Mehta files 137 individual returns in tax season 2026 from a strip-mall office in Tulsa. He prepares them on commercial software, prints them, hands the client a paper copy, and mails the originals to Austin. The IRS flags 126 of them. As a preparer who filed well over 11 covered returns, Mehta was required to e-file every one, and paper-filing them without a documented Form 8948 exception puts him out of compliance with the e-file mandate.
Anyone who wants to originate electronic returns for taxpayers must be an Authorized IRS e-file Provider. The application is a three-step administrative gate, all of it free.
Step One. e-Services registration. Each principal, responsible official, and contact must create an e-Services account at IRS.gov. Identity proofing uses ID.me (or the legacy Secure Access process). Applicants supply name, SSN, date of birth, filing status of last return, AGI from that return, mobile number for two-factor authentication, and government photo ID.
Step Two. IRS e-file Application. Once inside e-Services, the firm completes the IRS e-file Application online. The application identifies:
Common mistakes
- Counting only personally signed returns toward the 11-return threshold. The mandate aggregates firm-wide covered returns. Three preparers each signing 5 returns triggers the mandate at 15 firm returns. Trap answer: "Each preparer counts separately, so 5 returns is below the threshold."
- Treating verbal taxpayer preference as a waiver from e-file. Form 8948 box 1 requires the taxpayer to sign a written statement electing to paper-file. Verbal request is not enough; without a signed written election the paper filing violates the §6011(e)(3) mandate. Trap answer: "Client said paper, so no mandate violation."
- Mailing Form 8879 to the IRS. Form 8879 is retained by the ERO in firm records for 3 years. It is NEVER mailed. Form 8453 is the form mailed to transmit paper attachments. Trap answer: "Mail Form 8879 to Austin within 3 days."
Bottom line
- E-file mandate (IRC §6011(e)(3)): any preparer reasonably expecting to file 11 or more covered returns firm-wide in a calendar year must e-file every one; the mandate has no per-return dollar penalty, but paper filing requires a documented Form 8948 exception...
- Exceptions documented on Form 8948 attached to the paper return; its six boxes cover taxpayer written choice, hardship waiver, religious objection, uncorrectable rejection, unsupported form, and other.
- EFIN application: create e-Services account, submit IRS e-file Application, name a Principal and Responsible Official, pass suitability plus fingerprinting unless credentialed; no user fee; allow about 45 days.
- ERO duties (Pub 1345): verify taxpayer identity, originate the return, obtain Form 8879 signature before transmission, retain it 3 years; Form 8879 is never mailed to the IRS.
Exam shortcut
"Mandate or exception?" First ask if the firm files 11+ covered returns. If yes, every covered return must e-file unless one of Form 8948's six boxes applies and is documented; verbal taxpayer preference is NOT a box without the signed written statement. "Form 8879 or Form 8453?" 8879 = signature authorization, kept by the ERO, never mailed.
The full lesson (about 4,922 words, 33 min read) adds 2 worked examples, all 6 common mistakes, a self-check, free in the app.
Learning objectives
- 3
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