Forgot to renew EA

What happens if you forgot to renew your Enrolled Agent license by the due date?  

Don’t panic right away

This can happen to anyone, and it can be that you just forgot to submit the Renewal Form 8554 and your renewal fee, or it can be due to extenuating circumstance.

One of the most common reasons is that you forgot to take the CE hours required to renew your license. See our extensive discussion of “I forgot to take my EA CE hours” here.

    If you have only missed one renewal, you will be able to maintain your EA license. You can either

    • submit your renewal and check the “Inactive Status” box to remain on inactive status or
    • submit your renewal with proof of 72 hours of completed CE.

    In both cases, you still need to submit the renewal form with payment of the renewal fee.

    You have up until the due date of the second renewal to submit a renewal and keep your EA license. If you intend to keep your Enrolled Agent status, you should renew your EA as soon as you realize you failed to renew, even if you just stay on inactive status.

    When to panic

    If you did not send in your renewal Form 8554 before your license expiration date (or if you submitted it but did not meet renewal requirements such as adequate CE hours), you have been automatically placed on inactive status. 

    • Renewal form due by January 31st following the end of your three year cycle
    • License expires on March 31st after that.

    The IRS generally allows you to renew without issue if you submit your renewal after January 31st but before March 31st, but many years there have been extensive processing delays so this is not recommended if at all avoidable.

    If your licesnse has expired we recommend you contact the EA Helpline for instructions to re-activate.

    If you have failed to submit two renewals (and therefore missed two enrollment cycle renewals– i.e. it has been six years since your last enrollment cycle ended), time to panic because this means your EA license has been terminated and you cannot reactivate.

    You will have to retake the Special Enrollment Exam (SEE).  And I’ve heard it has gotten harder.

    What you CAN’T do

    Can’t go back in time

    What it comes down to, is you can’t go back in time to send in your renewal on time and/or make up missed CPE courses.

    If you could go back in time, you would just buy $10,000 of shares Berkshire Hathaway in 1964 (which were worth $240 million at the end of 2017), and you wouldn’t have to worry about maintaining your EA license.

    Since you can’t go back in time, the IRS generally advises you to submit a renewal as soon as you become aware of the fact that you have missed the due date.  

    Feel free to contact us for advice on courses to take or if you have questions.

     

    What you CAN do

    Review what is posted to your IRS PTIN account

    To verify what CPE credit has been reported to the IRS, you can login to your PTIN account to view the hours.  Each year is shown under separate tabs.  Review what has been reported to your PTIN account prior to calling the EA Helpline.

    You can call the IRS EA Helpline

    You can call the EA Helpline to verify what steps you need to take to get current.  Calling the IRS does not alert them to the fact that you have missed your renewal or CPE, and it won’t affect the renewal of your license.

    The IRS is already aware of your situation because the PTIN system contains a history of courses completed and posted by CPE providers.

    Case History of student that forgot to renew

    Background

    Our student, “Bob” enrolled in 72 hours of courses but didn’t complete all the courses and then didn’t file his renewal form, so his license expired 3/31/21.

    Bob contacted the EA Helpline in October 2022, midway through his next 3-year enrollment cycle. The email received from the IRS is shown in the next section.

    1. Bob needs to submit proof of 72 hours completed for the enrollment cycle ended 12/31/20.
    2. He then needs to complete at least 16 hours for 2021 and 2022 to get current with his requirements. The CE requirement is a minimum of 16 hours per year, and you must take 2 hours of ethics per year.

    A common problem we see in situations like this is that you must keep excellent records of which CE is used for the prior renewal and then which CE is used for the next enrollment cycle. You don’t want to double count any CE, and without your own records you can’t tell what was counted for each period.

    Email from the IRS EA Helpline

    Thank you for your inquiry.

    Your Enrolled Status has been inactive since 04/01/2021.

    Your Renewal Application Period was 11/01/2020 – 01/31/2021 to be considered timely.

    You will need to file Form 8554, Application for Renewal of Enrollment to Practice Before the Internal Revenue Service and pay the fee. You can file the Form 8554 online at pay.gov

    However, since you are renewing late, you will need to provide proof that you have completed the minimum required 66 CE’s and 6 Ethics. Please provide copies of your CE certificates or a copy of your CE listing located on your online PTIN account by using one of the options listed below:

    • Emailing to epp@irs.gov
    • Faxing to 855-889-7959
    • Mailing to: Enrolled Agent Policy & Management, 985 Michigan Ave. Detroit, MI 48226

    To view a list of the CE courses you completed you can log into your online PTIN account at www.irs.gov/ptin.

    Please review the following for additional information:

    Maintain Your Enrolled Agent Status | Internal Revenue Service (irs.gov)

    Please call our help desk at 855-472-5540, Monday – Friday, 7:00 am – 5:00 pm CT if you have any additional questions.

    Regards

    More monitoring and notifications in the future

    Since the IRS does have direct access to your CE hours reported, as well as your renewal due date, the IRS could start using email to inform EAs of any missed renewals.

    We also expect the IRS to start sending out reminders of due dates for renewals.  In the distant past, the IRS sent out (snail mail) renewal notices, but they discontinued that practice many years ago.

    We have also speculated that the renewal could be changed to an annual renewal, and coordinated with the PTIN renewal.

    Not sure what to do next?

    It has been our experience that most CPE credit deficiencies can be resolved by taking the appropriate courses.

    Send us a quick email with some information about your situation and we will promptly get back with you with our advice on how to proceed.

    We can recommend a personalized list of courses for you to take.  You can keep your license active and move on down the road!

     

    Information we need to assess your situation

    Send an email  with the following information, and anything else you want us to know:

    1) Last digit of your Social Security number, or if you have no Social Security number

    2) When you originially received your EA license–if it’s within the last 3 years we need the month and year, otherwise just a ballpark of the year

    3) Last renewal date, if you have that information

    4) How many CPE hours you have taken so far this period, if any, and whether those hours are posted to your PTIN account

    5) Copy of any correspondence received from the IRS about your situation