AFSP Record of Completion vs. No Credential: What Changes for Tax Preparers
- PTIN-only preparers have no federal CE requirement.
- The AFSP is voluntary and earns a Record of Completion.
- The Record gives limited representation rights and an IRS directory listing.
- Non-exempt: 18 hours. Exempt: 15 hours.
What is the difference between a PTIN-only preparer and an AFSP participant?
A PTIN-only preparer has the required identification number but has not completed IRS continuing education. An AFSP participant also completes the required hours and earns a Record of Completion for the filing season. The Record adds limited representation rights and a listing in the IRS directory.
Is the AFSP required to prepare tax returns?
No. The program is voluntary. Paid preparers must have a PTIN, but the Record of Completion is optional. For more, see whether the AFSP is required.
What can an AFSP Record holder do that a PTIN-only preparer cannot?
A Record holder has limited representation rights: they may represent clients whose returns they prepared and signed, before revenue agents, customer service representatives and similar IRS employees. PTIN-only preparers have no representation rights. Collections and appeals are not covered; read limited representation rights.
Does the AFSP make you an enrolled agent or CPA?
No. The Record of Completion is not a license or professional credential. Enrolled agents, CPAs and attorneys have unlimited representation rights. Compare the routes in AFSP vs. enrolled agent.
Why would a PTIN-only preparer still take the AFSP?
The Record shows clients and employers that you completed IRS-recognized education, and it places you in the IRS directory of tax return preparers. See how the directory works.
How many hours does it take to move from PTIN-only to AFSP?
Non-exempt preparers complete 18 hours: 6 AFTR, 10 Topics and 2 Ethics. Exempt preparers complete 15 hours. Everyone must finish by December 31, 2026 for the 2027 season. See the full breakdown.
Do the rules vary by state?
The AFSP is federal and identical everywhere. Some states set their own preparer rules separately, and those do not change the AFSP.
Next step: enroll in the 2026 Annual Federal Tax Refresher (AFTR) course or visit the AFSP & AFTR hub.
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.