AFSP Requirements for Tax Preparers in New York: Hours, Deadlines, and State CE
- Non-exempt New York preparers need 18 hours of federal CE; exempt preparers need 15 hours.
- All AFSP hours are due December 31, 2026 for the 2027 filing season.
- New York separately requires most registered preparers to complete 4 hours of state CE annually — a distinct requirement from the AFSP.
- The Record of Completion grants limited representation rights before the IRS, on top of whatever New York State registration allows.
§1 What Is the AFSP, and How It Differs From New York’s State Program
The Annual Filing Season Program (AFSP) is the IRS’s voluntary federal CE credential for non-credentialed preparers, earning a Record of Completion, a Tax Pro Directory listing, and limited IRS representation rights. New York adds its own layer on top: the state’s Tax Preparer Registration Program, run by the New York State Department of Taxation and Finance, separately requires most commercial preparers to register with the state and complete state-mandated CE. The two programs are entirely independent — one doesn’t fulfill the other.
§2 Exempt vs. Non-Exempt in New York
Non-exempt preparers need 18 hours of federal CE including the 6-hour AFTR course. Exempt preparers — those who passed the old RTRP test, hold active registration with Oregon, California (CTEC), or Maryland’s state programs, passed SEE Part 1 within three years, or serve as qualifying VITA/TCE volunteers — need 15 hours and skip the AFTR.
New York’s own state registration is not on the IRS’s exemption list, so being registered with New York State does not make a preparer AFSP-exempt. Most non-credentialed New York preparers fall into the standard 18-hour, AFTR-required track. For the full AFTR walkthrough specific to New York, see our AFTR course guide for New York preparers.
§3 The 18-Hour Path (Non-Exempt)
NON-EXEMPT AFSP REQUIREMENT — 18 HOURS
| Course Category | Required Hours |
|---|---|
| AFTR course + comprehension test | 6 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 18 |
§4 The 15-Hour Path (Exempt)
EXEMPT AFSP REQUIREMENT — 15 HOURS
| Course Category | Required Hours |
|---|---|
| Federal Tax Law Updates | 3 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 15 |
Very few New York preparers land on this track, since New York’s own registration doesn’t qualify — it requires an out-of-state credential or the SEE. See our full exempt vs. non-exempt guide for every qualifying category.
§5 Two Systems, Two Deadlines: AFSP vs. New York State CE
New York’s Tax Preparer Registration Program requires most commercial preparers (those who aren’t attorneys, CPAs, EAs, or otherwise exempt) to register with the New York State Department of Taxation and Finance and complete continuing education — 4 hours annually for preparers with three or more years’ experience, with a heavier first-year requirement for new preparers. These hours are tracked entirely separately from AFSP hours; a course has to be both IRS-approved for AFSP purposes and New York-approved for state purposes to count toward both, and not every provider offers that overlap. Preparers working in New York generally need to plan for both CE calendars, not just one.
§6 Deadlines, Record of Completion, and Representation Rights
December 31, 2026 for all AFSP hours and PTIN Circular 230 consent. New York State’s own CE and registration renewal follow a separate schedule set by the Department of Taxation and Finance.
Without the AFSP Record of Completion, a non-credentialed New York preparer — registered with the state or not — can accompany a client to an IRS appointment but cannot represent them. With it, you gain limited representation rights for returns you personally signed. See our PTIN renewal guide for the federal side of the process.
§7 FAQs
Does registering with New York State exempt me from the AFSP’s AFTR requirement?
No. New York’s state tax preparer registration is not one of the IRS’s recognized AFSP exemption categories (unlike CTEC in California). New York-registered preparers still need the AFTR unless they qualify through a separate federal exemption.
Do my New York state CE hours count toward the AFSP?
Only if the specific course is both IRS-approved and tagged for AFSP credit. New York state CE and federal AFSP CE are reported through separate systems, so hours don’t automatically cross over.
How many state CE hours does New York require each year?
4 hours annually for most registered commercial preparers with three or more years’ experience, with a larger first-year requirement for newly registered preparers, per the New York State Department of Taxation and Finance. This is separate from, and in addition to, any AFSP hours.
Is the AFSP mandatory for New York preparers?
No, it’s voluntary, but without it a non-credentialed preparer has no IRS representation rights and no Tax Pro Directory listing, regardless of New York state registration status. See our complete AFSP requirements guide.
Ready to start your 2026 federal CE? Enroll in the 2026 AFTR course, or browse the 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.