SEE Part 2: Enrolled Agent vs CPA
For representing clients before the IRS, an Enrolled Agent and a CPA have the same rights: the IRS states that enrolled agents, CPAs and attorneys all have unlimited representation rights, covering any taxpayer, any tax matter and any IRS office. The difference is everything else. The EA is a federal tax credential earned by passing the three-part SEE, with no degree requirement. The CPA is a state licence covering accounting, audit and tax, earned through education, the CPA Exam and supervised experience. If your work is tax and only tax, the EA gets you the same standing before the IRS far faster. If you want to sign audit opinions or build an accounting career, you need the CPA.
Side by side
| Enrolled Agent | CPA | |
|---|---|---|
| Granted by | The IRS | State boards of accountancy (55 jurisdictions) |
| Scope | Federal tax | Accounting, audit and attest, tax, advisory |
| Representation before the IRS | Unlimited | Unlimited |
| Exam | SEE: three parts, 100 questions each | CPA Exam: four sections, 16 hours in total |
| Exam content | Individuals, businesses, representation | Three Core sections plus one Discipline |
| Education requirement | None listed by the IRS | Yes; set by each jurisdiction |
| Experience required | None to sit the exam | Yes; NASBA cites about 2,000 hours, varying by jurisdiction |
| Pass mark | 500 scaled (200–800) | 75 (0–99 scale) |
| Time to pass a set | Each part valid 3 years | Credit window set by each jurisdiction |
| Continuing education | 72 hours per 3 years (16 a year, 2 ethics) | Set by each jurisdiction |
CPA facts in this table come from the AICPA and NASBA; anything that varies by state is described as such rather than given a number.
Scope of practice
Before the IRS they are equals. An EA can represent a corporation in an examination, negotiate a collection case for a partnership or take an appeal, exactly as a CPA can. There is no tier of IRS matter reserved for CPAs.
Outside the IRS they are not. Only a licensed CPA firm can issue an audit or review report on financial statements. Many employers in accounting, audit and corporate finance treat the CPA as the entry ticket. The EA says nothing about financial accounting competence, and no one will expect it to.
State tax work is its own question: representation before a state revenue department is governed by that state, not by the IRS.
The route
EA: obtain a PTIN, pass Part 1, Part 2 and Part 3 in any order within three-year validity windows, then apply on Form 23, pay the $140 enrollment fee and pass the suitability check. Each part costs $317. No degree, no experience, no state residency.
CPA: meet your jurisdiction’s education requirement, pass the four-section CPA Exam, complete supervised experience and meet the character requirements, then be licensed by your state board. The exam has three four-hour Core sections — Auditing and Attestation, Financial Accounting and Reporting, and Taxation and Regulation — plus one four-hour Discipline section of your choice: Business Analysis and Reporting, Information Systems and Control, or Tax Compliance and Planning. Education rules, fees, credit windows and experience details are set by each jurisdiction, so check with your own board rather than trusting a national figure.
How the tax content compares
Part 2 of the SEE is 85 scored questions on business tax alone: entities, partnerships, corporations, S corporations, business income and deductions, depreciation, reconciliations, trusts, exempt organisations, retirement plans, farmers and rental property. Taxation and Regulation on the CPA Exam covers tax too, but alongside business law and ethics, and only as one section of four.
That makes the SEE deeper on tax and narrower overall. A candidate who passes Part 2 has spent far more hours on, say, partnership basis and Form 1041 than most CPA candidates will. Conversely, the SEE never asks about revenue recognition, audit sampling or internal control.
Cost and time
| EA | CPA | |
|---|---|---|
| Exam fees | 3 × $317 = $951 | Varies by jurisdiction |
| Licence or enrollment fee | $140 | Varies by jurisdiction |
| Education | None required | Set by each jurisdiction |
| Typical study time | Weeks to a few months per part | Considerably longer across four sections |
For someone already working in tax, the EA is realistically achievable in a year of part-time study. The CPA usually takes longer because of the education and experience requirements as much as the exam.
Who each suits
Choose the EA if:
- You prepare returns or run a tax practice and want representation rights.
- You have no accounting degree, or your degree is in another field.
- Your clients are small businesses, partnerships and S corporations that need tax compliance, not audited statements.
- You want a credential in months, not years.
Choose the CPA if:
- You want to work in audit, assurance or corporate accounting.
- Your employer or career path requires a licensed accountant.
- You want advisory work where financial reporting matters as much as tax.
Both is common. Some CPAs add the EA to signal a tax specialism; some EAs later pursue the CPA. The credentials do not conflict.
Where Part 2 fits
Part 2 is the part most relevant to the comparison, because business tax is where CPA and EA work overlaps most. If you are deciding, sit down with the free sample questions: if partnership basis and S corporation distributions feel like your kind of problem, the EA route is a good fit. Then read is Part 2 worth it? for the practical case.