IRS Fingerprinting: Who Needs It, the Appointment, and Appeals

IRS fingerprinting is a background-screening step required for three groups: applicants for authorized IRS e-file provider status who don’t hold a qualifying professional credential, IRS employees, and IRS contractors with access to federal tax systems or sensitive taxpayer data. Fingerprints are captured electronically through Live Scan at an IRS-authorized vendor and run against FBI criminal history databases as part of a broader suitability check. If you’re a tax preparer with a PTIN and nothing more, this generally doesn’t apply to you unless you’re separately applying to become an e-file provider.

Who Actually Has To Be Fingerprinted

E-File Provider Applicants Without a Credential

If you’re applying to become an authorized IRS e-file provider, you’ll be fingerprinted only if you can’t provide a qualifying professional credential on the application. Attorneys, certified public accountants, and enrolled agents who enter their current professional status information are exempt from the fingerprinting requirement.¹ Enrolled retirement plan agents and enrolled actuaries are also expected to be exempt.²

The suitability screening that surrounds the fingerprint check can include a credit check, a tax compliance check, a criminal background check, and a review of any prior e-file violations.³

IRS Employees

Every new IRS hire completes a background investigation that includes fingerprint submission, regardless of position level. A favorable result is required before the employee is given access to facilities, IT systems, or taxpayer information. Higher-risk or national security positions get a more extensive investigation on top of that.

IRS Contractors

Contractors and vendor employees who need staff-like access to IRS facilities, IT systems, or sensitive information have to be fingerprinted and pass a background investigation. Contractors whose work will exceed 180 calendar days in a year need a favorable FBI fingerprint check and a review of investigative paperwork before they can begin. Even short-term contractors under 180 days need a favorably adjudicated fingerprint check before starting.⁴

Who Doesn’t Need To Be Fingerprinted

A few boundaries are worth being explicit about, because the requirement is narrower than many people assume.

Fingerprinting is tied to the e-file provider application, not to the Preparer Tax Identification Number. PTIN registration and renewal don’t involve biometric screening. Credentialed preparers (attorneys, CPAs, enrolled agents) who list their current credential on the e-file application don’t get fingerprinted either. And applicants who live and work outside the United States are generally exempt from the fingerprinting requirement for tax professional programs like the e-file provider application.² International IRS contractor employees may have alternative procedures coordinated through their contracting officer.

Scheduling the Appointment

E-file provider applicants schedule through a link on the e-file application summary page after submitting the application, using the IRS-authorized fingerprinting vendor.³ IdentoGO by IDEMIA is the primary vendor providing identity-related fingerprinting services for federal programs nationwide.

IRS contractor employees are usually sponsored through the USAccess enrollment system. If a USAccess station isn’t readily available, Live Scan is offered at certain IRS offices and other IRS-approved locations. Traditional ink-and-roll fingerprint cards are still used in rare cases.⁴

What To Bring

You need two forms of identification, at least one of which must be a government-issued photo ID. A state driver’s license, U.S. passport, or military ID satisfies the photo requirement. The second document can be anything listed on the back of Form I-9, such as a Social Security card or birth certificate.⁵ The name and date of birth on your IDs must exactly match what’s on your application. A mismatch will cause the FBI to reject the submission outright.

You’ll also need the correct service code, sometimes called “Reason for Fingerprinting,” which links your prints to the right investigation request. For e-file applicants, this comes through the scheduling link on the application summary page. Fees vary by vendor and location and are generally paid to the service provider at the appointment. For contractors, the cost of fingerprinting outside an IRS office or approved enrollment station falls on the contractor or their employer.⁴

What Happens at the Appointment

The technician checks your identity documents and confirms your biographical data and service code before starting the capture. The Live Scan device electronically captures all ten fingerprints and checks image quality in real time, which is a real advantage over the old ink-and-card method that often produced illegible prints not discovered until weeks later at the FBI.

Once capture is complete, the encrypted data transmits directly to the FBI’s Criminal Justice Information Services Division for processing against national criminal databases. You’ll get a receipt with a transaction control number. Hold on to it. That number is your proof of submission and the only way to check status later.

