At a glance
What to know before choosing
- On September 30, 2026, the Senate passed H.R. 5349 with a substitute containing the bipartisan TAS Act's 65 provisions. S. 5441 was the reported Senate bill; Congress.gov does not record Senate passage of S. 5441.
- Section 504 of the Senate-passed H.R. 5349 proposes new PTIN qualification and education rules for paid tax return preparers. These rules have not been enacted. Current PTIN and applicable professional or state requirements remain in effect.
- The House passed the earlier version of H.R. 5349 on December 1, 2025. As of October 25, 2026, Congress.gov records no House action on the Senate's September 30, 2026 amendment. House agreement or another resolution of the differences is needed before the measure can go to the President.
Bill progress
This timeline tracks the TAS Act's progress through Congress and the steps that would still be required before its preparer qualification provisions could take effect.
| Date or stage | Milestone | What it means | Status |
|---|---|---|---|
| December 1, 2025 | House passed H.R. 5349 in its earlier form | The House approved a narrower IRS judicial-review bill. The Senate later used H.R. 5349 as the vehicle for its TAS Act substitute. | Completed |
| February 26, 2026 | TAS Act introduced as S. 3931 | Senate Finance Committee leaders introduced the original bipartisan TAS Act proposal and released bill text and a section-by-section summary. | Completed |
| July 2026 | Chairman's Mark prepared for markup | The committee published its Chairman's Mark and related materials ahead of the July 30 executive session. | Completed |
| July 30, 2026 | Finance Committee approval | The committee favorably reported the TAS Act proposal by a 26–1 vote. | Completed |
| September 17, 2026 | S. 5441 reported | The committee reported TAS Act legislative text as S. 5441, which Congress.gov lists on the Senate legislative calendar. | Completed |
| September 30, 2026 | Senate passed TAS Act text in H.R. 5349 | The Senate adopted a TAS Act substitute and title amendment to H.R. 5349, then passed the amended House bill by unanimous consent. | Completed |
| As of October 25, 2026 | House response to Senate amendment | Congress.gov lists no later House action. The House would need to agree to the Senate amendment or resolve differences with the Senate before the measure could be sent to the President. | Pending |
| If enacted | Section 504 implementation | The Senate-passed text generally makes Section 504's amendments effective 180 days after enactment and includes transition rules for the Annual Filing Season Program. Final requirements would depend on enacted text and Treasury or IRS guidance. | Conditional |
What Section 504 could change for paid preparers
The Senate-passed version of H.R. 5349 includes Section 504, a proposed framework for issuing, renewing, denying, suspending, or revoking PTINs. It offers three qualification paths: satisfying federal suitability and education requirements; qualifying through a comparable state preparer licensing or registration program; or being a specified practitioner, such as a qualifying CPA, attorney, or enrolled agent. None of these new Section 504 conditions is in effect. The House can change the text, and implementation would require enactment and Treasury or IRS guidance.
Practitioners should treat the provisions as a planning signal - not a current filing-season rule. Existing PTIN renewal, Circular 230, enrolled-agent, CPA, attorney, and state requirements continue to apply under current law.
- The federal path would include a background and personal tax-compliance check and education on ethics, professional responsibility, and tax law.
- The Senate-passed text caps required educational programs at 18 hours annually; it does not itself set an 18-hour requirement for every preparer. It generally prohibits an examination as a PTIN prerequisite, apart from a method within an education program to confirm attendance and understanding.
- A comparable state preparer program or qualifying CPA, attorney, or enrolled-agent status could provide another route under the proposed framework. The bill also includes transition treatment for certain Annual Filing Season Program participants and approved education providers.
- The bill proposes authority to deny, suspend, or revoke a PTIN in specified circumstances. The final scope and administrative process would depend on enacted law and implementing guidance.
Education requirements and possible alternatives
Under the Senate-passed proposal, the federal qualification path would require educational programs on ethics, professional responsibility, and tax law, with an annual maximum of 18 hours. Comparable state programs and specified practitioners would have separate qualification routes. The bill gives Treasury and the IRS roles in setting program standards and publishing accepted courses. These are proposals, not current PTIN renewal requirements; the House may change them.
The important operational question is not simply how many hours a preparer has completed. It is whether the preparer, provider, program, subject matter, completion evidence, and reporting process meet the standards ultimately adopted for PTIN qualification.
When a new framework could begin
The House passed an earlier version of H.R. 5349, but it has not agreed to the Senate's September 30 TAS Act substitute. The House must act on the Senate amendment, and any differences must be resolved before a final bill can be sent to the President. The Senate-passed Section 504 would generally take effect 180 days after enactment and includes transition rules for certain Annual Filing Season Program participants and approved education providers. There is no operative Section 504 start date because the bill has not become law.
Until those steps occur, practitioners should continue using current IRS PTIN instructions and official renewal notices. Basics & Beyond will continue monitoring the bill and update this page as it advances.
Who should monitor the proposal closely
The proposal is most relevant to people and organizations whose work or systems depend on PTIN eligibility, preparer onboarding, education reporting, or return-preparer compliance.
- Uncredentialed paid federal tax return preparers.
- Tax firms that hire, supervise, or onboard seasonal preparers.
- Education providers that may seek approval for a future preparer qualification program.
- Software, payroll, compliance, and professional-services organizations that validate preparer information.
- Credentialed practitioners evaluating whether the final rules create exemptions or simplified renewal treatment.
Frequently asked questions
Questions about this guide
Is a new PTIN education requirement in effect now?
No. As of October 25, 2026, the TAS Act has not been enacted. Section 504's proposed PTIN qualification and education conditions are not in effect. Paid preparers must still follow current PTIN rules and any applicable credential or state requirements.
Did the Senate pass the Taxpayer Assistance and Service Act?
Yes. On September 30, 2026, the Senate passed H.R. 5349 by unanimous consent after adopting a TAS Act substitute and title amendment. S. 5441 is the committee-reported Senate bill, but H.R. 5349 is the measure the Senate passed. The House had passed an earlier version of H.R. 5349 and has not yet agreed to the Senate's amendment.
Should a preparer take a course now to satisfy the proposed requirement?
Continue meeting current credential and education obligations, but do not assume a course will satisfy a future Section 504 requirement until final law and IRS guidance identify accepted programs and alternatives.
Will CPAs, attorneys, enrolled agents, and AFSP participants be treated the same?
The Senate-passed bill contemplates different qualification routes and possible recognition of credentials or existing programs. The final treatment depends on enacted text and implementation guidance.
Current information