IRS fingerprinting is required for three groups of people: applicants for authorized e-file provider status who don’t hold a qualifying professional credential, IRS employees, and most IRS contractors. Everyone else involved in tax preparation, including paid preparers who only hold a Preparer Tax Identification Number, is not fingerprinted. If you do need it, the prints are captured electronically through an IRS-authorized vendor and run against FBI criminal history records as part of a broader suitability check.
Who Actually Needs Fingerprints Taken
The common thread across all three groups is access to taxpayer data or IRS systems. If your role doesn’t involve that access, the requirement doesn’t reach you.
E-File Provider Applicants Without a Credential
When you apply to become an authorized IRS e-file provider, the IRS runs a suitability check that can include a credit check, a tax compliance check, a criminal background check, and a review of any prior e-file violations.1Internal Revenue Service. Become an Authorized E-File Provider The fingerprint step is only triggered for applicants who cannot provide a qualifying professional certification or license.
Attorneys, certified public accountants, and enrolled agents who enter their current professional status on the application are exempt from fingerprinting.2Internal Revenue Service. Tax Pros Can Apply To Be an IRS Authorized E-File Provider in a Few Simple Steps Enrolled retirement plan agents and enrolled actuaries are also expected to be exempt. Applicants who live and work outside the United States are also generally exempt.3IRS.gov. IRS Issues Guidance to Further Implement Return Preparer Oversight
One point of confusion worth clearing up: the fingerprinting requirement is tied to the e-file provider application, not to the PTIN. Getting or renewing a PTIN does not involve biometric screening.
IRS Employees
Every new IRS hire completes a background investigation that includes fingerprint submission, regardless of position level. A favorable FBI criminal history result is required before the employee gets access to facilities, IT systems, or taxpayer information. Higher-risk and national security positions trigger more extensive investigations, but the fingerprinting step is universal.
IRS Contractors
Contractors and vendor employees who need staff-like access to IRS facilities, IT systems, or sensitive information must also be fingerprinted and pass a background investigation. Contractors whose work exceeds 180 calendar days per year need a favorable FBI fingerprint check and a review of investigative paperwork before starting. Even shorter-term contractors under 180 days need a favorably adjudicated fingerprint check before they begin.4Internal Revenue Service. 10.23.2 Contractor Investigations International contractor employees may follow alternative procedures coordinated through their contracting officer.
Scheduling the Appointment and What To Bring
How you schedule depends on your category. E-file provider applicants book through a link on the e-file application summary page after submitting the application, using the IRS-authorized fingerprinting vendor.1Internal Revenue Service. Become an Authorized E-File Provider IdentoGO by IDEMIA is the primary vendor providing these services nationwide for federal programs.
IRS contractor employees are sponsored through the USAccess enrollment system when possible. If a USAccess station isn’t readily available, contractors can use Live Scan at certain IRS offices or other IRS-approved locations. Traditional ink-and-roll fingerprint cards are still used in rare cases.4Internal Revenue Service. 10.23.2 Contractor Investigations
Bring two forms of identification. At least one must be a government-issued photo ID such as a state driver’s license, U.S. passport, or military ID. The second document can be anything listed on the back of Form I-9, like a Social Security card or birth certificate.5Internal Revenue Service. IRS HSPD-12 PIV Procedures Manual The name and date of birth on your IDs have to exactly match what’s on your application. A mismatch causes the FBI to reject the submission outright.
You’ll also need the correct service code, sometimes called “Reason for Fingerprinting,” which links your prints to the right investigation request. For e-file applicants, this is supplied through the scheduling link on your application summary page. Fees vary by vendor and location and are paid directly to the service provider at the appointment. For contractors fingerprinted outside an IRS office or approved enrollment station, the cost falls on the contractor or their employer.4Internal Revenue Service. 10.23.2 Contractor Investigations
What Happens During the Appointment
The technician verifies your identity documents and confirms your biographical data and service code before touching the scanner. The Live Scan device electronically captures all ten fingerprints and checks image quality in real time, which is a meaningful improvement over the old ink-and-card method that often produced illegible prints not discovered until weeks later.
