Line 11 of paper Form W-12 is about data security. It has you confirm you know the law requires a written information security plan for paid preparers. That plan is often called a WISP. Your PTIN expires on December 31. That makes renewal a good yearly point to check that your plan exists and still fits your office.
What does Form W-12 line 11 say?
Form W-12 is the IRS form to apply for or renew a PTIN. The current paper version is Rev. October 2025. Line 11, "Data Security Responsibilities," reads:
"I am aware that paid tax return preparers are required by law to create and maintain a written information security plan that provides data and system security protections for all taxpayer information." IRS Form W-12 (Rev. October 2025), line 11
What those phrases mean for a small office:
- "Required by law." The form calls the plan a legal duty.
- "Create and maintain." The plan has to change when your office changes.
- "Written." It has to exist on paper or in a file.
- "All taxpayer information." Count every place client data lives: paper files, laptops, phones, email, cloud storage and your tax software.
Does PTIN renewal require a WISP?
Line 11 points to a duty that already exists in federal law. Under the FTC Safeguards Rule, tax preparation firms count as financial institutions. IRS Publication 5708 says this applies regardless of size. A one-person office is a tax preparation firm too.
That means the plan is a year-round duty. Renewal is the one time a year the form puts it in front of you.
Before you renew, ask yourself three things. Could you find your written plan today? Does it describe how your office works now? If a laptop went missing tomorrow, would your staff know who to call?
When does your PTIN expire?
PTINs expire on December 31 of the year they are issued. The 2026 renewal fee was $18.75. Check the IRS PTIN page for the current fee before you renew.
Because the date is fixed, you can plan around it. Put a plan review on your calendar a few weeks before December 31. Then you renew with a plan that matches your office.
Does a solo preparer need the same plan as a big firm?
No. IRS Publication 5708 says there is no one-size-fits-all WISP. It also says a sole practitioner can use a more abbreviated plan.
A shorter plan is fine. It still has to be in writing.
Make it specific. Name the people, devices and software your office uses. Include the outside help you rely on, like your IT provider or software vendor. Generic sample text won't tell anyone what to do on the day something goes wrong.
What should you check before you renew?
Set aside about 30 minutes for these five steps.
- Find your written plan and note where the current copy lives. If you have two versions, keep one and archive the other.
- Check when you last updated it. If you can't remember, update it now.
- Compare it to your office today. New staff, new software, a new office or a new laptop may be missing. So may a change of IT provider.
- Write down what is missing or out of date. Keep the list short and specific.
- Fix what you can now. Put the rest on your calendar with dates.
What if you don't have a plan yet?
A short plan you finish is better than a long one you don't. One way to start:
- Read IRS Publication 5708, "Creating a Written Information Security Plan for your Tax & Accounting Practice." It walks through how to build a plan.
- Run the free checklist to see what you already do. You may already lock devices or use strong sign-ins. Those habits belong in the plan.
- Write each habit down in plain words. Note who does it and how often.
- Set a date for the next review.
You can build all of this yourself. If you'd rather start from a fill-in plan, the kit below has one.
Is the online renewal worded the same way?
We don't know. This guide quotes only the paper Form W-12. The online screens may word things differently. Read each statement before you confirm it. Save a copy or a screenshot for your records.
Sources
- IRS, Form W-12 (Rev. October 2025), line 11. Checked October 12, 2026.
- IRS, IR-2025-108: IRS reminds tax pros to renew PTINs for the 2026 tax season, October 27, 2025.
- IRS, Publication 5708 (Rev. 8-2024), Creating a Written Information Security Plan for your Tax & Accounting Practice.
- FTC, FTC Safeguards Rule: What Your Business Needs to Know, updated December 2024.