The PTIN Renewal WISP Compliance Guide

Before you hit “submit” on that PTIN renewal… Read this:

The Tiny Checkbox That Can Wreck Your Week

Every year, tax pros log in, renew their PTINs and EFINs, and breeze through the forms like it’s muscle memory. And then they hit the question that makes a lot of people squirm.

“Do you have a written security plan in place to protect taxpayer data?”

Some folks check yes without thinking. Others hesitate. Some just hope no one ever asks to actually see it.

But here’s the uncomfortable truth: that question isn’t there for decoration. It’s the IRS quietly reminding you that the FTC Safeguards Rule applies to you just as much as it does to giant firms. If you handle taxpayer data, you’re expected to have a documented, real, working plan to protect it.

And no, saying “we use passwords and antivirus” does not count.

What That Question Really Means

When the IRS asks about your WISP, they’re not just asking if you care about security. They’re asking if you can prove that you have a structure in place. That means they want to know things like:

• How do you protect taxpayer data from unauthorized access
• Who actually has access to those files, and how is that controlled
• What happens if something goes wrong
• How your team is trained to handle security issues

They want to see that this isn’t just “some IT guy’s problem.” They want it written, documented, and ready to hand over if the FTC or IRS ever audits your practice.

If you can’t show them that, you’re standing on very thin ice.

Why This Matters Right Now — Not Later

Most tax firms wait too long to get their security plan together. I get it. You’ve got filings, clients, calls, and probably a hundred things going wrong at once. But here’s the problem. Once tax season starts, no one has the bandwidth to stop and write policies or check their systems.

And when you renew your PTIN and EFIN, that’s basically you declaring to the IRS, “I’ve got my house in order.” If you don’t… it’s like putting a “Kick Me” sign on your compliance.

This is why renewal season is the sweet spot. You’re not in the chaos yet. You can set aside a couple of hours to get your systems cleaned up, documented, and actually ready for whatever 2026 tax season decides to throw at you.

Step One: Write or Update Your WISP (Without Overcomplicating It)

A WISP doesn’t have to be a massive binder full of legal mumbo jumbo. What matters is that it actually explains how your firm protects sensitive information. If your plan is stuck in a folder from three years ago, or if you’ve never made one, this is your moment.

Here’s a simple structure to follow:

1. Where the data lives – spell out if your files are stored locally, in the cloud, or both.
2. Who can touch it – list staff roles that have access and why.
3. How it’s protected – mention MFA, encryption, secure storage, anything that shows control.
4. What happens if something goes wrong – who does what if there’s a breach, lost laptop, or other incident.
5. How you review it – your plan isn’t static. Show how and when you update it.

That alone puts you ahead of most small firms who are still winging it.

Step Two: Bring Your Team Into the Game

Security fails most often at the human level. All it takes is one accidental click, one unsecured laptop, one well-crafted phishing email.

That’s why staff training isn’t optional anymore. And it doesn’t have to be boring either. If your team tunes out after two slides, you’re doing it wrong.

A practical approach looks like this:

• Schedule a 15-minute “Security Kickoff” meeting once a month.
• Pick one real-world example, like a phishing scam targeting tax pros or a story of a firm that got breached.
• Explain how your team can spot and stop that scenario.
• Log who attended and what you covered.

This isn’t about shaming anyone. It’s about turning security from a lecture into muscle memory.

And yes, if you’re a solo preparer, this still applies to you. You’re your own staff. Document what you review and when. It matters.

Step Three: Stop Blindly Trusting Vendors

This one sneaks up on a lot of firms. You might have your own systems locked down tight, but what about the software and services you rely on every day?

If your tax software provider, cloud storage, CRM, or IT contractor has a breach, and you can’t show that you did your due diligence, you’re still on the hook.

Here’s how you fix that quickly:

• Make a list of every vendor you use that touches client data.
• Send them a quick email asking them to confirm their security standards (SOC 2, ISO 27001, or equivalent).
• Save those replies in a folder called “Vendor Compliance.”
• Add a short note in your WISP that shows you reviewed their practices this year.

This takes less than 30 minutes and turns a massive liability into documented due diligence.

Step Four: Test Your Backup — Don’t Just Hope It Works

Backups are like fire extinguishers. Everyone feels good knowing they’re there. Almost no one actually checks if they work.

Pick a file, restore it, and document the process. If it works, great. If it doesn’t, you just saved yourself a world of pain down the line. An untested backup isn’t a backup. It’s a false sense of security.

This one simple step can be the difference between a minor inconvenience and a devastating, reputation-killing event.

Step Five: Make It Part of the Way You Work

This is where the pros separate from the “I’ll deal with it later” crowd.

A security plan isn’t something you set once and forget. It’s something you live with. Bake it into your routines. Add it to your quarterly checklist. Bring it up in team meetings. Revisit it when you bring on new tools or staff.

When compliance becomes part of your firm’s rhythm, it stops being a burden and starts being a shield.

Why Doing This Now Gives You an Edge

Here’s the part a lot of firms miss. When you get this done now, before the rush, you’re not just protecting your business. You’re making yourself more credible to clients and regulators alike.

When someone asks, “Are you compliant with FTC Safeguards?” you won’t stutter. You’ll have a clean, updated WISP. You’ll have proof of training. You’ll have your vendor checks. And you’ll have a tested backup plan.

Clients notice. Regulators notice. And in an industry built on trust, that’s worth gold.

Your Next Step

If you’re already renewing your PTIN and EFIN, this is the moment to tighten your house before the storm.

Write or update your WISP.
Train your team.
Vet your vendors.
Test your backup.
Document everything.

And if you’d rather not build this from scratch, we’ll hand you a fully compliant, done-for-you WISP and implementation guide – Completely Free.

That way, when you click “Yes” on that PTIN renewal question, it actually means something. You’ll walk into the season prepared, protected, and one step ahead of 90% of the industry.