AFSP Requirements for Tax Preparers in Texas: Hours, Deadlines, Exemptions
- Non-exempt Texas preparers need 18 hours of CE; exempt preparers need 15 hours.
- All hours must be completed by December 31, 2026 for the 2027 filing season.
- The Record of Completion grants limited representation rights before the IRS — something non-credentialed preparers otherwise don’t have.
- Texas has no state income tax and no state preparer competency program, so the AFSP is the primary credential most Texas preparers can earn.
§1 What Is the AFSP, and Why Should Texas Preparers Earn It?
The Annual Filing Season Program (AFSP) is a voluntary IRS continuing education program for tax preparers who don’t hold a credential like EA, CPA, or attorney licensure. Complete the required hours and you earn a Record of Completion: a listing in the IRS’s public Tax Pro Directory and limited representation rights before the IRS for returns you personally prepared and signed.
For Texas preparers, the AFSP fills a gap that doesn’t exist in every state. Texas has no state income tax and, unlike California, Oregon, or Maryland, no state-run competency program for tax preparers. That means the AFSP isn’t competing with a parallel state credential — for most non-credentialed preparers here, it’s the only formal, IRS-recognized signal of competence available.
§2 Exempt vs. Non-Exempt in Texas
Exempt preparers have already passed a recognized competency test: the old RTRP exam, SEE Part 1 within the past three years, or active registration with Oregon, California (CTEC), or Maryland’s state programs. They complete 15 hours and skip the AFTR course. Non-exempt preparers — everyone else holding a PTIN — complete 18 hours including the 6-hour AFTR.
Because Texas has no equivalent state program, Texas preparers can’t become exempt through a state credential the way a California or Oregon preparer can. Nearly all Texas-based non-credentialed preparers fall into the non-exempt, 18-hour track unless they’ve passed the SEE or the now-discontinued RTRP test.
§3 The 18-Hour Path (Non-Exempt)
NON-EXEMPT AFSP REQUIREMENT — 18 HOURS
| Course Category | Required Hours |
|---|---|
| Annual Federal Tax Refresher (AFTR) + comprehension test | 6 |
| Federal Tax Law Topics | 10 |
| Ethics | 2 |
| Total | 18 |
The AFTR is only available June 1 through December 31, 2026, is timed, and requires a passing score on its comprehension test. For a full walkthrough of the course itself, see our AFTR course guide for Texas preparers.
§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 Texas preparers qualify for this track since it requires an out-of-state credential or the SEE. For the full exempt-vs-non-exempt breakdown and the complete list of who qualifies, see our AFSP exempt vs. non-exempt guide.
§5 Why the AFSP Matters More in a No-Income-Tax State
Texas’s tax landscape is unusual: the Texas Comptroller of Public Accounts administers sales, franchise, and property-related taxes, but there is no individual income tax return for the Comptroller — or any Texas preparer — to file. That means a Texas tax preparer’s entire practice is typically built around federal returns, and the federal AFSP credential carries more relative weight here than in a state where preparers also juggle a state income tax CE requirement. The requirements themselves (hours, deadlines, testing) are identical to every other state; what’s different is how central the AFSP is to a Texas preparer’s overall credentialing picture.
§6 Deadlines, Record of Completion, and Representation Rights
December 31, 2026. All CE hours and your Circular 230 consent (via your PTIN account) must be complete by this date to receive the 2027 Record of Completion. There is no grace period.
Without the Record of Completion, a non-credentialed Texas preparer can accompany a client to an IRS appointment but cannot speak on their behalf. With it, you gain limited representation rights for the returns you signed. See our PTIN renewal guide to make sure your PTIN status won’t hold up your Record of Completion.
§7 FAQs
Does Texas have its own AFSP-style state program?
No. Unlike California (CTEC), Oregon, or Maryland, Texas has no state tax preparer competency program. Texas preparers rely on the federal AFSP as their primary voluntary credential.
Since Texas has no state income tax, do Texas preparers need fewer AFSP hours?
No. The AFSP is entirely federal, and its hour requirements (18 for non-exempt, 15 for exempt) are identical in every state regardless of whether that state has its own income tax.
What does the Texas Comptroller of Public Accounts have to do with the AFSP?
Nothing directly — the Comptroller administers Texas’s sales, franchise, and property tax systems, not individual income tax or preparer credentialing. The AFSP is administered entirely by the IRS.
What’s the fastest way to complete the 18-hour requirement?
Most non-exempt preparers complete their AFTR, federal tax law, and ethics hours through a single bundled IRS-approved course rather than sourcing each category separately. Check our AFSP & AFTR resource hub for current course options.
Ready to start your 2026 CE? Enroll in the 2026 AFTR course, or browse 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.