AFSP Requirements for Tax Preparers in California: Hours, Deadlines, and the CTEC Exemption
- Active CTEC registration exempts California preparers from the AFTR — 15 hours instead of 18.
- CTEC’s own state renewal requires a separate 20 hours of CE annually, on a different (earlier) deadline.
- All AFSP hours are due December 31, 2026; CTEC renewal runs August 1 – October 31, 2026.
- California is 1 of only 3 states (with Oregon and Maryland) whose own preparer program qualifies for federal AFTR exemption.
§1 What Is the AFSP, and Why California Is a Special Case
The Annual Filing Season Program (AFSP) is the IRS’s voluntary CE credential for non-credentialed tax preparers, earning a Record of Completion, a listing in the IRS Tax Pro Directory, and limited representation rights. Every state follows the same federal hour requirements — except that California is one of just three states (with Oregon and Maryland) where the IRS treats an existing state credential as equivalent to its own AFTR course.
§2 Exempt vs. Non-Exempt: CTEC Changes the Math
For most of the country, “exempt” status requires the discontinued RTRP test or recent SEE Part 1 completion — narrow categories that apply to relatively few preparers. In California, any preparer with active CTEC registration is automatically exempt, which means the majority of California’s non-credentialed, paid preparers (CRTPs) qualify for the shorter 15-hour AFSP track rather than the 18-hour non-exempt path most of the country falls into.
§3 The 15-Hour Path (CTEC-Exempt)
EXEMPT AFSP REQUIREMENT — 15 HOURS
| Course Category | Required Hours |
|---|---|
| Federal Tax Law Updates | 3 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 15 |
No AFTR course or comprehension test is required on this track. For more on exactly how the CTEC exemption works, see our dedicated AFTR course guide for California preparers.
§4 The 18-Hour Path (Non-Exempt)
California preparers who are not actively CTEC-registered — a lapsed registration, or a PTIN holder who hasn’t registered with CTEC — fall back to the standard non-exempt track.
NON-EXEMPT AFSP REQUIREMENT — 18 HOURS
| Course Category | Required Hours |
|---|---|
| AFTR course + comprehension test | 6 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 18 |
§5 AFSP vs. CTEC: Two Separate Requirements, One Course
It’s easy to conflate the AFSP and CTEC because most CRTPs satisfy both from the same enrollment, but they’re legally distinct. The AFSP is a federal, voluntary IRS program; CTEC is California’s mandatory state registration for paid non-credentialed preparers, requiring 20 hours of CE annually — 5 hours more than the AFSP’s exempt track. A course from a provider approved by both the IRS and CTEC typically covers all 15 AFSP hours within its 20 CTEC hours, letting most CRTPs renew both credentials in one purchase. For the fee-by-fee cost of the CTEC side specifically, see our CTEC renewal cost guide.
§6 Deadlines and the Record of Completion
December 31, 2026 for all AFSP hours and PTIN Circular 230 consent. CTEC renewal runs on its own, earlier window: August 1 – October 31, 2026.
Because the CTEC deadline lands months before the AFSP cutoff, most California preparers complete both requirements together well ahead of December 31. See our CTEC renewal checklist for that state-side timeline in full.
§7 FAQs
Do CTEC-registered preparers still need to do anything for the AFSP, or does CTEC cover it automatically?
CTEC registration grants AFSP exemption from the AFTR, but you still need to complete 15 hours of federal CE (tax law updates, tax law topics, ethics) and report them under your PTIN to earn the AFSP Record of Completion — it isn’t automatic just from registering with CTEC.
Is CTEC’s 20-hour requirement the same as the AFSP’s 15-hour requirement?
No, they’re separate totals for separate programs, though a dual-approved course is typically built so the 20 CTEC hours include the 15 AFSP-qualifying hours, satisfying both requirements from one enrollment.
What happens if my CTEC registration lapses mid-year?
You lose AFSP exempt status and would need to complete the AFTR and shift to the 18-hour non-exempt track to still earn a Record of Completion for that filing season, in addition to whatever CTEC requires to reinstate your registration.
Does the AFSP replace CTEC registration?
No. CTEC registration is legally required to prepare paid returns in California as a non-credentialed preparer; the AFSP is a voluntary federal add-on. You need CTEC regardless of whether you also pursue the AFSP.
Ready to knock out both requirements at once? See this year’s CE course options, or browse the AFSP & AFTR resource hub.