Should an EA get the AFSP Record of Completion?
Starting in 2014, the IRS introduced a new program to replace the failed RTRP program. The Annual Filing Season Program (AFSP) is designed for non-credentialed preparers to obtain a credential after completing specific CPE courses.
The AFSP program is not designed for Enrolled Agents, but EAs can participate if desired and there is no cost to do so. Many EAs will already be getting the required CPE to meet the EA CPE requirements, so there may be no additional cost.
However the CE Courses needed for the AFSP are specific, so an EA might or might not take the exact courses needed.
Is there any advantage for an Enrolled Agent to also get an AFSP Record of Completion?
No, I don’t believe there is any advantange. Professionals with a Record of Completion will be listed in the IRS tax preparer database, but Enrolled Agents will already be listed there, regardless of whether or not they get the ROC.
Some people compare an EA getting the AFSP to a CPA getting a Certified Bookkeeper credential–sure, you could do it, but does it add anything?
But it is a free program at this point, so it doesn’t hurt to get it either.
AFSP courses required
AFSP Courses required for an exempt tax preparer (EAs are considered exempt)
- 3 hours Tax Update
- 2 hours Ethics
- 10 hours Tax Law (i.e. any other course covering any aspect of Federal Tax laws)
Not all EAs take a Tax Update course, but you could, and it would count towards your annual EA CPE requirements, as well as the AFSP requirements.
What does the IRS have to say about this?
This excerpt was taken from an IRS transcript of CE Provider call notes:
“Attorneys, certified public accountants, EAs, Enrolled Retirement Plan Agents (ERPAs), and enrolled actuaries may elect to participate in AFSP if they choose.
Still, participation isn’t as valuable since they have a higher credential, have unlimited representation rights, and are already subject to Circular 230.”
What correspondence will you get from the IRS regarding the AFSP?
1) If you do not have an online PTIN account
If you do in fact take the required courses, you must have an active PTIN to participate in the AFSP.
Create or renew your online PTIN account at www.irs.gov/ptin
Notify your CE course provider of your PTIN and request that your completed courses be posted to your account.
After the courses are posted to your account, this will trigger a notice to you from the IRS asking if you want to partipate in the AFSP for the upcoming tax season.
The final step is to elect to participate by agreeing to the Circular 230 consent (see Step 4 above).
2. If you have an online PTIN account and have taken some but not all the necessary courses to qualify for the AFSP
You will get the following email (note--adjust the dates as needed, this is just an example):
Subject: You are almost eligible for the 2024 Annual Filing Season Program
Our records indicate you need three or less hours of continuing education by December 31, 2023, to be eligible for the Internal Revenue Service's 2024 Annual Filing Season Program. Don't miss the deadline!
[This message pertains to Exempt Preparers, who have a 15 hour requirement.] You must have a total of 15 hours of continuing education from IRS-Approved CE Providers in the following categories to participate in the 2024 program:
- 3 hours of federal tax law updates;
- 10 hours of other federal tax law topics; and
- 2 hours of ethics.
You can view your current CE credits in your online PTIN account. On the Main Menu, select "View My Continuing Education Credits".
Attorneys, certified public accountants, and enrolled agents have full representation rights for all clients before all IRS offices. Annual Filing Season Program Record of Completion holders have limited representation rights, meaning they can represent clients whose returns they prepared and signed, but only before examination, customer service representatives, and the Taxpayer Advocate Service.
[Non-credentialed preparers who are] Non-participants in the Annual Filing Season Program do not have any representational rights before the IRS for returns prepared after December 31, 2015.
For more information about the IRS Annual Filing Season Program, visit www.irs.gov/tax-professionals/annual-filing-season-program.
Return Preparer Office
Internal Revenue Service
3. If you have completed the courses required to get the AFSP
You will receive the standard email asking you to consent to the Circular 230 standards. We do not have an example of the exact email sent out by the IRS, but this is how it works:
- Following the completion of all Continuing Education requirements and renewal of PTIN for the upcoming year, eligible return preparers will receive an email from the IRS.
- The email will provide instructions for logging into your PTIN account and completing the process.
- Among the final steps will be a required consent to adhere to specific practice obligations outlined in Subpart B and section 10.51 of Treasury Department Circular No. 230 PDF.
- Following successful completion of these steps, you will be issued an Annual Filing Season Program - Record of Completion.
Credentialed tax preparers such as EA, CPA, Attorney, RTRP, ABA, ATP and preparers registered in CA, OR or MD are not required to notify the IRS of their credential or provide evidence of it. These credentials for exempt tax preparers are independently verified directly by the IRS, and may result in a longer delay in completing the AFSP process.
The IRS provides a video showing the final steps to consent to the Circular 230 and finalize the AFSP-Record of Completion.