PTIN for Tax Preparers Without an SSN: Forms, Fees, and Renewal

A tax preparer who does not have and cannot get a Social Security Number can still obtain a PTIN by filing a paper application with the IRS. The route for tax preparers without an SSN uses Form W-12 together with a supplemental form, Form 8946, plus two identity documents and an $18.75 fee. Processing takes about six weeks, and the PTIN must be renewed every year.¹²

Whether This Pathway Applies to You

The IRS uses “foreign person” for this purpose to mean someone who does not have and is not eligible to get an SSN, and who is neither a U.S. citizen nor a resident alien.³ Resident-alien status usually turns on the substantial presence test, which counts days of physical presence in the United States across a three-year period; if the count reaches 183 days, you are treated as a resident alien and need to pursue an SSN instead.⁴

Two situations look like they might qualify but do not. An ITIN is not a substitute for an SSN here: ITIN holders can use this pathway only if they are foreign persons with a permanent non-U.S. address and can document that status.⁵ And if you have an SSN application pending with the Social Security Administration, wait until the SSA notifies you in writing that an SSN cannot be issued before filing Form 8946.³

The Two Forms You File

Form W-12 is the standard PTIN application every paid preparer files. It collects personal information, business details, and professional credentials such as CPA or Enrolled Agent status.⁶ Form 8946 is the supplemental application built for applicants without an SSN. It asks you to explain why you cannot get one and provides fields for a foreign address.³

The name on Form W-12 must match the name on your identity documents exactly. Small differences in spelling or name order are among the most common reasons paper applications are rejected. Answer every question about professional conduct and past tax compliance truthfully, because inaccuracies can trigger penalties.

Identity Documents

Form 8946 requires two government-issued identity documents. At least one must include your photograph, and together they must verify both your identity and your status as a foreign person.³ Documents the IRS accepts:

Passport
U.S. Department of State visa
Foreign driver’s license
Foreign military ID card
Foreign voter’s registration card
USCIS document (Form I-766, I-551, I-94, or I-94A)
National ID card

A passport plus one other item from the list is the cleanest combination, since a passport by itself satisfies the photo requirement and strongly establishes foreign status. A second document is still required regardless.

Originals or Certified Copies

You can send originals or notarized copies. Copies must be certified either by a U.S. consulate or embassy employee, or by a foreign notary who is legally authorized within their local jurisdiction. The certifying authority must examine the original, unaltered documents and confirm the copies match, and every copy must carry the notary’s stamp or signature.³ Certified copies are the safer choice when international mail is involved.

Fee and Mailing Address

The 2026 fee is $18.75, made up of a $10 IRS fee and an $8.75 fee paid to the agency’s third-party contractor. Paper applicants pay by check or money order, each payment must state the calendar year it covers, and you need a separate check for each year if you are applying or renewing for more than one period at once.⁷

Online filing is not available for this pathway. Mail the full package (Form W-12, Form 8946, identity documents, and payment) to:

IRS Tax Professional PTIN Processing Center
PO Box 380638
San Antonio, TX 78268⁸

After You Mail It

Allow six weeks for processing.⁸ If you sent original identity documents, the IRS returns them to the mailing address on Form 8946 with no return envelope required. If originals have not come back within 60 days, call the IRS for a status update.³

Renewing Each Year

Every PTIN expires on December 31 regardless of when it was issued. The renewal window opens in mid-October for the following year.⁷ Renewal is faster than the initial application when your status and address have not changed, but the $18.75 fee applies every year.² Signing a return with an expired PTIN counts the same as having no PTIN at all, so build in extra time for international mail.

Penalties for Preparing Returns Without a Valid PTIN

Federal law requires every return prepared by a paid preparer to bear the preparer’s identifying number.⁹ Failing to include one carries a penalty of $65 per return for filings in 2026, capped at $32,500 per preparer per calendar year.¹⁰ The penalty does not apply where the failure was due to reasonable cause rather than willful neglect.¹¹

Beyond per-return fines, a federal court may enjoin someone from acting as a tax return preparer at all where the person has repeatedly engaged in conduct subject to penalties, misrepresented credentials, guaranteed refunds, or committed fraud that interferes with tax administration.¹²

Conduct Rules That Come With the Number

Every paid preparer who practices before the IRS is subject to Treasury Department Circular 230. You must exercise due diligence in preparing returns, verify the correctness of representations you make to clients or the IRS, and take on only work you are competent to perform. You cannot sign a return you know or should know takes an unreasonable position, you must tell clients about penalties that could apply to positions on their returns, and when a client has made an error or omission on a previously filed return, you must advise them of the fact and its consequences.¹³

The IRS Office of Professional Responsibility enforces Circular 230 and can impose sanctions ranging from censure to monetary penalties to permanent disbarment from practice before the IRS.¹⁴ These duties apply to every PTIN holder, whether the number was issued off an SSN or through the foreign-person route.

1
Internal Revenue Service. PTIN Requirements for Tax Return Preparers
2
Internal Revenue Service. PTIN Top FAQs
3
Internal Revenue Service. Form 8946 – PTIN Supplemental Application for Foreign Persons Without a Social Security Number
4
Internal Revenue Service. Substantial Presence Test
5
Internal Revenue Service. Frequently Asked Questions: Do I Need a PTIN?
6
Internal Revenue Service. Form W-12 (Rev. October 2025)
7
Internal Revenue Service. Frequently Asked Questions: PTIN Application/Renewal Assistance
8
Internal Revenue Service. Instructions for Form W-12
9
Office of the Law Revision Counsel. 26 USC 6109
10
Internal Revenue Service. Rev. Proc. 2024-40
11
Office of the Law Revision Counsel. 26 U.S. Code 6695 – Other Assessable Penalties With Respect to the Preparation of Tax Returns for Other Persons
12
Office of the Law Revision Counsel. 26 USC 7407 – Action to Enjoin Tax Return Preparers
13
Internal Revenue Service. Treasury Department Circular No. 230
14
Internal Revenue Service. Office of Professional Responsibility and Circular 230