{"id":4677,"date":"2026-07-29T15:45:23","date_gmt":"2026-07-29T10:15:23","guid":{"rendered":"https:\/\/skillarbitra.ge\/blog\/?p=4677"},"modified":"2026-07-29T19:29:59","modified_gmt":"2026-07-29T13:59:59","slug":"irs-direct-file-free-file-2026-offshore","status":"publish","type":"post","link":"https:\/\/skillarbitra.ge\/blog\/irs-direct-file-free-file-2026-offshore\/","title":{"rendered":"IRS Direct File &#038; Free File 2026: What Changed Offshore"},"content":{"rendered":"<!--\n  IRS Direct File & Free File 2026 - VERSION-A\n  WP-paste-ready HTML. Paste directly into the WordPress block editor as\n  Custom HTML or via the Code Editor view.\n  - Slug: irs-direct-file-free-file-2026-offshore-tax-prep\n  - Last verified: 2026-07-29\n  - Schema (FAQPage) is included at the bottom in separate wp:html blocks.\n  - VERSION-A: clean (no CTAs \/ Expert Inserts)\n-->\n\n\n<p>Last verified: 2026-07-29<\/p>\n<p>IRS Direct File 2026 does not exist. The IRS ended the programme in November 2025 and set no date to bring it back. IRS Free File continues, with an income ceiling of 89,000 dollars and eight software partners, and it runs under contract until October 2029. For anyone preparing US tax returns from India or another offshore location, the practical effect of all this is much smaller than the outsourcing industry is saying, because Direct File handled about two tenths of one percent of American returns in its best year.<\/p>\n<!-- SNIPPET-BAIT START -->\n\n<hr>\n\n<p>The IRS told its 25 partner states on 3 November 2025 that Direct File &#8220;will not be available in Filing Season 2026,&#8221; and Treasury Secretary Scott Bessent confirmed the closure publicly two days later. Direct File accepted 296,531 returns in its final season, about 0.2% of roughly 146 million returns filed. IRS Free File remains open to taxpayers with adjusted gross income of 89,000 dollars or less for 2025 income, through eight partner companies, and Free File Fillable Forms remain open at any income level. In the first filing season without Direct File, returns e-filed by tax professionals rose 0.3% and self-prepared returns rose 1.7%, so the closure produced no measurable shift toward paid preparers.<\/p>\n<!-- SNIPPET-BAIT END -->\n\n<p>This article sets out what happened to IRS Direct File 2026, what Free File does now, what the 2026 season numbers show, and what changes for people who prepare US returns from outside the United States.<\/p>\n<p>Almost everything written about this topic falls into one of two groups. The first is taxpayer advice, telling Americans where to file for free now. The second is marketing from outsourcing firms, telling US accounting firms that demand is about to jump and they should buy offshore capacity to meet it. Neither group is writing for the person who will actually sit down and prepare the return.<\/p>\n<p>That person carries obligations nobody in either group mentions. There are rules about whether a US firm may send a taxpayer&#8217;s social security number to you at all, rules about what identification number you need before you touch a return for money, and contract terms that arrive because of a Federal Trade Commission rule rather than because the client is being difficult. Those rules are the part of this story that affects your work, and they are covered here in the same detail as the news.<\/p>\n\n<hr>\n\n<nav class=\"ls-toc\" aria-label=\"Table of contents\">\n<h2>Table of Contents<\/h2>\n<ol class=\"ls-toc-list\">\n<li><a href=\"#h2-1\">Why there is no IRS Direct File 2026<\/a>\n<ul>\n<li><a href=\"#what-it-cost\">What it cost<\/a><\/li>\n<li><a href=\"#the-replacement-study-is-not-finished\">The replacement study is not finished<\/a><\/li>\n<\/ul>\n<\/li>\n<li><a href=\"#h2-2\">IRS Free File in 2026<\/a>\n<ul>\n<li><a href=\"#why-free-filing-keeps-failing-to-take-share\">Why free filing keeps failing to take share<\/a><\/li>\n<\/ul>\n<\/li>\n<li><a href=\"#h2-3\">What the 2026 filing season numbers show<\/a>\n<\/li>\n<li><a href=\"#h2-4\">How IRS Direct File 2026 changes offshore tax-prep work<\/a>\n<ul>\n<li><a href=\"#what-offshore-tax-prep-work-pays\">What offshore tax-prep work pays<\/a><\/li>\n<\/ul>\n<\/li>\n<li><a href=\"#h2-5\">Section 7216 and offshore 1040 data<\/a>\n<ul>\n<li><a href=\"#the-social-security-number-rule\">The social security number rule<\/a><\/li>\n<li><a href=\"#what-an-adequate-data-protection-safeguard-means\">What an adequate data protection safeguard means<\/a><\/li>\n<li><a href=\"#the-checklist-before-you-touch-a-us-return\">The checklist before you touch a US return<\/a><\/li>\n<\/ul>\n<\/li>\n<li><a href=\"#h2-6\">How to qualify for US tax-prep work from India<\/a>\n<ul>\n<li><a href=\"#getting-a-ptin-without-a-us-social-security-number\">Getting a PTIN without a US social security number<\/a><\/li>\n<li><a href=\"#the-enrolled-agent-route\">The Enrolled Agent route<\/a><\/li>\n<\/ul>\n<\/li>\n<li><a href=\"#h2-7\">Automation is the bigger pressure on 1040 work<\/a>\n<\/li>\n<li><a href=\"#h2-8\">Common mistakes in offshore US tax-prep work<\/a>\n<\/li>\n<li><a href=\"#h2-9\">Frequently asked questions<\/a>\n<\/li>\n<li><a href=\"#h2-10\">References<\/a>\n<ul>\n<li><a href=\"#official-guidance-and-regulations\">Official guidance and regulations<\/a><\/li>\n<li><a href=\"#data-and-research\">Data and research<\/a><\/li>\n<li><a href=\"#secondary-sources\">Secondary sources<\/a><\/li>\n<\/ul>\n<\/li>\n<\/ol>\n<\/nav>\n\n<hr>\n\n<h2 id=\"h2-1\">Why there is no IRS Direct File 2026<\/h2>\n<p>There is no IRS Direct File 2026 because the IRS shut the programme down two months before the season opened. The decision came in two steps. In the first week of November 2025, the IRS emailed the 25 states that had partnered on the service to say that Direct File &#8220;will not be available in Filing Season 2026&#8221; and that &#8220;no launch date has been set for the future.&#8221; The report of that email is dated Wednesday 5 November and says it went out on the Monday, which is 3 November. On the Wednesday, Treasury Secretary Scott Bessent, who was also acting IRS commissioner at the time, confirmed the closure to reporters at the White House.<\/p>\n<p>The reason given was usage. &#8220;We have better alternatives,&#8221; Bessent said. &#8220;It wasn&#8217;t used very much, and we think that the private sector can do a better job.&#8221; The usage numbers support the first half of that statement even if you disagree with the second.<\/p>\n<p>Direct File ran for two seasons. The 2024 filing season pilot covered 12 states and accepted 140,803 returns for tax year 2023. The 2025 season expanded to 25 states and accepted 296,531 tax year 2024 returns as of 20 April 2025.<\/p>\n<p>Treasury describes that as less than 0.5% of the roughly 146 million returns filed for that year. The actual ratio is smaller still, at about 0.2%. That is the figure to use if someone tells you the closure moved the market.<\/p>\n<p>More people started than finished. The Treasury Inspector General for Tax Administration found that 751,000 taxpayers registered with Direct File during the 2025 season, and 59% of them never submitted a return through it. The IRS had estimated 32 million taxpayers were eligible, so actual completed use came to roughly 1% of the eligible population.<\/p>\n<h3 id=\"what-it-cost\">What it cost<\/h3>\n<p>The cost figures were central to the decision. They point in two directions, so both belong here. On one side, Treasury&#8217;s report puts the cost to the federal budget at a minimum of 41,000,000 dollars for tax year 2024 returns, which is at least 138 dollars for every return Direct File accepted that year. The first season was worse on that measure: 31,800,000 dollars for tax year 2023, or about 226 dollars a return.<\/p>\n<p>Note that these are per-year figures rather than a programme total, and Treasury says both understate the real cost because not all agency support functions were counted. Added together the two seasons come to roughly 73,000,000 dollars.<\/p>\n<p>On the other side, the Treasury Inspector General for Tax Administration found the IRS running well under its own spending projection. The agency had budgeted 61,200,000 dollars for fiscal year 2025 and had spent 16,200,000 dollars as of 31 May 2025. Those two numbers do not cover the same period, so the 45,000,000 dollar difference is a mid-year run rate rather than a proven full-year saving. Development of the pilot cost at least 33,400,000 dollars.<\/p>\n<p>Both things can be true. Direct File was expensive per return because almost nobody used it, and it was also tracking below what the IRS had budgeted to run it. Anyone quoting only one of those numbers is arguing a position rather than describing what happened.<\/p>\n<h3 id=\"the-replacement-study-is-not-finished\">The replacement study is not finished<\/h3>\n<p>Congress ordered a report before the IRS closed the programme. Section 70607 of Public Law 119-21, the One Big Beautiful Bill Act, provided 15,000,000 dollars and required Treasury to deliver a report to Congress within 90 days. The subject was the cost of enhancing and establishing public-private partnerships providing free tax filing for up to 70% of all taxpayers by adjusted gross income, and of replacing any direct e-file programmes run by the IRS. The statute says replace, not evaluate.<\/p>\n<p>Treasury published its Report on the Replacement of Direct File on 2 October 2025, a month before the closure was announced. The report does not recommend building a new government filing tool. It sets out four steps instead, and the second of them is to suspend Direct File.<\/p>\n<p>Step one is to raise awareness of Free File and launch a public communications strategy. Step two is the suspension. Step three is to survey taxpayers on their filing preferences and convene a Free Filing Modernization Summit with partners. Step four is to define what counts as a &#8220;free&#8221; return, collect data from commercial tax software companies, and prepare a supplemental report on the future of free tax filing.<\/p>\n<p>That is a plan to make the existing private programme work better, not to replace it.<\/p>\n<p>The question is still open. In February 2026, Senators Elizabeth Warren and Angus King wrote to Bessent asking how the IRS had promoted Direct File and Free File, how it had implemented earlier watchdog recommendations, and how participating companies use taxpayer data.<\/p>\n<p>For planning purposes, treat Free File as the free-filing channel and treat a Direct File revival as something that may or may not happen. The IRS has stated no launch date. Predicting one either way is guessing.<\/p>\n<p>One piece of Direct File did survive. The IRS published its source code on GitHub, which lets individual states build their own filing tools, though that repository is now archived and no longer maintained. The companion state tool that Code for America ran alongside it, FileYourStateTaxes, closed on 31 October 2025 and was not renewed for 2026.<\/p>\n<h2 id=\"h2-2\">IRS Free File in 2026<\/h2>\n<p>IRS Free File is open in 2026 to taxpayers with adjusted gross income of 89,000 dollars or less for the 2025 tax year. Eight companies participate as trusted partners. Each one sets its own additional conditions, which may include age, income, state of residence and military status.<\/p>\n<p>That last point matters more than it looks. Qualifying for the programme is not the same as qualifying for a particular partner&#8217;s product. A taxpayer at 70,000 dollars of income may clear the programme ceiling comfortably and still be turned away by most of the eight partners on age or state rules.<\/p>\n<p>The memorandum of understanding sets each provider&#8217;s share rather than guaranteeing universal cover. Article 4.1.3(i) requires every member to make its services available to not less than 10% and not more than 50% of the individual taxpayer population within what the agreement calls the Coverage, which is the lowest 70% of taxpayers by adjusted gross income.