Jan 22, 2027 group exemption cleanup checklist
Group exemption letters that existed on Jan 20, 2026 get temporary relief from four of the new rules until Jan 22, 2027. Before then, the central organization brings its group in line and records it on Form 15644 (Rev. Proc. 2026-8 §12.02(2)).
Checked against IRS sources on Oct 23, 2026
Two deadlines
- Your yearly Form 15644 window: 90 to 30 days before your fiscal year ends (table by year-end).
- Before Jan 22, 2027 for this cleanup, whatever your year-end. If your window opens later, file the cleanup as an interim update.
What applies to your group
| If | Then, before Jan 22, 2027 |
|---|---|
| You hold more than one group exemption letter | Keep one, give the IRS copies of all of them, and terminate the others (§12.02(2)(c)). |
| Your group letter has no chapters (if the IRS file shows none under your GEN, check your records) | Add at least one chapter, or terminate the group exemption letter (§12.02(2)(b)). |
| Some chapters fall under a different 501(c) paragraph than the one in your group application | Remove them. |
| Some chapters aren’t affiliated with you, or you can’t supervise them | Remove them. |
Revoked chapters aren’t a cleanup step: report them on your next Form 15644 (Rev. Proc. 2026-8 §7.02(2)(a)(iii)), and the IRS removes them from the group. A revoked chapter can rejoin only after the IRS reinstates it (§9.07).
Steps
- Get your IRS chapter list and compare it with your own (how).
- Decide which situations above apply. Ask your adviser where judgment is needed, for example on supervision.
- Give removal notice early. Give each chapter you remove at least 30 days’ notice before the filing that removes it, and tell it how it can get its own exemption (Rev. Proc. 2026-8 §8.02(2)–(3)). Send notice by mid-December 2026. December 21 is the last safe day for a filing before Jan 22, 2027.
- File Form 15644: as your annual update if your window is open, otherwise as an interim update. Keep a copy and the confirmation.
Our Form 15644 guide walks through each part of the form.
Sources
- IRS, Rev. Proc. 2026-8 (PDF): §§7.02(2), 8.02, 9.07 and 12.02.
- IRS, Form 15644 and its instructions (Rev. 10-2026, PDF).
General information from public IRS documents, checked Oct 23, 2026. Not tax or legal advice. Not affiliated with the IRS.