IRS e-File Compliance and Practitioner Responsibilities

Categories: IRS CE, Tax PT
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About Course

This two-hour continuing education course provides tax professionals with a complete, procedure-focused examination of the IRS Authorized e-file Provider Program, from initial application through ongoing compliance. It is designed for practitioners who transmit returns as an Electronic Return Originator (ERO) or hold another authorized e-file role, and who need a working command of the obligations that attach to that role beyond the substantive tax law addressed elsewhere in this catalog. Grounded in Revenue Procedure 2007-40, the current Publication 3112 (November 2025) and Publication 1345 (December 2025), and Internal Revenue Manual sections 3.42.10 and 4.21.1, the course examines the online e-Services e-file application process, the distinct duties of an Electronic Return Originator under Publication 1345, the IRS’s ongoing monitoring and sanction program, and the specific requirements for protecting and maintaining an Electronic Filing Identification Number (EFIN) throughout the life of the practice.

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What Will You Learn?

  • Identify the roles recognized under the IRS e-file Provider Program, including Electronic Return Originator, Transmitter, Software Developer, and Intermediate Service Provider, and describe the online e-Services e-file application process
  • Distinguish the responsibilities of a Principal from those of a Responsible Official, and describe the components of the IRS suitability check conducted before an EFIN is issued
  • Apply the Publication 1345 signature requirements for Forms 8879 and 8878 and the associated recordkeeping period for an Electronic Return Originator
  • Identify an ERO's obligations for transmitting returns, handling acknowledgments and rejected returns, avoiding prohibited stockpiling, and furnishing copies of the return to the taxpayer
  • Identify the IRS e-file monitoring program under Internal Revenue Manual section 4.21.1, including its four types of monitoring visits and periodic suitability rechecks
  • Distinguish the sanction levels available to the IRS for e-file noncompliance — warning, suspension, and expulsion or revocation — and describe a provider's right to respond and seek administrative review
  • Apply EFIN protection best practices and identify the required response when an EFIN is lost, stolen, or compromised
  • Identify the circumstances requiring an updated e-file application within 30 days, including new office locations and changes in Principals or Responsible Officials, and explain why an EFIN cannot be sold or transferred

Course Content

Module 1 – Becoming an Authorized IRS e-file Provider
Tax professionals apply to become an Authorized IRS e-file Provider through the online e-Services e-file application, identifying their Principals and Responsible Officials and selecting an e-file provider option such as Electronic Return Originator; the IRS then conducts a suitability check, which may include a credit check, tax compliance check, and criminal background check, before issuing an Electronic Filing Identification Number.

  • Becoming an Authorized IRS e-file Provider

Module 2 – Operational Duties of an ERO
Once authorized, an Electronic Return Originator operates under Revenue Procedure 2007-40 and the current Publication 1345, which govern taxpayer signature requirements on Forms 8879 and 8878, recordkeeping and retention of e-file records, transmission of returns and handling of acknowledgments and rejections, the prohibition on stockpiling returns, and the obligation to furnish the taxpayer a complete copy of the return.

Module 3 – IRS Monitoring, Sanctions and Administrative Review
The IRS monitors Authorized e-file Providers on an ongoing basis under Internal Revenue Manual section 4.21.1, including its four types of monitoring visits and periodic suitability rechecks, and may impose sanctions ranging from a written warning through suspension to expulsion or revocation for e-file infractions, subject to the provider's right to respond and, in appropriate cases, seek administrative review.

Module 4 – EFIN Lifecycle and Incident Response
A provider must actively monitor its own e-file volume for signs of unauthorized use, report a lost, stolen, or compromised EFIN to the IRS immediately, and update its e-file application within 30 days of specified changes such as a new office location or a change in Principals or Responsible Officials; because an EFIN is tied to the specific entity and location approved by the IRS, it cannot be sold, gifted, or otherwise transferred, including upon the sale of the practice.

Final Assessment – IRS e-File Compliance and Practitioner Responsibilities
This final assessment consists of 10 multiple-choice questions covering all four modules of this course. A passing score of 70% or better is required.

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