If you are preparing U.S. returns for pay and you cannot get a Social Security Number, Form 8946 is the small form that decides whether your PTIN application glides through or stalls. Let’s make sure you clear it with confidence.
Key Takeaways
- Form 8946 is for foreign preparers with a non U.S. address who cannot obtain an SSN, and need to verify identity to receive a PTIN. Use it only if you are not a U.S. citizen or resident and you are ineligible for an SSN.
- You can submit the identity documents online through your PTIN account or mail Form W 12 and Form 8946 with supporting documents to the IRS PTIN Processing Center. Typical review time is about 6 weeks.
- A current passport works as the only stand alone ID. If you do not have a valid passport, submit two acceptable documents, for example a foreign driver’s license and a national ID card, with proper notarization.
- The current form shows “Form 8946, Rev. October 2023” with OMB control number 1545 2189. The information collection was extended in 2024, so always confirm you are using the latest version.
- Only preparers with a foreign, non U.S. address may file Form 8946. If you use a U.S. address, the application is rejected.
What Form 8946 Is, and When You Should Use It
Form 8946 is the IRS’s identity check for foreign tax return preparers who cannot get a U.S. Social Security Number. You file it so the IRS can issue a PTIN, which you must have before you prepare tax returns for compensation. If you already have or can get an SSN, do not use this form. Apply for your PTIN with your SSN instead.
In plain language, use Form 8946 if all of the following are true:
- You are a foreign person under U.S. tax law, not a U.S. citizen and not a resident alien.
- You do not have, and are not eligible to obtain, an SSN.
- You maintain a foreign, non U.S. physical address.
- You are applying for a PTIN so you can prepare returns for compensation.
Tip: If the Social Security Administration later issues you an SSN, you must update your PTIN account to add it. Keep that in your compliance checklist.
Who Should Not Use Form 8946
- U.S. citizens or resident aliens, because you are eligible for an SSN.
- Anyone with a U.S. mailing or physical address, because Form 8946 requires a foreign address.
- Anyone with an SSN application pending. Wait for the SSA decision, then proceed accordingly.
What You Need Before You Start
Gather your identity and foreign status documents first, then complete the form. Doing it in this order prevents mismatches and avoids back and forth with the IRS.
- Primary ID, best choice, a current passport, the only stand alone document.
- If you do not have a valid passport, provide two current government issued documents that together prove identity and foreign status, for example a foreign driver’s license plus a national ID card, and at least one must include your photo.
- Original documents or notarized copies, notarized by a foreign notary with authority in the local jurisdiction or by U.S. embassy or consular staff. The notary must compare copies to the originals.
Also have your exact legal name, date of birth, and non U.S. physical address ready to match what appears on your documents. If your birth name differs from your current name, you will enter both. Applications that miss these small details often get delayed.
Keep duplicates of everything you submit. If you mail originals, the IRS returns them to the address on your Form 8946, but copies are not returned.
How to Apply, Online or by Mail
You have two routes, and you should choose based on how quickly you can assemble clear documents.
- Online, preferred. Create or sign in to your PTIN account, then during the PTIN application you will be prompted to complete and upload Form 8946 and your supporting documents. Watch file types and clarity.
- By mail. Complete Form W 12 and Form 8946, attach originals or notarized copies of your documents, and mail to: IRS Tax Professional PTIN Processing Center, PO Box 380638, San Antonio, TX 78268. Processing typically takes about 6 weeks.
During peak season, plan for delays. The IRS FAQ confirms you can upload documents in your online PTIN account and notes the same 6 week review window. After approval, you will be notified to log in and finish the PTIN application.
Caution: Only preparers with a foreign address may file this form. If you enter a P.O. Box for the non U.S. address, the application is rejected. Use your physical address abroad.
Step by Step, Completing Form 8946 Without Errors
Follow this sequence and double check each item against your ID.
- Name and address
- Enter your full legal name exactly as it appears on your documents.
- Enter your complete non U.S. physical address, not a P.O. Box.
- Birth information
- Provide date of birth, country of birth, and, if different, name at birth. Match formats on your ID.
- Foreign status and identification
- Check the document types you are submitting, for example, Passport or National ID Card.
- Remember, a valid passport alone is enough, otherwise submit two approved documents, properly notarized.
- Signature
- Sign and date under penalties of perjury. Unsigned forms are returned, and the clock restarts.
Important note: If you live and work outside the U.S. and obtain a PTIN without an SSN, you are not authorized to prepare returns in the United States for compensation. This statement appears on the form and matters for your practice planning.
