Under current federal rules, holding a PTIN does not by itself require most unenrolled preparers to complete annual continuing education. Section 504 would change that framework by tying PTIN eligibility to education and suitability standards for many paid preparers, while providing separate paths for qualifying state registrants and credentialed practitioners.
TAS Act at a Glance
| Question | Answer |
|---|---|
| Is it law? | No |
| Are new CE rules in effect? | No |
| Could more preparers need CE? | Yes, if enacted |
| Maximum CE under Senate bill | 18 hours/year |
Why the TAS Act Matters to Tax Preparers
The TAS Act contains 65 bipartisan tax-administration reforms addressing IRS service, taxpayer rights, digital access, Tax Court procedures and return-preparer oversight. Most of the bill is broader than the tax-preparation profession, but Section 504 could materially change who qualifies for a PTIN and what some preparers must do to renew one.
The proposal would not impose one uniform requirement on every preparer. Instead, it creates three general qualification paths:
| Qualification path | Who it could cover |
|---|---|
| Suitability and education | Paid preparers who meet background and suitability requirements and complete approved continuing education. |
| Qualifying state program | Preparers with a valid state license or registration under a program Treasury determines has comparable standards. |
| Specified practitioner | Attorneys, CPAs and enrolled agents in good standing who are authorized to practice before Treasury. |
Proposed Education and Suitability Requirements
For preparers using the suitability-and-education path, Treasury would determine the required number of annual continuing-education hours. The legislation identifies ethics, professional responsibility, tax law and recently enacted federal income tax legislation as relevant subjects.
The frequently cited 18-hour figure is a ceiling, not a requirement established by the bill. Treasury could require fewer hours, and the distribution of those hours among subject areas would need to be addressed through regulations or guidance.
Approved education programs would need to provide written materials and use a method for confirming attendance and sufficient understanding. That does not amount to a general PTIN competency examination: the Senate-passed text generally prohibits Treasury from requiring such an exam as a condition of receiving or renewing a PTIN.
The same qualification path would include a suitability review and a check of the preparer’s compliance with personal tax obligations. The IRS would also receive explicit authority to deny, suspend or revoke a PTIN in specified circumstances.
How Different Tax Professionals Could Be Affected
Attorneys, CPAs and enrolled agents
Qualifying attorneys, CPAs and enrolled agents would be treated as specified practitioners rather than using the general suitability-and-education path. To qualify, they would need to remain in good standing, retain authority to represent taxpayers before Treasury and avoid a suspended or revoked professional license or certification.
CTEC-registered preparers
The state-program path could be important for California preparers because the bill expressly contemplates state licensing and registration programs, including state tax education councils. It does not, however, automatically declare CTEC registration equivalent to the proposed federal standards.
Treasury would decide whether a state program’s examination, education and background-check requirements are comparable. Until Treasury provides further guidance, California preparers should continue following existing CTEC requirements, including the annual education covered by the 20-Hour CTEC Renewal Package.
Annual Filing Season Program participants
The proposal includes transition protection for the Annual Filing Season Program (AFSP). A preparer holding an AFSP Record of Completion when the legislation is enacted would be treated as satisfying the new education requirement for the calendar year covered by that record.
Existing AFSP-approved continuing-education providers would also receive transitional recognition while Treasury develops the new educational standards and publishes its approved-program list.
Preparers pursuing a current AFSP Record of Completion can review the 15-Hour IRS AFSP Package for Exempt Preparers.
When Could the New Requirements Begin?
Senate approval alone does not change the rules. The House must act on the Senate-amended legislation, and any version approved by both chambers would then require presidential action.
If enacted in its current form, Section 504 would take effect 180 days after enactment. Treasury and the IRS would still need to establish essential implementation details, including the number and allocation of CE hours, approved education standards, and the treatment of individual state programs.
What Tax Preparers Should Do Now
- Continue following current requirements. Existing PTIN, credential, state-registration and continuing-education rules remain in effect.
- Do not plan around an assumed 18-hour mandate. The bill establishes a maximum; Treasury has not set a new federal CE requirement.
- Watch the next stages. House action will determine whether the preparer provisions advance, and later IRS and Treasury guidance would control implementation.
Tax Courses Online will update this article as Congress acts and implementation guidance becomes available.
Frequently Asked Questions
Is the TAS Act law?
No. As of October 1, 2026, the Senate has passed the TAS Act, but further House action is required.
Does the TAS Act require 18 hours of continuing education?
Not exactly. The Senate-passed bill allows Treasury to set the required number of hours but says the annual requirement may not exceed 18 hours.
Does the TAS Act require tax preparers to take an exam?
The Senate-passed bill generally prohibits a separate examination as a prerequisite for receiving or renewing a PTIN. Educational programs would still need a method to verify attendance and understanding.
Would the TAS Act affect CTEC preparers?
Potentially. State tax education councils are expressly contemplated in the bill’s state-program pathway, but Treasury would need to determine whether a particular state program meets the federal comparability standard.
Are new TAS Act requirements in effect for the 2026 filing season?
No. Current PTIN and continuing-education requirements remain in effect while the Senate-approved measure awaits further House action.
Related Tax Preparer Resources
For requirements already in effect, review the IRS Continuing Education Requirements Guide, the CTEC Renewal Requirements Guide and the Unenrolled Return Preparer Guide.