The appointment itself typically runs 15 to 20 minutes if nothing goes wrong.

If the FBI Rejects Your Prints

Rejections for poor image quality happen more often than you’d expect, particularly for people with worn fingerprints from manual labor, aging, or certain skin conditions. If your prints come back rejected, you’ll get a notice and need to return for a second capture. Many vendors don’t charge for the re-scan when the first rejection was a quality issue.

If prints get rejected multiple times, the investigating agency may accept an alternative identity verification method or request a manual review. Don’t ignore a rejection notice. The delay cascades into your suitability determination and can hold up an e-file application or an employment start date.

How the Results Feed Into the Suitability Decision

The fingerprint check is one piece of a larger evaluation. For e-file providers, the IRS layers in a credit check, tax compliance check, criminal background check, and review of prior e-file compliance issues. The full application review can take up to 45 days from submission.³

For employees and contractors, the review is more extensive. The FBI fingerprint results often come back within 48 to 72 hours when there’s no matching criminal history, but the full determination takes longer because it also incorporates the other investigative elements.

What Can Lead to an Unfavorable Determination

Federal regulation at 5 CFR 731.202 lists the factors that can support an unfavorable suitability decision:⁶

Criminal conduct, though severity and recency matter.
Dishonest conduct, including fraud, misrepresentation, or deceptive behavior.
False statements on your application or during the investigation.
Misconduct in employment, such as a pattern of workplace problems or negligence.
Substance abuse, meaning excessive alcohol use or illegal drug use without evidence of rehabilitation.
Violent conduct.
Statutory bars — any law that specifically prevents employment in the position.

Evaluators are required to weigh each factor against the nature of the position, the seriousness of the conduct, how recent it was, and any evidence of rehabilitation. A decades-old misdemeanor is treated differently than a recent felony. If information in your credit report could support an unfavorable decision, the IRS must notify you.⁷

A failed suitability check means an employee or contractor won’t be authorized to access federal tax information. For an e-file provider applicant, it means the application is denied and you can’t electronically transmit returns through the IRS system.

Fixing Errors and Appealing Decisions

Correcting Your FBI Criminal History Record

If the fingerprint results turn up criminal history information that’s inaccurate or incomplete, you can challenge the FBI’s Identity History Summary at no cost. Your challenge must clearly identify the information you believe is wrong and include supporting documentation, such as court records showing a dismissal, expungement, or correction. The FBI processes challenges in the order received, with an average response time of about 45 days.⁸ For state-level arrest records, contact the state identification bureau where the offense occurred. Federal arrest data is only removed at the request of the submitting agency or by federal court order specifically directing expungement.

Appealing an Unfavorable IRS Decision

If the IRS proposes an unfavorable suitability action against you, it must notify you in writing at least 30 days before the action takes effect. The notice has to explain the reasons and your right to respond. You then have 30 days to submit a written answer, along with any supporting evidence or affidavits, and you can hire a representative at your own expense. The IRS must issue a final written decision within 30 days of reviewing your response.⁷

If the final decision goes against you, you can appeal to the Merit Systems Protection Board. The Board reviews whether the charges are supported by a preponderance of the evidence. If it sustains fewer than all charges, the case goes back to the IRS to reconsider whether the action is still appropriate based only on the charges that held up.⁹

1
Internal Revenue Service. Tax Pros Can Apply To Be an IRS Authorized E-File Provider in a Few Simple Steps
2
IRS.gov. IRS Issues Guidance to Further Implement Return Preparer Oversight
3
Internal Revenue Service. Become an Authorized E-File Provider
4
Internal Revenue Service. 10.23.2 Contractor Investigations
5
Internal Revenue Service. IRS HSPD-12 PIV Procedures Manual
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eCFR. 5 CFR Part 731 – Suitability and Fitness
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Internal Revenue Service. 6.731.1 Suitability Determinations for Employment
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Federal Bureau of Investigation. Identity History Summary Checks Frequently Asked Questions
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eCFR. 5 CFR 731.501 – Appeal to the Merit Systems Protection Board