Starting a Church & 501(c)(3)

The 14 IRS Characteristics of a Church (and Why You Don't Need All 14)

Published 2026-09-27 · Starting a Church & 501(c)(3)

Short answer: the IRS 14 characteristics of a church are a list of features the agency has historically looked at when deciding whether an organization is a church for federal tax purposes. They aren't a test with a passing score. No single characteristic is decisive, plenty of established churches lack several of them, and the IRS says it weighs these features together with all the other facts and circumstances.

Somebody on your board found the list. Now there's a question in the room about the seminary you don't run, the denominational literature you don't publish, and the building you don't own, and whether any of that means you aren't really a church.

It doesn't. The list is still worth understanding properly, because it tells you what the agency is looking for underneath the fourteen bullet points, and that's a genuinely useful thing for a young church to know before it works through the nine steps, in order.

Where the 14 characteristics come from

The list isn't in the tax code. Congress never defined "church" in the Internal Revenue Code, largely because a statutory definition of a religious body raises constitutional problems nobody wanted to create.

So the IRS developed a working set of characteristics for its own examiners, and it has published them for decades, most accessibly in IRS Publication 1828, Tax Guide for Churches and Religious Organizations (IRS Publication 1828, Tax Guide for Churches). Publication 1828 lists the characteristics and then says something people skip past: the IRS considers these characteristics *along with other facts and circumstances*.

That sentence is the whole story. The list is a description of what churches commonly look like, not a definition of what one must be.

Courts have said much the same thing, and some have been openly critical of treating the list as a checklist. Part of the reason is that several of the items describe a large, settled, denominationally organized institution, which is not what most congregations in the country look like.

What are the 14 characteristics?

Here's the list as the IRS states it (IRS, Definition of a church):

1. A distinct legal existence
2. A recognized creed and form of worship
3. A definite and distinct ecclesiastical government
4. A formal code of doctrine and discipline
5. A distinct religious history
6. A membership not associated with any other church or denomination
7. An organization of ordained ministers
8. Ordained ministers selected after completing prescribed courses of study
9. A literature of its own
10. Established places of worship
11. Regular congregations
12. Regular religious services
13. Sunday schools for the religious instruction of the young
14. Schools for the preparation of its ministers

Read them together and a picture forms: an organized religious body with its own beliefs, its own leadership structure, its own people, and a regular pattern of gathering them.

Do you really not need all 14?

You don't, and it's worth being concrete about why.

Item 14: schools for the preparation of its ministers. A congregation of two hundred people doesn't operate a seminary. Neither do the overwhelming majority of churches in the country.

Item 9: a literature of its own. Most congregations use published curricula and hymnals written by somebody else.

Item 8: ministers selected after prescribed courses of study. Whole traditions ordain on calling and examination rather than on a degree program, as a matter of conviction.

Item 5: a distinct religious history. A church plant that held its first service last spring has, by definition, almost no history. That can't be disqualifying, or no new church could ever exist.

Item 6: membership not associated with any other church or denomination. Read strictly, this would be a problem for any congregation whose members attend a midweek group elsewhere.

If all fourteen were required, most of the churches on most of the streets in this country would fail. That isn't how the list works, and it isn't how it's applied.

Which characteristics actually carry weight?

In practice, the ones that describe an organized religious body with an identifiable congregation do most of the work. If you're trying to understand where your church stands, look hard at these.

Regular religious services and regular congregations (11 and 12). This is the center of gravity. A church gathers people, repeatedly, for worship. A ministry that produces content, runs a benevolence program, or supports missionaries may do enormously valuable religious work without gathering a congregation, and that distinction is exactly where "church" and "religious organization" part company. If that question is live for you, church vs. ministry vs. nonprofit is the one to read next.

A distinct legal existence (1). This one you can simply do. Incorporating creates a legal entity that exists apart from its founders, holds property, signs contracts, and continues when leadership changes. It's also the item most commonly missing in a two-year-old church. What incorporation actually requires walks through it.

A definite and distinct ecclesiastical government (3). Your bylaws. Who decides what, who may be removed and how, what the board does, how members are received. Written down and actually followed.

A recognized creed and form of worship, and a formal code of doctrine and discipline (2 and 4). A statement of faith and a written membership and discipline process. Most churches have the first and skip the second.

Established places of worship (10). Note the phrasing: a *place*, not a building you own. A rented school gymnasium used every Sunday is an established place of worship.

An organization of ordained ministers (7). You have a pastor, and there's a recorded process by which the church recognized that person.

