EFIN Background Check: What the IRS Suitability Check Covers for E-File Provider Applicants

Before the IRS issues an Electronic Filing Identification Number, it runs a suitability check on every principal listed on the application. That check includes a criminal background review, a credit review, a tax compliance review, and a review of prior IRS disciplinary history. For most non-credentialed applicants, it also includes fingerprinting.

This guide is the companion reference to the main EFIN application guide. It covers the suitability check in full: what the IRS looks at, who must be fingerprinted, how to schedule an electronic Livescan submission, what can disqualify an applicant, and what to do if your application is denied. All details here are drawn from IRS.gov and IRM 3.42.5. Because IRS policies can change, verify current requirements at IRS.gov before submitting your application.

What the IRS Suitability Check Covers

The IRS suitability check is not a single search. It is a multi-part review that touches four distinct areas. Each area can independently affect the outcome of your application.

Criminal background check

The criminal background check is fingerprint-based and runs through the FBI. Fingerprint data is transmitted electronically from an IRS-authorized Livescan vendor to the FBI and then to the IRS. The IRS reviews the results as part of the full suitability determination. This component applies specifically to applicants who do not hold a current qualifying professional credential (see the fingerprinting section below).

Credit check

The IRS reviews credit history as a measure of financial responsibility. Unresolved federal tax liens are a particular concern, but the credit review is broader than lien status alone. Serious, unresolved financial obligations can weigh against an applicant during the suitability review.

Tax compliance check

Every principal on the application must be current on their own federal tax obligations at the time of review. This means filed returns for all applicable years and no unresolved balances due. If you owe back taxes or have unfiled returns, address them before submitting your EFIN application. The IRS will review your compliance history directly.

Prior IRS non-compliance check

The IRS also reviews whether any principal has a history of prior program violations: prior EFIN suspensions or revocations, and any disciplinary history with the IRS Office of Professional Responsibility (OPR). If you or a responsible official on your application has had prior issues with IRS e-file programs, that history will surface during this review. See the Circular 230 guide for background on OPR jurisdiction and the conduct standards that can lead to disciplinary proceedings.

Who Must Be Fingerprinted

Whether you need to submit fingerprints depends on whether you currently hold a qualifying professional license.

Exempt from fingerprinting: applicants who hold a current CPA license, active attorney bar membership, active Enrolled Agent credential, or a current AFSP (Annual Filing Season Program) Record of Completion. These applicants submit a copy of their current credential in place of fingerprints. The credential must be active at the time of application; an expired credential does not satisfy this exemption.

Required to submit fingerprints: all other applicants, including non-credentialed preparers and applicants whose credentials fall outside the categories above. If you are not sure whether your credential qualifies for the exemption, check the current list of qualifying credentials at IRS.gov before scheduling a fingerprint appointment.

If you do not yet hold one of the qualifying credentials but plan to pursue the AFSP Record of Completion, note that the AFSP credential must be current at the time you submit your EFIN application to count toward the fingerprint exemption. Completing it before applying is the more direct path for preparers who are close to the AFSP finish line.

Electronic Fingerprinting: Livescan and IdentoGO

The IRS requires fingerprints to be submitted electronically through an IRS-authorized Livescan vendor. Paper fingerprint cards are no longer accepted. The electronic Livescan requirement has been in effect since September 25, 2022; confirm current requirements at IRS.gov before scheduling, as policies can change after this guide was written.

IdentoGO is currently the IRS-authorized Livescan vendor for most applicants. You schedule your appointment through the IdentoGO portal, where you will select the IRS service code for EFIN applicants and choose a location. Livescan sites are available at post offices, retail locations, and dedicated enrollment centers in most metro areas.

The cost of the fingerprinting session falls in an approximate range of $10 to $50 depending on location and any applicable service fees. These are approximate figures; verify current fees at IdentoGO.com or the IRS Livescan vendor locator before scheduling. The IRS itself does not charge a fee for the EFIN application.

After your Livescan session, your fingerprint data is transmitted electronically to the FBI on your behalf. You do not need to send anything separately to the IRS. Fingerprint results are typically returned to the IRS faster than the full application decision.