Once the capture is complete, the encrypted data goes directly to the FBI’s Criminal Justice Information Services Division for processing against national criminal databases. You’ll receive a receipt with a transaction control number. Keep it. That number is your proof of submission and the only way to check on your fingerprints later. The appointment itself typically runs 15 to 20 minutes.
If the FBI Rejects Your Prints
Image-quality rejections happen more often than people expect, particularly for applicants with worn fingerprints from manual labor, aging, or certain skin conditions. If your prints are rejected you’ll get a notice and need to return for a second capture. Many vendors don’t charge for the re-scan when the first rejection was a quality issue.
If prints are rejected multiple times, the investigating agency may accept an alternative identity verification method or request a manual review. Don’t sit on a rejection notice. The delay cascades into your suitability determination and can stall an e-file application or an employment start date.
What the IRS Is Actually Checking
The fingerprint check is one piece of a larger suitability evaluation. For e-file providers, the IRS looks at credit, tax compliance, criminal history, and any prior e-file compliance issues. The full application review can take up to 45 days from submission.1Internal Revenue Service. Become an Authorized E-File Provider For employees and contractors, FBI fingerprint results often come back within 48 to 72 hours when there’s no matching criminal history, but the full determination takes longer because it incorporates the other investigative elements.
What Can Lead to an Unfavorable Decision
Under 5 CFR 731.202, factors that can produce an unfavorable determination include:6eCFR. 5 CFR Part 731 – Suitability and Fitness
- Criminal conduct, with severity and recency weighed.
- Dishonest conduct such as fraud, misrepresentation, or deceptive behavior.
- False statements on the application or during the investigation.
- Misconduct in employment, including a pattern of workplace problems or negligence.
- Excessive alcohol use or illegal drug use without evidence of rehabilitation.
- A history of violent conduct.
- Statutory bars that specifically prevent employment in the position.
Evaluators weigh each factor against the nature of the position, the seriousness of the conduct, how recent it was, and any evidence of rehabilitation. A decades-old misdemeanor is treated differently than a recent felony. If credit report information could lead to an unfavorable decision, the IRS must notify you.7Internal Revenue Service. 6.731.1 Suitability Determinations for Employment
A failed suitability check means an employee or contractor won’t be authorized to access federal tax information, and an e-file applicant’s application is denied, blocking them from electronically transmitting returns through the IRS system.8Internal Revenue Service. Background Investigations
Fixing Errors and Appealing a Denial
If the fingerprint results pull up criminal history information that’s inaccurate or incomplete, you can challenge the FBI’s Identity History Summary at no cost. Your challenge needs to identify what you believe is wrong and include supporting documentation such as court records showing a dismissal, expungement, or correction. The FBI processes challenges in the order received, with an average response time of about 45 days.9Federal Bureau of Investigation. Identity History Summary Checks Frequently Asked Questions State-level arrest records are handled by the state identification bureau where the offense occurred. Federal arrest data is only removed at the request of the submitting agency or by a federal court order directing expungement.
If the IRS proposes an unfavorable suitability action against you, it must notify you in writing at least 30 days before the action takes effect, and the notice must explain the reasons and your right to respond. You then have 30 days to submit a written answer with any supporting evidence or affidavits, and you can bring a representative at your own expense. After reviewing your response, the IRS has to issue a final written decision within 30 days.7Internal Revenue Service. 6.731.1 Suitability Determinations for Employment
If the final decision goes against you, you can appeal to the Merit Systems Protection Board. The Board reviews whether the charges are supported by a preponderance of the evidence. If it sustains fewer than all charges, the case goes back to the IRS to reconsider whether the action is appropriate based only on the charges that held up.10eCFR. 5 CFR 731.501 – Appeal to the Merit Systems Protection Board