IRS Form 15644 (2026): Group Ruling Annual Filing
If your nonprofit is the central organization on a group exemption letter, the IRS has changed the way you satisfy your annual reporting duty. Beginning in 2026, the annual Supplemental Group Ruling Information (SGRI) filing — the core of the Form 15644 group ruling maintenance cycle — must be made on IRS Form 15644. The obligation itself is not new; the format is. And because Revenue Procedure 2026-8 modifies and supersedes the 45-year-old Rev. Proc. 80-27, this is a rare moment when the mechanics for maintaining a group exemption letter actually change.
At SW Accounting & Consulting Corp, we work with exempt-organization clients across Los Angeles — from religious groups and civic associations to national federations with dozens of subordinate chapters. Below is what the new form is, who has to file it, when, how, and the traps we expect to see in the first filing cycle.
What is IRS Form 15644, and what did Rev. Proc. 2026-8 change? 📝
Form 15644 is the new IRS form that central organizations use to make their annual Supplemental Group Ruling Information submission, replacing the old free-form letter under Rev. Proc. 80-27.
Group exemption letters let a single central organization obtain a group ruling that covers many subordinate organizations at once — think of a national religious body and its local congregations, or a federation and its state or local chapters. Under long-standing IRS practice, the central organization had to report certain information about its subordinates every year so that the group ruling stayed current. That requirement dates back to Rev. Proc. 80-27 and was later modified by Rev. Proc. 96-40.
Now Revenue Procedure 2026-8, 2026-4 I.R.B. 380, retains that annual-information requirement but standardizes the submission on a single form. New Form 15644, Supplemental Group Ruling Information, “ensures that all necessary information, described in section 7.02 of Revenue Procedure 2026-8, is provided in the correct format for efficient processing,” according to the IRS.
Who must file under the new Form 15644 group ruling process? 👥
Generally, every central organization with at least one subordinate organization must use Form 15644 annually to maintain its group exemption letter.
The filing duty applies broadly to central organizations, but there is one important carve-out that has always existed for religious groups and remains in place:
- Standard rule: A central organization with one or more subordinates must file Form 15644 each year to keep its group exemption letter in effect.
- Church exception: A central organization described in Section 501(c)(3) that is a church, or a convention or association of churches, and that maintains a group exemption letter may file Form 15644 but is not required to.
- Interim updates: Any central organization — church-status or not — may file Form 15644 outside the annual cycle to update its subordinate roster (for example, to add a new subordinate before the next annual filing is due).
If you administer a group ruling, the practical implication is that the church exception is narrow. It applies only to central organizations that are themselves churches or conventions/associations of churches. Many faith-adjacent groups — schools, publishing arms, ministries — do not fit that definition and remain subject to the annual filing rule.
When is Form 15644 due, and how do you file it? 📅
Form 15644 is due annually, at least 30 days but not more than 90 days before the close of your accounting period, and must be submitted by fax to (833) 312-5228.
The deadline is tied to your annual accounting period, not the calendar. For a June 30 fiscal-year end, that means the window is roughly April 1 through May 31. For a calendar-year filer, it is October 2 through December 1. Missing the window does not just embarrass the compliance calendar — it undermines the reliability of the group ruling itself.
Filing method matters too. The IRS instructions for Form 15644 direct submission by fax to (833) 312-5228. There is currently no e-file portal for the SGRI submission, and central organizations should keep a fax confirmation as part of the group-ruling file.
What can Form 15644 be used for beyond the annual filing? 🔄
Form 15644 is a multi-purpose SGRI vehicle — annual reporting, adding or removing subordinates, terminating the group exemption, and communicating other required changes.
Per the IRS, Form 15644 is used to:
- Update IRS records regarding subordinate organizations under the group exemption.
- Add or remove subordinate organizations under the group exemption.
- Terminate the group exemption when the central organization no longer wishes to maintain it.
- Provide notice to the IRS of any other changes required under Rev. Proc. 2026-8.
A useful practice tip from the IRS: each central organization should use Form 15644 to update information about its subordinate organizations before filing a group return on their behalf. Otherwise the group return can list subordinates whose status has quietly changed, which invites downstream questions from the IRS.
Which information does the IRS require on Form 15644? 📋
The form collects the subordinate information described in section 7.02 of Revenue Procedure 2026-8, formatted for efficient IRS processing.
Historically, the SGRI submission included, for each subordinate covered by the group ruling, information such as name, mailing address, employer identification number (EIN), and any changes since the last submission — plus lists of subordinates added, removed, or that had material changes to their purposes or activities. Rev. Proc. 2026-8 continues that framework and directs central organizations to the official Form 15644 and its instructions for the current data fields.
Because the form is now the “correct format” the IRS wants, a free-form letter that would have been accepted for decades under Rev. Proc. 80-27 is no longer the right way in. If you have a template from prior years, retire it — the new form is the official channel.
Form 15644 at a glance 📊
| Item | Rule |
|---|---|
| Who files | Central organization with one or more subordinates under a group exemption letter |
| Church exception | Section 501(c)(3) church or convention/association of churches may file but is not required to |
| Annual deadline | 30–90 days before the close of the accounting period |
| Interim updates | May be filed at any time (e.g., add subordinate before annual filing) |
| How to file | Fax to (833) 312-5228 |
| Governing guidance | Rev. Proc. 2026-8, 2026-4 I.R.B. 380 (supersedes Rev. Proc. 80-27, as modified by Rev. Proc. 96-40) |
📌 Key Takeaways
- Form 15644 is now the required format for the annual SGRI filing under Rev. Proc. 2026-8.
- Annual deadline: 30–90 days before the close of the accounting period.
- Submit by fax to (833) 312-5228; retain the confirmation with the group-ruling file.
- The same form handles adds, removals, and termination — not just annual reporting.
Frequently Asked Questions ❓
Q. Is Form 15644 replacing an existing form?
Not exactly. It replaces the free-form letter that central organizations used under Rev. Proc. 80-27 to submit their annual Supplemental Group Ruling Information. The information requirement continues; the submission format is now standardized on Form 15644.
Q. When is my first Form 15644 due?
The IRS says central organizations begin using Form 15644 in 2026 for the annual SGRI submission. Your specific deadline falls at least 30 days but not more than 90 days before the close of your annual accounting period.
Q. My organization is a church — do I have to file?
If your central organization is a Section 501(c)(3) church or a convention or association of churches, and it maintains a group exemption letter, filing Form 15644 is optional. Any other central organization with subordinates must file.
Q. Can I file Form 15644 to add a subordinate mid-year?
Yes. Central organizations may submit additional Form 15644 updates at any time — for example, to add a new subordinate before the next annual SGRI filing is due.
Q. What is Rev. Proc. 2026-8 and why does it matter?
Revenue Procedure 2026-8, published at 2026-4 I.R.B. 380, modifies and supersedes Rev. Proc. 80-27 (as modified by Rev. Proc. 96-40). It preserves the annual subordinate-information requirement and standardizes the submission on new Form 15644.
Q. Can I email Form 15644 or submit it through IRS.gov?
Under current IRS instructions, Form 15644 must be submitted by fax to (833) 312-5228. There is no e-file or upload portal for the SGRI submission at this time.
If your nonprofit administers a group exemption letter and wants a second set of eyes on the 2026 Form 15644 filing — including a subordinate-roster clean-up before submission — contact SW Accounting & Consulting Corp. Primary sources: IRS Form 15644, Rev. Proc. 2026-8 (2026-4 I.R.B. 380), and the IRS Charities and Nonprofits pages.
