Groups whose chapters share one IRS exemption letter have until January 22 to Comply.

National groups with local chapters, and associations whose members hold tax-exempt status through a single "group exemption letter," have a date to mark: January 22, 2027. That is when the transition period for existing letters ends under Revenue Procedure 2026-8, which the IRS published in Internal Revenue Bulletin 2026-4 on January 20, 2026. This is a plain-language summary, not legal or tax advice.

What changed

The revenue procedure updates how organizations affiliated with a central organization obtain and keep recognition of exemption as a group. It applies to group applications filed after January 20, 2026, ending a pause on new group letters that began in June 2020, KPMG reported. Applications are now filed electronically on Form 8940.

A central organization needs at least five subordinates to obtain a new group letter, and it may maintain only one group letter, the procedure says. All subordinates must be the same type of 501(c) organization, and each must be affiliated with the central organization and under its general supervision or control. Private foundations and Type III supporting organizations are among the entities that cannot be subordinates, the advisory firm Forvis Mazars notes.

What the transition period covers

Central organizations that held a group letter as of January 20, 2026, have until January 22, 2027, to bring their groups into line, according to summaries by Forvis Mazars and the law firm Taft. Some rules are relaxed for subordinates already in a group; they do not have to adopt a uniform purpose statement, for example, Taft notes. After the transition, an existing group needs at least one subordinate to keep its letter, and a central organization that holds two letters must decide which to keep, Forvis Mazars says.

What a central organization should confirm

• That it holds only one group letter, and that every subordinate on it is the same type of 501(c) organization.
• That its roster of subordinates is current, including additions, removals and name or address changes. Forvis Mazars gives the example of an organization accidentally left off the roster for three years, which then faces automatic revocation; see how three missed filings end an exemption.
• That it can show each subordinate is affiliated with it and under its general supervision or control.
• When its annual submission is due. The procedure requires the central organization's annual information on its subordinates 30 to 90 days before the end of its annual accounting period, and KPMG notes it must be submitted electronically. Forvis Mazars describes the deadline as at least 30 days before year-end, which is the same final cutoff.

Why boards should care

In our view, a group letter is easy to forget until a funder, state regulator or bank asks for proof of exemption. Subordinates covered by a group letter do not hold their own determination letters, and Forvis Mazars notes this can create confusion with local funders, grantors, state registrations and bond applications. A board member at the national office could ask for the current roster and the last annual submission to the IRS before the year ends. Chapters can also check that each one's Form 990 filing is current.