<\/p>\n<p>So no single provider has to serve everyone, and nothing in the agreement promises that a given taxpayer will find a match. Working out which provider will take you takes effort. State coverage is a separate question, with its own limits that are often tighter.<\/p>\n<p>Two other free channels sit alongside it. Free File Fillable Forms are open to everyone regardless of income, though they are electronic versions of the paper forms with no guided interview. MilTax covers a federal return and up to three state returns for eligible members of the military community. The Volunteer Income Tax Assistance and Tax Counseling for the Elderly programmes provide free basic preparation for taxpayers who qualify.<\/p>\n<p>Free File is contracted well past the current season. An amendment dated 30 April 2024 extended the terms of the ninth memorandum of understanding between the IRS and Free File, Inc. to 31 October 2029, and the IRS announced the five-year extension publicly on 22 May 2024. That date is the planning horizon for anyone whose work touches the bottom of the US filing market.<\/p>\n<h3 id=\"why-free-filing-keeps-failing-to-take-share\">Why free filing keeps failing to take share<\/h3>\n<p>Free filing keeps failing to take share because eligible taxpayers do not use it. Treasury&#8217;s report says the memorandum of understanding sets the annual income limit deliberately, to make approximately 70% of taxpayers eligible for Free File.<\/p>\n<p>Actual use ran at about 3% of those eligible in 2024, according to the Treasury Inspector General for Tax Administration. Read across five processing years the direction is down, not up: 4% in 2020 and 2021, then 2% in 2022 and 2023, then 3% in 2024. Part of that last uptick is the denominator shrinking, because the eligible population fell from 108 million in 2021 to 85 million in 2024.<\/p>\n<p>The Inspector General also found that more than 14 million people eligible for Free File in the 2019 filing season may have paid to file with a tax software company that took part in the programme. They were entitled to the free product and bought the paid one from the same company.<\/p>\n<p>Compare that with Direct File&#8217;s roughly 1% completed take-up among its eligible population and a pattern appears. Two different free filing products, one government-run and one industry-run, both reached low single-digit percentages of the people entitled to use them.<\/p>\n<p>The constraint is not availability. It is awareness, plus the friction of working out which of eight products a given taxpayer actually qualifies for, plus the fact that access is only through IRS.gov rather than through the places people already go. This is the single most important fact in the article, because it explains why the paid preparation market has not shrunk despite two decades of free alternatives existing.<\/p>\n<h2 id=\"h2-3\">What the 2026 filing season numbers show<\/h2>\n<p>The 2026 filing season numbers show that removing Direct File changed almost nothing. The IRS publishes weekly filing statistics through the season, so this is measurable rather than a matter of opinion. The season opened on 26 January 2026 with about 164 million individual returns expected, and the deadline fell on 15 April 2026.<\/p>\n<p>Here is where the season stood in the week ending 1 May 2026.<\/p>\n<table>\n<thead>\n<tr>\n<th>Metric<\/th>\n<th>2026<\/th>\n<th>Change vs 2025<\/th>\n<\/tr>\n<\/thead>\n<tbody>\n<tr>\n<td>Total returns received<\/td>\n<td>143,667,000<\/td>\n<td>Down 0.8%<\/td>\n<\/tr>\n<tr>\n<td>Total returns processed<\/td>\n<td>142,539,000<\/td>\n<td>Up 0.2%<\/td>\n<\/tr>\n<tr>\n<td>Total e-filed<\/td>\n<td>140,234,000<\/td>\n<td>Up 0.9%<\/td>\n<\/tr>\n<tr>\n<td>E-filed by tax professionals<\/td>\n<td>74,678,000<\/td>\n<td>Up 0.3%<\/td>\n<\/tr>\n<tr>\n<td>E-filed self-prepared<\/td>\n<td>65,557,000<\/td>\n<td>Up 1.7%<\/td>\n<\/tr>\n<tr>\n<td>Refunds issued<\/td>\n<td>97,918,000<\/td>\n<td>Up 6.5%<\/td>\n<\/tr>\n<tr>\n<td>Average refund<\/td>\n<td>3,273 dollars<\/td>\n<td>Up 11.1%<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<p>Read the two e-filing lines together. In the first season with no government filing tool at all, returns prepared by professionals grew by 0.3%. Returns people prepared themselves grew by 1.7%, more than five times the professional rate.<\/p>\n<p>That is the reverse of the story being sold. If Direct File&#8217;s closure had pushed a meaningful number of filers toward paid preparers, professional volume would have grown faster than self-preparation, not slower. It did not, and the reason is arithmetic. A programme handling 296,531 returns cannot move a market of 140 million, whatever happens to it.<\/p>\n<p>Professionals still did the majority of the work. Of the 140,234,000 returns filed electronically, about 53% came through a paid preparer. That share has barely moved in four years, running at 53.7% in 2023, 53.4% in 2024, 53.6% in 2025 and 53.3% in 2026 at a comparable point in each season.<\/p>\n<p>It is worth putting the 2026 gap next to the two seasons before it, including the one that cuts the other way. In 2024, self-prepared e-filing rose 2.6% against 1.2% for professionals. In 2025, the season Direct File was at its largest, that reversed: professionals rose 2.1% and self-preparation 1.2%. In 2026 it flipped back, 1.7% against 0.3%.<\/p>\n<p>So the relationship between the two moves around from year to year, in both directions, while Direct File was growing and after it closed. The 2026 spread of about 1.4 percentage points matches 2024 to one decimal place. What the three seasons together do not show is a step change at the point Direct File disappeared.<\/p>\n\n\n<figure class=\"ls-infographic-wrap\" style=\"margin:2rem 0;\">\n<div class=\"sa-ig sa-ig-season\">\n<style>\n.sa-ig-season{max-width:820px;margin:32px auto;border:1px solid #e0e0e0;border-radius:8px;overflow:hidden;font-family:-apple-system,BlinkMacSystemFont,'Segoe UI',Roboto,sans-serif;color:#212121;background:#fff}\n.sa-ig-season .ig-head{background:#2941ba;color:#fff;padding:20px 24px;text-align:center}\n.sa-ig-season .ig-head h3{margin:0;font-size:20px;font-weight:700;color:#fff;line-height:1.3}\n.sa-ig-season .ig-head p{margin:6px 0 0;font-size:14px;font-weight:400;opacity:.9;color:#fff}\n.sa-ig-season .ig-scroll{overflow-x:auto}\n.sa-ig-season table{width:100%;border-collapse:collapse;font-size:14.5px;min-width:560px}\n.sa-ig-season th{background:#f5f6fb;color:#1b2a8a;text-align:left;padding:11px 14px;font-size:12.5px;letter-spacing:.4px;text-transform:uppercase;border-bottom:2px solid #2941ba}\n.sa-ig-season td{padding:11px 14px;border-bottom:1px solid #eceff1;vertical-align:top;line-height:1.45}\n.sa-ig-season td.num{font-variant-numeric:tabular-nums;font-weight:600;white-space:nowrap}\n.sa-ig-season tr.key{background:#fffaf0}\n.sa-ig-season tr.key td{font-weight:600}\n.sa-ig-season tr.closed td{background:#f7f7f7;color:#555}\n.sa-ig-season .up{color:#1b7f3b;font-weight:700;white-space:nowrap}\n.sa-ig-season .down{color:#a33;font-weight:700;white-space:nowrap}\n.sa-ig-season .flat{color:#9e9e9e;font-weight:700;white-space:nowrap}\n.sa-ig-season .ig-foot{padding:14px 20px;font-size:12.5px;color:#616161;border-top:1px solid #e0e0e0;background:#fafafa;line-height:1.55}\n@media(max-width:600px){.sa-ig-season .ig-head h3{font-size:16px}.sa-ig-season table{font-size:13px}.sa-ig-season td,.sa-ig-season th{padding:9px 10px}}\n<\/style>\n<div class=\"ig-head\">\n<h3>The 2026 filing season, with and without Direct File<\/h3>\n<p>IRS filing season statistics, week ending 1 May 2026<\/p>\n<\/div>\n<div class=\"ig-scroll\">\n<table>\n<thead><tr><th>Metric<\/th><th>2026<\/th><th>vs 2025<\/th><th>What it means<\/th><\/tr><\/thead>\n<tbody>\n<tr><td>Total returns received<\/td><td class=\"num\">143,667,000<\/td><td class=\"down\">Down 0.8%<\/td><td>Slightly fewer returns overall, not more.<\/td><\/tr>\n<tr><td>Total e-filed<\/td><td class=\"num\">140,234,000<\/td><td class=\"up\">Up 0.9%<\/td><td>Electronic filing keeps growing regardless.<\/td><\/tr>\n<tr class=\"key\"><td>E-filed by tax professionals<\/td><td class=\"num\">74,678,000<\/td><td class=\"up\">Up 0.3%<\/td><td>No rush to paid preparers. This is the number that answers the question.<\/td><\/tr>\n<tr class=\"key\"><td>E-filed self-prepared<\/td><td class=\"num\">65,557,000<\/td><td class=\"up\">Up 1.7%<\/td><td>Self-preparation grew faster, by the same 1.4 point margin as in 2024.<\/td><\/tr>\n<tr><td>Refunds issued<\/td><td class=\"num\">97,918,000<\/td><td class=\"up\">Up 6.5%<\/td><td>More refunds, and larger ones.<\/td><\/tr>\n<tr><td>Average refund<\/td><td class=\"num\">3,273 dollars<\/td><td class=\"up\">Up 11.1%<\/td><td>Unrelated to filing channel, shown for completeness.<\/td><\/tr>\n<tr class=\"closed\"><td>Direct File accepted returns<\/td><td class=\"num\">0<\/td><td class=\"flat\">296,531 in 2025<\/td><td>Programme closed. It was under 0.5% of all returns filed.<\/td><\/tr>\n<\/tbody>\n<\/table>\n<\/div>\n<div class=\"ig-foot\">The 2026 season opened 26 January 2026 and closed 15 April 2026, with about 164 million individual returns expected. Roughly 53% of e-filed returns went through a paid preparer, a share that did not move when Direct File closed. Source: Internal Revenue Service filing season statistics.<\/div>\n<\/div>\n<\/figure>\n\n<h2 id=\"h2-4\">How IRS Direct File 2026 changes offshore tax-prep work<\/h2>\n<p>IRS Direct File 2026 changes offshore tax-prep work very little on its own, and the changes that do matter were already under way before the announcement. Separating the two is the useful thing to do here, because the outsourcing industry has spent the last year merging them.<\/p>\n<p>Start with what did not change. Direct File served straightforward returns, and its scope grew between the two seasons. The 2025 version handled wage income, Social Security income, unemployment compensation, interest, the Alaska Permanent Fund dividend, and a list of common credits and deductions including the Earned Income Tax Credit and health savings account contributions. Retirement income was added part way through, from 5 March 2025.<\/p>\n<p>What the list never included matters more. There was no self-employment income, no rental income and no capital gains, and the IRS described its plan as expanding &#8220;to support most common tax situations&#8221; over coming years rather than having done so.<\/p>\n<p>Those gaps are where the offshore market actually sits. Business returns, multi-state returns and anything with a Schedule C are the work US firms actually send out, because those are the returns with enough hours in them to be worth moving. At the pricing offshore providers publish, a simple individual return is the cheapest item on the rate card, and it is the first type of work software takes over. Direct File&#8217;s closure moved a category of work that was never part of the offshore market to begin with.<\/p>\n<p>Now what did change. The free-filing floor of the US market is in private hands for the life of the Free File agreement, which runs to 31 October 2029. Whatever gets automated at the very bottom will be automated by commercial software vendors, who have a reason to widen their own free tier and capture users, rather than by a government tool that reached 1% of the people eligible for it. The bottom of the market is now a competitive product feature rather than a public service.<\/p>\n<p>And here is what was already changing, whatever happened to Direct File. Offshoring is an established practice at US firms, not a new one. Of the more than 1,100 firms in the AICPA&#8217;s 2023 National Management of an Accounting Practice survey, 25% said they outsourced to offshore workers and about 30% outsourced domestically. Another 12% said they planned to start offshoring.<\/p>\n<p>Be careful with the bigger claims here. A characterisation widely attributed to Thomson Reuters, that offshoring has become a long-term operating strategy letting firms separate production from advisory, originates in an outsourcing provider&#8217;s marketing page rather than in the research. What the Thomson Reuters Institute does say, in an October 2025 piece on firm leadership, is narrower: offshoring and outsourcing remain in the toolkit, especially at larger firms, but as retention improves the hiring mix is shifting from emergency capacity toward structured resourcing.