If you prepare federal tax returns for compensation and you do not hold an Enrolled Agent, CPA, or attorney credential, you have no automatic pathway to IRS representation rights, and nothing on the public IRS directory to show prospective clients. The IRS Annual Filing Season Program changes that, within specific limits.
This guide explains exactly what the AFSP is, what it requires, and what it actually gets you. Every detail here has been verified against IRS.gov. Because AFSP involves specific regulatory requirements, verify current requirements at IRS.gov before enrolling.
What Is the IRS Annual Filing Season Program
The IRS Annual Filing Season Program (AFSP) is a voluntary continuing education program for non-credentialed paid tax preparers. Completing it earns three things: an IRS record of completion, a listing in the IRS public directory (formally titled the "Directory of Federal Tax Return Preparers with Credentials and Select Qualifications"), and limited representation rights before certain IRS personnel on returns the preparer prepared and signed.
AFSP is not a license. It is not a certification. It is not a credential. It does not confer the same authority or representation scope as an Enrolled Agent, CPA, or attorney. What it is: a structured, annual CE requirement with a competency test component, backed by IRS recognition for the non-credentialed preparers who complete it.
Who Is AFSP For
AFSP is designed for paid tax preparers who do not hold an EA, CPA, or attorney credential and who want to demonstrate professional commitment, appear in the IRS public directory, and gain limited representation rights before the IRS.
If you are a non-credentialed preparer, AFSP is the most direct path the IRS offers to those benefits. If you already hold an EA, CPA, or attorney license, you already have broader IRS representation rights through your existing credential and typically do not need AFSP for that purpose (though you may still complete CE for other professional reasons).
The exempt track
Some preparers who hold certain non-exempt credentials may qualify for a reduced 15-hour CE track rather than the standard 18-hour track. The IRS specifies which credentials qualify for exempt status on IRS.gov. If you hold a credential and are unsure whether you qualify for the exempt track, verify at IRS.gov before enrolling in a course package.
AFSP Requirements: CE Hours
Non-exempt preparers must complete 18 CE hours per year to qualify for the AFSP record of completion. Exempt-track preparers must complete 15 CE hours (the specific breakdown and eligible credentials are published at IRS.gov).
Non-exempt preparer requirements: 18 CE hours total
| CE Category | Hours Required |
|---|---|
| Federal tax law topics | 10 hours |
| Ethics | 2 hours |
| Federal tax law updates (including the Annual Federal Tax Refresher course with competency test) | 6 hours |
| Total | 18 hours |
Exempt-track preparer requirements: 15 CE hours total
Preparers who hold certain credentials specified by the IRS may qualify for a 15-hour track with a different course breakdown. The current list of qualifying credentials and the exempt-track breakdown is published on IRS.gov. Do not assume you qualify for the exempt track without verifying your specific credential against the current IRS criteria.
Timing and provider requirements
All AFSP CE must be completed annually, before the IRS deadline (typically in December, though the exact date may vary year to year). Verify the current deadline at IRS.gov.
All CE must be completed through an IRS-approved CE provider. Courses taken through non-approved providers do not count toward AFSP requirements, even if the subject matter matches.
The Annual Federal Tax Refresher Course
The 6-hour federal tax law updates component of the 18-hour requirement is not simply any update course. It must be the Annual Federal Tax Refresher (AFTR) course, a structured course that concludes with a competency test that preparers must pass.
This is the element that distinguishes AFSP from simply accumulating CE hours. You cannot complete 18 hours of IRS-approved CE from unrelated course categories and receive the record of completion. The AFTR course and its competency test are a required, distinct component. If you do not pass the AFTR test, you do not qualify for the record of completion for that year.
The AFTR course is offered by IRS-approved CE providers and must be completed in its entirety, including the test, by the annual IRS deadline.
What AFSP Record of Completion Gets You
Completing the AFSP requirements earns two specific, IRS-defined benefits. Understand exactly what each one is, and what each one is not.
1. Listing in the IRS public directory
The IRS maintains a publicly searchable tool called the "Directory of Federal Tax Return Preparers with Credentials and Select Qualifications." Completing AFSP gets you listed there alongside credentialed preparers (EAs, CPAs, attorneys) who have active credentials.
Some clients use this directory to research and compare preparers before hiring. Being listed signals that you completed a structured annual CE program recognized by the IRS. It is not a seal of approval and it does not imply any credential you do not hold, but it is a visible, verifiable signal of professional standing that non-credentialed preparers cannot obtain any other way.
2. Limited representation rights before the IRS
AFSP holders gain limited representation rights before the IRS, and understanding what "limited" means here is critical.
What AFSP representation rights cover:
- Revenue agents
- Customer service representatives
- Similar IRS personnel
- The Taxpayer Advocate Service
This representation is permitted ONLY on returns the preparer prepared and signed for the client in question.
