CPAs, enrolled agents, and tax preparers: who can do what.

The IRS says any tax professional with a preparer tax identification number (PTIN) is authorized to prepare federal tax returns, but tax professionals have differing levels of skills, education, and expertise (IRS, preparer credentials and qualifications).

The biggest practical difference is who can represent you before the IRS. Certified public accountants, enrolled agents, and attorneys have unlimited representation rights. Annual Filing Season Program participants have limited rights. Other preparers with only a PTIN can prepare returns but can’t represent you.

The table summarizes the IRS’s description of each type of preparer and how to check one.

CPAs are licensed by state boards of accountancy, the District of Columbia, and U.S. territories. According to the IRS, they have passed the Uniform CPA Examination, completed a study in accounting at a college or university, met experience and good character requirements set by their board, and must meet ethical and continuing education requirements to keep an active license (IRS).

CPAs may practice before the IRS (31 C.F.R. § 10.3(b)). Because CPAs are licensed by a state, the state board of accountancy is where you check a license or file a complaint about a CPA (NASBA, state boards of accountancy).

Enrolled agents are licensed by the IRS. They are subject to a suitability check, must pass a three-part Special Enrollment Examination covering tax planning, individual and business return preparation, and representation, and must complete 72 hours of continuing education every three years (IRS).

An enrolled agent who isn’t suspended or disbarred may practice before the IRS (31 C.F.R. § 10.3(c)). Enrolled agents must also have a valid PTIN (IRS, PTIN requirements).

Attorneys are licensed by state courts, the District of Columbia, or their designees, such as the state bar. The IRS notes that some attorneys specialize in tax preparation and planning (IRS). Attorneys may practice before the IRS (31 C.F.R. § 10.3(a)).

The Annual Filing Season Program is voluntary. It recognizes preparers who aren’t attorneys, CPAs, or enrolled agents and who complete 18 hours of continuing education, including a six-hour federal tax law refresher course with a test, renew their PTIN, and agree to follow certain IRS practice rules (IRS, Annual Filing Season Program).

Participants have limited representation rights: 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. They can’t represent clients in appeals or collection matters.

Preparers with only a PTIN, no professional credential, and no program record are authorized to prepare returns but have no authority to represent clients before the IRS, apart from returns they prepared and filed on or before December 31, 2015 (IRS).

Every paid preparer is subject to federal preparer penalties, whatever their credential. See tax preparer penalties.

Credentials also affect where you can complain and what standards apply. A CPA answers to a state board of accountancy. Attorneys, CPAs, enrolled agents, and others who practice before the IRS are subject to the IRS rules on practice, known as Circular 230, which the IRS Office of Professional Responsibility administers (IRS, Office of Professional Responsibility and Circular 230).

Whether you can recover losses from a preparer depends on state law, what the preparer agreed to do, and the deadlines that apply, not only on the preparer’s title. For deadlines and rules for people who weren’t the accountant’s client, see accounting malpractice.

• Look for the PTIN. Everyone who prepares your return for pay must have one and enter it on the return filed with the IRS (IRS).
• Search the IRS directory. The IRS publishes a searchable directory of attorneys, CPAs, enrolled agents, and other credentialed preparers with valid PTINs, plus Annual Filing Season Program participants (IRS, Choosing a tax professional).
• Check a CPA license with the state board of accountancy, or through CPAverify for participating states.
• Ask about their training, and what they will and won’t do if the IRS has questions about your return.

We wrote this page from the primary sources below and checked it against them on October 22, 2026.

• IRS, Understanding tax return preparer credentials and qualifications: CPAs, enrolled agents, attorneys, AFSP participants, PTIN holders, and representation rights
• IRS, Annual Filing Season Program: program requirements
• IRS, PTIN requirements for tax return preparers: who must have a PTIN
• IRS, Choosing a tax professional: the directory of preparers
• 31 C.F.R. § 10.3: who may practice before the IRS
• IRS, Office of Professional Responsibility and Circular 230: practice rules
• NASBA, State boards of accountancy: CPA licensing boards

We are not attorneys, and this page is not legal advice. Laws change and differ from state to state. If anything here is out of date or wrong, email support@malpracticeattorneys.com with the page name, and we’ll review it and update the page.