<\/p>\n<p>The driver is supply, not demand. Accounting degrees awarded in the United States, bachelor&#8217;s and master&#8217;s together, fell to 55,152 in the 2023-24 academic year, down 6.6% on the previous year, according to the AICPA&#8217;s 2025 Trends report. The pipeline is recovering at the entry end: undergraduate accounting enrolment reached 281,992 students in spring 2026, up 5.7%, after a 12.7% rise the year before.<\/p>\n<p>The gap shows up in replacement rather than growth. The Bureau of Labor Statistics projects about 124,200 openings a year for accountants and auditors through 2034, against total employment growth of 72,800 across the decade. Divide that out and roughly 7,300 openings a year come from growth, with the rest from people transferring to other occupations or leaving the workforce.<\/p>\n<p>That split is arithmetic from the two published figures rather than a BLS finding, though the direction is the agency&#8217;s own, since it attributes many of those openings to replacement. US firms are short of hands, and they have been for years.<\/p>\n<p>That is the real driver of offshore tax-prep work. It has nothing to do with Direct File. The work that moves offshore is the work that has volume and still needs a person: business returns, multi-state returns, reconciliations, workpaper preparation. If you already handle <a href=\"https:\/\/skillarbitra.ge\/blog\/us-sales-tax-nexus-remote-bookkeepers\/\" target=\"_blank\" rel=\"noopener\">multi-state compliance work<\/a>, that is the category to build on.<\/p>\n<p>The political risk to this arrangement is a separate question, and one we have covered in <a href=\"https:\/\/skillarbitra.ge\/blog\/us-ban-offshoring\/\" target=\"_blank\" rel=\"noopener\">whether the US could legally restrict offshoring of accounting work<\/a>. Nothing in the Direct File decision changes that analysis.<\/p>\n<h3 id=\"what-offshore-tax-prep-work-pays\">What offshore tax-prep work pays<\/h3>\n<p>Every published rate for offshore US tax-prep work comes from the pricing pages of outsourcing companies selling the service, not from an independent survey, and that should be said before the numbers rather than after them. Read them as asking prices, because that is what they are.<\/p>\n<p>On that basis, providers advertise hourly rates of roughly 8 to 25 dollars, simple individual returns at 30 to 75 dollars each, business returns at 100 to 350 dollars each, and dedicated full-time staff somewhere between 1,200 and 3,200 dollars a month depending on the provider and the country. Claimed savings against a fully loaded US hire run from 40% to 80% depending on who is doing the claiming.<\/p>\n<p>Treat all of those as asking prices with a wide spread, not as a market rate for the work. What the profession&#8217;s independent bodies publish is adoption rather than price. The Journal of Accountancy&#8217;s own treatment of offshoring for CPA firms carries no cost, hourly-rate or savings figures at all.<\/p>\n<p>The other side of the transaction is better documented. The National Society of Accountants ran a 2024 income and fees survey of 183 participants, mostly independent practitioners at firms with fewer than three partners. It puts the average fee for a Form 1040 with itemised deductions at 300 to 600 dollars, and a Form 1120 at 750 to 1,250 dollars.<\/p>\n<p>The same survey reports what those firms pay their own people, which is a different number from what they charge. Median wages were 60 dollars an hour for principals, 53 for bookkeepers and 45 for support staff.<\/p>\n<p>Put the two together and the business is easy to see. A US firm charging in the region of 300 to 600 dollars for an itemised return and paying tens of dollars to have it prepared keeps the difference in exchange for review, signature and the client relationship. The preparer&#8217;s share rises with complexity, which is the practical argument for moving toward business and multi-state returns rather than competing for volume at the simple end.<\/p>\n<h2 id=\"h2-5\">Section 7216 and offshore 1040 data<\/h2>\n<p>Section 7216 of the Internal Revenue Code is the rule that decides whether a US firm may send you a taxpayer&#8217;s information at all. Before anything else, correct a piece of vocabulary that circulates widely in the outsourcing world: there is no &#8220;Form 7216.&#8221; Section 7216 is a criminal statute. The consent document people mean is drafted by the US firm to specifications the IRS set out in Revenue Procedure 2013-14, at section 5.04. Asking a US client to send you &#8220;the 7216&#8221; tells them you have not read the rule.<\/p>\n<p>The penalties sit in two places. Section 7216 makes the offence a misdemeanour, carrying a fine of up to 1,000 dollars, imprisonment of up to one year, or both, together with the costs of prosecution. The fine rises to 100,000 dollars where the disclosure or use is made in connection with a crime relating to the misappropriation of another person&#8217;s taxpayer identity, whether or not that crime involves any tax filing.<\/p>\n<p>Section 6713 is the civil companion and carries 250 dollars for each disclosure or use, capped at 10,000 dollars in a calendar year. In identity misappropriation cases the figures rise to 1,000 dollars per disclosure and 50,000 dollars a year, and that annual cap applies separately from the ordinary one. Real exposure in a bad year is therefore 60,000 dollars, not 50,000.<\/p>\n<p>The consent itself has to come first. The taxpayer must sign and date it before the disclosure happens, not afterwards as a tidying-up exercise. The regulations make the timing explicit in two places, in a rule headed &#8220;no retroactive consent&#8221; and in the disclosure provision that requires consent prior to any disclosure, so a consent obtained after the file has already crossed the border does not cure the disclosure that already took place.<\/p>\n<h3 id=\"the-social-security-number-rule\">The social security number rule<\/h3>\n<p>The rule specific to offshore preparation concerns social security numbers. It is the one to remember. Under 26 CFR 301.7216-3(b)(4)(i), a tax return preparer located within the United States may not obtain consent to disclose a taxpayer&#8217;s social security number to a tax return preparer located outside the United States. It applies to taxpayers filing a return in the Form 1040 series, not to every return type.<\/p>\n<p>Two points of scope are easy to miss. The rule treats the United States as including its territories and possessions, so a preparer in Puerto Rico or Guam is inside the line, not outside it. And an employee normally based in the United States who is temporarily travelling abroad is not treated as located outside the country.<\/p>\n<p>There is an exception, and it has parts drawn from two different documents. The regulation itself requires the US preparer to make the disclosure through an adequate data protection safeguard, and to verify the maintenance of that safeguard in the request for the taxpayer&#8217;s consent. Revenue Procedure 2013-14, at section 5.07, adds that both the disclosing and the receiving preparer must maintain such a safeguard, and must do so both when the consent is obtained and when the disclosure is made.<\/p>\n<p>Where those conditions are not met, the general rule applies and the social security number must be redacted or otherwise masked before the tax return information is disclosed outside the United States. This produces the two working patterns you will meet in practice. Either the numbers arrive redacted and the US firm reinserts them at review, which needs one form of consent, or they arrive intact under a verified safeguard, which needs different consent language.<\/p>\n<p>Two narrow exceptions apply. A social security number that was originally received from the preparer abroad may be sent back to them without a fresh consent. And the restriction is on obtaining consent to disclose the number, not on the offshore engagement itself.<\/p>\n<p>For work outside the Form 1040 series, the consent can sit inside the engagement letter, provided it identifies the recipient abroad and states that information will be disclosed to a tax return preparer located outside the United States.<\/p>\n<p>One more distinction matters. Outsourcing inside the United States does not need consent where the services provided are not substantive determinations or advice affecting the tax liability reported. The regulation defines a substantive determination as one involving an analysis, interpretation, or application of the law, which is a narrower test than it sounds.<\/p>\n<p>Purely mechanical work does not trigger consent, but it is not obligation-free either. A firm disclosing information to a contractor for equipment or software services must give that contractor written notice of sections 7216 and 6713, and the contractor then becomes a tax return preparer itself. Once the work crosses the border, consent is required in practice almost every time.<\/p>\n<h3 id=\"what-an-adequate-data-protection-safeguard-means\">What an adequate data protection safeguard means<\/h3>\n<p>An adequate data protection safeguard is a named privacy framework, not a general promise to be careful. Revenue Procedure 2013-14 lists six acceptable options at section 5.07, paragraphs (1) to (6). Paragraph (4) is the AICPA and CICA Privacy Framework. The others include IRS Publication 1075, an industry standard such as the shared assessment programme, a foreign data protection law with a security component, the US Commerce Department safe harbour framework, and a catch-all for anything equivalent.<\/p>\n<p>Two notes on that list. The AICPA published its Privacy Management Framework in 2020 as a superseding update to that earlier work rather than a straight rename, and CICA has not been a co-author since it merged into CPA Canada. The safe harbour entry names a framework invalidated in 2015, though the revenue procedure adds &#8220;or a successor program&#8221;, which keeps it workable. The list is dated but still operative.<\/p>\n<p>In commercial practice, the attestation US firms ask an offshore provider to produce is usually a SOC 2 report, covering security, availability, processing integrity, confidentiality and privacy.<\/p>\n<p>A second rule sits on top of section 7216 and explains most of the paperwork you will be asked for. The Federal Trade Commission&#8217;s Safeguards Rule, made under the Gramm-Leach-Bliley Act, classifies an accountant or other tax preparation service in the business of completing income tax returns as a financial institution. Such a firm must keep a comprehensive information security program, written in one or more readily accessible parts. The industry calls this a Written Information Security Plan, and the IRS publishes a sample as Publication 5708, which it is careful to say is not a substitute for developing your own.<\/p>\n<p>The clause in that rule that reaches you is the one about service providers, at 16 CFR 314.4(f). A firm must take reasonable steps to select and retain service providers capable of maintaining appropriate safeguards, must require those safeguards by contract, and must periodically assess its providers based on the risk they present and the continued adequacy of their safeguards.<\/p>\n<p>Those three duties are where the security questionnaire comes from, and the third is why it recurs rather than happening once. The rule says periodically and sets no fixed interval.<\/p>\n<p>Other clauses in an offshore engagement come from elsewhere in the same rule. The named responsible person traces to the qualified individual requirement at 16 CFR 314.4(a), and breach notification to the incident response duty at 314.4(h) and the notification rule at 314.5. All of them are obligations a US firm is legally required to impose, which is why pushing back on them usually fails.