Common Errors That Slow PTIN Approvals
- Blurry or cropped ID scans that hide a face, number, or expiration date.
- Names, punctuation, or birth dates that do not match the ID exactly.
- Using a U.S. or P.O. Box address instead of a non U.S. physical address.
- Uploading the wrong document types or missing notarization on copies.
- Forgetting to sign and date the form.
If your application stalls, check your PTIN account messages first. The IRS often asks for clearer scans or specific pages, and quick responses keep you in the current review batch.
Where Accountably can help, if your firm uses offshore or international staff, formalize a document checklist with sample image quality, naming rules, and notarization instructions. This saves cycles during busy season and avoids last minute resubmissions. Use it as part of your onboarding SOPs, not as an afterthought.
OMB Control Number 1545 2189, What It Means and How To Check Currency
You will see the OMB control number 1545 2189 on Form 8946. This number identifies the official information collection approved for the IRS. The form currently shows “Rev. October 2023.” The Office of Management and Budget extended this collection in 2024, which signals the IRS is authorized to keep using it. Before you file, confirm you have the latest revision on the IRS page for Form 8946.
Why you should care
- Using the current version helps you avoid rejects tied to stale instructions.
- The OMB listing also links to the Supporting Statement and regulatory materials, which outline what documents the IRS expects and typical time burdens.
Quick check: If your PDF says “Form 8946, Rev. October 2023,” you are on a current track. If you find an older September 2010 version floating around in a file share, replace it.
Documents, Notarization, and Upload Tips That Actually Work
Here is the checklist my team uses with international preparers applying for PTINs.
- Use a current passport whenever possible, it is the lone stand alone document. If you cannot submit a passport, line up two acceptable documents and make sure at least one has your photo.
- If you upload, scan at a resolution that keeps text crisp, and avoid filters that distort contrast.
- If you mail, send notarized copies rather than originals to reduce risk. The IRS will return originals, copies are not returned.
- For notarization abroad, use a local notary authorized in that jurisdiction or a U.S. embassy or consulate. Ensure the notary sees the original and stamps or signs the copy.
- Name your files logically, for example, “Passport_Lastname_Firstname.pdf.” Small details speed review, especially during peak season.
Expect roughly 6 weeks from submission to approval. When approved, you will be notified to log in and complete your PTIN application.
Related Forms You Will See, and What They Actually Do
It is easy to mix up the supporting forms. Use this quick map to stay clear.
Fast Comparison
| Form | Primary purpose | Who uses it | How it relates to Form 8946 |
| 8946 | PTIN supplemental application for foreign preparers without an SSN, identity and foreign status verification | Foreign preparers with a non U.S. address who cannot get an SSN | The identity gate you clear before the PTIN is issued |
| W 12 | PTIN application and renewal | All preparers applying for or renewing a PTIN | If filing by mail, you send W 12 with 8946 and documents |
| 8948 | Preparer Explanation for Not Filing Electronically | Specified tax return preparers who must file a paper return for an allowed reason | Not an identity form, you attach it to a client’s paper return when an e file exception applies |
| 8453 | U.S. Individual Income Tax Transmittal for an IRS e file Return | Taxpayers or EROs to send specific paper attachments that the IRS cannot accept electronically | Not part of the PTIN process, used when a 1040 e file requires paper attachments |
| 1042 | Annual withholding return for U.S. source FDAP income of foreign persons | Withholding agents | Unrelated to PTINs, included here because it is often confused in search results |
Sources: IRS pages for Form 8948 and Form 8453, and IRS discussions of Form 1042 filings and due dates.
Important clarifications
- Form 8948 is not an identity form and not a PTIN application, it explains why a specific return is filed on paper. You attach it to the paper return when an exception to the e file mandate applies.
- Form 8453 is only a transmittal for certain attachments to an e filed 1040, do not mail W 2 or 1099 R with it.
- Form 1042 is a withholding agent’s annual return, due around March 15 for the prior year, with electronic filing required for many filers today. Check current instructions because dates and e file thresholds can change.
FAQ, Straight Answers
What is Form 8946?
It is the identity verification form a foreign preparer files to get a PTIN without an SSN. You submit it with acceptable ID documents, either online through your PTIN account or by mail with Form W 12, then finish the PTIN application after approval. Expect about 6 weeks for the review.
Can I upload my documents, or must I mail originals?