Every one of those is something a small, young, non-denominational church can genuinely have. Several are just paperwork you were going to need anyway.

How this looks for a new or non-traditional church

The church plant. No history, no literature, no seminary, meeting in rented space. It can still have articles of incorporation, bylaws with a real governing structure, a statement of faith, a recognized pastor, a membership process, a fixed meeting place and weekly services. That's a church that presents well, and it's achievable in the first ninety days.

The house church. Meeting in a home doesn't disqualify anything, since "established place of worship" is about regularity, not square footage. The things house churches more often lack are the organizational ones: no entity, no bylaws, no minutes, no separate bank account. Those are fixable.

The online-only ministry. Here's where the real question sits, and it deserves an honest answer rather than an encouraging one. An organization whose audience never assembles has difficulty showing a congregation in any meaningful sense. It may well qualify as a religious organization under 501(c)(3), a different and perfectly respectable thing, without qualifying as a church. If that describes you, don't guess. Talk to a qualified adviser before you build a structure on the assumption.

The multi-site or network church. Usually straightforward, provided the governing documents make clear what the single legal entity is and how the sites relate to it.

Why the label matters at all

It's easy to treat this as a philosophical question. It isn't. The classification carries concrete consequences.

Churches are treated differently from other exempt organizations in several ways. They aren't required to apply for recognition of exemption to be exempt (IRS, About Form 1023). They're generally not required to file the annual Form 990 information return. They have specific procedural protections around IRS examinations (IRC §7611, Church tax inquiries and examinations). And ministers of a church have access to compensation treatment, the housing allowance in particular, that turns on the employer being a church and the individual being a minister for tax purposes.

That last point is where churches most often trip. The housing allowance depends on both halves being true, and it only ever applies to compensation designated in advance of the pay it covers (IRS, Ministers' Compensation & Housing Allowance). Getting the entity classification right early is part of making the rest of it defensible later.

What to do about it

1. Stop scoring yourself out of fourteen. It isn't that kind of list, and treating it as one produces anxiety without producing action.
2. Fix the organizational items you can control. Legal existence, bylaws, a statement of faith, a membership process, recorded leadership recognition. These are the ones an examiner can verify and the ones a young church most often lacks.
3. Keep evidence of the ordinary things. Service times and locations, bulletins, membership rolls, board minutes, baptism and marriage records. Not because someone is coming, but because the ordinary record of a church operating as a church is the most persuasive material there is.
4. Write down what you do have. A one-page internal summary of how the church is governed, when and where it gathers, what it believes, and how ministers are recognized is worth the hour it takes. The church formation documents cover most of what belongs in it.
5. Get advice if you are genuinely on the line. An online ministry, a family foundation with worship attached, a network without a congregation: these are fact-specific, and a template won't settle them. Consult a licensed attorney or a qualified tax adviser who works with religious organizations.

Common questions

Is the 14-point test in the law?

No. There's no statutory definition of a church in the Internal Revenue Code. The characteristics are an administrative aid the IRS developed and publishes in Publication 1828, and courts have applied them with varying enthusiasm. Treat the list as a description of what churches generally look like, not as a legal test you pass or fail.

How many of the 14 do we need?

There's no number, and anyone who gives you one is inventing it. The IRS states that it weighs the characteristics along with all the other facts and circumstances. Two churches with the same count of items can come out differently depending on what else is true about them.

Do we have to be part of a denomination?

No. Independent congregations are churches. Item 6 is about your members' affiliation, not about yours, and item 3 is satisfied by having a real governing structure of your own, which is what your bylaws are for.

We meet in a school. Is that a problem?

No. "Established places of worship" speaks to a regular, identifiable place of gathering. Renting the same space every week is fine. Owning property has never been the point.

Does the IRS decide whether we are a church?

For federal tax purposes, the IRS applies the classification, usually when something puts the question in front of it, such as an exemption application or an examination. A church that has never applied for a determination letter and has never been examined has simply never had the question formally asked. That's normal and not a defect.

The practical version

Meet regularly. Gather actual people. Write down what you believe, how you're governed, and who leads. Incorporate. Keep minutes. Do the ordinary things a church does, and keep ordinary records that you did them.

That's what the fourteen characteristics are pointing at. The list is long; the underlying idea is short.

---

Get the first year right. Now That Your Church Is Formed covers what to get right after the paperwork: board duties, compensation, Form 990 questions and donor receipts, in plain English, so the record shows a church operating like one. $29, instant download.

*Faith Docs provides self-help document templates, not legal advice. We are not a law firm. For representation, consult a licensed attorney.*