Form 8948, Preparer Explanation for Not Filing Electronically, is the one-page form a paid tax preparer attaches to a paper return to tell the IRS why it wasn't e-filed. It's only used by specified tax return preparers, meaning preparers who reasonably expect to file 11 or more individual, estate or trust returns in a calendar year and are therefore required to e-file. You tick exactly one of six reasons, and the form goes in with the paper return.
Everything below comes from the IRS's Form 8948 (Rev. September 2018), which carries its own instructions on page 2, as of October 2026. The IRS still points to this revision for current filings.
Who has to file Form 8948
The rule hangs on two definitions in the form's instructions. A specified tax return preparer is a preparer who reasonably expects to file 11 or more covered returns during a calendar year. Covered returns are income tax returns of individuals, estates and trusts.
Here's the part many small firms miss: the count is for the firm as a whole, not each person. The IRS's own example is a firm with 2 preparers who each expect to file 6 returns. That's 12 returns in total, so both preparers are specified tax return preparers and both must e-file, even though neither one alone reaches 11.
If you're a taxpayer doing your own return, you never need this form. It belongs to the preparer, and you'll only see it if your preparer hands you a paper return with it attached.
What counts as the preparer filing
A return is treated as filed by the preparer if the preparer, or anyone in the firm, submits it to the IRS for the client, on paper or electronically. Dropping the client's return in a mailbox counts as filing it. Giving the client an addressed envelope, postage estimates or mailing instructions doesn't, as long as the client mails it themselves.
The six reasons, line by line
| Line | Reason | What you add |
|---|---|---|
| 1 | The taxpayer chose to file on paper | Nothing on the form, but keep the client's signed choice statement in your own records |
| 2 | The preparer has an approved hardship waiver | The waiver reference number and the date of the approval letter |
| 3 | The preparer belongs to a recognized religious group opposed to filing electronically | Nothing further |
| 4 | The return was rejected by IRS e-file and the reject couldn't be fixed | The reject code and the number of attempts to resolve it |
| 5 | The preparer's e-file software doesn't support a form or schedule on the return | The form or schedule numbers the software couldn't handle |
| 6a, 6b, 6c | Foreign preparer without an SSN, a preparer barred from e-file by an IRS sanction, or other documented technical problems | For 6c, a short description of what went wrong |
Only one box can be checked. The religious group exception on line 3 applies only to a group that has existed continuously since December 31, 1950, according to the instructions.
The taxpayer choice statement trap
Line 1 is the box used most, and it's where preparers slip. Form 8948 is not the taxpayer's written choice to file on paper. The instructions say the taxpayer choice statement is a separate document that stays in the preparer's records. Don't attach it to the return and don't send it to the IRS. Rev. Proc. 2011-25 sets out how that choice should be documented.
The same applies to the hardship waiver: you enter the waiver number and approval date on line 2, but you don't send the approval letter itself.
Line 6 in more detail
Line 6 covers three narrower situations, and each has its own condition:
- 6a: the preparer is a foreign person without a social security number who can't enroll in IRS e-file and isn't part of a firm that can. To tick it, the preparer must have applied for a PTIN and submitted Form 8946, but neither goes with the return.
- 6b: the preparer is barred from e-file by an IRS sanction, confirmed in a letter, for some or all of the calendar year. The box can be used until the sanction ends or the IRS accepts the preparer back into e-file, whichever comes first.
- 6c: other technology problems that are verifiable and documented, described in the space on the form.
When you don't need Form 8948 at all
Some covered returns can't be accepted electronically, and in some cases the IRS has told taxpayers not to e-file a particular return. If a return can't be e-filed for one of those reasons, the preparer doesn't complete Form 8948. There's one catch: if an attachment the IRS won't take electronically can be mailed separately with Form 8453 as a transmittal, the rest of the return still has to be e-filed.
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Line 5 has a related warning. Don't check it when the real reason is that the IRS itself doesn't accept a form electronically; it's only for gaps in your own software.
Filling it in, step by step
- Enter the names, tax year and identifying number exactly as they appear on the return. For a joint return, use the first SSN listed.
- Enter your name and Preparer Tax Identification Number (PTIN).
- Check one reason box and add the detail that box asks for, such as the reject code or waiver number.
- Attach Form 8948 to the paper return you give the client to sign.
- Keep the client's choice statement or your waiver letter on file, not with the return.
If the client signs an e-file authorization instead, the paper route doesn't apply at all; see Form 8879 for how that signature works.
The verdict
Form 8948 takes a couple of minutes, but it matters if your firm is near the 11-return line. Count returns across the whole firm, tick only one reason, and keep the client's paper-filing choice in your own files rather than on the return. Get those three right and the form does its job: it shows the IRS that a paper return was allowed, not an oversight.
Frequently asked questions
What is Form 8948 used for?
Specified tax return preparers attach it to a paper return to explain why the return wasn't filed electronically.
Do I need Form 8948 if I prepare my own return?
No. It's only for specified tax return preparers. Individuals filing their own return on paper don't use it.
How many returns make a preparer a specified tax return preparer?
A preparer, or the firm in aggregate, who reasonably expects to file 11 or more covered returns during a calendar year.
Can I check more than one box on Form 8948?
No. The form tells you not to check more than one box.
Do I attach the taxpayer choice statement to the return?
No. The instructions say it's a separate document kept with the preparer's records, not attached to the return or sent to the IRS.
Which revision of Form 8948 is current?
The IRS form in use is the September 2018 revision, with the instructions printed on page 2.