You can upload scans through your PTIN account. If you submit by mail, you may send notarized copies instead of originals. The IRS returns originals to the address on your Form 8946.
Do I qualify if I have a U.S. address?
No. Only preparers with a foreign, non U.S. address may file this form. A P.O. Box in place of a physical address causes rejection.
What is Form 8948 used for?
It documents why a specified tax return preparer files a particular return on paper, for example client choice, system reject that cannot be resolved, or an administrative exemption. Attach it to the paper return, it is not part of PTIN identity verification.
What is Form 8453 used for?
It is a transmittal for specific paper attachments to an electronically filed Form 1040. Use it only for the forms listed on the front of Form 8453.
What is Form 1042 used for?
It is the annual withholding return for U.S. source FDAP income paid to foreign persons, filed by withholding agents. The due date is generally March 15 for the prior year.
A Clean, Repeatable Workflow You Can Use Today
Here is a simple, reliable process to keep your PTIN application on track.
- Confirm eligibility
- Foreign person, no SSN eligibility, non U.S. address, paid preparer needing a PTIN.
- Gather documents
- Prefer a current passport. If not available, prepare two acceptable IDs and ensure notarization meets IRS standards.
- Complete Form 8946
- Match name and birth data exactly, check your document types, sign and date.
- Submit
- Upload through your PTIN account or mail with Form W 12 to the San Antonio PTIN Processing Center. Track your submission.
- Monitor and finish
- Watch for IRS messages, respond quickly, then complete your online PTIN application once approved. Typical review time is about 6 weeks.
Compliance note, The IRS updates forms and instructions. The pages cited here show last reviews in 2025, always check the latest IRS page for Form 8946 before you file.
Troubleshooting, What To Do If Something Goes Wrong
If you get a request for more information
- Recheck that your name, date of birth, and document numbers match the form.
- Replace any low contrast or cropped scans. Rescan in color, then compress without reducing clarity.
- Confirm notarizations include the notary’s stamp and any required signature.
If you used an outdated form
- Download the current revision that references OMB 1545 2189 and reflects the latest instructions. Re submit with corrected attachments. The information collection was extended in 2024, so the IRS continues to accept the current version.
If you are asked about e filing exceptions
- Remember, Form 8948 explains paper filing of a specific return, it is not your PTIN application. Keep a signed taxpayer choice statement if the client insists on paper.
Special Notes for International Firms and Teams
When your firm employs international staff who support U.S. tax preparation, SOPs are your friend. A few low friction practices make a real difference.
- Use a shared, version controlled checklist for Form 8946 submissions, including image standards and file naming.
- Store notarization guidance for each country where you hire, including embassy options, so no one scrambles at deadline.
- Centralize copies of approvals and submission confirmations, with access controls and audit trails.
If you are growing and want the offshore work to be disciplined, not chaotic, structure helps. At Accountably, we integrate trained offshore teams into firm workflows with SOP driven execution, standard workpapers, multi level reviews, and clear SLAs, which keeps identity, security, and documentation clean. Mentioning it once here is enough, the real goal is that you have a repeatable system you trust.
Final Checklist Before You Click Submit
- You are a foreign person with a non U.S. address and cannot get an SSN.
- Your documents are current, readable, and either original or properly notarized copies.
- Your name and birth data match your ID exactly.
- You signed and dated Form 8946.
- You uploaded through your PTIN account or mailed W 12 with 8946 to the San Antonio PTIN Processing Center, and you saved your confirmation.
- You blocked out 6 weeks for review and set reminders to check messages.
Conclusion
If you treat Form 8946 like a quick identity sprint, you get a smooth PTIN finish. Set up your documents, complete the form with exact matches, and submit through the route that fits your timeline. Keep your files tidy, answer IRS requests fast, and you will be ready to prepare returns for compensation with your PTIN in hand.
One last reminder, Confirm the current Form 8946 and instructions on the IRS site, look for Rev. October 2023 and OMB 1545 2189, and check updates before filing.
Sources
- Form 8946, Rev. October 2023, instructions, eligibility, online upload, mailing address, acceptable documents, foreign address requirement, processing time.
- IRS PTIN FAQ, upload option, acceptable documents, notarization standards, six week review, finish online. Page last updated August 14, 2025.
- OMB 1545 2189, Information Collection record, 2024 extension and supporting materials.
- About Form 8948, purpose and use.
- About Form 8453, transmittal purpose for e filed 1040 attachments.
- Discussion of Form 1042 and due dates.