AFTR Course for Virginia Tax Preparers: What the 2027 Season Requires
- Non-exempt Virginia preparers need 18 hours of CE, including the 6-hour AFTR course, by December 31, 2026.
- Virginia has no state preparer license, but since tax years beginning January 1, 2019, Va. Code § 58.1-348.4 has required every paid preparer to include their PTIN on any Virginia income tax return they sign.
- Skipping that PTIN carries a $50-per-offense civil penalty, capped at $25,000 per preparer per calendar year.
- Exempt preparers (CTEC, Oregon OBTP, Maryland board registrants, recent SEE Part 1 passers) need only 15 hours and skip the AFTR.
§1 Virginia’s PTIN Mandate, Explained
Virginia has never licensed or tested paid tax preparers — there’s no state exam or registration beyond your federal PTIN. But Virginia does enforce that PTIN directly at the state level. Under Va. Code § 58.1-348.4, for taxable years beginning on and after January 1, 2019, no income tax return preparer may provide Virginia tax preparation services unless they include their PTIN on any return they prepare or assist in preparing and sign it as the preparer. A preparer who skips this owes the Virginia Department of Taxation a civil penalty of $50 per offense, capped at $25,000 per calendar year — unless the Department finds the violation was reasonable and unintentional.
This is an identification and accountability rule, not a competency credential — it doesn’t test anyone’s tax knowledge, and it runs in parallel to (not in place of) your federal PTIN obligation. Keeping your PTIN renewal current matters even more in Virginia, since the state statute is built directly around that number.
§2 Exempt vs. Non-Exempt: Where Virginia Preparers Land
Virginia isn’t one of the three states — Oregon, California, and Maryland — whose own credential grants IRS AFSP exemption, so a Virginia-only preparer without an outside qualifying credential falls into the non-exempt track by default and needs the full 18-hour package, including the AFTR course. Run the 2-minute exempt check if you hold a qualifying out-of-state credential or passed Part 1 of the Special Enrollment Exam within the last three years. 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 Virginia preparers need 18 CE hours from IRS-approved providers before December 31, split into fixed categories.
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 — Virginia’s PTIN-disclosure statute doesn’t satisfy this, since it isn’t a CE program. The AFTR is a single timed course with a built-in comprehension test and 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, the window closes December 31, 2026. It covers the coming season’s federal tax law changes, common preparer errors, and procedural updates, ending with a pass/fail comprehension test. See what the test itself involves before scheduling 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.
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 Still Matters Alongside the PTIN Mandate
Virginia’s PTIN-disclosure statute confirms who prepared a return and holds them accountable to the state — it doesn’t say anything about how competent they are. The AFSP Record of Completion fills that gap: it puts your name in the IRS’s public Tax Pro Directory and grants limited representation rights before the IRS for returns you personally prepared, letting you actually represent a client during an exam or collections matter rather than just sitting beside them. In a state that already tracks your PTIN by law, pairing it with an AFSP credential gives clients a clearer picture of who they’re hiring. See the companion page on AFSP requirements for Virginia preparers for the full hour breakdown, or browse the AFSP & AFTR guide hub.
§7 FAQs
Does Virginia license tax preparers?
No. Virginia has no state exam, license, or registration for paid tax preparers. It does require, under Va. Code § 58.1-348.4, that a preparer’s PTIN appear on any Virginia return they sign — but that’s an identification rule, not a competency credential.
What happens if I don’t put my PTIN on a Virginia return?
The Virginia Department of Taxation can assess a $50 civil penalty per offense, capped at $25,000 per preparer per calendar year, unless the Department determines the violation was reasonable and unintentional.
Does complying with Virginia’s PTIN rule satisfy AFSP requirements?
No. Virginia’s statute is a disclosure and accountability rule, not continuing education. It has no bearing on your AFSP hour requirement 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. You’d lose the limited representation rights and Tax Pro Directory listing until you complete requirements for the following season.