The 2027 Season AFSP Requirements Guide: Exempt vs. Non-Exempt, Hour by Hour

§1 What Is the AFSP—and Why Does It Still Matter?

The IRS Annual Filing Season Program (AFSP) is a voluntary continuing education initiative designed to encourage non-credentialed tax preparers to stay sharp, stay compliant, and stay competitive. Launched after the courts blocked mandatory PTIN-holder CE requirements, the AFSP became the IRS’s best available tool to raise the competency floor for the roughly 350,000 preparers who hold no professional credential.

Earning the Record of Completion does three concrete things for your practice: it lands your name in the IRS’s public Tax Pro Directory, it signals to clients that you take your craft seriously, and—critically—it grants you limited representation rights before the IRS during examinations, collections, and appeals for returns you personally prepared. Without it, non-credentialed preparers can only accompany a client to an IRS appointment; they cannot speak on the client’s behalf. That distinction alone is worth the CE investment.

§2 Exempt vs. Non-Exempt: Which Category Are You?

The AFSP splits the preparer universe into two tracks based on existing credentials and testing history. Here is how the IRS defines each group.

Exempt preparers have already passed a recognized state or national competency test, so the IRS excuses them from the Annual Federal Tax Refresher (AFTR) course and its comprehension test. Per the IRS, exempt status applies to:

• Anyone who passed the IRS Registered Tax Return Preparer (RTRP) test offered between November 2011 and January 2013
• Active registrants of recognized state programs: the Oregon Board of Tax Practitioners, the California Tax Education Council (CTEC), or the Maryland State Board of Individual Tax Preparers
• Preparers who passed Part 1 of the Special Enrollment Exam (SEE) within the past three calendar years
• VITA/TCE volunteers serving as quality reviewers, instructors, or return preparers with active PTINs

Attorneys, CPAs, and Enrolled Agents already hold unlimited representation rights and do not need the AFSP at all — though if they want the Record of Completion, they follow the same 15-hour exempt track.

Non-exempt preparers are everyone else—PTIN holders who do not fall into one of the above categories. They must complete the full 18-hour package, including the AFTR course.

If you are unsure of your status, log into your IRS Tax Pro Account or check the IRS AFSP landing page. Misclassifying yourself as exempt when you are not will invalidate your Record of Completion.

§3 The Hour-by-Hour Breakdown for Non-Exempt Preparers

Non-exempt preparers must accumulate 18 CE hours from IRS-approved providers before December 31, 2026. The IRS prescribes exactly how those hours must be allocated—you cannot substitute extra ethics hours for federal tax law hours, or vice versa.

SCHEDULE A — NON-EXEMPT PREPARER CE REQUIREMENTS (2027 FILING SEASON)

A few practical notes: the 10 hours of federal tax law can cover any IRS-approved topic—individual returns, business entities, credits, deductions, or a mix. You have flexibility there. The 2 ethics hours must come from an IRS-approved ethics course; general business ethics or state bar ethics will not satisfy this requirement. And the 6-hour AFTR is a single, timed, exam-based course—you cannot split it across multiple shorter courses.

§4 The Hour-by-Hour Breakdown for Exempt Preparers

Exempt preparers skip the AFTR but must still log 15 hours of CE to earn the Record of Completion for the 2027 filing season.

SCHEDULE B — EXEMPT PREPARER CE REQUIREMENTS (2027 FILING SEASON)

Note the distinction between tax law updates (3 hours, focused on recent legislative and regulatory changes) and tax law topics (10 hours, broader subject matter). IRS-approved course catalogs will label each course by category—always confirm the category before you enroll so the hours count toward the correct bucket.

Exempt preparers who also maintain their primary credential (e.g., EA CE for license renewal) should check whether any of those hours double-count toward AFSP requirements. In many cases they do, provided the provider is IRS-approved and the course category aligns.

§5 The AFTR Course: What to Expect

The AFTR is the cornerstone of the non-exempt track and the element most preparers ask about. Here is what you need to know before you sit down to take it.

The course is exactly 6 hours, offered only by IRS-approved CE providers during a specific window each year (June 1 through December 31 of the calendar year preceding the filing season). It covers federal tax topics relevant to the upcoming filing season—recent law changes, common errors, and procedural updates. The course concludes with a comprehension test; you must achieve a passing score to receive CE credit. The IRS sets the passing threshold, and providers are required to use IRS-approved content.

Practical tips: do not wait until late December. Providers get congested, and technical issues at the last minute can cost you the Record of Completion for the entire season. Many experienced preparers target October or November completion.

§6 Deadlines, the Record of Completion, and Limited Representation Rights

Once you complete your hours, your IRS-approved provider reports them directly to the IRS CE system. You do not submit transcripts yourself. However, it is your responsibility to confirm that all hours appear correctly in your IRS Continuing Education Transcript (accessible via your Tax Pro Account). Discrepancies between provider records and IRS records have caused preparers to miss the cutoff—always verify by mid-December.

The Record of Completion is issued electronically. It covers the calendar year filing season (so the 2027 Record of Completion covers returns filed during the 2027 filing season). The limited representation rights attached to it are specific to that season and to returns you personally prepared and signed.

§7 FAQs