What AFSP representation rights do NOT cover:
- IRS Appeals Officers
- U.S. Tax Court
If a client's matter reaches Appeals or Tax Court, an AFSP holder cannot represent them there. That representation requires an EA, CPA, or attorney. Do not represent to clients that your AFSP record of completion grants broader authority than the IRS has defined. Overstating your representation scope in marketing is itself a Circular 230 Section 10.30 advertising violation, so review the tax preparer marketing and advertising compliance guide before describing your AFSP status in any ad or directory listing.
AFSP participants use Form 2848 for limited IRS contacts on behalf of clients whose returns they prepared. For a complete comparison of IRS representation rights across all credential levels, see the IRS representation rights guide for tax preparers.
How to Earn the AFSP Record of Completion
The IRS issues the AFSP record of completion through the IRS Tax Professional PTIN System. Here are the steps:
Hold a valid PTIN for the calendar year
You must have an active Preparer Tax Identification Number for the year in which you are seeking the record of completion. If you do not yet have a PTIN, complete that registration first. See the full guide at How to Get a PTIN.
Find an IRS-approved CE provider
Not every CE provider is IRS-approved. Verify that the provider you choose appears in the IRS CE Provider lookup at IRS.gov before enrolling. Only courses from IRS-approved providers count toward AFSP.
Complete the required CE hours, including the AFTR course with competency test
For non-exempt preparers: 18 hours total (10 federal tax law, 2 ethics, 6 federal tax law updates including the AFTR course). The AFTR course includes a competency test you must pass. Complete all hours before the annual IRS deadline.
Consent to Circular 230 requirements for non-credentialed preparers
Before the IRS issues the record of completion, you must consent to adhere to the Circular 230 standards that apply to non-credentialed preparers with limited representation rights. This consent is a mandatory step. The IRS will not issue the record without it.
Receive the record of completion through the IRS PTIN System
Once your approved CE provider reports your completed hours to the IRS and you have consented to Circular 230 requirements, the IRS issues the record of completion through the PTIN System. Your listing in the IRS public directory follows.
If you are new to the tax preparation profession and working through the full sequence of IRS registrations, start with How to Start a Tax Preparation Business for the complete picture.
GSTTI AFSP Courses
Golden State Tax Training Institute, Inc. (GSTTI) is an IRS-approved CE provider (IRS Provider Number P619F) that offers AFSP-qualifying courses, including the 18-hour package that meets the non-exempt preparer requirement and includes the Annual Federal Tax Refresher course with competency test.
GSTTI is one of many IRS-approved CE providers. You are not required to use any specific provider to earn the AFSP record of completion. If GSTTI's course offerings fit your schedule, budget, and learning format, you can enroll directly through America's Tax Professionals.
Frequently Asked Questions
What is the IRS Annual Filing Season Program?
The IRS Annual Filing Season Program (AFSP) is a voluntary continuing education program for non-credentialed paid tax preparers. Completing the required CE hours, including passing the Annual Federal Tax Refresher competency test, and consenting to Circular 230 requirements earns a preparer an IRS record of completion, a listing in the IRS public directory, and limited representation rights before specific IRS personnel on returns the preparer prepared and signed. AFSP is not a credential, license, or certification.
Does completing AFSP allow me to represent clients before the IRS?
Yes, but only within defined limits. AFSP holders may represent clients before revenue agents, customer service representatives, similar IRS personnel, and the Taxpayer Advocate Service, but only for returns the AFSP holder personally prepared and signed. AFSP does not authorize representation before IRS Appeals Officers or before the U.S. Tax Court. If a client's matter moves to Appeals or Tax Court, representation by an Enrolled Agent, CPA, or attorney is required.
How many CE hours does the Annual Filing Season Program require?
Non-exempt preparers must complete 18 CE hours per year: 10 hours of federal tax law topics, 2 hours of ethics, and 6 hours of federal tax law updates that include the Annual Federal Tax Refresher (AFTR) course with a required competency test. Preparers who qualify for the exempt track (based on credentials specified by the IRS) must complete 15 CE hours. Verify current requirements and exempt criteria at IRS.gov before enrolling.
Is AFSP the same as becoming an Enrolled Agent?
No. An Enrolled Agent (EA) is a federally authorized tax practitioner who has earned that credential by passing the IRS's three-part Special Enrollment Examination (or through qualifying IRS experience) and meeting continuing education requirements. EAs have unlimited representation rights before the IRS for any taxpayer, on any tax matter. AFSP is a voluntary annual CE program. Completing it does not confer EA status, does not count as credit toward EA exam eligibility, and does not grant the representation scope that an EA credential carries.