Annual Filing Season Program - Record of Completion
This voluntary program recognizes the efforts of return preparers who are generally not attorneys, certified public accountants, or enrolled agents. The IRS issues an Annual Filing Season Program Record of Completion to return preparers who obtain a certain number of continuing education hours in preparation for a specific tax year.
Annual Filing Season Program participants do not have unlimited practice rights (unless they are also an attorney, certified public accountant, or enrolled agent). Their representation rights are limited to clients whose returns they prepared and signed, but they can only represent clients before revenue agents, customer service representatives, and similar IRS employees, including the Taxpayer Advocate Service. They cannot represent clients whose returns they did not prepare, nor can they represent clients regarding collection or appeals matters.
To represent a client on returns prepared and signed on or after January 1, 2016, a non-credentialed tax return preparer must be an Annual Filing Season Program participant in both the year of tax return preparation and the year of representation.
For returns prepared and signed before January 1, 2016, PTIN holders who neither have a professional credential nor an Annual Filing Season Program Record of Completion continue to be allowed to represent clients before the IRS.
