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Who Needs A PTIN?

May 9, 2025

The 2026 tax season isn’t here yet, but it’s never too late to start preparing, starting with your PTIN. A Preparer Tax Identification Number (PTIN) serves as the equivalent of a tax professional’s social security number. The IRS uses this to track returns prepared by each tax professional and to monitor their continuing education requirements. Your PTIN appears on tax returns you prepare, allowing the IRS to identify who worked on each submission. But exactly who needs this credential? We’re here to break it down for you.

Tax Preparers Who Receive Compensation

The IRS regulations are clear: anyone who prepares or assists in preparing federal tax returns for compensation must have a valid PTIN. This requirement applies regardless of your credentials or professional status. If you receive payment for preparing or assisting in the preparation of U.S. federal tax returns, you need a PTIN. This includes:

Certified Public Accountants (CPAs)
Attorneys who prepare tax returns
Enrolled Agents (EAs)
Annual Filing Season Program participants
Uncredentialed tax preparers who charge for their services

Note: All Enrolled Agents must have a valid PTIN, even if they’re not actively preparing tax returns. This is because the PTIN is a prerequisite for maintaining EA status and tracking continuing education requirements.

Those Who Assist in Preparing Tax Returns

According to the IRS, the PTIN requirement extends beyond those who complete entire returns. You need a PTIN if you assist in the tax preparation process by “making determinations that affect tax liability.” This includes:

Tax professionals who prepare all or substantially all a tax return
Staff who review and make tax determinations on client information
Associates who analyze financial information and apply tax law
Anyone exercising discretion or independent judgment on tax positions
Professionals who render tax advice to clients during return preparation

However, the IRS specifically exempts certain support roles from the PTIN requirement in Treasury Regulation section 301.7701-15(f). This includes:

Staff who only provide typing, reproduction, or mechanical assistance
Employees who only organize client paperwork without making tax determinations
Data entry personnel who input information but don’t determine tax treatment
Administrative assistants who only record client information in systems
Interns who only gather documentation or perform routine tasks

Why Firms Don't Have PTINs

If you work in an office with multiple preparers, every individual who significantly contributes to tax return preparation needs their own PTIN. PTINs belong to individuals, not to businesses or firms.

This individual-only approach was established by the IRS to ensure accountability and quality control. This distinction exists because the IRS wants to track and monitor the specific individuals who prepare returns, not just the firms they work for.

By requiring each preparer to have their own PTIN, the IRS can:

Track the quality and accuracy of returns prepared by specific individuals
Monitor continuing education requirements for each preparer
Hold individual preparers accountable for the returns they prepare
Maintain a public directory of qualified preparers for taxpayers to reference

Who Doesn't Need a PTIN?

Not everyone involved in tax-related activities needs a PTIN. You generally don’t need a PTIN if:

You prepare tax returns solely as an unpaid volunteer
You’re an attorney, CPA, or enrolled retirement plan agent who doesn’t prepare tax returns as a significant part of your practice
You only provide administrative or clerical assistance without making tax determinations
You’re a VITA site volunteer preparer

PTIN and Compliance

There’s no mincing words here: using your PTIN correctly is a legal requirement. Tax preparers must include their PTIN on each return they prepare. Failure to obtain, renew, or properly use a PTIN may result in penalties under Section 6695 and potential disciplinary action from the Office of Professional Responsibility.

Need a PTIN in the Future?

For uncredentialed preparers, the Annual Filing Season Program (AFSP) offers a way to gain limited representation rights and inclusion in the IRS Directory of Federal Tax Return Preparers. Uncredentialed preparers can complete the AFSP by taking AFTR course and comprehension test, along with continuing education requirements. For those who are looking to participate in the AFSP, learn how to apply for your PTIN here.

Your Mark on the Industry

Your PTIN is like a fingerprint for all the work you do in the tax industry, and it is essential for your career growth. Whether you’re just starting your career or expanding your professional services to include tax preparation, obtaining a PTIN is your first step toward compliance with IRS regulations. Remember that PTINs belong to individuals, not businesses, and PTIN renewal occurs each year. By maintaining a valid PTIN, you’re maintaining your presence in the tax preparation market, ensuring that you can provide services to clients without the ire of the IRS.

For everyone who needs a PTIN, you or your firm will be needing a Written Information Security Plan (WISP) to stay compliant. We’ve got you covered with a free WISP template and directions on how to create your own WISP.