What Is an AFSP Tax Preparer? Duties, Credentials, and Costs

An AFSP tax preparer is a paid federal tax return preparer who has completed the IRS Annual Filing Season Program and holds a current-year Record of Completion. The credential is voluntary, aimed at preparers who are not attorneys, CPAs, or enrolled agents, and it gives them two things a plain PTIN holder does not have: a listing in the IRS public directory of tax professionals, and limited authority to represent clients before the IRS during an examination of a return the preparer personally prepared and signed.¹

What an AFSP Preparer Can Do for a Client

Representation is the core benefit. An AFSP participant can speak for a client during an IRS examination of a return that participant prepared and signed, dealing with revenue agents, customer service representatives, and the Taxpayer Advocate Service.² In an audit, that means answering IRS questions, explaining how the return was put together, and providing supporting documentation.

The limits matter as much as the authority. AFSP participants cannot represent clients before the IRS Appeals Office or on collection matters, even for a return they prepared.² If an audit moves to appeals, or if a balance goes into collections, you would need an enrolled agent, CPA, or attorney to take over.

One rule catches both preparers and clients off guard. To represent you in an examination, the preparer must hold a Record of Completion for the year the return was prepared and for the year the representation actually happens.² A preparer who let the credential lapse for a single year loses representation authority for anything filed during that gap.

An unenrolled preparer with no credential at all has no authority to represent clients before the IRS for any return prepared and signed after December 31, 2015.³ The AFSP is what fills that gap for non-credentialed preparers.

How AFSP Preparers Compare to CPAs, Enrolled Agents, and Attorneys

Enrolled agents, CPAs, and attorneys hold unlimited practice rights. They can represent any client on any tax matter before any IRS office, including audits, collections, and appeals.⁴ An AFSP participant’s authority is narrower by design.

The training gap explains the rights gap. Enrolled agents pass the three-part Special Enrollment Examination covering individual tax, business tax, and representation procedures.⁵ CPAs meet state licensing rules including an exam and experience hours. Attorneys pass a state bar. AFSP participants complete 18 hours of continuing education and a comprehension test each year.

For a straightforward return with no unusual issues, an AFSP preparer may be all you need. For a complex situation, or one with any real chance of collections or appeals, the higher credential is worth the higher fee.

Finding an AFSP Preparer in the IRS Directory

The IRS keeps a searchable public database called the Directory of Federal Tax Return Preparers with Credentials and Select Qualifications. Only six categories appear in it: enrolled agents, CPAs, attorneys, enrolled retirement plan agents, enrolled actuaries, and AFSP Record of Completion holders.⁶ Any other paid preparer, even one with a valid PTIN, is not listed.

You can search by location and see each preparer’s name, city, state, ZIP code, and credential type.⁷ Some qualifying preparers opt out of the directory, so absence is not proof someone lacks credentials, but the directory is the fastest first check.⁶

How a Preparer Earns the Record of Completion

The Record of Completion is valid for one calendar year, so preparers repeat the requirements every year.⁸ Everything must be finished by December 31, with no exceptions.⁹

PTIN Renewal

Every paid preparer needs a current-year Preparer Tax Identification Number. For 2026, the fee is $18.75, which combines a $10 IRS user fee and an $8.75 third-party processing fee.¹⁰¹¹

18 Hours of Continuing Education

The education requirement breaks into three parts, all through IRS-approved providers:¹²

6 hours of the Annual Federal Tax Refresher (AFTR) course, followed by a knowledge-based comprehension test given by the course provider.
10 hours of federal tax law topics.
2 hours of ethics.

CE providers report completed credits to the IRS electronically, so preparers do not submit proof themselves.⁹

Circular 230 Consent

The last step is consenting to the professional duties in Subpart B of Treasury Department Circular 230. Once PTIN renewal opens in October, the IRS sends instructions by email or letter explaining how to sign the consent and receive the Record of Completion certificate.¹²

Exemptions From the AFTR Course

Some preparers can skip the 6-hour AFTR course because they have already shown competency elsewhere. They still complete 15 hours: 10 hours of federal tax law, 3 hours of federal tax law updates, and 2 hours of ethics.¹³ Qualifying groups include:

Individuals who passed the IRS Registered Tax Return Preparer test given between November 2011 and January 2013.¹⁴
Active registrants of the Oregon Board of Tax Practitioners, California Tax Education Council, or Maryland State Board of Individual Tax Preparers.
Tax practitioners who passed Part 1 of the Special Enrollment Examination within the past three calendar years.
Holders of the Accredited Business Accountant/Advisor or Accredited Tax Preparer designation from the Accreditation Council for Accountancy and Taxation.
VITA and TCE quality reviewers, instructors, and return preparers who hold active PTINs.

Professional Standards and Sanctions

Signing the Circular 230 consent binds AFSP participants to duties of competence, due diligence, honesty with the IRS, accuracy in written tax advice, and avoidance of conflicts of interest. It also bars disreputable conduct, including helping clients evade taxes or violate federal tax law.

The IRS can impose real penalties on any practitioner, AFSP participants included, who breaks those rules:

Censure, a public reprimand that becomes part of the practitioner’s record.
Suspension of the right to practice before the IRS.
Disbarment, a permanent revocation of practice rights.
Monetary penalties up to the gross income the practitioner earned from the misconduct, which can be imposed in addition to or instead of suspension or disbarment.¹⁵

Triggers include conviction of a crime involving dishonesty, giving false information to the IRS, misappropriating client funds, and a pattern of failing to file personal tax returns.¹⁵

What It Costs

The federal cost is small. PTIN renewal runs $18.75 per year, and the IRS charges nothing extra for the Record of Completion. The main out-of-pocket expense is the coursework: complete 18-hour packages from IRS-approved providers generally run under $100, and the IRS keeps a searchable list of approved providers.¹⁶ Some states also require non-credentialed preparers to register or hold a state license, with separate fees and sometimes bonding requirements independent of the federal program.

1
Internal Revenue Service. Annual Filing Season Program
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IRS.gov. AFSP – Record of Completion
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Internal Revenue Service. Revenue Procedure 2014-42
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Internal Revenue Service. Understanding Tax Return Preparer Credentials and Qualifications
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Internal Revenue Service. Enrolled Agents – Frequently Asked Questions
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Internal Revenue Service. FAQs Directory of Federal Tax Return Preparers with Credentials and Select Qualifications
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IRS – Treasury. RPO Preparer Directory
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Internal Revenue Service. AFSP Top FAQ
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Internal Revenue Service. CE Provider FAQs – Annual Federal Tax Refresher (AFTR) Course
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Internal Revenue Service. Treasury, IRS Issue Regulations to Reduce the Amount of the User Fee for Tax Professionals Who Apply for or Renew a PTIN
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Internal Revenue Service. General Requirements for the Annual Filing Season Program Record of Completion
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eCFR. 31 CFR Part 10 Subpart C – Sanctions for Violation of the Regulations
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Internal Revenue Service. Continuing Education for Tax Professionals