AFSP Requirements for Michigan Tax Preparers: Hours, Deadlines, and the Taxpayer Protection Act
- Non-exempt preparers need 18 hours of AFSP CE, including the 6-hour AFTR course, by December 31, 2026.
- Exempt preparers need only 15 hours and skip the AFTR — Michigan isn’t one of the three states (OR, CA, MD) whose own credential grants that exemption.
- Michigan’s Taxpayer Protection Act (MCL 205.4a, effective 2021-01-01) requires a signed ID number on paid returns, with a $50-per-return penalty capped at $25,000 a year — but it’s not a CE requirement.
- The Record of Completion grants a Tax Pro Directory listing and limited representation rights before the IRS.
§1 The AFSP Alongside Michigan’s Taxpayer Protection Act
Michigan has no preparer license or competency exam, but it isn’t silent on paid preparers either. Since January 1, 2021, the Taxpayer Protection Act (MCL 205.4a) has required anyone preparing Michigan individual, fiduciary, or claimant returns for compensation to sign the return and list an identification number — their PTIN or another federal ID. Miss it, and the Michigan Department of Treasury can assess $50 per return, capped at $25,000 per preparer annually, absent reasonable cause.
That statute is an identification and accountability rule, not a competency program — it doesn’t test or credential anyone. For actual continuing education, non-credentialed Michigan preparers rely entirely on the IRS Annual Filing Season Program, which is voluntary at the federal level even though Michigan’s own signature rule is mandatory.
§2 Exempt vs. Non-Exempt for Michigan Preparers
The AFSP splits preparers into two tracks: exempt preparers have already passed a recognized competency test and skip the AFTR, while non-exempt preparers complete the full 18-hour package. Exempt status applies to active registrants of the Oregon Board of Tax Practitioners, California’s CTEC, or the Maryland State Board of Individual Tax Preparers, to anyone who passed the old RTRP test, to recent SEE Part 1 passers, and to active VITA/TCE volunteers — run the 2-minute exempt check if you’re unsure. Michigan has no state program of its own, so a Michigan-only preparer defaults to the non-exempt track. See the full exempt vs. non-exempt guide for every qualifying category.
§3 Non-Exempt Hour Requirements
SCHEDULE A — NON-EXEMPT PREPARER CE REQUIREMENTS (2027 FILING SEASON)
| Course Category | Required Hours |
|---|---|
| Annual Federal Tax Refresher (AFTR) — includes comprehension test | 6 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 18 |
These categories are fixed and can’t substitute for one another. For what the AFTR course itself covers and when it’s offered, see our AFTR course guide for Michigan preparers.
§4 Exempt Hour Requirements
Preparers with a qualifying out-of-state credential skip the AFTR and need 15 hours instead.
SCHEDULE B — EXEMPT PREPARER CE REQUIREMENTS (2027 FILING SEASON)
| Course Category | Required Hours |
|---|---|
| Federal Tax Law Updates | 3 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 15 |
Tax law updates and tax law topics are separate categories in IRS-approved course catalogs — our guide to exact CE hours by preparer type breaks each one down.
§5 Deadlines and Reporting
December 31, 2026. All CE hours must be completed and reported to the IRS by this date — there is no extension. See what missing this deadline actually costs you.
Providers report completed hours to the IRS CE system directly, but confirm they appear correctly on your IRS Continuing Education Transcript through your Tax Pro Account before mid-December. Keep your PTIN renewal current too — Michigan’s own Taxpayer Protection Act already requires that same PTIN on every return you sign.
§6 What the Record of Completion Actually Gets You
Michigan’s signature-and-ID rule holds preparers accountable, but it doesn’t vouch for anyone’s competency. The AFSP Record of Completion does that instead: a listing in the IRS’s public Tax Pro Directory, and limited representation rights before the IRS during exams, collections, and appeals for returns you personally prepared and signed. Without it, a non-credentialed preparer can sit beside a client at an IRS meeting but can’t speak on their behalf. For the AFTR course requirement itself, see our companion page, AFTR Course for Michigan Tax Preparers, or browse the full AFSP & AFTR guide hub.
§7 FAQs
Is the AFSP mandatory in Michigan?
No. It’s a voluntary IRS program. Michigan’s own Taxpayer Protection Act requires a signature and ID number on paid returns, but that’s a separate, mandatory state rule — not a substitute for AFSP CE.
Does Michigan’s Taxpayer Protection Act count toward AFSP hours?
No. It’s an identification and accountability statute, not a CE program. It has no effect on your AFSP hour requirement or exempt/non-exempt status.
What’s the penalty for not complying with Michigan’s preparer ID rule?
A $50 penalty per non-compliant return, capped at $25,000 per preparer per calendar year, unless the Michigan Department of Treasury finds reasonable cause for the failure.
I’m exempt under CTEC or Oregon’s OBTP but prepare Michigan returns. Which track applies?
The 15-hour exempt track. AFSP exemption follows your credential, not the state where you practice. An active CTEC or OBTP registration qualifies you as exempt regardless of which states’ returns you prepare.
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.