AFSP Requirements for Missouri Tax Preparers: Hours, Deadlines, Exemptions
- Non-exempt Missouri preparers need 18 CE hours total; exempt preparers need only 15.
- The deadline for the 2027 Record of Completion is December 31, 2026 — no grace period.
- Missouri has no preparer license, but RSMo § 143.980 fines preparers $50 per return (capped at $25,000/year) for omitting a signature or PTIN on a Missouri return.
- Exemption is tied to credentials (CTEC, Oregon OBTP, Maryland board, recent SEE Part 1), not to anything Missouri-specific.
§1 What the AFSP Is, and How It Relates to Missouri’s PTIN Rule
The Annual Filing Season Program (AFSP) is a voluntary IRS continuing-education program — Missouri has no equivalent of its own. What Missouri does have is RSMo § 143.980, which requires paid preparers to sign the state return and list their PTIN, with a $50-per-occurrence penalty (capped at $25,000/year) for skipping either, for tax years beginning on or after January 1, 2020. That statute checks identification, not competency. The AFSP is the only continuing-education credential available to Missouri preparers, and it’s what actually puts a preparer in the IRS’s public Tax Pro Directory.
§2 Exempt vs. Non-Exempt Hours
Missouri isn’t one of the three states — Oregon, California, Maryland — whose own credential holders are automatically AFSP-exempt (see our 2-minute exemption check). Most non-credentialed Missouri preparers fall on the standard non-exempt track and need the full 18-hour package including the 6-hour AFTR course. You’d only qualify for the lighter, exempt 15-hour track by separately holding one of the recognized out-of-state credentials, having passed SEE Part 1 in the last three years, or serving as an active VITA/TCE volunteer. See the full exempt vs. non-exempt guide for every qualifying category.
§3 The Full Hour Breakdown
SCHEDULE B — AFSP HOURS BY TRACK (2027 FILING SEASON)
| Course Category | Non-Exempt | Exempt |
|---|---|---|
| Annual Federal Tax Refresher (AFTR) | 6 | — |
| Federal Tax Law Topics | 10 | 10 |
| Federal Tax Law Update | — | 3 |
| Ethics | 2 | 2 |
| Total | 18 | 15 |
Exempt preparers skip the AFTR entirely but still need 2 ethics hours from an AFSP-approved ethics course. Hours can’t be shifted between categories to cover a shortfall.
§4 Deadlines You Can’t Miss
December 31, 2026. All CE hours must be completed and reported to the IRS by this date to earn the 2027 Record of Completion. There is no extension.
Providers report your hours directly to the IRS — you don’t submit anything yourself — but missing the deadline still means missing the season entirely. Keep your PTIN renewal current alongside your CE — in Missouri, a lapsed PTIN affects both your federal Record of Completion and your state compliance under RSMo § 143.980.
Consent Requirement. You must consent to the Circular 230 practice obligations during PTIN renewal. Hours completed without that consent won’t produce a Record of Completion.
§5 What You Get for Completing It
A completed AFSP earns you a spot in the IRS’s public Tax Pro Directory plus limited representation rights before the IRS for returns you personally prepared and signed. It does not grant the unlimited representation rights that attorneys, CPAs, and Enrolled Agents hold.
§6 Why Your PTIN Does Double Duty in Missouri
In most states, your PTIN only matters federally. In Missouri, it matters twice: the IRS uses it to track your AFSP CE hours and issue your Record of Completion, and the Missouri Department of Revenue uses it under RSMo § 143.980 to confirm every return you file carries a valid preparer signature and ID. The department has explicitly said it uses the PTIN to flag preparers with high error rates or suspected fraud and to coordinate with the IRS on disciplinary matters. Letting your PTIN lapse mid-season risks both consequences at once — a state penalty and a lost federal Record of Completion. For the AFTR course itself, see our companion page on the AFTR course for Missouri preparers, and browse the full AFSP & AFTR guide hub for every state and topic.
§7 FAQs
Does Missouri have its own AFSP-equivalent program?
No. Only Oregon, California, and Maryland have state programs the IRS recognizes for AFSP exemption. Missouri preparers follow the standard federal exempt/non-exempt rules, separate from the state’s own PTIN-signature statute.
How many hours do I need if I’m not exempt?
18 total: 6 for the AFTR course, 10 for federal tax law topics, and 2 for ethics, all completed by December 31, 2026 for the 2027 season.
What’s the penalty for a missing PTIN on a Missouri return?
$50 per occurrence under RSMo § 143.980, capped at $25,000 per calendar year, unless the omission is shown to be due to reasonable cause.
Does completing the AFSP satisfy Missouri’s signature requirement?
No, they’re separate. The AFSP is a voluntary federal CE credential; RSMo § 143.980 is a mandatory state signature-and-PTIN rule. You need an active PTIN for both, but completing one doesn’t substitute for the other.
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.