AFSP Requirements for Pennsylvania Tax Preparers: Hours, Deadlines, and the PTIN Gap
- 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 — but Pennsylvania isn’t one of the three states (OR, CA, MD) whose own credential grants that exemption.
- Pennsylvania has no state preparer license and doesn’t require a PTIN on the PA-40 return, unlike Virginia, Michigan, or Illinois.
- The Record of Completion grants a Tax Pro Directory listing and limited representation rights before the IRS for returns you personally prepared.
§1 The AFSP in a State With No Preparer License
Pennsylvania has no state licensing exam, no registration, and no continuing-education mandate for paid tax preparers — the Pennsylvania Department of Revenue processes PA-40 returns but doesn’t run a credentialing program the way a handful of other states do. For a non-credentialed preparer working Pennsylvania clients, the IRS Annual Filing Season Program is effectively the only structured continuing-education path available, and completing it is a voluntary choice rather than a state mandate.
It’s also worth knowing what Pennsylvania doesn’t require: unlike Virginia, Michigan, and Illinois, which each have a state statute requiring a preparer’s PTIN on the state return with a civil penalty for skipping it, Pennsylvania has no such rule for the PA-40. Every paid preparer still needs a federal PTIN to prepare any return regardless of state — see our PTIN renewal walkthrough — but Pennsylvania’s own enforcement layer simply doesn’t exist.
§2 Exempt vs. Non-Exempt for Pennsylvania Preparers
The AFSP splits preparers into two tracks. Exempt preparers have already passed a recognized competency test — the IRS grants this status to active registrants of the Oregon Board of Tax Practitioners, the California Tax Education Council (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). Pennsylvania has no state program of its own, so a Pennsylvania-only preparer without one of those outside credentials falls into the non-exempt track by default and needs the full 18-hour package including the AFTR course — our full exempt vs. non-exempt guide covers 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 hours must all come from IRS-approved CE providers, and the categories are fixed — you can’t cover a shortfall in one bucket with surplus hours from another. The 2 ethics hours specifically need a course tagged for AFSP ethics credit. For the AFTR course itself — what it covers, when it’s offered — see our AFTR course guide for Pennsylvania preparers.
§4 Exempt Hour Requirements
If you separately hold an out-of-state exempt credential, you 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 (3 hours, focused on recent legislative changes) and tax law topics (10 hours, broader subject matter) are separate categories in IRS-approved course catalogs — confirm which bucket a course counts toward before enrolling. Our guide on exact CE hours by preparer type breaks down every category in more depth.
§5 Deadlines and Reporting
December 31, 2026. All CE hours must be completed and reported to the IRS by this date to earn the 2027 filing season Record of Completion — there is no extension. See what missing this deadline actually costs you.
Providers report your completed hours to the IRS CE system directly, but discrepancies between a provider’s records and what shows on your IRS Continuing Education Transcript do happen. Check your transcript through your IRS Tax Pro Account well before mid-December rather than assuming your provider’s confirmation email is the final word.
§6 What the Record of Completion Actually Gets You
Two concrete things: a listing in the IRS’s public Tax Pro Directory, which Pennsylvania clients increasingly check before hiring a preparer given that the state itself doesn’t vet anyone, and limited representation rights before the IRS during exams, collections, and appeals for returns you personally prepared and signed. Without the Record of Completion, a non-credentialed preparer can sit beside a client at an IRS meeting but can’t speak for them. In a state with no licensing signal of its own, that’s the differentiator most worth having. For the AFTR course requirement specifically, see our companion page, AFTR Course for Pennsylvania Tax Preparers, and browse the full AFSP & AFTR guide hub for more.
§7 FAQs
Is the AFSP mandatory for Pennsylvania preparers?
No. It’s a voluntary IRS program. Pennsylvania has no state law requiring it, and no state licensing body to enforce it. Preparers complete it to earn limited representation rights and the Tax Pro Directory listing.
Does a Pennsylvania return require a preparer’s PTIN to be listed on it?
No. Pennsylvania has no state statute requiring a PTIN on the PA-40, unlike Virginia, Michigan, and Illinois. You still need an active federal PTIN to prepare any return for compensation.
I’m exempt under CTEC or Oregon’s OBTP but live in Pennsylvania. Which track do I use?
The 15-hour exempt track. AFSP exemption follows your credential, not your location or the state returns you prepare. An active CTEC or OBTP registration qualifies you as exempt no matter where you practice.
What if I complete more than 18 hours — does the extra roll over to next year?
No. AFSP CE hours don’t carry over between program years. Every filing season requires a fresh set of qualifying hours completed within that year’s window.
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.