It says this in the manual:
Procedure: To form an Army, select a 2 or 3 star leader within range
of an Army Group plus any Units (including any Corps, Divisions
and leaders) you want to include in the Armies, then select the “Create
Army” Special Order.
Note: An Army must always occupy a single region and is a single
Stack of Units. You could separate Units from their Armies to extend
your coverage, but they would become an Independent Stack in the
process, losing Armies benefits and suffering possible Out of Command
Chain penalties as a consequence.
In the 1914 East Prussia campaign as Germany Max von Gallwitz cannot create an army to negate some of the CP penalty. This is weird as all the usual and age old requirements for army/corps creation are fullfilled.