<\/p>\n<p>Because these obligations arrive as contract terms, you need to understand the contract. The clause-by-clause guide to <a href=\"https:\/\/blog.ipleaders.in\/how-to-draft-a-master-service-agreement\/\" target=\"_blank\" rel=\"noopener\">drafting a master service agreement<\/a> on iPleaders covers the structure most of these engagements use, including the confidentiality and liability provisions that carry the security promises.<\/p>\n<p>There is an Indian side to this too. A provider in India handling the personal data of US taxpayers is processing personal data at home as well, and sits inside the Digital Personal Data Protection Act framework for its own operations. The LawSikho piece on <a href=\"https:\/\/lawsikho.com\/blog\/data-protection-officer-dpdp-act\/\" target=\"_blank\" rel=\"noopener\">data protection officer obligations under the DPDP Act<\/a> sets out what that involves for an Indian organisation. Meeting a US firm&#8217;s SOC 2 expectations and meeting Indian obligations are two separate exercises, and firms discover the second one late.<\/p>\n<h3 id=\"the-checklist-before-you-touch-a-us-return\">The checklist before you touch a US return<\/h3>\n<p>Six things to settle before the first file arrives.<\/p>\n<ol>\n<li>Confirm the US firm holds the taxpayer&#8217;s consent, and that it was signed and dated before any data moves. Ask to see that it exists. You do not need the document itself.<\/li>\n<li>Confirm in writing whether social security numbers will arrive masked or intact under a verified safeguard. If the answer is intact and nobody can name the safeguard, something is wrong.<\/li>\n<li>Get a Preparer Tax Identification Number if you prepare all or substantially all of a return for compensation, whether or not you sign it.<\/li>\n<li>Work inside the firm&#8217;s systems wherever possible rather than on local copies. Fewer copies means fewer places a breach can start.<\/li>\n<li>Keep your own written security procedures, and map them to what the firm&#8217;s Written Information Security Plan promises. You will be asked to evidence this.<\/li>\n<li>Keep the engagement in a signed contract that names the security obligations explicitly, rather than relying on email.<\/li>\n<\/ol>\n\n\n<figure class=\"ls-infographic-wrap\" style=\"margin:2rem 0;\">\n<div class=\"sa-ig sa-ig-ssn\">\n<style>\n.sa-ig-ssn{max-width:820px;margin:32px auto;border:1px solid #e0e0e0;border-radius:8px;overflow:hidden;font-family:-apple-system,BlinkMacSystemFont,'Segoe UI',Roboto,sans-serif;color:#212121;background:#fff}\n.sa-ig-ssn .ig-head{background:#2941ba;color:#fff;padding:20px 24px;text-align:center}\n.sa-ig-ssn .ig-head h3{margin:0;font-size:20px;font-weight:700;color:#fff;line-height:1.3}\n.sa-ig-ssn .ig-head p{margin:6px 0 0;font-size:14px;font-weight:400;opacity:.9;color:#fff}\n.sa-ig-ssn .ig-body{padding:22px 20px 6px}\n.sa-ig-ssn .lane{border:1px solid #e0e0e0;border-left:5px solid #2941ba;border-radius:6px;padding:14px 16px;margin-bottom:16px;background:#fff}\n.sa-ig-ssn .lane.no{border-left-color:#c62828;background:#fdf6f6}\n.sa-ig-ssn .lane .lname{font-size:15.5px;font-weight:700;color:#1b2a8a;line-height:1.35}\n.sa-ig-ssn .lane.no .lname{color:#a32020}\n.sa-ig-ssn .lane .lhow{font-size:14px;line-height:1.5;margin-top:7px;color:#424242}\n.sa-ig-ssn .lane .lverdict{font-size:14px;line-height:1.5;margin-top:9px;padding:9px 12px;border-radius:4px;background:#f2f5ff}\n.sa-ig-ssn .lane.no .lverdict{background:#fbeaea}\n.sa-ig-ssn .tag{display:inline-block;font-size:11.5px;font-weight:700;letter-spacing:.5px;text-transform:uppercase;padding:3px 9px;border-radius:3px;background:#1b7f3b;color:#fff;margin-bottom:8px}\n.sa-ig-ssn .tag.stop{background:#c62828}\n.sa-ig-ssn .box{margin:4px 0 18px;border:1px dashed #feae2d;border-radius:6px;padding:14px 16px;background:#fffaf0}\n.sa-ig-ssn .box h4{margin:0 0 9px;font-size:14px;color:#1b2a8a;font-weight:700}\n.sa-ig-ssn .box ol{margin:0;padding-left:20px;font-size:13.8px;line-height:1.65}\n.sa-ig-ssn .box .concl{margin-top:10px;font-size:13.8px;line-height:1.55;font-weight:600;color:#424242}\n.sa-ig-ssn .ig-foot{padding:14px 20px;font-size:12.5px;color:#616161;border-top:1px solid #e0e0e0;background:#fafafa;line-height:1.55}\n@media(max-width:600px){.sa-ig-ssn .ig-head h3{font-size:16px}.sa-ig-ssn .ig-body{padding:18px 14px 4px}.sa-ig-ssn .lane .lname{font-size:14.5px}}\n<\/style>\n<div class=\"ig-head\">\n<h3>Can this 1040 data leave the United States?<\/h3>\n<p>The social security number rule under 26 CFR 301.7216-3<\/p>\n<\/div>\n<div class=\"ig-body\">\n\n<div class=\"lane\">\n<span class=\"tag\">Allowed<\/span>\n<div class=\"lname\">Social security number masked before transfer<\/div>\n<div class=\"lhow\">The US preparer redacts the number, sends the file, and reinserts it at review.<\/div>\n<div class=\"lverdict\">This is the general rule. Needs the taxpayer&#8217;s consent in the Revenue Procedure 2013-14 form, signed and dated <strong>before<\/strong> the disclosure.<\/div>\n<\/div>\n\n<div class=\"lane\">\n<span class=\"tag\">Allowed, conditionally<\/span>\n<div class=\"lname\">Social security number retained under a safeguard<\/div>\n<div class=\"lhow\">Both sides use an adequate data protection safeguard, and the US preparer verifies this when asking for consent.<\/div>\n<div class=\"lverdict\">Permitted only where every condition below holds. Requires <strong>different consent language<\/strong> from the masked route.<\/div>\n<\/div>\n\n<div class=\"lane no\">\n<span class=\"tag stop\">Not allowed<\/span>\n<div class=\"lname\">No consent, or no safeguard on both sides<\/div>\n<div class=\"lhow\">File sent intact on trust, or consent obtained after the transfer.<\/div>\n<div class=\"lverdict\">The number should have been masked. A consent signed after the disclosure does not cure the disclosure that already happened.<\/div>\n<\/div>\n\n<div class=\"box\">\n<h4>The conditions for the safeguard route, and where each comes from<\/h4>\n<ol>\n<li><strong>26 CFR 301.7216-3(b)(4)(ii):<\/strong> the US preparer discloses through an adequate data protection safeguard.<\/li>\n<li><strong>26 CFR 301.7216-3(b)(4)(ii):<\/strong> the US preparer verifies the maintenance of that safeguard in the request for the taxpayer&#8217;s consent.<\/li>\n<li><strong>Rev. Proc. 2013-14, section 5.07:<\/strong> both the disclosing and the receiving preparer maintain such a safeguard, when consent is obtained <em>and<\/em> when the disclosure is made.<\/li>\n<\/ol>\n<div class=\"concl\">All must hold. If any one fails, the general rule applies and the number must be redacted or otherwise masked before disclosure.<\/div>\n<\/div>\n\n<\/div>\n<div class=\"ig-foot\"><strong>There is no Form 7216.<\/strong> The rule applies to the Form 1040 series, and the United States includes its territories and possessions, so a preparer in Puerto Rico or Guam is inside the line. Section 7216 is a criminal misdemeanour: up to 1,000 dollars, up to one year, or both, plus costs of prosecution, rising to 100,000 dollars where the disclosure is connected to a crime involving misappropriation of another person&#8217;s taxpayer identity. Section 6713 is the civil companion: 250 dollars per disclosure capped at 10,000 dollars a year, with a separate 1,000 and 50,000 dollar scale in identity cases. Sources: 26 CFR 301.7216-3(b)(4), Rev. Proc. 2013-14 section 5.07, 26 U.S. Code sections 7216 and 6713.<\/div>\n<\/div>\n<\/figure>\n\n<h2 id=\"h2-6\">How to qualify for US tax-prep work from India<\/h2>\n<p>Qualifying for US tax-prep work from India needs a Preparer Tax Identification Number, and the credential that raises your rate above that floor is the Enrolled Agent. The scale of the opportunity is visible in the IRS&#8217;s own preparer statistics.<\/p>\n<p>As of 1 July 2026, 872,363 individuals held a current Preparer Tax Identification Number for 2026. The credential breakdown is where the story is.<\/p>\n<table>\n<thead>\n<tr>\n<th>Credential held<\/th>\n<th>Number<\/th>\n<th>Share of PTIN holders<\/th>\n<\/tr>\n<\/thead>\n<tbody>\n<tr>\n<td>Certified Public Accountants<\/td>\n<td>207,979<\/td>\n<td>23.8%<\/td>\n<\/tr>\n<tr>\n<td>Annual Filing Season Program participants<\/td>\n<td>72,045<\/td>\n<td>8.3%<\/td>\n<\/tr>\n<tr>\n<td>Enrolled Agents<\/td>\n<td>68,177<\/td>\n<td>7.8%<\/td>\n<\/tr>\n<tr>\n<td>Attorneys<\/td>\n<td>25,834<\/td>\n<td>3.0%<\/td>\n<\/tr>\n<tr>\n<td>Enrolled Retirement Plan Agents<\/td>\n<td>443<\/td>\n<td>0.1%<\/td>\n<\/tr>\n<tr>\n<td>Enrolled Actuaries<\/td>\n<td>213<\/td>\n<td>0.0%<\/td>\n<\/tr>\n<tr>\n<td><strong>Total PTIN holders<\/strong><\/td>\n<td><strong>872,363<\/strong><\/td>\n<td><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n<p>Read that table carefully, because the rows do not add up the way they look. The IRS treats only certified public accountants, attorneys and enrolled agents as credentialed. Annual Filing Season Program participants are described by the IRS as non-credentialed preparers with limited representation rights. The IRS also notes that some preparers hold more than one credential, so the rows overlap and cannot simply be summed.<\/p>\n<p>Taking the three credentialed categories together gives at most 301,990 people, or about 35% of PTIN holders, and the real figure is lower because of that overlap. Most people legally preparing US tax returns for money hold no professional credential. Around 2,305,910 people have been issued a PTIN since the register opened on 28 September 2010, so the working population turns over heavily.<\/p>\n<p>The IRS publishes these as national totals. It does not publish a country breakdown, so any India-specific figure you meet is not coming from IRS statistics.<\/p>\n<h3 id=\"getting-a-ptin-without-a-us-social-security-number\">Getting a PTIN without a US social security number<\/h3>\n<p>A person who is not a US citizen or resident alien, and who cannot obtain a US social security number, applies for a PTIN using Form W-12 supported by Form 8946, the supplemental application for foreign persons without a social security number. Applying by mail means completing both forms. Applying online means completing Form W-12 and then uploading the supporting documents when prompted.<\/p>\n<p>Only preparers with a non-US address may file Form 8946. The form says so in terms: if you do not have a foreign address, stop and do not file it. A post office box is rejected, and the address has to be the physical address where you normally reside outside the United States. For this purpose the IRS counts states, territories, possessions, commonwealths and the District of Columbia as inside the United States.<\/p>\n<p>The identity requirement is two current government-issued documents that together prove both identity and foreign status, with at least one carrying a photograph. Originals or notarised copies are required, and expired documents are not accepted. A passport and a national identity card are the usual pairing. The IRS asks for six weeks of processing time, so this is not something to start in January.<\/p>\n<p>Now the caution that anyone reading this needs to see. Form 8946 carries a warning on the face of the form: if you are a foreign preparer who resides outside the United States and you obtain a PTIN without a social security number, you are not authorised to prepare returns in the United States for compensation. The IRS has not published guidance elaborating on that sentence, so treat it as a live constraint to raise with the US firm engaging you rather than something to interpret on your own.<\/p>\n<p>The obligation applies more widely than people expect. Non-signing preparers still need a PTIN. The IRS states that although there is no plan to add non-signing preparers to the paid preparer section of the return, they are still required to have one.<\/p>\n<p>So if you prepare all or substantially all of a return for compensation and a US colleague signs it, you are inside the requirement. Staff doing only typing, reproduction or other mechanical assistance are not.