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IRS and Treasury’s 2026–2027 Priority Guidance Plan: Five Projects for Tax-Exempt Organizations

The initial 2026–2027 Treasury and IRS plan lists five tax-exempt-organization guidance projects. Here is what each covers and what the plan does—and does not—mean for organizations.
From TheFinanceBase Team3 min to read
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The initial 2026–2027 Treasury and IRS Priority Guidance Plan lists five projects directly concerning tax-exempt organizations, including private-school eligibility, political campaign intervention, group exemption letters, donor-advised funds, and information reporting. Released September 29, 2026, it sets agency work priorities for the federal fiscal year—not deadlines for completing projects or changes to current law.

What the plan covers—and what it does not

The plan year runs from October 1, 2026, through September 30, 2027, in line with the federal fiscal year. The initial plan contains 121 guidance projects across several areas, including implementation of the One, Big, Beautiful Bill Act; deregulation and burden reduction; tax-exempt organizations; Tribal tax issues; and digital assets. The joint Treasury and IRS statement says the projects will be a focus of agency efforts during the plan year, but “the plan does not provide any deadline for completing the projects.”

A project’s appearance on the list describes planned guidance work; it does not itself amend the law, establish a new compliance requirement, or guarantee that guidance will be issued by September 30, 2027. The agencies note that some projects from the prior plan were omitted because they were completed or priorities changed, and that some unfinished projects may be considered for a future plan.

The five tax-exempt-organization projects

The plan’s “Tax Exempt Organizations” section lists five projects. The descriptions below reflect the plan’s stated scope; they are not predictions about the outcome or timing of future guidance.

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Subject Planned work Status stated in the plan
Private-school eligibility and racial discrimination Final regulations on applying the fundamental public policy against racial discrimination, including consideration of recent caselaw, when determining whether private schools qualify for recognition of exemption under section 501(c)(3). Proposed regulations were published September 4, 2026; the listed project is for final regulations.
Political campaign intervention Guidance on the section 501(c)(3) statutory prohibition against participating or intervening in political campaigns, commonly called the Johnson Amendment. The plan lists guidance; it does not state a completion date.
Group exemption letters Guidance revising Rev. Proc. 2026-08 for certain types of group exemption letters. The plan lists guidance; it does not state a completion date.
Donor-advised funds Guidance under sections 4966 and 6033 concerning certain donor-advised-fund arrangements. The plan lists guidance; it does not state a completion date.
Information reporting and fiscal sponsorship Guidance under section 6033 concerning exempt-organization information-reporting requirements, including fiscal-sponsorship arrangements. The plan lists guidance; it does not state a completion date.

These project descriptions come from the plan’s Tax Exempt Organizations section. For organizations tracking a particular issue, the distinction between a proposed rule and a planned guidance project matters: the private-school item is expressly at the final-regulations stage after proposed regulations were published, while the other entries are described as guidance projects.

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How organizations should read the list

  • Do not treat a listing as a new rule. The plan identifies future agency work. An entry alone does not change an organization’s present obligations.
  • Do not infer a release date. The plan year is a period for prioritizing work, not a promised timetable for any individual project.
  • Track official updates for relevant subjects. Treasury and the IRS say they intend to add priorities, reflect guidance issued during the year, and address projects that may result from legislative developments. They invite comments and suggestions throughout the year.
  • Check the plan page for the latest version. The IRS Priority Guidance Plan index identifies the initial 2026–2027 version released September 29, 2026, and is the place to check whether a later version has been posted.

The agencies’ invitation for comments and their plans for updates are described in IRS Notice 2026-23 and the joint statement accompanying the plan. The initial list is therefore a snapshot of priorities, not a fixed inventory for the entire year.

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