organizations does not have to apply on its own. In return, the central organization must keep the IRS informed about them every year.

What the form is for

Form 15644 carries what the IRS calls supplemental group ruling information. Central organizations use it to update the IRS's records on their subordinates, to add or remove them, to terminate a group exemption and to report other changes. It is due every year at least 30 days, but no more than 90 days, before the end of the central organization's accounting year, and updates can be sent at any time. For a group whose year ends on December 31, that window runs from about October 2 to December 1, by our calculation. A central organization that is a church, or a convention or association of churches, may file the form but does not have to.

The 2026 rules behind it

The form follows Revenue Procedure 2026-8, published in the Internal Revenue Bulletin on January 20, 2026, which replaced group exemption procedures dating from 1980. The IRS had stopped accepting new applications for group exemption letters on June 17, 2020, while it worked on the update, and resumed after January 20, 2026. The Treasury Department and the IRS received 29 comments on the proposed version.

Under the procedure, general supervision means that each year the central organization obtains, reviews and keeps information on each subordinate's finances, activities and filings, and tells it about the rules for keeping its exemption. The information part is optional for subordinates that do not have to file an annual return or notice. A copy of a subordinate's Form 990 or Form 990-EZ satisfies it. A copy of a Form 990-N, the electronic notice filed by organizations that do not have to file the longer returns, does not. Our guide to Form 990 explains which return each organization files.

The January 2027 deadline

Central organizations that already held group exemption letters when the new rules were published have a transition period that ends on January 22, 2027. Before then, through their supplemental group ruling information submissions, they must:

• if a letter has no subordinates, add at least one or terminate the letter
• if they hold more than one group exemption letter, terminate all of them or all but one
• remove any existing subordinate that they cannot ensure is affiliated with them and under their general supervision or control
• remove subordinates described in a different paragraph of section 501(c) from the one named in their group application

Removal has consequences for the subordinate. Once an organization is removed from a group exemption letter, the IRS no longer recognizes its exemption unless it takes one of the steps the procedure sets out, such as filing its own application and receiving a favorable determination. An organization that the tax code does not require to apply for recognition can still qualify as tax-exempt without it, provided it meets the requirements and files its annual returns or notices where required. Removal does not affect the tax-exempt status of churches and conventions or associations of churches.