IRS Update! The SGRI - Subordinate Update Procedures.

In January of 2026, the IRS released updates to the group exemption program. In July 2026, the IRS released specific details explaining how central organizations will manage their group exemptions going forward. This included providing a specific form central organizations should use for interim or annual updates.

First, what is a group exemption?

At a high level, there are two ways an organization can obtain recognition of its 501(c) status: it can apply for recognition independently, or it can obtain recognition as a subordinate organization under a group exemption.

Under a group exemption, a central organization maintains a group of subordinate organizations that qualify for tax-exempt status under the same subsection of section 501(c). The central organization is responsible for providing the IRS with updates about the organizations included in its group exemption, including additions, deletions, and certain other changes. The IRS explains this very well in Publication 4573.

Historically, the IRS did not provide a standardized form or rigid format for submitting these updates. We have seen updates from large national organizations that look very official. We have also seen updates from tiny organizations with fewer than 20 subordinates that were essentially Word documents containing a list of organizations.

As of 2026, the IRS has formalized the process. The good news is that the IRS has officially formalized the process. The bad news is that the IRS has officially formalized the process.

Form 15644: Supplemental Group Ruling Information

The IRS now requires central organizations use Form 15644, Supplemental Group Ruling Information (SGRI) to report updates. The IRS divides the form into a header, information about subordinate organizations, attestations, and supplemental information.

Header

The header contains basic information about the central organization that holds the group exemption. The most complicated thing about this section is the GEN number and the number of subordinates. Ideally, large group exemption holders will have a roster that lists organizations that are on the official subordinate list as well as organizations that are actually listed in the Business Master File.

Part I: Information About Subordinate Organizations

Part I is a questionnaire about the subordinate organizations included in the group exemption.

This section focuses on identifying changes or circumstances affecting the group, such as subordinate organizations that have changed their purposes or organizations whose tax-exempt status has been automatically revoked.

Part II: Attestations

The IRS now requires the central organization to make several specific attestations regarding its subordinate organizations.

Among other things, the central organization must attest that:

● All subordinate organizations included in the group exemption are described in the same paragraph of section 501(c).

● No subordinate organization included in the group exemption is ineligible for inclusion.

● All subordinate organizations included in the group exemption have adopted a uniform purpose statement.

These attestations are important because the annual update is no longer simply a matter of sending the IRS a list of names and EINs. The central organization is affirmatively representing that the organizations included in its group continue to satisfy the requirements of the group exemption.

Part III: Supplemental Information

Part III is where the details start multiplying.

The first section is used to report subordinate organizations that have experienced a change in purpose. If a subordinate changed its purpose during the applicable period, information about that change is reported here. The final section is used to report changes to the subordinate roster itself,

including organizations being added to or deleted from the official subordinate list.

And Then There Are the Practical Problems

If you are working through Form 15644 yourself while reading this, you may already have noticed some problems.

For example, the IRS asks whether subordinate organizations have been automatically revoked, but the form does not provide an obvious corresponding section for listing those revoked organizations. You may also discover that seemingly simple things become surprisingly awkward, such as a subordinate organization's legal name being too long for the space provided on the form.

For a central organization with 10, 15, or even 50 subordinate organizations, these issues may be annoying but manageable.

For a national organization with hundreds or even thousands of chapters, the problem changes completely. At that scale, manually preparing and reconciling the information required by Form 15644 can quickly become impractical. The central organization needs a reliable way to determine not only what its internal records say, but also what the IRS currently has on record.

That is where automation becomes particularly valuable.

At RENOSI, we have developed our own system that automatically populates Form 15644 with the appropriate subordinate information. Our system also connects the preparation process with data from various IRS sources. This allows us to identify organizations that have been revoked, determine which organizations currently appear in the IRS Business Master File, and identify organizations that still need to be added to the group exemption.

For a small group exemption, Form 15644 may simply mean a little more paperwork.

For a group exemption containing thousands of subordinate organizations, it represents something much larger: the IRS has transformed what was historically a relatively informal annual update into a standardized compliance process that requires considerably more structured data, reconciliation, and oversight.