AFSP Limited Representation Rights: What a Record of Completion Lets You Do
- AFSP Record of Completion holders get limited representation rights.
- You may represent only clients whose returns you prepared and signed.
- Representation is before certain IRS employees such as revenue agents and customer service representatives.
- Collection and appeals representation is not included.
§1 What are limited representation rights?
Limited representation rights let a preparer who holds an AFSP Record of Completion speak for a client in certain IRS matters. The rights are narrower than those of attorneys, CPAs and enrolled agents, who have unlimited representation rights. Preparers who skip the program have none.
§2 Whom can an AFSP holder represent?
Only clients whose returns you prepared and signed. If another preparer signed the return, or the client never used you, the limited rights do not apply. Keep your signed copies on file so you can show you prepared the return in question.
§3 Before whom can you represent a client?
IRS Publication 947 describes representation before revenue agents, customer service representatives and similar IRS employees, including the Taxpayer Advocate Service. Typical uses include examinations of returns you prepared and answering notices about them. The IRS is the final word on the exact scope, so confirm against current IRS guidance before relying on it.
§4 What is not covered?
- Clients whose returns you did not prepare and sign.
- Representation before the IRS collection and appeals functions.
If a client needs that kind of help, refer them to an attorney, CPA or enrolled agent. Considering that path yourself? Read AFSP vs. Enrolled Agent.
§5 How do you earn the Record of Completion?
Complete the continuing education, renew your PTIN for the upcoming season, and finish by the program deadline. Non-exempt preparers need 18 hours (6 AFTR + 10 Topics + 2 Ethics); exempt preparers need 15 (3 Updates + 10 Topics + 2 Ethics). Details are in the 2027 AFSP requirements guide and the Record of Completion explainer. Start with the 2026 AFTR course or visit the AFSP & AFTR hub.
FAQ FAQs
Is the AFSP required to prepare returns?
No. It is voluntary; see is the AFSP required.
Do representation rights vary by state?
No. They come from federal IRS rules and are the same nationwide.
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.