AFSP Requirements for Arizona Tax Preparers: Hours, Deadlines, and the E-File Suspension Rule
- Non-exempt Arizona preparers need 18 CE hours, including the 6-hour AFTR.
- Exempt preparers need 15 hours and skip the AFTR.
- Hours, the Circular 230 consent, and PTIN renewal are due by December 31, 2026.
- Arizona has no state preparer license, so no Arizona credential grants AFSP exemption. ADOR can still suspend a preparer’s e-file privileges for program violations.
§1 The AFSP, Briefly
The Annual Filing Season Program (AFSP) is a voluntary IRS program for paid preparers who aren’t Enrolled Agents, CPAs, or attorneys. Each year you complete the required continuing education with IRS-approved providers, consent to the practice obligations in Circular 230, and keep your PTIN current. The IRS then issues a Record of Completion for the coming filing season.
Arizona doesn’t license or test paid tax preparers. That makes the AFSP the most accessible credential a non-credentialed Arizona preparer can hold that clients can verify. Record holders are listed in the IRS’s public Directory of Federal Tax Return Preparers. In fast-growing markets like Phoenix and Tucson, that listing is a simple way to stand out from preparers who hold only a PTIN.
§2 Exempt or Non-Exempt?
You’re exempt (15 hours, no AFTR) if any of these apply:
- You passed the former RTRP test.
- You passed SEE Part 1 within the past three years.
- You qualify through VITA/TCE volunteer or instructor work.
- You’re an active registrant of the Oregon, California (CTEC), or Maryland state preparer programs.
Otherwise you’re non-exempt (18 hours, including the AFTR).
Arizona has no state preparer registration, so nothing issued by Arizona can make you exempt. Most Arizona participants are non-exempt. Our 2-minute exemption check and the exempt vs. non-exempt guide walk through each route.
§3 Hour Requirements, Side by Side
These numbers are federal and are the same in every state.
NON-EXEMPT AFSP REQUIREMENT — 18 HOURS
| Course Category | Required Hours |
|---|---|
| AFTR course + comprehension test | 6 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 18 |
EXEMPT AFSP REQUIREMENT — 15 HOURS
| Course Category | Required Hours |
|---|---|
| Federal Tax Law Updates | 3 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 15 |
Our AFSP hours-by-preparer-type guide covers the category rules. Non-exempt preparers can find the 6-hour course covered on the AFTR page for Arizona preparers.
§4 Arizona’s Regulatory Picture
Arizona sits among the lightly regulated states: no preparer license, no exam, and no state CE requirement, so your continuing-education obligations are entirely federal. What Arizona does regulate is the e-file channel. The Arizona Department of Revenue (ADOR) requires a valid PTIN on paid-preparer returns, and it can suspend a preparer’s ability to electronically file Arizona returns for failing to meet the state’s e-file program requirements. That’s a narrower tool than a license, but it’s a real one, since most Arizona returns are filed electronically.
Arizona also has its own individual income tax (Form 140), so nearly every individual client has a state return that starts from the same federal figures the AFTR reviews. With no state credential available, the AFSP Record of Completion is the clearest, most verifiable signal a non-credentialed Arizona preparer can offer.
§5 Deadlines and a Clean Finish
December 31, 2026. All CE hours must be completed and reported, your Circular 230 consent must be recorded in your online PTIN account, and your PTIN must be renewed for 2027. There are no extensions.
Most preparers who miss out on the credential do so because of a missed reporting or consent step, not the coursework itself. Check your CE record as each course posts, and renew your PTIN as soon as renewal opens. The step-by-step PTIN renewal guide lays out the sequence, and what missing the December 31 deadline costs explains the stakes.
§6 What the Record of Completion Gets You
You’re listed in the IRS Directory of Federal Tax Return Preparers with Credentials and Select Qualifications. You also get limited representation rights for returns you prepared and signed during the covered period. With those rights, you can represent those clients before IRS revenue agents, customer service representatives, and similar IRS employees, including the Taxpayer Advocate Service. In a state with no preparer licensing, that’s a meaningful step beyond a PTIN alone.
§7 FAQs
Is the AFSP required for Arizona tax preparers?
No. The AFSP is voluntary. Federally, anyone who prepares returns for pay must have a valid PTIN, and Arizona requires that PTIN to stay in good standing with ADOR’s e-file program.
Does Arizona have a CE requirement for tax preparers?
No. Arizona has no preparer licensing program and no state CE mandate.
Can ADOR restrict a preparer?
Yes. ADOR can suspend a preparer’s ability to electronically file Arizona returns for failing to meet the state’s e-file program requirements, even without a licensing system.
Can an Arizona preparer be AFSP-exempt?
Yes, but only through a federal route (recent SEE Part 1, the former RTRP test, or qualifying VITA/TCE service) or through active registration in the Oregon, California, or Maryland programs.
Start your AFSP hours with the Tax IQ Academy 2026 AFTR course, or explore the full AFSP & AFTR resource 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.