What Is the IRS Annual Filing Season Program (AFSP)?

What the AFSP is

The Annual Filing Season Program (AFSP) is a voluntary IRS continuing-education program for tax preparers who do not hold one of the four professional credentials (Attorney, CPA, EA, or Enrolled Retirement Plan Agent). Participants who complete the program receive a Record of Completion from the IRS and are listed in the IRS’s public Directory of Federal Tax Return Preparers with Credentials and Select Qualifications.

The Loving v. IRS background

In 2011 the IRS attempted to regulate all paid preparers through a mandatory testing-and-CE program known as the Registered Tax Return Preparer (RTRP) program. The Institute for Justice sued on behalf of three preparers in Loving v. IRS, and the DC Circuit ultimately held in 2014 that the IRS lacked statutory authority to require unenrolled preparers to be tested. The court’s ruling left a gap: the IRS could no longer mandate testing of unenrolled preparers, but had no comparable mechanism for ensuring continuing competence in the unenrolled population.

The AFSP was launched later in 2014 as the IRS’s voluntary response. The program offers unenrolled preparers a way to demonstrate continuing professional education without overstepping the Loving ruling, and gives consumers a credential signal to look for when shopping among unenrolled preparers.

Recommended: a deeper background read on tax-professional credentialing →

The 18-hour CE requirement

To complete the AFSP for a given filing season, a preparer must take 18 hours of continuing education during the prior calendar year. The 18 hours include a six-hour Annual Federal Tax Refresher (AFTR) course, a three-hour federal tax law update, and ten additional hours of federal tax law and ethics. The AFTR concludes with a 100-question multiple-choice test that must be passed with a score of 70 percent or higher. CE must be obtained through IRS-approved providers; commercial platforms typically bundle the requirement into a single annual subscription.

What AFSP filers can and cannot do

AFSP filers can prepare any federal tax return, e-file with the IRS, and accept compensation for return preparation. They are listed in the IRS’s public preparer directory alongside EAs, CPAs, and attorneys, and they may use the AFSP Record of Completion as a marketing credential.

AFSP filers cannot represent taxpayers before the IRS to the same extent that EAs, CPAs, and attorneys can. They have only “limited” representation rights, described below.

Limited representation rights, explained

An AFSP filer may represent a client before the IRS only on returns the AFSP filer personally prepared and signed, and only at the examination level (in a correspondence audit or office audit, for example). They may not represent the client in collection cases, in appeals before the IRS Office of Appeals, or in any matter before the US Tax Court. They cannot represent clients on returns prepared by another preparer.

This is a meaningful limitation. If an audit escalates to appeals or a collection case develops, the taxpayer must engage an EA, CPA, or attorney to handle the matter. For routine returns that never receive IRS attention, the AFSP credential is generally sufficient.

Who should consider AFSP completion

From a preparer’s perspective, AFSP is the practical choice for unenrolled preparers who want IRS recognition but have not yet pursued (or do not plan to pursue) the EA or CPA credentials. From a consumer’s perspective, the AFSP Record of Completion is a meaningful signal that the preparer takes their continuing education seriously and has demonstrated current-year competence on a 100-question federal tax test.

How AFSP differs from EA and CPA

The EA and CPA credentials are full professional licenses with broad scope, multi-year examinations, ongoing CE obligations, and unlimited IRS representation rights. The AFSP is a single-year continuing-education program with a much shorter test, no professional licensure, and limited representation rights. The AFSP is to the EA roughly as a continuing-education certificate is to a graduate degree: useful, demonstrable, and a positive signal — but not a substitute for the underlying credential.

How to verify an AFSP filer

The IRS’s public preparer directory at irs.treasury.gov/rpo/rpo.jsf confirms AFSP completion for the current filing season. The directory shows the preparer’s name, city, state, ZIP, and credential. AFSP completion is granted on a year-by-year basis, so always confirm completion for the specific filing season you are filing.

Continue reading

• What Is an IRS Enrolled Agent? — A plain-English explainer of the Enrolled Agent credential, the Special Enrollment Examination, and what unlimited representation rights actually mean.
• What Is a Certified Public Accountant? — How CPAs become licensed by state boards of accountancy, what the four-section CPA exam covers, and when a CPA is the right hire for tax work.
• How to Verify a Tax Preparer's PTIN — Step-by-step instructions for confirming any paid preparer's PTIN against the IRS Return Preparer Office public directory.
• Enrolled Agent vs CPA: Which One Should You Hire? — A side-by-side comparison of the EA and CPA credentials across scope, cost, representation rights, and typical engagements.