What Can Disqualify an EFIN Applicant

The IRS does not publish a fixed list of automatic disqualifiers, because suitability determinations are made on an individual basis. That said, the following factors are among those that can weigh against an approval:

• Felony convictions involving financial crimes, tax offenses, dishonesty, or breach of trust within the past 10 years
• Unresolved federal tax liens or significant, unaddressed tax noncompliance
• Prior EFIN revocation or suspension from IRS e-file programs
• Disciplinary action by the IRS Office of Professional Responsibility, including sanctions under Circular 230
• Misrepresentation or omissions in the e-File Application itself

Each application is reviewed individually. The presence of one of these factors does not guarantee denial; the IRS weighs the full record of each applicant. Completeness and transparency in your application are important: incomplete or inaccurate applications extend processing time and can raise additional questions during review.

Applicants with a Prior Criminal Record

A prior conviction does not automatically disqualify you from receiving an EFIN. The IRS reviews each application individually and considers the nature of the offense, the time elapsed since the conviction, and evidence of rehabilitation. Applicants with prior records are not guaranteed denial, and they are not precluded from applying.

The practical guidance for applicants in this situation: disclose proactively. The e-File Application asks about criminal history, and omitting or misrepresenting a prior conviction is itself a basis for denial, separate from the underlying offense. A disclosed conviction that was addressed years ago is in a different position than a non-disclosure discovered during the FBI fingerprint check.

Be prepared to provide documentation that supports your rehabilitation record: completion of sentence and supervision, letters of reference, an established tax compliance history, and any professional licenses or credentials you have obtained since the conviction. The IRS is not looking for a reason to deny; it is assessing whether the applicant presents a current risk to the integrity of the e-file system. A well-documented file helps that assessment work in your favor.

Processing Timeline: How Long the Suitability Check Takes

The IRS may take up to 45 days to process a full EFIN application from the date all required materials, including fingerprints, are received. Processing times can vary; check IRS.gov for current estimates, as volumes fluctuate across the calendar year and close to filing season.

Fingerprint results from the FBI are typically returned to the IRS faster than the full 45-day window. However, the fingerprint result is one input to the overall suitability determination; a returned fingerprint result does not by itself mean your EFIN has been approved.

Do not begin transmitting e-filed returns until you receive your EFIN in writing from the IRS through your e-Services account. Transmitting returns without an active EFIN is a violation of IRS e-file program rules and can create complications for your clients. Monitor your e-Services account for correspondence during the review period.

If you are applying ahead of a filing season and are concerned about the timeline, apply early. Late applications close to January are at the highest risk of processing delays that push past the opening of filing season.

What to Do If Your EFIN Application Is Denied

If the IRS denies your EFIN application, you will receive written notice through your e-Services account. The notice will include the reason for the denial and the applicable next steps.

Your first step is to contact the IRS e-Help Desk at 1-866-255-0654. The e-Help Desk handles EFIN application inquiries and can explain the specific basis for the denial and what options are available to you. In some cases, providing additional documentation or resolving the underlying issue (such as an unpaid tax liability or an outstanding filing) can support a reconsideration request.

Depending on the circumstances, a formal appeal to the IRS Office of Appeals may be available. Not all EFIN denials qualify for the full Appeals process; the denial notice and e-Help Desk communication will clarify whether that path applies in your case.

If the denial stems from a criminal history finding, addressing the rehabilitation documentation described above and reapplying after a period of continued compliance is often the more viable path than contesting the underlying determination directly.

Ongoing Suitability: After Your EFIN Is Approved

Receiving an EFIN is not a one-time clearance. The IRS requires active EFIN holders to attest annually to their continued eligibility when renewing their e-file program participation. This annual attestation confirms that the information in your e-File Application remains accurate and that no disqualifying events have occurred.

Beyond the annual attestation, the IRS can re-screen and revoke an active EFIN if a post-approval disqualifying event occurs. A subsequent criminal conviction, a federal tax lien, or new OPR disciplinary action after your EFIN was issued can all trigger re-evaluation of your program participation. An active EFIN does not protect against future suitability review.

You are also required to update your e-File Application through e-Services when key information changes: firm name, address, responsible official, or business structure. Keeping your application current is part of maintaining good standing in the IRS e-file program.

One EFIN Per Location: What It Means for Multi-Site Practices

Each physical filing location that originates and transmits returns independently requires its own EFIN. A single EFIN does not cover multiple office addresses.

The suitability check is conducted per principal (the individual listed as responsible official), not per location. This means the same principal can hold EFINs for multiple locations, but each location requires a separate application and its own EFIN number. If you open a second office, apply for a new EFIN for that address before transmitting returns from that location.

The one-EFIN-per-location rule also means that if you operate a home-based practice and a separate office address, each address that functions as an origination point needs its own EFIN. For the full setup workflow, including EFIN in the context of office licensing and WISP requirements, see the tax office setup checklist.

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