24.1 Two Paths to EA (Exam vs. IRS Experience)
Key Takeaways
- Path 1: Pass all 3 parts of the Special Enrollment Examination (SEE) administered by PSI Services (PSI replaced Prometric on March 1, 2026).
- Path 2: 5 years of qualifying IRS experience in technical positions interpreting tax law.
- SEE Parts: Part 1 Individuals, Part 2 Businesses, Part 3 Representation/Practices/Procedures.
- 2026-2027 testing window: July 1, 2026 - February 28, 2027 (US domestic); March-April blackout for exam updates.
- Per-part fee: $317 ($66 IRS user fee + $251 PSI vendor fee, effective April 9, 2026); three parts total $951.
- Both paths require Form 23 ($140 fee), active PTIN, IRS suitability check (tax compliance + criminal background) handled by OPR.
Two Paths to Enrolled Agent Status
Why This Matters for the Exam
Understanding how one becomes an Enrolled Agent is foundational for Part 3. The exam tests your knowledge of the two paths, the SEE requirements, and the IRS experience alternative.
Exam Note: For the July 1, 2026 - February 28, 2027 testing window, you are tested on EA enrollment requirements and tax law as of December 31, 2025 (Tax Year 2025, post-OBBBA).
Vendor Transition (IMPORTANT): Prometric, LLC administered the SEE through February 28, 2026. PSI Services LLC took over as the IRS's SEE testing vendor on March 1, 2026. Every current candidate registers, schedules, pays, and tests through PSI — not Prometric.
Expect at least 2-3 questions on EA qualification paths.
Overview of the Two Paths
| Path | Method | Key Requirement |
|---|---|---|
| Path 1 | Special Enrollment Examination (SEE) | Pass all 3 parts within a 2-year integrated window (each individual part score is valid for 3 years, but all three must be completed within 2 years for enrollment) |
| Path 2 | IRS Experience | 5 years technical IRS experience |
Both paths require:
- IRS suitability check (tax compliance review + criminal background check) administered by the Office of Professional Responsibility (OPR).
- Form 23 application with $140 fee (submitted online via Pay.gov or by mail).
- Active PTIN (annual renewal fee $19.75 for 2026).
Path 1: Special Enrollment Examination (SEE)
The SEE is the most common path to becoming an Enrolled Agent. PSI Services administers the SEE on behalf of the IRS effective March 1, 2026 (replacing Prometric).
The Three Parts
| Part | Name | Content |
|---|---|---|
| Part 1 | Individuals | Individual income tax returns, filing requirements, income, deductions, credits |
| Part 2 | Businesses | Business entities, accounting periods, partnerships, corporations, trusts |
| Part 3 | Representation, Practices & Procedures | Circular 230, representation, ethics, IRS procedures |
Exam Specifications (2026-2027 Cycle)
| Specification | Detail |
|---|---|
| Questions per part | 100 multiple choice (85 scored + 15 unscored pretest) |
| Time per part | 3.5 hours |
| Passing score | Scaled score of 105 on a 40-130 scale (approx. 70-75% raw) |
| Per-part fee | $317 (effective April 9, 2026) — $66 IRS user fee + $251 PSI vendor fee |
| Total for 3 parts | $951 |
| Testing window (2026-2027) | July 1, 2026 - February 28, 2027 (US domestic) |
| Scheduling opens | May 1, 2026 (US domestic); September 1, 2026 (international) |
| International rollout | PSI began international testing July 1, 2026 |
| Closed period | March 1 - April 30 (exam updates — unchanged) |
Fee History (For Context)
| Period | Per-Part Fee | Notes |
|---|---|---|
| Pre-2024 | $206 | Prometric era |
| 2024-2025 | $259 / $267 | IRS user fee increases |
| Effective Apr 9, 2026 | $317 | $66 IRS user fee + $251 PSI vendor fee (Federal Register interim final rule) |
The 2-Year Completion Window
All three parts must be completed within a 2-year window for enrollment purposes (each individual part's passing score is valid for 3 years, but the integrated rule for completing all three is 2 years):
- The 2-year clock starts from the date you pass your first part.
- If you do not pass all three within 2 years, the oldest passed part is no longer credited toward enrollment.
- You can retake a part up to 4 times per testing window, with a mandatory 24-hour wait after a failed attempt before re-scheduling that same part.
- There is no lifetime limit on retakes — but you pay the $317 fee each time.
Example:
- Pass Part 1 on August 1, 2026.
- Must pass Parts 2 and 3 by July 31, 2028 for enrollment to be valid.
- If only Part 1 is passed by the deadline, you must retake Part 1.
Path 2: IRS Experience
Former IRS employees may qualify for enrollment based on technical experience.
Requirements
| Requirement | Detail |
|---|---|
| Years of experience | 5 years |
| Type of experience | Interpreting and applying tax code and regulations |
| Qualifying positions | Revenue Agent, Tax Law Specialist, Appeals Officer, etc. |
| SEE requirement | May request waiver (not automatic; OPR reviews qualifying experience) |
| Background check | Still required |
| Form 23 | Still required ($140 fee) |
Key Point: Not all IRS experience qualifies. The experience must be in technical tax positions involving interpretation of tax law.
Comparison: SEE vs. IRS Experience Path
| Factor | SEE Path | IRS Experience Path |
|---|---|---|
| Time to qualify | Variable (pass 3 exams) | 5 years IRS employment |
| Cost (exam fees) | $951 ($317 × 3 parts) | N/A |
| Form 23 fee | $140 | $140 |
| Background check | Required | Required |
| PTIN | Required ($19.75/yr) | Required ($19.75/yr) |
| Most common | Yes | No |
Real-World Scenario
Scenario: You passed Part 1 of the SEE on August 15, 2026 (PSI testing center, $317 fee). You pass Part 2 on January 10, 2027. When is the deadline to pass Part 3 for enrollment purposes?
- Answer: August 14, 2028 (2 years from passing Part 1 — the integrated completion window).
- Important: The 2-year window starts from your first passed part. Each individual part score remains technically valid for 3 years, but the IRS requires the three parts be completed within a 2-year span for enrollment.
On the Exam
Expect 2-3 questions on EA paths, typically:
- SEE Structure Questions: "How many parts does the SEE have?"
- Time Limit Questions: "Within what time frame must all SEE parts be passed for enrollment?"
- IRS Experience Questions: "How many years of IRS experience are required?"
- Vendor/Fee Questions: "Who administers the SEE?" or "What is the per-part SEE fee?"
The key is to remember: SEE = 3 parts, completed within 2 years for enrollment, $317 per part, PSI Services administers (post-March 2026). IRS = 5 years technical experience. Both require Form 23 ($140) and OPR suitability check.
How many parts does the Special Enrollment Examination have?
Who administers the SEE for the 2026-2027 testing window?
What is the per-part SEE fee effective April 9, 2026?
How many years of IRS experience are required for the alternative EA path?