AFTR Course for Michigan Tax Preparers: What the 2027 Season Requires
- Non-exempt Michigan preparers need 18 hours of CE, including the 6-hour AFTR course, by December 31, 2026.
- Michigan has no state preparer license, but since January 1, 2021 the Taxpayer Protection Act (MCL 205.4a) has required paid preparers to sign Michigan individual, fiduciary, and claimant returns and include an ID number.
- Skipping that signature or ID number carries a $50-per-return penalty, capped at $25,000 per preparer per year.
- Exempt preparers (CTEC, Oregon OBTP, Maryland board registrants, recent SEE Part 1 passers) need only 15 hours and skip the AFTR.
§1 Michigan’s Taxpayer Protection Act, Explained
Michigan has never required a preparer license or competency exam — there’s no state credential to earn beyond your federal PTIN. But Michigan isn’t hands-off, either. Effective January 1, 2021, the state’s Taxpayer Protection Act (MCL 205.4a, part of 2020 PA 77) requires anyone who prepares Michigan individual income tax, fiduciary, or claimant returns for compensation to sign the return and include an identification number — their PTIN or another federal ID. Skip it, and the Michigan Department of Treasury can assess a $50-per-return penalty, capped at $25,000 per preparer per year, unless the failure is due to reasonable cause.
The Act doesn’t create a licensing body or a competency test; it’s an identification and accountability rule layered on top of federal PTIN registration, similar in structure to what Virginia and Illinois have done with their own paid-preparer statutes. Practically, it means Michigan preparers already need their PTIN in good order well before they touch a client return — a good reason to keep PTIN renewal current alongside AFSP CE.
§2 Exempt vs. Non-Exempt: Where Michigan Preparers Land
Michigan isn’t one of the three states — Oregon, California, and Maryland — whose own credential grants IRS AFSP exemption, so a Michigan-only preparer without an outside qualifying credential falls into the non-exempt track by default and needs the full 18-hour CE package, including the AFTR course. Run the 2-minute exempt check if you hold an out-of-state credential or passed Part 1 of the Special Enrollment Exam recently — those can qualify you for the 15-hour exempt track regardless of where you practice. Attorneys, CPAs, and Enrolled Agents already have unlimited representation rights and don’t need the AFSP, though many complete it anyway for the Tax Pro Directory listing.
§3 The Hour-by-Hour Breakdown for Non-Exempt Preparers
Non-exempt Michigan preparers need 18 CE hours from IRS-approved providers before December 31, split into fixed categories that can’t substitute for each other.
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 |
The 10 hours of federal tax law topics can cover any IRS-approved subject area. The 2 ethics hours need a course specifically approved for AFSP ethics credit — Michigan’s own return-signing rule doesn’t satisfy this requirement, since it isn’t a CE program. The AFTR itself is a single timed course with a built-in comprehension test; it can’t be split into smaller pieces.
§4 The AFTR Course: What to Expect
The AFTR course runs 6 hours through IRS-approved providers between June 1 and December 31 of the year before the filing season — for the 2027 season, that window closes December 31, 2026. It covers the coming season’s federal tax law changes, common preparer errors, and procedural updates, and ends with a pass/fail comprehension test. Take a look at what the test itself involves before you schedule it, and aim for October or November rather than the congested final weeks of December.
§5 Deadlines and the Record of Completion
December 31, 2026. All CE hours — including the AFTR for non-exempt preparers — must be completed and reported to the IRS by this date to earn the 2027 filing season Record of Completion.
Your IRS-approved provider reports completed hours to the IRS CE system directly. Confirm they landed correctly in your IRS Continuing Education Transcript, accessible through your Tax Pro Account, before mid-December — provider-to-IRS reporting gaps have cost preparers their season before.
Consent Requirement. You must also consent to Circular 230 obligations during PTIN renewal. Completed CE hours without that consent will not produce a Record of Completion.
§6 Why the AFSP Pairs Well With Michigan’s Own Rule
Michigan’s Taxpayer Protection Act already puts your name and ID number on every return you sign — it’s an accountability measure, not a competency signal. The AFSP Record of Completion fills that gap: it puts you in the IRS’s public Tax Pro Directory and grants limited representation rights before the IRS for returns you personally prepared, meaning you can actually represent a client during an exam or collections matter rather than just accompanying them. Together, the state’s identification rule and the federal credential give Michigan clients two separate reasons to trust a preparer who has both in order. See the companion page on AFSP requirements for Michigan preparers for the full hour breakdown, or browse the AFSP & AFTR guide hub for other states and topics.
§7 FAQs
Does Michigan license tax preparers?
No. Michigan has no state exam, license, or registration for paid tax preparers. It does require, under the Taxpayer Protection Act, that preparers sign Michigan returns and include an ID number, with penalties for skipping it — but that’s separate from any competency credential.
What is Michigan’s Taxpayer Protection Act?
Effective January 1, 2021, MCL 205.4a requires paid preparers of Michigan individual, fiduciary, and claimant returns to sign the return and include an identification number such as their PTIN. Missing this carries a $50-per-return penalty, capped at $25,000 per preparer per year, absent reasonable cause.
Does complying with Michigan’s Taxpayer Protection Act satisfy AFSP requirements?
No. The Taxpayer Protection Act is a signature and identification rule, not a continuing-education program. It has no bearing on your AFSP hour requirements or exempt/non-exempt status.
What happens if I miss the December 31 AFSP deadline?
You won’t receive a Record of Completion for that filing season — there’s no grace period or late option. You’d lose the limited representation rights and Tax Pro Directory listing until you complete requirements for the following season.
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.