Do CPAs, Enrolled Agents and Attorneys Need the AFSP Record of Completion?
- CPAs, enrolled agents and attorneys do not need the AFSP; they already have unlimited representation rights.
- If they want the Record of Completion anyway, they follow the 15-hour exempt track.
- The AFSP is aimed at preparers with no professional credential.
- The program is voluntary for everyone.
Do CPAs, enrolled agents and attorneys need the AFSP?
No. Attorneys, CPAs and enrolled agents already hold unlimited representation rights before the IRS, so the Annual Filing Season Program adds nothing to their authority. The AFSP exists mainly for preparers who hold only a PTIN and no professional credential.
Can a credentialed professional still earn the Record of Completion?
Yes, and the path is shorter. They follow the exempt track: 3 hours of federal tax law updates, 10 hours of federal tax law topics and 2 hours of ethics, for 15 hours. They skip the 6-hour AFTR course and its test. The deadline is still December 31, 2026 for the 2027 filing season.
Why would a CPA or EA bother with it?
Some do so for listing in the IRS public directory of preparers, or to show a consistent credential across a firm that includes both credentialed and non-credentialed staff. It is optional, and there is no legal requirement behind it.
Do enrolled agent CE hours count toward the AFSP?
They can. Enrolled agents complete 72 hours of continuing education every three years, with a minimum of 16 each year, including 2 hours of ethics. If the provider is IRS-approved and the course category matches, those hours may double-count toward AFSP categories. Always confirm the category before you enroll. Read more in continuing education for tax preparers.
What if you are not credentialed?
Then the AFSP is the main route to limited representation rights. See what a Record of Completion lets you do, who qualifies as exempt in AFSP exempt preparers, or compare options in AFSP vs. Enrolled Agent.
Next step: the 2026 Annual Federal Tax Refresher (AFTR) course or the AFSP & AFTR hub.
Related reading
Tax IQ Academy is an IRS and CTEC approved provider of continuing education for tax professionals, offering AFSP, AFTR, and EA exam prep courses covering federal tax law, ethics, and practice management.