Do Baptist conventions (national or state level) or local associations “supervise or control” local churches? Ask almost any Baptist and you will get a quick “no.” The autonomy of the local congregation is as close to a first principle as Baptists have.

Yet thousands of Baptist churches sit on IRS “group exemption letters” that rest on the premise that conventions exercise “general supervision or control” over their congregations—at least for purposes of the group-exemption program.

On January 20, 2026, the IRS rewrote those rules and, for the first time, specifically defined important parts of them. Conventions now must decide whether to operate under that newly defined, though limited, form of “general supervision,” or step back. In September the SBC Executive Committee adopted procedures to comply. Its CEO, Jeff Iorg, told trustees the IRS language was “problematic…at several points related to our polity—particularly issues related to autonomy and ecclesiology.”

I’d suggest an easy fix for many local churches. You do not need a group exemption letter or the problems it might create. But you can get your own letter, without telling the IRS you are legally supervised by another Baptist group.

Your Church’s Exemption Is Not at Stake

Let me start with what did not change. Most charities must apply to the IRS to be recognized as tax-exempt. Churches need not. A church that meets the requirements of § 501(c)(3) is exempt automatically, and gifts to it are deductible, letter or no letter. The new rule says expressly that removal from a group letter does not affect a church’s exemption.

So no church is losing its exemption. But each convention and church now has a decision to make.

What Is a “Group Letter?”

Churches sometimes want a letter anyway: a donor or lender asks for one, or a state property or sales-tax office prefers one. A church can get its own “determination letter” by filing IRS Form 1023 and paying the user fee (currently $600). For decades the convenient alternative was a group letter, which let a convention or association cover its affiliated churches with one IRS letter.

The condition has always been that subordinates be “affiliated with” the central organization and “subject to its general supervision or control.” Until this year the IRS never defined “general supervision,” and conventions read it loosely. Agreeing with a confession of faith, or cooperating in a unified budget, seemed enough. Catholics and Presbyterians, whose polity includes real denominational oversight, obtained letters readily. Baptist bodies reasonably asked for equal access to the group exemption system, and the IRS didn’t press the point of denominational “general supervision.” So the SBC and most state conventions have held group exemptions for years. A church could even be covered by several at once: individual, state, and national.

But in 2020 the IRS signaled changes were coming and stopped accepting group applications. This January, it issued the final rule, Revenue Procedure 2026-8.

What Changed?

The final rule isn’t as bad as it could have been. The IRS softened the 2020 proposal’s reporting burdens after comments from many church groups. Unlike other nonprofits, conventions of churches need not collect their local churches’ financial reports or file annual updates with the IRS. For churches already on a letter on January 20, 2026, “general supervision” can be satisfied by an annual email reminding them of their tax obligations.

But three changes matter.

Churches added to a group after January 20, 2026, face new conditions. This includes any newly formed church, as well as older churches joining the letter. Each must sign a written authorization acknowledging that the convention may remove it from the letter “with or without cause.” Each must also place in its governing documents a “uniform purpose statement” shared by the other subordinates with the same purpose. The rule requires uniform language, and it’s hard to see how that doesn’t require conventions to set that statement. A convention setting language for local church constitutions is uneasy territory for Baptists.

Removing a church comes with IRS strings. Messengers can still vote a church out of friendly cooperation. But to drop it from the letter, the convention must give the church 30 days’ advance written notice, file a removal notice with the IRS (new Form 15644, by fax), and then notify the church again. A church voted out of friendly cooperation without that notice stays on the letter until the convention gives notice and files. I have a hard time imagining a court forcing a convention to keep a church it has voted out. But the new rules create a risk of “Baptist limbo”: a church out of fellowship but still on the group letter. Conventions need to think about how to avoid this pitfall.

The grace period is short. The 2020 proposal would have let existing subordinates keep their status permanently. The final rule gives existing letters until January 22, 2027, to comply. After that, even grandfathered churches must meet the new affiliation and supervision standards, though they are spared the signed authorization and the uniform purpose statement. That deadline binds conventions, not churches, but it shows which way the rules are moving.

The Executive Committee’s general counsel said the new policy “takes the necessary steps to address, in good faith,” the revenue procedure “while maintaining the autonomy and self-governance of local Southern Baptist churches.” I take that to mean the EC sees these problems, too. I trust it will explain them to local churches so they can make informed decisions—and so the SBC can decide whether this new system is worth the risks at all.

The Camel’s Nose

Why should any of this worry a church that never plans to leave its convention?

Anyone who follows the SBC knows there has been litigation about the relationship between the SBC and its churches. Plaintiffs regularly try to reach convention pockets for local church wrongs, arguing that the state convention or the SBC controlled the church. Others may try to hold a church answerable for a convention’s acts. Courts have generally rejected those arguments where the record reflects traditional Baptist polity: autonomous churches in voluntary cooperation.

The IRS’s “supervision” is light, and I expect most courts will keep reaching the right answer. But for a church added after January 20, 2026, expect plaintiffs to reach for three exhibits: 1) the group letter listing the church as a subordinate under the convention’s “general supervision or control,” 20 a signed paper conceding the convention can remove it for any reason, and 3) the uniform purpose statement in its constitution. Of course, Baptists will answer, “It says supervision, but it’s not much supervision.” Even when churches win that argument, fighting these documents case after case will add up. And a future revision of these rules could intrude further into Baptist polity.

What does the church get in return? A letter that was never a legal requirement at all.

What I Recommend

For churches: Resist the temptation to accept the IRS’s church polity to save a few bucks. No one is saying you must abandon group letters immediately. But if a lender, donor, or tax office needs paper, it’s healthiest to get your own determination letter. That cedes supervision or control to no one and keeps your polity clear. Church plants, especially, should plan now to decline the offer of “group” exemption status.

For conventions and associations: Choose deliberately. You may not need to cut off the letters entirely, but you need to have the discussion now. Reasonable options include closing the letter to further additions, restricting it to the institutions the convention actually controls, or weaning churches off over time. Keep a dated roster of who was on the letter on January 20, 2026. For a convention of churches, it may be the only proof of who is grandfathered. And write a removal procedure before the next annual meeting needs one.

For convention institutions and related ministries: Schools, camps, and other institutions on a convention’s letter face harder questions than churches do, especially those that stopped filing Form 990 on the theory that they are “integrated auxiliaries” of a church. That theory doesn’t fit every ministry.

Four Questions to Answer this Month

• Is our church on a group exemption letter? Whose, and since when?
• Were we added before or after January 20, 2026?
• What is our convention’s procedure for removing a church from the letter?
• Do the schools, camps, or other ministries connected to us file Form 990? If not, why not?

The Baptist Faith & Message doesn’t dictate answers. But this is a question of prudently protecting church polity laid out in Scripture. I think Baptist principles counsel churches to decline the government’s offer—it’s a “convenience” that does not justify the pinch of hierarchy.

Editor’s Note: This article discusses legal and theological principles, but should not be taken as official legal advice. You should consult a lawyer about your situation before taking action.