The IRS voluntary Annual Filing Season Program effects different classifications of tax practitioners in different ways. To participate in the Annual Filing Season Program requires the following:

  1. Take the 6-hour IRS Annual Federal Tax Refresher Course (AFTR) and pass (with a grade of 70% or better) a timed (3-hour) course comprehension examination.  
  2. Complete an additional 10-hours of continuing education that includes:
    > 10 hours of study in federal taxation
    > 2 hours of study in ethics
  3. Complete the PTIN registration
  4. Log into the IRS PTIN account and check the box agreeing to abide by Subpart B of Circular 230 (the same rules of practice that apply to EAs, CPAs, and attorneys).
  5. After completing those steps the IRS will issue the preparer a “Record of Completion.”
  6. Annual Filing Season Program participants that have a “Record of Completion” will have limited representation rights, meaning they can represent clients whose returns they prepared and signed, but only before revenue agents, customer service representatives, and similar IRS employees, including the Taxpayer Advocate Service.  In addition, they must have a record of completion for the year the return was prepared and for the year of the representation. 

To see how it may apply to you, see below.

Group 1: CPAs, EAs, and Attorneys - If you are a CPA, EA, or attorney, you need not read any further, as this program will have no effect on you. However, you may wish to continue reading to see how it might affect your employees.  

Group 2: Certain Exempt Preparers  - The voluntary program exempts certain preparers from having to take the Take the 6-hour IRS Annual Federal Tax Refresher Course (AFTR) and pass the course comprehension examination.  However, they are required to complete a 15-hour CE requirement that includes 3 hours of Federal update, 10 hours of Federal tax subjects and 2 hours of ethics. In addition, they must have a valid PTIN and agree to abide by sub-part B for Circular 230. Those include:

  • An individual who passed the Registered Tax Preparer examination
  • An individual registered with the California Tax Education Council (CTEC). Note: CTEC has additional 5 hour California CE requirement.  
  • An individual who is an Oregon Licensed Tax Preparer
  • An individual who has passed the ATP test offered by the Accreditation Council for Accounting/Taxation
  • An individual who passed Part 1 of the Special Enrollment Examination within the last two years
  • VITA program reviewers and instructors

Group 3: Non-Exempt Preparers - Includes individuals not included in Groups 1 and 2.

Why Should You Participate in the Program?

Beginning in 2016, tax preparers who are not CPAs, EAs, or attorneys will be unable to represent taxpayers before the IRS during an examination of a return that they signed or prepared without having a “record of completion” for both the year of preparation and the year of audit.

Example: The tax preparer didn’t get a record of completion for 2016 but did so in 2017. A return the preparer prepared in 2016 subsequently gets audited in 2017. The preparer will not be able to represent the client because to do so the preparer needs a record of completion for both 2016 (the year of preparation) and 2017 (the year of the audit).

Whether or not to participate in the program is an individual choice that should be carefully considered.  

Step-By-Step Process of Obtaining a “Record of Completion”

The following is the step-by-step process to obtain a “record of completion” The steps do not need to be completed in the exact order shown. However, all the requirements (steps), except renewing the PTIN, must be completed by December 31.

Step 1a - Non-exempt tax preparers -Take the Annual Federal Tax Refresher (AFTR) course from an approved IRS continuing education provider and pass the timed (3-hour) 100-question examination. Providers with courses including a pool of questions can offer multiple retakes, while those with only 100 exam questions can only offer one retake. The education provider will report the satisfactory completion of the course to IRS who will show the AFTR requirement as completed on the tax preparer’s PTIN account. ClientWhys provides a pool of questions thus allowing unlimited retakes. 

Step 1b - Exempt tax preparers - If you are an exempt tax preparer, the IRS will mark your AFTR requirement as “exempt” on your PTIN account after verifying with the various agency that you are still in good standing with them.

Step 2 - Complete the annual CE requirements with an IRS approved continuing education provider. Upon successful completing of a course, the provider will report the CE completion to the IRS who will include the CE on the tax preparer’s PTIN account.

Step 3 - Renew the PTIN for the year.

Step 4 - Once the tax preparer’s PTIN reflects that steps 1 through 3 have been completed, the IRS will notify the tax preparer and instruct him or her to go to his or her PTIN account and electronically sign a statement that they will comply with Circular 230, Subpart B—“Duties and Restrictions Relating to Practice Before the Internal Revenue Service.”  IMPORTANT: This step is frequently overlooked by individuals participating in the voluntary program. The IRS provides a video tutorial if you need some assistance with that very important step. 

Step 5 - Once the tax preparer has completed Step 4, he or she can go to the secure mailbox and retrieve/print the “record of completion.”