<\/p>\n<h3 id=\"the-enrolled-agent-route\">The Enrolled Agent route<\/h3>\n<p>An Enrolled Agent is licensed federally by the IRS and holds unlimited rights to represent taxpayers before the agency, on any matter, in any office. The credential is earned either by passing a three-part examination covering individual and business returns, or through qualifying past employment with the IRS.<\/p>\n<p>The continuing education requirement has a shape worth knowing before you commit. It is 72 hours per three-year enrolment cycle, but with a floor of 16 hours in each year, two of which must be ethics. Banking all 72 hours in the final year does not satisfy it. Circular 230 also requires an applicant to be at least 18 and to hold a current valid PTIN.<\/p>\n<p>Circular 230 sections 10.4 and 10.5 set out the conditions for enrolment, and neither imposes a citizenship or residency requirement. Nor does the IRS&#8217;s enrolled agent guidance. That absence is what makes the credential unusual compared with a state-licensed CPA, and it is why it is the common route for professionals working on US returns from outside the country.<\/p>\n<p>Read that alongside the Form 8946 caution above rather than instead of it. The enrolment rules do not turn on where you live. The PTIN route you used to get there may still carry a restriction on preparing returns in the United States for compensation, and those are two different questions.<\/p>\n<p>Whether it is the right credential for you depends on what you want the work to look like. We have compared the two paths in detail in <a href=\"https:\/\/skillarbitra.ge\/blog\/enrolled-agent-vs-cpa-2026\/\" target=\"_blank\" rel=\"noopener\">Enrolled Agent vs CPA in 2026<\/a>, and the current exam mechanics, fees and testing arrangements are covered in <a href=\"https:\/\/skillarbitra.ge\/blog\/ea-exam-2026-changes\/\" target=\"_blank\" rel=\"noopener\">the 2026 EA exam changes<\/a>.<\/p>\n<p>The arithmetic in the table above is the argument. 68,177 Enrolled Agents serve a market that filed more than 143 million returns in 2026, and a credential that carries representation rights is the difference between preparing a return and being able to deal with what happens after it is filed.<\/p>\n\n\n<figure class=\"ls-infographic-wrap\" style=\"margin:2rem 0;\">\n<div class=\"sa-ig sa-ig-ptin\">\n<style>\n.sa-ig-ptin{max-width:820px;margin:32px auto;border:1px solid #e0e0e0;border-radius:8px;overflow:hidden;font-family:-apple-system,BlinkMacSystemFont,'Segoe UI',Roboto,sans-serif;color:#212121;background:#fff}\n.sa-ig-ptin .ig-head{background:#2941ba;color:#fff;padding:20px 24px;text-align:center}\n.sa-ig-ptin .ig-head h3{margin:0;font-size:20px;font-weight:700;color:#fff;line-height:1.3}\n.sa-ig-ptin .ig-head p{margin:6px 0 0;font-size:14px;font-weight:400;opacity:.9;color:#fff}\n.sa-ig-ptin .ig-body{padding:24px 22px 8px}\n.sa-ig-ptin .total{text-align:center;margin-bottom:20px}\n.sa-ig-ptin .total .n{font-size:34px;font-weight:800;color:#1b2a8a;line-height:1;font-variant-numeric:tabular-nums}\n.sa-ig-ptin .total .l{font-size:13px;color:#616161;margin-top:6px}\n.sa-ig-ptin .bar{display:flex;height:34px;border-radius:5px;overflow:hidden;margin-bottom:18px;border:1px solid #d5d9e8}\n.sa-ig-ptin .bar span{display:block;height:100%}\n.sa-ig-ptin .s1{background:#1b2a8a}\n.sa-ig-ptin .s2{background:#2941ba}\n.sa-ig-ptin .s3{background:#feae2d}\n.sa-ig-ptin .s4{background:#6f7fd4}\n.sa-ig-ptin .s5{background:#b9c1e8}\n.sa-ig-ptin .s6{background:#eceff1}\n.sa-ig-ptin .rows{font-size:14.5px}\n.sa-ig-ptin .row{display:flex;align-items:center;gap:10px;padding:9px 4px;border-bottom:1px solid #eceff1}\n.sa-ig-ptin .row:last-child{border-bottom:0}\n.sa-ig-ptin .sw{flex:0 0 14px;width:14px;height:14px;border-radius:3px}\n.sa-ig-ptin .lab{flex:1;line-height:1.4}\n.sa-ig-ptin .val{font-variant-numeric:tabular-nums;font-weight:700;white-space:nowrap}\n.sa-ig-ptin .pct{flex:0 0 52px;text-align:right;color:#616161;font-size:13px;font-variant-numeric:tabular-nums}\n.sa-ig-ptin .row.hi{background:#fffaf0;border-radius:4px}\n.sa-ig-ptin .row.rest{background:#f7f7f7;border-radius:4px;margin-top:4px}\n.sa-ig-ptin .ig-foot{padding:14px 20px;font-size:12.5px;color:#616161;border-top:1px solid #e0e0e0;background:#fafafa;line-height:1.55}\n@media(max-width:600px){.sa-ig-ptin .ig-head h3{font-size:16px}.sa-ig-ptin .total .n{font-size:27px}.sa-ig-ptin .rows{font-size:13.5px}.sa-ig-ptin .ig-body{padding:20px 14px 6px}}\n<\/style>\n<div class=\"ig-head\">\n<h3>Who holds a 2026 PTIN<\/h3>\n<p>IRS Return Preparer Office statistics, as of 1 July 2026<\/p>\n<\/div>\n<div class=\"ig-body\">\n\n<div class=\"total\">\n<div class=\"n\">872,363<\/div>\n<div class=\"l\">individuals with a current Preparer Tax Identification Number for 2026<\/div>\n<\/div>\n\n<div class=\"bar\">\n<span class=\"s1\" style=\"width:23.8%\"><\/span>\n<span class=\"s2\" style=\"width:8.3%\"><\/span>\n<span class=\"s3\" style=\"width:7.8%\"><\/span>\n<span class=\"s4\" style=\"width:3.0%\"><\/span>\n<span class=\"s5\" style=\"width:0.1%\"><\/span>\n<span class=\"s6\" style=\"width:65.4%\"><\/span>\n<\/div>\n\n<div class=\"rows\">\n<div class=\"row\"><span class=\"sw s1\"><\/span><span class=\"lab\">Certified Public Accountants<\/span><span class=\"val\">207,979<\/span><span class=\"pct\">23.8%<\/span><\/div>\n<div class=\"row\"><span class=\"sw s2\"><\/span><span class=\"lab\">Annual Filing Season Program (not credentialed)<\/span><span class=\"val\">72,045<\/span><span class=\"pct\">8.3%<\/span><\/div>\n<div class=\"row hi\"><span class=\"sw s3\"><\/span><span class=\"lab\"><strong>Enrolled Agents<\/strong><\/span><span class=\"val\">68,177<\/span><span class=\"pct\">7.8%<\/span><\/div>\n<div class=\"row\"><span class=\"sw s4\"><\/span><span class=\"lab\">Attorneys<\/span><span class=\"val\">25,834<\/span><span class=\"pct\">3.0%<\/span><\/div>\n<div class=\"row\"><span class=\"sw s5\"><\/span><span class=\"lab\">Enrolled Retirement Plan Agents and Enrolled Actuaries<\/span><span class=\"val\">656<\/span><span class=\"pct\">0.1%<\/span><\/div>\n<div class=\"row rest\"><span class=\"sw s6\"><\/span><span class=\"lab\"><strong>Neither CPA, attorney nor enrolled agent<\/strong><\/span><span class=\"val\">570,373<\/span><span class=\"pct\">65.4%<\/span><\/div>\n<\/div>\n\n<\/div>\n<div class=\"ig-foot\"><strong>Read the rows, not the sum.<\/strong> The IRS treats only CPAs, attorneys and enrolled agents as credentialed. Annual Filing Season Program participants are described by the IRS as non-credentialed preparers with limited representation rights, so they are shown separately here. The IRS also notes that some preparers hold more than one credential, so the categories overlap and cannot be added together. The three credentialed categories come to at most 301,990 people, about 35% of the total, and the true figure is lower. 2,305,910 people have been issued a PTIN since 28 September 2010. The IRS publishes national totals and no country breakdown, so any India-specific figure is not coming from IRS statistics.<\/div>\n<\/div>\n<\/figure>\n\n<h2 id=\"h2-7\">Automation is the bigger pressure on 1040 work<\/h2>\n<p>The pressure on routine 1040 preparation comes from software, not from free-filing programmes. This is the part of the story that deserved the attention Direct File received, and it moves faster than any policy decision.<\/p>\n<p>The tasks vendors describe themselves as automating are the ones that fill an offshore preparer&#8217;s day: extracting data from source documents, categorising transactions, flagging anomalies, and drafting workpapers. The tasks the same vendors still describe as human are research, professional judgment and quality review.<\/p>\n<p>A caution about the numbers in this area. A figure circulates saying AI tools now deliver individual returns 80 to 90% complete before a professional looks at them, attributed to Thomson Reuters. It does not appear on any Thomson Reuters page.<\/p>\n<p>The company&#8217;s own product material describes a complete draft return ready for review and carries no numeric claim of its own. The one figure in circulation, roughly an hour saved on each simple 1040, comes from a named customer rather than from the vendor&#8217;s measurement.<\/p>\n<p>There is a real percentage nearby, and it points the other way. Thomson Reuters says its SurePrep 1040SCAN tool eliminates the need to verify optical character recognition data for 65% of standard documents. That is a measure of review steps removed from document handling, not a measure of how finished a return is.<\/p>\n<p>The direction is clear even without a disputed statistic. The safer work is the work someone has to review. Volume data entry is the exposed task, because it is repetitive, high-volume and rule-bound, which is the profile software handles best. Reconciliation work, multi-state returns, business returns, responding to IRS notices, and anything that ends in a credentialled signature are not.<\/p>\n<p>If you use these tools yourself, the client-data rules apply again. The same confidentiality procedures that section 7216 requires apply to what you paste into a model, and we have set out the practical version of that in <a href=\"https:\/\/skillarbitra.ge\/blog\/how-bookkeepers-use-ai\/\" target=\"_blank\" rel=\"noopener\">how bookkeepers can use AI safely<\/a>.<\/p>\n<h2 id=\"h2-8\">Common mistakes in offshore US tax-prep work<\/h2>\n<p>The mistakes that cost offshore preparers work are usually compliance mistakes, not technical ones. Eight come up repeatedly.<\/p>\n<p><strong>Calling it &#8220;Form 7216.&#8221;<\/strong> No such form exists. Section 7216 is a criminal statute and the consent is a document the US firm drafts to Revenue Procedure 2013-14. Using the phrase in a proposal signals to a US firm that you have picked up the vocabulary without reading the rule, which is a poor first impression in a compliance-sensitive engagement.<\/p>\n<p><strong>Assuming the US firm has handled consent.<\/strong> The obligation to obtain consent sits with the US preparer, but the data lands on your machine. Confirm the consent exists and was dated before the transfer. A firm that cannot answer that question quickly has a process problem you are about to inherit.<\/p>\n<p><strong>Accepting unmasked social security numbers without asking about the safeguard.<\/strong> If numbers arrive intact on a Form 1040 series return, the exception in 26 CFR 301.7216-3(b)(4)(ii) must apply, together with the requirement in Revenue Procedure 2013-14 section 5.07 that both sides maintain an adequate data protection safeguard. If nobody can name the framework, the numbers should have been redacted and the disclosure was improper.<\/p>\n<p><strong>Skipping the PTIN because you do not sign returns.<\/strong> Non-signing preparers who prepare all or substantially all of a return for compensation still need one. This is one of the most common gaps among people working through an outsourcing intermediary, because the intermediary often does not raise it.<\/p>\n<p><strong>Treating the security questionnaire as procurement paperwork.<\/strong> It comes from the Federal Trade Commission&#8217;s Safeguards Rule, which requires the US firm to bind its service providers by contract. The clause it produces is enforceable against you, and the breach-notification timelines in it are real obligations with real deadlines.<\/p>\n<p><strong>Reading the end of Direct File as a demand surge.<\/strong> Professional e-filing rose 0.3% in 2026. Anyone who added capacity in expectation of a rush was working from a press release rather than from the IRS statistics, which were published weekly and were free to read.<\/p>\n<p><strong>Competing on price at the bottom of the market.<\/strong> Simple individual returns are where software is strongest and margins are thinnest. Provider price lists put them at 30 to 75 dollars, and that is the segment most exposed to automation. Build a practice on that work and you will have to rebuild it in a few years.<\/p>\n<p><strong>Ignoring obligations in India.<\/strong> An Indian provider handling US taxpayer personal data is processing personal data under Indian law as well. SOC 2 readiness for a US client and Digital Personal Data Protection Act compliance at home are separate exercises, and the second one is usually discovered late.