AFSP Requirements 2026: AFTR, Hours & Record of Completion
The Annual Filing Season Program (AFSP) is the IRS’s voluntary program for tax return preparers who are not attorneys, CPAs, or Enrolled Agents but still want to demonstrate competence—and keep limited rights to represent their clients. Earning the AFSP Record of Completion each year takes planning, because the hours reset on December 31 and the deadline does not move. This guide covers the 2026 AFSP requirements: the hour breakdown, the Annual Federal Tax Refresher (AFTR) course and test, exempt versus non-exempt preparers, and what the Record of Completion actually gets you. These figures reflect what the IRS publishes for the AFSP.
What is the AFSP Record of Completion?
The AFSP is not a license—it is an annual recognition. Preparers who complete the required continuing education and consent to the duties in Circular 230 receive an AFSP Record of Completion for that filing season and are listed in the IRS public Directory of Federal Tax Return Preparers. It is designed for the large population of preparers who hold a PTIN but no professional credential, giving them a way to stand out and to preserve limited representation rights.
How many hours does the AFSP require?
The number of hours you need depends on whether you are classified as non-exempt or exempt.
Non-exempt preparers: 18 hours
Most preparers fall into the non-exempt category and must complete 18 hours of continuing education each year, broken down as:
- 6 hours: Annual Federal Tax Refresher (AFTR) course, which ends with a knowledge-based comprehension test.
- 10 hours of federal tax law topics.
- 2 hours of ethics.
Exempt preparers: 15 hours
Certain preparers are exempt from the AFTR course because they have already demonstrated a higher level of testing—for example, those who passed certain recognized state or national exams, or former Registered Tax Return Preparers. Exempt preparers need 15 hours:
- 3 hours of federal tax law updates.
- 10 hours of federal tax law topics.
- 2 hours of ethics.
The ethics component is identical for both groups, and you can find qualifying courses in our regulatory ethics category. If you are unsure which category applies to you, our AFSP and PTIN preparer requirements page walks through the exemption rules in detail.
The AFTR course and test
For non-exempt preparers, the Annual Federal Tax Refresher is the centerpiece. It is a 6-hour course covering the current year’s tax law, common filing issues, and preparer responsibilities, and it concludes with a timed, 100-question comprehension test. You must pass the test to receive AFTR credit—there is a minimum passing score set by the IRS, and providers may allow multiple attempts. The AFTR content is refreshed each year to reflect new tax law, so last year’s course does not carry forward.
One scheduling detail matters: the AFTR course and test must be completed by the December 31 deadline. Because the material is tied to the upcoming filing season, providers typically make the AFTR available around mid-year. Do not leave it until late December, when support and retake windows tighten.
The December 31 deadline
All AFSP continuing education—the AFTR, the federal tax law hours, and the ethics hours—must be completed by December 31 to earn the Record of Completion for the following filing season. Unlike the multi-year cycles that Enrolled Agents work with, AFSP is a clean annual reset. There is no carryover, so hours earned in excess of the requirement do not roll into the next year. Our tax course category is organized so you can assemble the 10 (or 3-plus-10) federal tax law hours without hunting across unrelated topics.
PTIN and consent
Two things are required beyond the coursework. First, you must hold a valid, current PTIN—every paid preparer needs one, and it is renewed annually. Second, you must consent to the practice requirements in Subpart B and section 10.51 of Treasury Department Circular 230, which you do through your online PTIN account. Your CE provider reports your completed hours to the IRS under your PTIN, and once your hours and consent are on file, the IRS issues your Record of Completion.
What limited representation rights mean
The most practical benefit of the AFSP is limited representation rights. A preparer with a current-year Record of Completion may represent clients whose returns they prepared and signed before the IRS—specifically before revenue agents, customer service representatives, and similar IRS employees—during an examination of that return. This is narrower than the unlimited representation rights held by Enrolled Agents, CPAs, and attorneys, who can represent any taxpayer on any matter. Preparers without an AFSP Record of Completion and without a credential generally cannot represent clients at all beyond the return they prepared for filing.
Put simply: the AFSP does not make you an Enrolled Agent, but it does give you a meaningful, if limited, seat at the table when your client is examined—plus a public listing that signals you invest in staying current. If you are weighing AFSP against pursuing the EA credential, our CE requirements hub compares both paths side by side.
Planning your AFSP year
A smooth AFSP year looks like this: renew your PTIN, complete your ethics and federal tax law hours over the summer and fall, tackle the AFTR course and test in early autumn while you have time for a retake if needed, and record your Circular 230 consent. That leaves December free of last-minute pressure. You can see current AFSP-focused bundles on our pricing page.
Frequently asked questions
How many hours do I need for the AFSP?
Non-exempt preparers need 18 hours (a 6-hour AFTR course with test, 10 hours of federal tax law, and 2 hours of ethics). Exempt preparers need 15 hours (3 hours of updates, 10 hours of federal tax law, and 2 hours of ethics).
Am I exempt from the AFTR course?
You may be exempt if you have passed certain recognized tax exams or hold specific prior credentials, such as former Registered Tax Return Preparer status. Exempt preparers skip the AFTR but still need 15 total hours. Check the IRS exemption list to confirm your status.
When is the AFSP deadline?
All required hours, including the AFTR, must be completed by December 31 to earn the Record of Completion for the next filing season. AFSP does not carry hours over year to year.
What can I do with limited representation rights?
You may represent clients whose returns you prepared and signed before certain IRS employees during an examination of that return. This is more limited than the unlimited rights held by EAs, CPAs, and attorneys.
Last reviewed 2026-07-17. Always confirm current rules with the IRS or CFP Board.
