AFSP Requirements for Virginia Tax Preparers: Hours, Deadlines, and the PTIN Mandate
- 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 — Virginia isn’t one of the three states (OR, CA, MD) whose own credential grants that exemption.
- Since tax years beginning 2019-01-01, Va. Code § 58.1-348.4 has required every paid preparer’s PTIN on any Virginia return, with a $50-per-offense penalty capped at $25,000 a year.
- The Record of Completion grants a Tax Pro Directory listing and limited representation rights before the IRS.
§1 The AFSP Alongside Virginia’s PTIN Mandate
Virginia has no preparer license or competency exam, but it does enforce PTIN disclosure directly. Under Va. Code § 58.1-348.4, for taxable years beginning on and after January 1, 2019, any paid preparer of a Virginia income tax return must include their PTIN on that return and sign as the preparer. Skipping it draws a $50 civil penalty per offense from the Virginia Department of Taxation, capped at $25,000 per preparer per calendar year, unless the Department finds the violation reasonable and unintentional.
That statute confirms who prepared a return; it doesn’t test or credential anyone’s tax knowledge. For actual continuing education, non-credentialed Virginia preparers rely on the IRS Annual Filing Season Program, which remains voluntary at the federal level even though Virginia’s PTIN rule is mandatory.
§2 Exempt vs. Non-Exempt for Virginia Preparers
The AFSP splits preparers into two tracks: exempt preparers have already passed a recognized competency test and skip the AFTR, while non-exempt preparers complete the full 18-hour package. Exempt status applies to active registrants of the Oregon Board of Tax Practitioners, California’s 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. Virginia has no state program of its own, so a Virginia-only preparer defaults to the non-exempt track. See the full exempt vs. non-exempt guide for 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 categories are fixed and don’t substitute for one another. For what the AFTR course covers and when it’s offered, see our AFTR course guide for Virginia preparers.
§4 Exempt Hour Requirements
Preparers with a qualifying out-of-state credential 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 and tax law topics are separate categories in IRS-approved course catalogs — our guide to exact CE hours by preparer type breaks each one down.
§5 Deadlines and Reporting
December 31, 2026. All CE hours must be completed and reported to the IRS by this date — there is no extension. See what missing this deadline actually costs you.
Providers report completed hours to the IRS CE system directly, but confirm they appear correctly on your IRS Continuing Education Transcript through your Tax Pro Account before mid-December. Keep your PTIN renewal current too — Virginia’s own statute is built directly around that number appearing on every return you sign.
§6 What the Record of Completion Actually Gets You
Virginia’s PTIN-disclosure rule confirms who prepared a return; it says nothing about competency. The AFSP Record of Completion does that instead: a listing in the IRS’s public Tax Pro Directory, and limited representation rights before the IRS during exams, collections, and appeals for returns you personally prepared and signed. Without it, a non-credentialed preparer can sit beside a client at an IRS meeting but can’t speak on their behalf. For the AFTR course requirement itself, see our companion page, AFTR Course for Virginia Tax Preparers, or browse the full AFSP & AFTR guide hub.
§7 FAQs
Is the AFSP mandatory in Virginia?
No. It’s a voluntary IRS program. Virginia’s own PTIN-disclosure statute is mandatory and separate — it requires your PTIN on any Virginia return you sign, but it isn’t a substitute for AFSP CE.
What is Virginia’s PTIN requirement?
Under Va. Code § 58.1-348.4, for taxable years beginning on and after January 1, 2019, paid preparers must include their PTIN on any Virginia income tax return they prepare and sign it as the preparer, or face a $50-per-offense penalty capped at $25,000 a year.
Does Virginia’s PTIN rule count toward AFSP hours?
No. It’s a disclosure and accountability statute, not a CE program. It has no effect on your AFSP hour requirement or exempt/non-exempt status.
I’m exempt under CTEC or Oregon’s OBTP but prepare Virginia returns. Which track applies?
The 15-hour exempt track. AFSP exemption follows your credential, not the state where you practice. An active CTEC or OBTP registration qualifies you as exempt regardless of which states’ returns you prepare.
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.