<\/p>\n<h2 id=\"h2-9\">Frequently asked questions<\/h2>\n<p><strong>Is IRS Direct File available in 2026?<\/strong>\nNo. The IRS told its 25 partner states on 3 November 2025 that Direct File &#8220;will not be available in Filing Season 2026,&#8221; and Treasury Secretary Scott Bessent confirmed the closure to reporters at the White House on 5 November 2025. No launch date has been set for any future season.<\/p>\n<p><strong>Why did the IRS end Direct File?<\/strong>\nThe stated reason was low usage and cost. Direct File accepted 296,531 tax year 2024 returns, which Treasury describes as less than 0.5% of roughly 146 million returns filed and which works out at about 0.2%. Treasury puts the cost for that year at a minimum of 41,000,000 dollars, or at least 138 dollars per accepted return, following 31,800,000 dollars and about 226 dollars a return for the tax year 2023 pilot. Bessent said the private sector could do the job better.<\/p>\n<p><strong>Is Direct File coming back?<\/strong>\nThe IRS has stated no launch date. Treasury&#8217;s Report on the Replacement of Direct File, published 2 October 2025, recommends strengthening Free File rather than rebuilding a government filing tool. Congress mandated the study under section 70607 of Public Law 119-21, with 15,000,000 dollars and a target of free filing for up to 70% of taxpayers, but no replacement has been launched.<\/p>\n<p><strong>What is the IRS Free File income limit for 2026?<\/strong>\nAdjusted gross income of 89,000 dollars or less for the 2025 tax year. Eight trusted partners participate, and each sets its own further conditions on age, income, state residency and military status, so meeting the programme limit does not guarantee eligibility for a specific partner&#8217;s product.<\/p>\n<p><strong>Is Free File going away too?<\/strong>\nNo. The IRS extended the Free File agreement for five years on 22 May 2024, running through October 2029. Treasury&#8217;s replacement report recommends strengthening it further.<\/p>\n<p><strong>What can a taxpayer use instead of Direct File?<\/strong>\nIRS Free File for adjusted gross income of 89,000 dollars or less, Free File Fillable Forms at any income level, MilTax for eligible members of the military community covering a federal return and up to three state returns, and the Volunteer Income Tax Assistance and Tax Counseling for the Elderly programmes for those who qualify.<\/p>\n<p><strong>Did ending Direct File increase work for paid tax preparers?<\/strong>\nNot measurably. In the week ending 1 May 2026, returns e-filed by tax professionals stood at 74,678,000, up 0.3% on 2025, while self-prepared returns stood at 65,557,000, up 1.7%. The relationship between those two growth rates moves around from year to year in both directions: self-preparation grew faster in 2024, professional preparation grew faster in 2025 when Direct File was at its largest, and self-preparation grew faster again in 2026. There is no step change at the point Direct File closed.<\/p>\n<p><strong>Is it legal for a US firm to send tax returns to India for preparation?<\/strong>\nYes, subject to section 7216 of the Internal Revenue Code. The US preparer must obtain the taxpayer&#8217;s written consent, signed and dated before the disclosure, in the form specified by Revenue Procedure 2013-14. Separate and stricter rules apply to the taxpayer&#8217;s social security number, which is covered in the next answer.<\/p>\n<p><strong>Can a taxpayer&#8217;s social security number be sent to a preparer outside the United States?<\/strong>\nOnly under a specific exception. Under 26 CFR 301.7216-3(b)(4), a preparer within the United States may not obtain consent to disclose a Form 1040 series taxpayer&#8217;s social security number to a preparer located outside the United States. The exception requires the disclosure to be made through an adequate data protection safeguard and verified in the consent request, and Revenue Procedure 2013-14 section 5.07 requires both preparers to maintain such a safeguard, at the time consent is obtained and when the disclosure is made. Otherwise the number must be redacted or otherwise masked first. Note that the United States includes its territories and possessions for this purpose, so a preparer in Puerto Rico or Guam is not &#8220;outside&#8221; it.<\/p>\n<p><strong>What is a Form 7216 consent?<\/strong>\nThere is no Form 7216. Section 7216 is a criminal statute in the Internal Revenue Code. The document people mean is a consent to disclose tax return information, drafted by the US firm to the mandatory content and format requirements in Revenue Procedure 2013-14, section 5.04.<\/p>\n<p><strong>Can someone in India get a PTIN?<\/strong>\nYes. A person who is not a US citizen or resident alien and cannot obtain a US social security number files Form W-12 supported by Form 8946, by mail or online with uploaded documents. Two current government-issued documents proving identity and foreign status are required, at least one with a photograph. Only preparers with a non-US address may file Form 8946, and the IRS asks for six weeks of processing time. Note the caution printed on Form 8946: a foreign preparer residing outside the United States who obtains a PTIN without a social security number is not authorised to prepare returns in the United States for compensation.<\/p>\n<p><strong>Do I need a PTIN if I do not sign the returns?<\/strong>\nYes, if you prepare all or substantially all of a return for compensation. The IRS states that non-signing preparers are still required to have a PTIN, even though there is no plan to add them to the paid preparer section of the return.<\/p>\n<p><strong>Can a non-US resident become an enrolled agent?<\/strong>\nCircular 230 sections 10.4 and 10.5 set out the conditions for enrolment and impose no citizenship or residency requirement, and neither does the IRS&#8217;s enrolled agent guidance. The credential is earned by passing a three-part examination covering individual and business returns, or through qualifying past IRS employment. Applicants must be at least 18 and hold a valid PTIN. Continuing education is 72 hours per three-year cycle with a minimum of 16 hours each year, two of them on ethics.<\/p>\n<p><strong>Will AI replace offshore tax preparation work?<\/strong>\nSoftware vendors describe themselves as automating document extraction, transaction categorisation, anomaly flagging and workpaper drafting, and describe research, judgment and quality review as remaining human. High-volume data entry on simple returns is the most exposed task. Reconciliation, multi-state and business returns, notice response and work requiring a credentialled signature are less so.<\/p>\n<h2 id=\"h2-10\">References<\/h2>\n<h3 id=\"official-guidance-and-regulations\">Official guidance and regulations<\/h3>\n<ol>\n<li><a href=\"https:\/\/www.law.cornell.edu\/cfr\/text\/26\/301.7216-2\" target=\"_blank\" rel=\"noopener\">26 CFR 301.7216-2, Permissible disclosures or uses without consent of the taxpayer<\/a> &#8211; Legal Information Institute, Cornell Law School. Subsection (d)(1) sets the substantive determination test for domestic outsourcing. Subsection (d)(2) requires written notice of sections 7216 and 6713 to a contractor.<\/li>\n<li><a href=\"https:\/\/www.law.cornell.edu\/cfr\/text\/26\/301.7216-3\" target=\"_blank\" rel=\"noopener\">26 CFR 301.7216-3, Disclosure or use permitted only with the taxpayer&#8217;s consent<\/a> &#8211; Legal Information Institute, Cornell Law School. Subsection (b)(4) carries the social security number rule for preparers located outside the United States and its safeguard exception. Subsection (b)(1) is the no-retroactive-consent rule.<\/li>\n<li><a href=\"https:\/\/www.law.cornell.edu\/uscode\/text\/26\/7216\" target=\"_blank\" rel=\"noopener\">26 U.S. Code section 7216, Disclosure or use of information by preparers of returns<\/a> &#8211; Legal Information Institute, Cornell Law School. Misdemeanour, fine of up to 1,000 dollars, up to one year, costs of prosecution, and the 100,000 dollar figure reached through the section 6713(b) cross-reference.<\/li>\n<li><a href=\"https:\/\/www.law.cornell.edu\/uscode\/text\/26\/6713\" target=\"_blank\" rel=\"noopener\">26 U.S. Code section 6713, Disclosure or use of information by preparers of returns<\/a> &#8211; Legal Information Institute, Cornell Law School. Civil penalties, and subsection (b)(2) under which the annual cap applies separately to enhanced and ordinary disclosures.<\/li>\n<li><a href=\"https:\/\/www.law.cornell.edu\/cfr\/text\/16\/314.4\" target=\"_blank\" rel=\"noopener\">16 CFR 314.2 and 314.4, Standards for Safeguarding Customer Information<\/a> &#8211; Federal Trade Commission. Section 314.2(h)(2)(viii) classifies a tax preparation service as a financial institution. Section 314.4(f) sets the three service provider duties: selection, contractual requirement, and periodic assessment.<\/li>\n<li><a href=\"https:\/\/www.law.cornell.edu\/cfr\/text\/31\/10.4\" target=\"_blank\" rel=\"noopener\">31 CFR 10.4, Regulations Governing Practice before the Internal Revenue Service (Circular 230)<\/a> &#8211; Department of the Treasury. Section 10.4(a) carries the conditions for enrolment as an enrolled agent, including age 18 and a current or otherwise valid PTIN. Section 10.5 covers application procedure, fee, and tax compliance and suitability checks. Neither imposes a citizenship or residency requirement.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/pub\/irs-drop\/rp-13-14.pdf\" target=\"_blank\" rel=\"noopener\">Revenue Procedure 2013-14<\/a> &#8211; Internal Revenue Service. Section 5.04 sets the mandatory consent language for the Form 1040 series. Section 5.07 lists the six acceptable adequate data protection safeguards, including the AICPA and CICA Privacy Framework, and requires both preparers to maintain one. Modified and superseded Revenue Procedure 2008-35.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/pub\/irs-drop\/rp-13-19.pdf\" target=\"_blank\" rel=\"noopener\">Revenue Procedure 2013-19<\/a> &#8211; Internal Revenue Service. Changed the transition timing of Revenue Procedure 2013-14. Consents obtained on or after 1 January 2014 must use the section 5.04 language.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/tax-professionals\/section-7216-information-center\" target=\"_blank\" rel=\"noopener\">Section 7216 information center<\/a> &#8211; Internal Revenue Service. Landing page for section 7216 guidance. Note that the final regulations dated 28 December 2012 changed only parts of 301.7216-2. The consent rules in 301.7216-3 apply to disclosures made on or after 1 January 2009.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/tax-professionals\/frequently-asked-questions-do-i-need-a-ptin\" target=\"_blank\" rel=\"noopener\">Frequently asked questions: Do I need a PTIN?<\/a> &#8211; Internal Revenue Service. Foreign preparer requirements, and the statement that non-signing preparers are still required to have a PTIN.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/pub\/irs-pdf\/f8946.pdf\" target=\"_blank\" rel=\"noopener\">Form 8946, PTIN Supplemental Application For Foreign Persons Without a Social Security Number<\/a> &#8211; Internal Revenue Service, revised October 2025. Source of the two-document identity requirement, the foreign-address-only restriction, the six-week processing time, and the caution that a foreign preparer residing outside the United States who obtains a PTIN without a social security number is not authorised to prepare returns in the United States for compensation.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/forms-pubs\/about-form-w-12\" target=\"_blank\" rel=\"noopener\">Form W-12, IRS Paid Preparer Tax Identification Number (PTIN) Application and Renewal<\/a> &#8211; Internal Revenue Service. The application itself, by mail or online.