The Internal Revenue Service has introduced Form 15644, Supplemental Group Ruling Information, for central organizations that maintain group exemption letters.
Form 15644 is the annual reporting form used to provide the IRS with updated information on subordinate organizations included in a group exemption. The form is part of the revised group exemption procedures under Revenue Procedure 2026-8.
Overview of the Update
Revenue Procedure 2026-8 updated the rules for obtaining and maintaining group exemption letters. Under these rules, a central organization generally must report certain information each year about the subordinate organizations covered by its group exemption, unless an exception applies.
Beginning in 2026, central organizations generally use Form 15644 to make this annual submission. The form may also be used to report updates during the year, such as adding or removing subordinate organizations before the annual filing period.
Form 15644 does not replace the process for requesting a new group exemption letter. New group exemption requests continue to be submitted on Form 8940 through Pay.gov, with the required supporting information and applicable IRS user fee.
Key Provisions
- Purpose of Form 15644
Form 15644 is used to maintain and update IRS records for subordinate organizations included in a group exemption.
The form may be used to report additions, removals, terminations, name or address changes, and other updates required under Revenue Procedure 2026-8.
- Annual filing requirement
A central organization with one or more subordinate organizations generally must submit Form 15644 each year.
The annual submission is required even if there are no reportable changes. In that case, the central organization should indicate that there are no changes to report.
- Filing deadline
Form 15644 is generally due at least 30 days, but not more than 90 days, before the close of the central organization’s annual accounting period.
Central organizations may also submit updates during the year if information needs to be reported before the annual filing window.
- Church exception
A central organization described in Section 501(c)(3) that is a church, or a convention or association of churches, may submit Form 15644 but is not required to do so.
- Filing method
Form 15644 is currently submitted to the IRS by fax at 833-312-5228.
Practical Considerations
Organizations that maintain group exemption letters should:
- Confirm whether Form 15644 applies to their group exemption
- Calendar the annual filing window based on the central organization’s year-end
- Maintain an updated list of subordinate organizations
- Track additions, removals, automatic revocations, and name or address changes
- Update internal procedures for collecting annual subordinate organization information
Conclusion
Form 15644 adds a formal annual reporting step to the group exemption compliance process under Revenue Procedure 2026-8.
Central organizations should review their group exemption procedures, confirm applicable filing deadlines, and maintain accurate subordinate organization records to support continued group exemption coverage.
Have a question on how Revenue Procedure 2026-8 could affect your organization? Contact our Calibre team.
