E-file rules: provider status, the specified preparer mandate and Form 8879

• Describe the e-file application, EFIN and suitability steps in Publication 3112
• Determine whether a preparer is a specified tax return preparer under 6011(e)(3)
• Apply the Form 8879 rules on timing, PIN and retention
• List the records an ERO keeps after transmitting a return

Becoming an authorized provider

Publication 3112 (Rev. 11-2025) governs the IRS e-file application. A firm applies, meets the eligibility criteria and passes a suitability check before the IRS assigns an Electronic Filing Identification Number (EFIN). Accepted applicants become Authorized IRS e-file Providers. Provider options include Electronic Return Originator (ERO), Intermediate Service Provider, Transmitter, Software Developer and others. Most CPA firms are EROs: the ERO begins the electronic submission of returns to the IRS.

Points staff should know:

• Each Principal and Responsible Official on the application must pass a suitability check, which may include a tax compliance check.
• Each new Principal or Responsible Official must be fingerprinted through the IRS authorized vendor unless they provide professional credentials (such as a CPA or attorney license).
• Providers must update the application within 30 days of a change in any information, and must notify the IRS within 30 days if they sell, transfer or discontinue the e-file business.
• An EFIN belongs to the firm that applied for it. Publication 3112 bars renting, leasing or selling an EFIN, or transferring it to another entity when the business is sold; the new owner applies for its own.

Publication 1345 is the handbook for providers of individual returns. It says the IRS has mandated six security, privacy and business standards to supplement the Gramm-Leach-Bliley Act. The first five apply to Online Providers, and standard six, reporting of security incidents, applies to all providers.

The specified preparer mandate

Section 6011(e)(3) requires the IRS to require a tax return preparer to file individual income tax returns electronically if the preparer is a specified tax return preparer for the calendar year in which the return is filed. A specified tax return preparer is any preparer unless the preparer reasonably expects to file 10 or fewer individual income tax returns during the year. So a preparer who expects to file 11 or more is covered. Under Treas. Reg. 301.6011-7, a preparer who is a member of a firm counts the firm's returns in the aggregate: if the firm's members together expect to file more than 10, every member is a specified preparer. Individual income tax returns include returns of tax imposed by subtitle A on individuals, estates and trusts, so Form 1041 counts as well as Form 1040.

The statute lets the IRS waive the requirement for a preparer located in an area without internet access (other than dial-up or satellite). The IRS uses Form 8944 for hardship waiver requests and Form 8948, Preparer Explanation for Not Filing Electronically, for a specified preparer to explain why a particular return is filed on paper, such as a client's documented choice to file on paper or a return the IRS system cannot accept.

Form 8879: signature authorization

Form 8879, IRS e-file Signature Authorization, is the declaration and signature authorization for an e-filed individual return when the Practitioner PIN method is used or when the taxpayer authorizes the ERO to enter or generate the taxpayer's PIN. Rules from the form:

• The ERO must receive the completed and signed Form 8879 from the taxpayer before the return is transmitted or released for transmission.
• The taxpayer verifies the return, including direct deposit information, picks or authorizes the PIN (five digits, not all zeros), and signs by handwritten or supported electronic signature.
• The ERO confirms the taxpayer's identity.
• The ERO does not send Form 8879 to the IRS unless asked, and keeps it for 3 years from the return due date or IRS received date, whichever is later. Electronic retention is allowed under Rev. Proc. 97-22.

Records after filing

Publication 1345 lists what an ERO keeps until the end of the calendar year and makes available to the IRS: copies of Form 8453 and supporting paper documents not transmitted, copies of Forms W-2, W-2G and 1099-R, signed e-file consents to disclosure, a complete copy of the electronic portion of the return, and the acknowledgment file. Forms 8879 and 8878 stay available for the 3-year period above, associated with the Submission ID.

The tax season workflow guide shows where the 8879 step sits.

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