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/tax-professionals\/enrolled-agents\/enrolled-agent-information\" target=\"_blank\" rel=\"noopener\">Enrolled agent information<\/a> &#8211; Internal Revenue Service. Three-part examination, unlimited practice rights, and 72 hours of continuing education per three-year cycle.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/tax-professionals\/enrolled-agents\/maintain-your-enrolled-agent-status\" target=\"_blank\" rel=\"noopener\">Maintain your enrolled agent status<\/a> &#8211; Internal Revenue Service. The annual minimum of 16 hours including 2 on ethics, under 31 CFR 10.6(e).<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/newsroom\/irs-security-summit-remind-tax-pros-they-must-have-a-written-information-security-plan-to-protect-client-data\" target=\"_blank\" rel=\"noopener\">IRS, Security Summit remind tax pros they must have a Written Information Security Plan to protect client data<\/a> &#8211; Internal Revenue Service. Gramm-Leach-Bliley Act obligations and the service provider requirement.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/pub\/irs-pdf\/p5708.pdf\" target=\"_blank\" rel=\"noopener\">Publication 5708, Creating a Written Information Security Plan for your Tax and Accounting Practice<\/a> &#8211; Internal Revenue Service. A sample plan, which the IRS says is not a substitute for developing your own.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/newsroom\/irs-announces-extension-of-free-file-program-through-2029\" target=\"_blank\" rel=\"noopener\">IRS announces extension of Free File program through 2029<\/a> &#8211; Internal Revenue Service, IR-2024-145, 22 May 2024.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/pub\/irs-efile\/ninth-memorandum-of-understanding-on-service-standards-and-disputes.pdf\" target=\"_blank\" rel=\"noopener\">Ninth Memorandum of Understanding on Service Standards and Disputes<\/a> &#8211; Internal Revenue Service and Free File, Inc. Clause 1.5 defines Coverage as the lowest 70% of the taxpayer population by adjusted gross income. Article 4.1.3(i) requires each member to serve not less than 10% and not more than 50% of the individual taxpayer population within that Coverage. The agreement contains no clause requiring providers collectively to cover every eligible taxpayer.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/pub\/irs-wi\/addendum-to-the-free-file-ninth-mou-2024.pdf\" target=\"_blank\" rel=\"noopener\">Addendum to the Free File Ninth Memorandum of Understanding<\/a> &#8211; Internal Revenue Service, 30 April 2024. Extends the ninth memorandum of understanding to 31 October 2029.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/newsroom\/2026-tax-filing-season-opens-with-several-free-filing-options-available\" target=\"_blank\" rel=\"noopener\">2026 tax filing season opens with several free filing options available<\/a> &#8211; Internal Revenue Service. The 89,000 dollar threshold, the eight partners, Free File Fillable Forms, MilTax, VITA and TCE.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/newsroom\/irs-opens-2026-filing-season\" target=\"_blank\" rel=\"noopener\">IRS opens 2026 filing season<\/a> &#8211; Internal Revenue Service. Season opened 26 January 2026, deadline 15 April 2026, about 164 million returns expected.<\/li>\n<li><a href=\"https:\/\/home.treasury.gov\/system\/files\/131\/Report-Replacement-of-Direct-File-2025.pdf\" target=\"_blank\" rel=\"noopener\">Report on the Replacement of Direct File<\/a> &#8211; Department of the Treasury, 2 October 2025, issued under section 70607 of Public Law 119-21. Source of the 140,803 and 296,531 return figures, the statement that Direct File was less than 0.5% of approximately 146 million returns filed, the cost table giving 31.8 million dollars and 225.85 per return for tax year 2023 and 41 million dollars and 138.27 per return for tax year 2024, the roughly 32 million eligible tax units, and the four steps in Section V including the suspension of Direct File. Note that the executive summary lists five unnumbered actions, so the step count depends on which part of the report you read.<\/li>\n<\/ol>\n<h3 id=\"data-and-research\">Data and research<\/h3>\n<ol>\n<li><a href=\"https:\/\/www.irs.gov\/newsroom\/filing-season-statistics-for-week-ending-may-1-2026\" target=\"_blank\" rel=\"noopener\">Filing season statistics for week ending May 1, 2026<\/a> &#8211; Internal Revenue Service. Compares 2 May 2025 with 1 May 2026. Source of all seven figures in the season table.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/newsroom\/filing-season-statistics-for-week-ending-may-3-2024\" target=\"_blank\" rel=\"noopener\">Filing season statistics for week ending May 3, 2024<\/a> &#8211; Internal Revenue Service. Source of the 2023 and 2024 professional and self-prepared e-filing volumes used in the four-year share comparison and the 1.4 percentage point growth gap.<\/li>\n<li><a href=\"https:\/\/www.irs.gov\/tax-professionals\/return-preparer-office-federal-tax-return-preparer-statistics\" target=\"_blank\" rel=\"noopener\">Return Preparer Office federal tax return preparer statistics<\/a> &#8211; Internal Revenue Service, as of 1 July 2026. National totals only. No country breakdown is published.<\/li>\n<li><a href=\"https:\/\/www.bls.gov\/ooh\/business-and-financial\/accountants-and-auditors.htm\" target=\"_blank\" rel=\"noopener\">Accountants and Auditors, Occupational Outlook Handbook<\/a> &#8211; U.S. Bureau of Labor Statistics, page last changed 28 August 2025. Median pay 81,680 dollars in May 2024, 1,579,800 jobs in 2024, 5% growth and an employment change of 72,800 over 2024 to 2034, and about 124,200 openings a year.<\/li>\n<li><a href=\"https:\/\/www.journalofaccountancy.com\/issues\/2024\/nov\/offshoring-for-cpa-firms-the-hows-and-whys\/\" target=\"_blank\" rel=\"noopener\">Offshoring for CPA firms: The hows and whys<\/a> &#8211; Journal of Accountancy, November 2024. Source of the AICPA 2023 National Management of an Accounting Practice survey figures: of more than 1,100 firms, 25% outsourced offshore, about 30% outsourced domestically, and 12% planned to start offshoring. Carries no cost or rate figures.<\/li>\n<li><a href=\"https:\/\/www.journalofaccountancy.com\/news\/2025\/oct\/the-accounting-graduate-pipeline-where-do-things-stand\/\" target=\"_blank\" rel=\"noopener\">The accounting graduate pipeline: Where do things stand?<\/a> &#8211; Journal of Accountancy, October 2025, reporting the AICPA 2025 Trends report. The 55,152 graduates in 2023-24, down 6.6%.<\/li>\n<li><a href=\"https:\/\/www.journalofaccountancy.com\/news\/2026\/jun\/student-enrollment-in-accounting-continues-to-rise\/\" target=\"_blank\" rel=\"noopener\">Student enrollment in accounting continues to rise<\/a> &#8211; Journal of Accountancy, 9 June 2026, reporting National Student Clearinghouse data. Spring 2026 enrolment of 281,992, up 5.7%. Replaces the spring 2025 figure of about 266,500.<\/li>\n<li><a href=\"https:\/\/www.thomsonreuters.com\/en-us\/posts\/tax-and-accounting\/tax-firm-leadership-strategies\/\" target=\"_blank\" rel=\"noopener\">Racing forward: Tax firm leadership strategies for the era of AI, advisory and private equity<\/a> &#8211; Thomson Reuters Institute, 3 October 2025. Source of the statement that offshoring and outsourcing remain in the toolkit while the hiring mix shifts from emergency capacity to structured resourcing. The widely repeated &#8220;separate production from advisory&#8221; phrasing is not from Thomson Reuters. It comes from an outsourcing provider&#8217;s marketing page.<\/li>\n<li><a href=\"https:\/\/www.thomsonreuters.com\/en-us\/posts\/tax-and-accounting\/state-of-tax-professionals-report-2026\/\" target=\"_blank\" rel=\"noopener\">2026 State of Tax Professionals Report<\/a> &#8211; Thomson Reuters Institute, 9 June 2026, more than 600 respondents worldwide.<\/li>\n<li><a href=\"https:\/\/nsacct.org\/wp-content\/uploads\/2025\/09\/2024-Profit-and-Practice-Report-Summary.pdf\" target=\"_blank\" rel=\"noopener\">2024 Profit and Practice Report Summary<\/a> &#8211; National Society of Accountants, 183 participants, mostly independent practitioners at firms with fewer than three partners. Form 1040 with itemised deductions at 300 to 600 dollars and Form 1120 at 750 to 1,250 dollars. The median hourly figures of 60 dollars for principals, 53 for bookkeepers and 45 for support staff are reported under compensation and wages, so they are what firms pay staff, not what they bill clients.<\/li>\n<li><a href=\"https:\/\/www.tigta.gov\/sites\/default\/files\/reports\/2026-03\/2026408006fr.pdf\" target=\"_blank\" rel=\"noopener\">Direct File participation in Filing Season 2025<\/a> &#8211; Treasury Inspector General for Tax Administration, report 2026-408-006. The 751,000 registrations of which 59% did not submit a return, the more than 32 million eligible taxpayers, and the 61.2 million dollar estimate against 16.2 million dollars actually spent.<\/li>\n<li><a href=\"https:\/\/www.tigta.gov\/sites\/default\/files\/reports\/2025-08\/2025408015fr.pdf\" target=\"_blank\" rel=\"noopener\">Direct File pilot costs<\/a> &#8211; Treasury Inspector General for Tax Administration, report 2025-408-015. At least 33.4 million dollars spent to develop the pilot.<\/li>\n<li><a href=\"https:\/\/oversight.gov\/sites\/default\/files\/documents\/reports\/2024-10\/2024400067fr.pdf\" target=\"_blank\" rel=\"noopener\">Free File participation<\/a> &#8211; Treasury Inspector General for Tax Administration, report 2024-400-067. Free File take-up by processing year: 4% of eligible taxpayers in 2020 and 2021, 2% in 2022 and 2023, 3% in 2024, and the eligible population falling from 108 million in 2021 to 85 million in 2024.<\/li>\n<li><a href=\"https:\/\/oversight.gov\/sites\/default\/files\/documents\/reports\/2020-02\/202040009fr.pdf\" target=\"_blank\" rel=\"noopener\">Free File usage in the 2019 filing season<\/a> &#8211; Treasury Inspector General for Tax Administration, report 2020-40-009, issued 3 February 2020. More than 14 million taxpayers eligible for Free File in the 2019 filing season may have paid to file instead.<\/li>\n<\/ol>\n<h3 id=\"secondary-sources\">Secondary sources<\/h3>\n<ol>\n<li><a href=\"https:\/\/federalnewsnetwork.com\/it-modernization\/2025\/11\/irs-direct-file-will-not-be-available-in-2026-agency-tells-states\/\" target=\"_blank\" rel=\"noopener\">IRS tells states Direct File &#8216;will not be available&#8217; in 2026<\/a> &#8211; Federal News Network, published 5 November 2025. Reports that the IRS emailed the 25 partner states &#8220;on Monday,&#8221; which is 3 November 2025, and quotes both phrases used in this article.<\/li>\n<li><a href=\"https:\/\/www.thetaxadviser.com\/news\/2025\/nov\/irs-ends-direct-file-shifts-focus-to-free-file-upgrades-and-private-sector\/\" target=\"_blank\" rel=\"noopener\">IRS ends Direct File, shifts focus to Free File upgrades and private sector<\/a> &#8211; The Tax Adviser, published 6 November 2025, reporting the remarks Bessent made on 5 November 2025.<\/li>\n<li><a href=\"https:\/\/fedscoop.com\/irs-cost-to-run-direct-file\/\" target=\"_blank\" rel=\"noopener\">IRS overestimated Direct File costs last year by $45 million<\/a> &#8211; FedScoop, reporting the Treasury Inspector General for Tax Administration audit.<\/li>\n<li><a href=\"https:\/\/www.nextgov.com\/digital-government\/2026\/02\/senators-demand-know-irs-path-forward-following-end-direct-file\/411421\/\" target=\"_blank\" rel=\"noopener\">Senators demand to know the IRS&#8217; path forward following the end of Direct File<\/a> &#8211; Nextgov\/FCW, February 2026. The Warren and King letter of February 2026.<\/li>\n<li><a href=\"https:\/\/www.cpajournal.com\/2025\/08\/26\/considerations-for-tax-return-preparers-outsourcing-overseas\/\" target=\"_blank\" rel=\"noopener\">Considerations for Tax Return Preparers Outsourcing Overseas<\/a> &#8211; The CPA Journal, 26 August 2025. Consent mechanics, the masking and safeguard options in practice, and the AICPA Privacy Management Framework.<\/li>\n<li><a href=\"https:\/\/www.thetaxadviser.com\/issues\/2024\/jan\/the-many-implications-of-sec-7216\/\" target=\"_blank\" rel=\"noopener\">The many implications of Sec. 7216<\/a> &#8211; The Tax Adviser, January 2024. Practitioner treatment of the consent rules and of outsourcing overseas.