AFSP Requirements for Tennessee Tax Preparers: Hours, Deadlines, and Exemptions
- Non-exempt Tennessee preparers need 18 CE hours, including the 6-hour AFTR.
- Exempt preparers need 15 hours and skip the AFTR.
- Hours, the Circular 230 consent, and PTIN renewal are all due by December 31, 2026.
- Tennessee has no state preparer program, so no Tennessee credential grants AFSP exemption.
§1 What the AFSP Does for Tennessee Preparers
The Annual Filing Season Program (AFSP) is the IRS’s voluntary program for paid preparers who don’t hold an EA, CPA, or attorney credential. You complete the required CE from IRS-approved providers, consent to Circular 230’s practice obligations, and keep your PTIN current. In return, the IRS issues an annual Record of Completion.
Tennessee has no preparer licensing, so the AFSP is the most direct way for a non-credentialed Tennessee preparer to show clients a verifiable standard. Record holders appear in the IRS’s public Directory of Federal Tax Return Preparers, and that listing is often the difference between a prospective client trusting you and moving on.
§2 Exempt or Non-Exempt?
You’re exempt (15 hours, no AFTR) if you’ve passed the former RTRP test, passed SEE Part 1 within the past three years, qualify through VITA/TCE volunteer or instructor work, or are an active registrant of the Oregon, California (CTEC), or Maryland state preparer programs. Everyone else is non-exempt (18 hours, including the 6-hour AFTR).
Because Tennessee has no state program, a Tennessee-only preparer can’t reach exempt status through state registration. Most Tennessee AFSP participants are non-exempt. VITA/TCE service is a real exemption route for newer preparers, and our exempt vs. non-exempt guide walks through it and the other routes.
§3 The Hour Requirements
These are federal figures, identical in every state.
NON-EXEMPT AFSP REQUIREMENT — 18 HOURS
| Course Category | Required Hours |
|---|---|
| AFTR course + comprehension test | 6 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 18 |
EXEMPT AFSP REQUIREMENT — 15 HOURS
| Course Category | Required Hours |
|---|---|
| Federal Tax Law Updates | 3 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 15 |
See our AFSP hours-by-preparer-type guide for the category rules. If you’re non-exempt, the AFTR page for Tennessee preparers covers the 6-hour course in detail.
§4 Tennessee’s Regulatory Picture
The Tennessee Department of Revenue administers the state’s taxes, but Tennessee no longer taxes personal income in any form. The Hall income tax on interest and dividends was phased down and then fully repealed for tax years beginning January 1, 2021. That leaves no Tennessee individual income tax return, and there has never been a state CE mandate for tax preparers.
That doesn’t make the AFSP lighter in Tennessee. The 18- and 15-hour requirements, the ethics hours, and the December 31 cutoff apply the same way in Nashville, Memphis, and every other state. What Tennessee lacks is a state layer on top. Preparers who also handle business clients will deal with Tennessee’s franchise and excise taxes, but those fall outside the AFSP. Clients relocating from income-tax states may still need part-year or nonresident returns elsewhere.
§5 Deadlines and Finishing Cleanly
December 31, 2026. All CE hours must be completed and reported, your Circular 230 consent must be recorded in your online PTIN account, and your PTIN must be renewed for 2027. There are no extensions.
Most lost credentials come from paperwork, not coursework. Check your PTIN account’s CE record as each course posts, and renew your PTIN early. If you’re cutting it close, read what’s at stake in missing the December 31 AFSP deadline. Our PTIN renewal guide covers the full sequence.
§6 What the Record of Completion Earns You
The Record of Completion lists you in the IRS Directory of Federal Tax Return Preparers with Credentials and Select Qualifications and grants limited representation rights. You can represent clients whose returns you prepared and signed before IRS revenue agents, customer service representatives, and similar IRS employees, including the Taxpayer Advocate Service, for returns prepared during the covered period. Without a state license to point to, that’s a real advantage over holding a PTIN alone.
§7 FAQs
Is the AFSP mandatory in Tennessee?
No. It’s voluntary everywhere. The federal requirement for anyone who prepares returns for pay is a valid PTIN.
Does Tennessee require CE for tax preparers?
No. Tennessee has no preparer licensing program and no personal income tax, so there’s no state CE requirement.
How can a Tennessee preparer become AFSP-exempt?
Only through federal routes (recent SEE Part 1, the former RTRP test, or qualifying VITA/TCE service) or through active registration in the Oregon, California, or Maryland programs.
Do I still need the Circular 230 consent if I finish all my hours?
Yes. The consent is a separate step in your online PTIN account. Without it, the IRS won’t issue your Record of Completion.
Start your AFSP hours with the Tax IQ Academy 2026 AFTR course, or explore the full 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.