AFSP Requirements for Minnesota Tax Preparers: Hours, Deadlines, and the PTIN Penalty
- Non-exempt Minnesota preparers need 18 CE hours; exempt preparers need 15.
- Minnesota has no state preparer license, but fines preparers $500 for lacking a required PTIN and $50 per return for omitting it (Minn. Stat. 289A.60, subd. 28).
- The PTIN penalty is a state identification rule, separate from the AFSP’s federal CE requirement.
- All CE must be completed and reported to the IRS by December 31, 2026 for the 2027 Record of Completion.
§1 The AFSP in Minnesota: Why It’s the Main Credential Available
Minnesota leaves preparer competency testing almost entirely to the federal government. There’s no state exam, no state license, and no state-mandated CE curriculum for the many Minnesota preparers working without a CPA, EA, or law license. That leaves real distance between “has a PTIN” and “can show a client proof of federal tax competency” — and the IRS’s Annual Filing Season Program (AFSP) is the credential built to close it.
Completing the AFSP’s annual CE requirement earns a Record of Completion, which does two concrete things: it lists the preparer in the IRS’s public Tax Pro Directory, and it grants limited representation rights — the ability to speak to the IRS on a client’s behalf, for returns the preparer personally signed, during an exam, a collections matter, or an appeal.
§2 Minnesota’s Own Rule: The PTIN-on-Return Penalty
Where Minnesota does get specific is making sure the PTIN already shows up correctly on every return. Under Minnesota Statute 289A.60, subdivision 28, the Department of Revenue can fine a preparer $500 for each instance of being required to have a PTIN but not having one, and $50 for each Minnesota return filed without the PTIN included, even when the preparer holds one. It’s a per-occurrence identification penalty, not a one-time license fee, and it scales with the number of returns a preparer processes.
This rule runs on a completely separate track from the AFSP. Being current on your Minnesota PTIN-disclosure obligations does nothing to satisfy the IRS’s CE requirement, and completing your AFSP hours does nothing to protect you from the state penalty if your firm’s intake process keeps leaving the PTIN field blank. Preparers in Minnesota are effectively managing two independent compliance checklists that happen to share the same identifying number.
§3 Exempt vs. Non-Exempt Hours
The IRS’s two-track system applies in Minnesota the same way it applies everywhere. Exempt preparers hold an active credential from the Oregon Board of Tax Practitioners, CTEC in California, or the Maryland State Board of Individual Tax Preparers, or passed Part 1 of the Special Enrollment Exam in the last three years, or passed the old RTRP test between 2011 and 2013. Minnesota isn’t one of the three state programs the IRS recognizes, so a Minnesota-only preparer reaches exempt status mainly through the SEE or legacy RTRP routes, or by carrying over an out-of-state credential. Non-exempt preparers — the bulk of Minnesota’s non-credentialed preparer population — complete the full 18-hour track including the AFTR.
§4 The Non-Exempt 18-Hour Breakdown
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 |
§5 The Exempt 15-Hour Breakdown
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 |
Exempt Minnesota preparers skip the AFTR but still need all 15 hours completed and reported by the deadline — there’s no partial Record of Completion for partial hours.
§6 Deadlines and What the Record of Completion Gets You
December 31, 2026. All CE hours for the 2027 Record of Completion must be completed and reported to the IRS by this date, with no grace period.
Your CE provider reports hours to the IRS directly, but confirm they landed correctly in your IRS Tax Pro Account CE transcript, with enough time left in December to fix any mismatch. PTIN renewal also requires a separate Circular 230 consent — without it, completed CE alone won’t produce a Record of Completion.
§7 FAQs
Is the AFSP required in Minnesota?
No. It’s a voluntary IRS program with no state mandate behind it. What Minnesota does enforce is a separate PTIN-disclosure penalty under state law — $500 for lacking a required PTIN, $50 per return for omitting one you already have.
Does paying the Minnesota PTIN penalty satisfy any part of the AFSP?
No. The two are unrelated. The state penalty is about disclosing a PTIN on the return itself; the AFSP is a federal CE program measured in hours. Fixing one doesn’t touch the other.
I’m an Enrolled Agent practicing in Minnesota. Do I need the AFSP?
No. EAs, CPAs, and attorneys already hold unlimited representation rights and don’t need the AFSP for that purpose, though some complete the 15-hour exempt track anyway for the Tax Pro Directory listing.
What happens if I only complete some of my required hours?
No Record of Completion is issued for that season — the IRS doesn’t grant partial credit. All 18 hours (or 15, if exempt) must be finished and reported by December 31, or the preparer starts over the following year.
For the complete federal framework, see the 2027 AFSP Requirements Guide, check whether you’re AFSP-exempt, and review the PTIN renewal steps. Start your CE with TIQA’s 2026 AFTR Course, browse the full AFSP & AFTR hub, or see Minnesota’s AFTR course requirements in detail.
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.