AFSP Requirements for Illinois Tax Preparers: Hours, Deadlines, and Exemptions
- Non-exempt Illinois 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.
- Illinois has no state preparer license, so no Illinois credential grants AFSP exemption. It does require your PTIN on paid Illinois returns.
§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.
Illinois doesn’t license or test paid tax preparers. That makes the AFSP the most accessible credential a non-credentialed Illinois preparer can hold that clients can verify. Record holders are listed in the IRS’s public Directory of Federal Tax Return Preparers. In a large, crowded market like the Chicago metro area, 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).
Illinois has no state preparer registration, so nothing issued by Illinois can make you exempt. Most Illinois 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 Illinois preparers.
§4 Illinois’s Regulatory Picture
Illinois sits between the lightly regulated states and the licensing states. It has no preparer license, exam, or state CE requirement, so your continuing-education obligations are entirely federal. But the State Tax Preparer Oversight Act (35 ILCS 35) gives the Illinois Department of Revenue real enforcement tools. For tax years beginning on or after January 1, 2017, anyone paid to prepare an Illinois income tax return or refund claim must enter their IRS-issued PTIN on it. Preparers employed by a firm also list the firm’s name, FEIN, address, and phone number.
The Department uses that PTIN data to identify fraudulent or erroneous returns. Leaving the PTIN off can cost $50 per offense, up to $25,000 per calendar year, unless there’s reasonable cause. After notice and a hearing, the Department can bar or suspend a preparer from filing returns with it for good cause, and it exchanges information on suspected or disciplined preparers with the IRS. So Illinois doesn’t set your CE hours, but it does tie your state standing to your federal PTIN. Illinois also has its own individual income tax (Form IL-1040), which means nearly every individual client has a state return that starts from the federal one.
§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. In Illinois, a lapsed PTIN is also a state problem. 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 Illinois tax preparers?
No. The AFSP is voluntary. Federally, anyone who prepares returns for pay must have a valid PTIN, and Illinois requires that PTIN on every paid Illinois income tax return.
Does Illinois have a CE requirement for tax preparers?
No. Illinois has no preparer licensing program and no state CE mandate.
Can the Illinois Department of Revenue discipline a preparer?
Yes. Under the State Tax Preparer Oversight Act, it can impose PTIN penalties and, after notice and a hearing, bar or suspend a preparer from filing returns with the Department for good cause.
Can an Illinois 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.