After more than 45 years under a reporting framework largely governed by Rev. Proc. 80-27 (PDF), the IRS has modernized the group exemption reporting process through Revenue Procedure 2026-8 (PDF) and the release of Form 15644, Supplemental Group Ruling Information (SGRI). New Revenue Procedure 2026-8, 2026-4 I.R.B. 380, modifies and supersedes Rev. Proc. 80-27, 1980-1 C.B. 677, as modified by Rev. Proc. 96-40, 1996-2 C.B. 301. The new form standardizes the information central organizations must provide to maintain a group exemption and report changes involving subordinate organizations.

What is Form 15644?

Form 15644 is the IRS' new prescribed method for reporting information related to group exemptions. Central organizations use the form to:

• • Update information regarding subordinate organizations
  • Add or remove subordinate organizations from a group exemption
  • Report other required changes affecting a group exemption
  • Terminate a group exemption, when applicable

The IRS has indicated that the form is intended to improve consistency, efficiency, and oversight of group exemption reporting.

Who must file?

Generally, central organizations maintaining one or more subordinate organizations under a group exemption letter must submit Form 15644 annually. Certain church group exemptions may file voluntarily but are not required to do so.

Key changes from prior guidance

In addition to introducing a standardized reporting form, Revenue Procedure 2026-8 updates the information and certifications central organizations must provide regarding subordinate organizations. Depending on the filing purpose, reportable items may include:

• • Additions or removals of subordinate organizations
  • Changes to information previously reported to the IRS
  • Automatic revocations or other status changes affecting subordinate organizations
  • Annual certifications regarding continued eligibility for inclusion in the group exemption

A notable enhancement is the IRS' formal recognition of interim updates. Central organizations may use Form 15644 to notify the IRS of changes – including the addition or removal of subordinate organizations – as they occur rather than waiting for the next annual reporting cycle.

When is it due?

Form 15644 generally must be filed annually between 30 and 90 days before the end of the central organization’s accounting period. Organizations may also submit updates throughout the year as changes occur. Revenue Procedure 2026-8 became effective on Jan. 20, 2026.

Filing method: A step toward electronic reporting?

One of the more significant operational changes involves how group exemption information is submitted to the IRS.

Revenue Procedure 2026-8 contemplated electronic submission of Supplemental Group Ruling Information and provided a mailing alternative until the IRS established reporting procedures. The IRS has now released Form 15644 as the prescribed method for annual SGRI submissions and certain interim updates.

Currently, Form 15644 must be submitted by fax to 833-312-5228. Although Revenue Procedure 2026-8 envisioned electronic reporting, the IRS has not yet announced whether future submissions will be made through Pay.gov, commercial tax software, or another electronic platform. As a result, the current fax-based submission process may represent an interim step as the IRS continues to implement the reporting framework described in Revenue Procedure 2026-8 and aims to streamline exempt organization compliance reporting.

What does CohnReznick think?

Form 15644 is more than simply a new IRS form. It represents another step in the IRS' broader effort to standardize and modernize exempt organization compliance. While central organizations have long been required to provide information regarding subordinate organizations, the introduction of a dedicated reporting form creates a more structured process for maintaining and updating group exemption records.

Perhaps most notably, organizations now have a clear mechanism to report certain changes throughout the year rather than waiting for the annual reporting cycle. For organizations with large or frequently changing group exemption structures, this may provide a more efficient way to keep IRS records current and reduce administrative issues down the road.

Organizations operating under a group exemption should use the implementation of Form 15644 as an opportunity to review subordinate organization information, confirm records are current, and assess whether any updates should be reported before the next annual submission.

Contact your trusted advisors for assistance with this review.