<\/li>\n<li><a href=\"https:\/\/codeforamerica.org\/news\/making-state-tax-filing-easy-with-fileyourstatetaxes\/\" target=\"_blank\" rel=\"noopener\">Making State Tax Filing Easy with FileYourStateTaxes<\/a> &#8211; Code for America. The state companion tool, which closed on 31 October 2025 and was not renewed for 2026.<\/li>\n<\/ol>\n<hr>\n<p><em>This article is for informational and educational purposes only and does not constitute professional, financial, legal, or tax advice. Obligations under section 7216 of the Internal Revenue Code sit jointly with the US firm making a disclosure and the preparer receiving it, and the correct consent language depends on facts specific to each engagement. US tax rules and IRS guidance change frequently. Consult a qualified US tax professional before acting on any compliance decision, and take Indian legal advice separately on data protection obligations that apply to your own operations.<\/em><\/p>\n\n\n\n<script type=\"application\/ld+json\">\n{\n  \"@context\": \"https:\/\/schema.org\",\n  \"@type\": \"FAQPage\",\n  \"mainEntity\": [\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Is IRS Direct File available in 2026?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"No. The IRS told its 25 partner states on 3 November 2025 that Direct File \\\"will not be available in Filing Season 2026,\\\" and Treasury Secretary Scott Bessent confirmed the closure to reporters at the White House on 5 November 2025. No launch date has been set for any future season.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Why did the IRS end Direct File?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"The stated reason was low usage and cost. Direct File accepted 296,531 tax year 2024 returns, which Treasury describes as less than 0.5% of roughly 146 million returns filed and which works out at about 0.2%. Treasury puts the cost for that year at a minimum of 41,000,000 dollars, or at least 138 dollars per accepted return, following 31,800,000 dollars and about 226 dollars a return for the tax year 2023 pilot. Bessent said the private sector could do the job better.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Is Direct File coming back?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"The IRS has stated no launch date. Treasury's Report on the Replacement of Direct File, published 2 October 2025, recommends strengthening Free File rather than rebuilding a government filing tool. Congress mandated the study under section 70607 of Public Law 119-21, with 15,000,000 dollars and a target of free filing for up to 70% of taxpayers, but no replacement has been launched.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"What is the IRS Free File income limit for 2026?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Adjusted gross income of 89,000 dollars or less for the 2025 tax year. Eight trusted partners participate, and each sets its own further conditions on age, income, state residency and military status, so meeting the programme limit does not guarantee eligibility for a specific partner's product.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Is Free File going away too?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"No. The IRS extended the Free File agreement for five years on 22 May 2024, running through October 2029. Treasury's replacement report recommends strengthening it further.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"What can a taxpayer use instead of Direct File?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"IRS Free File for adjusted gross income of 89,000 dollars or less, Free File Fillable Forms at any income level, MilTax for eligible members of the military community covering a federal return and up to three state returns, and the Volunteer Income Tax Assistance and Tax Counseling for the Elderly programmes for those who qualify.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Did ending Direct File increase work for paid tax preparers?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Not measurably. In the week ending 1 May 2026, returns e-filed by tax professionals stood at 74,678,000, up 0.3% on 2025, while self-prepared returns stood at 65,557,000, up 1.7%. The relationship between those two growth rates moves around from year to year in both directions: self-preparation grew faster in 2024, professional preparation grew faster in 2025 when Direct File was at its largest, and self-preparation grew faster again in 2026. There is no step change at the point Direct File closed.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Is it legal for a US firm to send tax returns to India for preparation?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Yes, subject to section 7216 of the Internal Revenue Code. The US preparer must obtain the taxpayer's written consent, signed and dated before the disclosure, in the form specified by Revenue Procedure 2013-14. Separate and stricter rules apply to the taxpayer's social security number, which is covered in the next answer.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Can a taxpayer's social security number be sent to a preparer outside the United States?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Only under a specific exception. Under 26 CFR 301.7216-3(b)(4), a preparer within the United States may not obtain consent to disclose a Form 1040 series taxpayer's social security number to a preparer located outside the United States. The exception requires the disclosure to be made through an adequate data protection safeguard and verified in the consent request, and Revenue Procedure 2013-14 section 5.07 requires both preparers to maintain such a safeguard, at the time consent is obtained and when the disclosure is made. Otherwise the number must be redacted or otherwise masked first. Note that the United States includes its territories and possessions for this purpose, so a preparer in Puerto Rico or Guam is not \\\"outside\\\" it.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"What is a Form 7216 consent?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"There is no Form 7216. Section 7216 is a criminal statute in the Internal Revenue Code. The document people mean is a consent to disclose tax return information, drafted by the US firm to the mandatory content and format requirements in Revenue Procedure 2013-14, section 5.04.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Can someone in India get a PTIN?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Yes. A person who is not a US citizen or resident alien and cannot obtain a US social security number files Form W-12 supported by Form 8946, by mail or online with uploaded documents. Two current government-issued documents proving identity and foreign status are required, at least one with a photograph. Only preparers with a non-US address may file Form 8946, and the IRS asks for six weeks of processing time. Note the caution printed on Form 8946: a foreign preparer residing outside the United States who obtains a PTIN without a social security number is not authorised to prepare returns in the United States for compensation.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Do I need a PTIN if I do not sign the returns?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Yes, if you prepare all or substantially all of a return for compensation. The IRS states that non-signing preparers are still required to have a PTIN, even though there is no plan to add them to the paid preparer section of the return.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Can a non-US resident become an enrolled agent?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Circular 230 sections 10.4 and 10.5 set out the conditions for enrolment and impose no citizenship or residency requirement, and neither does the IRS's enrolled agent guidance. The credential is earned by passing a three-part examination covering individual and business returns, or through qualifying past IRS employment. Applicants must be at least 18 and hold a valid PTIN. Continuing education is 72 hours per three-year cycle with a minimum of 16 hours each year, two of them on ethics.\"\n      }\n    },\n    {\n      \"@type\": \"Question\",\n      \"name\": \"Will AI replace offshore tax preparation work?\",\n      \"acceptedAnswer\": {\n        \"@type\": \"Answer\",\n        \"text\": \"Software vendors describe themselves as automating document extraction, transaction categorisation, anomaly flagging and workpaper drafting, and describe research, judgment and quality review as remaining human. High-volume data entry on simple returns is the most exposed task. Reconciliation, multi-state and business returns, notice response and work requiring a credentialled signature are less so.\"\n      }\n    }\n  ]\n}\n<\/script>\n\n\n<style>.ls-cta-br{display:none;}@media(max-width:768px){#ls-floating-cta{padding:8px 12px !important;}#ls-floating-cta .ls-wrap{flex-direction:column !important;align-items:center !important;gap:8px !important;}#ls-floating-cta a{font-size:11px !important;padding:8px 16px !important;white-space:normal !important;text-align:center !important;max-width:90vw !important;}.ls-cta-br{display:block !important;}}<\/style><div id=\"ls-floating-cta\" style=\"position:fixed;bottom:0;left:0;right:0;z-index:9999;background:#0f0f0f;border-top:3px solid #2941BA;padding:12px 20px;box-shadow:0 -4px 20px rgba(0,0,0,0.3);\"><div class=\"ls-wrap\" style=\"display:flex;align-items:center;justify-content:center;gap:24px;\"><div style=\"display:flex;align-items:center;gap:10px;\"><a href=\"https:\/\/growthx.lawsikho.com\/f\/14may-id-30day-lpcore1?p_source=id2_blog_sa&#038;p_cta=sa-id-irs-direct-file-free-file-2026\" onclick=\"gtag(&#039;event&#039;,&#039;cta_click&#039;,{send_to:&#039;G-B23VVGPQ92&#039;,p_source:&#039;id2_blog_sa&#039;,p_cta:&#039;sa-id-irs-direct-file-free-file-2026&#039;});\" target=\"_blank\" rel=\"noopener\" style=\"display:inline-block;background:#2941BA;color:#fff;padding:11px 20px;border-radius:7px;font-size:13px;font-weight:700;text-decoration:none;white-space:nowrap;\">Become a board-ready Independent Director in 30 days \u2014<br class=\"ls-cta-br\"> Rs. 100 \u2192<\/a><button onclick=\"document.getElementById('ls-floating-cta').style.display='none'\" style=\"background:none;border:none;color:#555;font-size:18px;cursor:pointer;padding:4px;line-height:1;position:absolute;right:16px;\">\u2715<\/button><\/div><\/div><\/div>\n","protected":false},"excerpt":{"rendered":"<p>There is no IRS Direct File 2026. The IRS ended it in November 2025. Free File runs to 2029. What that actually changes for offshore tax-prep work<\/p>\n","protected":false},"author":35,"featured_media":4678,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[798,745],"tags":[822,1446,1447,1444,898,1448,1445,1438],"class_list":["post-4677","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-us-accounting-tax","category-accounting-and-tax","tag-enrolled-agent","tag-irs-direct-file-2026","tag-irs-free-file","tag-offshore-tax-preparation","tag-ptin","tag-remote-accounting","tag-section-7216","tag-us-tax-compliance"],"_links":{"self":[{"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/posts\/4677","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/users\/35"}],"replies":[{"embeddable":true,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/comments?post=4677"}],"version-history":[{"count":2,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/posts\/4677\/revisions"}],"predecessor-version":[{"id":4690,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/posts\/4677\/revisions\/4690"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/media\/4678"}],"wp:attachment":[{"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/media?parent=4677"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/categories?post=4677"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/skillarbitra.ge\/blog\/wp-json\/wp\/v2\/tags?post=4677"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}