How to File FBAR (FinCEN Form 114): Accounts, Deadline, and Records

To file an FBAR, submit FinCEN Form 114 electronically through the Financial Crimes Enforcement Network’s BSA E-Filing System by April 15, with an automatic extension to October 15. The form is required from any U.S. person whose foreign financial accounts, added together, exceeded $10,000 at any point during the calendar year.¹ It is not filed with the IRS and is not attached to your tax return; it goes directly to FinCEN, a bureau within the Treasury Department.

Confirm You Have to File

The requirement applies to every “United States person” who crosses the threshold. That includes U.S. citizens and residents wherever they live, along with domestic corporations, partnerships, trusts, and estates.² Income is irrelevant. A non-interest-bearing foreign checking account counts.

The $10,000 figure is not per account. Add up the highest balance each account reached during the year. Two accounts that each peaked at $6,000 would put you over the threshold, and both would have to be reported.³

Signature Authority Counts, Even Without Ownership

If you can control a foreign account by communicating directly with the bank, you have signature authority and must file, even if none of the money is yours.² This often catches people who handle finances for an employer, a family member, or a business.

Ownership Through a Company or Trust

You have a reportable financial interest in a foreign account held by a corporation if you own more than 50 percent of its shares by value or voting power, or in one held by a partnership if you own more than 50 percent of its profits or capital. For a trust, you must file if you are the grantor with an ownership interest for federal tax purposes, or if you hold a greater than 50 percent beneficial interest in the trust’s assets or income.⁴

Which Accounts to Include

The FBAR covers accounts at financial institutions physically located outside the United States. Reportable types include:⁵

Bank accounts: savings, checking, demand deposit, and other deposit accounts at foreign banks.
Securities and brokerage accounts held with foreign institutions.
Foreign-issued life insurance or annuity contracts that have a cash surrender value.³
Commodity or futures accounts with a foreign broker or dealer.
Shares in a foreign mutual fund or similar pooled fund open to the general public.

Several categories are exempt. Foreign accounts held by or on behalf of an IRA or a retirement plan under Internal Revenue Code sections 401(a), 403(a), or 403(b) do not have to be reported by the participant, owner, or beneficiary.¹ Overseas banking facilities operated by a U.S. financial institution to serve U.S. government installations are not treated as foreign accounts. Accounts of government entities and of international financial institutions the U.S. belongs to are exempt, as are bank-to-bank correspondent and nostro accounts used only for interbank settlement.⁵

A narrow point on cryptocurrency: FinCEN has said that accounts holding only virtual currency at a foreign exchange are not currently reportable, though it has signaled that a rule change is in the works. If a foreign account holds both virtual currency and other reportable assets like cash, the whole account is reportable.⁶

What to Gather Before You Start

Pull together the following for every account you’ll report:¹

Your Social Security Number or Individual Taxpayer Identification Number.
The account number, the type of account (bank, securities, or other), and the full legal name and address of the foreign institution.
The highest balance the account reached at any point during the calendar year.

If an account is denominated in a foreign currency, convert the maximum balance to U.S. dollars using the Treasury Department’s reporting rate of exchange for the last day of the calendar year. Do not use the rate on the date the balance peaked. The Treasury publishes these rates on its website.

Filing the Form

The FBAR is filed only online, through FinCEN’s BSA E-Filing System. There is no paper option.¹ You can either complete the form directly in your browser or download a fillable PDF and upload it. The workflow is the same either way:

Open the BSA E-Filing System and select FinCEN Form 114.
Enter your name, taxpayer ID, and address.
For each foreign account, enter the institution’s name and address, the account number, the account type, and the maximum value during the year.
Review every field. Account numbers and maximum values are the most common sources of follow-up inquiries.
Sign electronically. Your signature is a declaration that the information is true and correct. Submit.

A confirmation screen appears immediately after a successful submission, and the system emails an automated confirmation with a unique BSA Identifier. Save that email. It is your proof of filing for the year.

If Someone Else Is Filing for You

To have a tax professional or another person file on your behalf, complete FinCEN Report 114a (Record of Authorization to Electronically File FBARs). Do not send 114a to FinCEN. Keep it in your records and produce it if asked.¹

If You Are Filing for a Married Couple

A spouse can skip a separate FBAR only if all three of these are true: every reportable account of the non-filing spouse is jointly owned with the filing spouse; the filing spouse reports those accounts on a timely, electronically signed FBAR; and both spouses have signed Form 114a.⁷ If any condition fails, for instance one spouse holds a separate account, both must file, and each must report the full value of any jointly held accounts.

The Deadline and the Automatic Extension

The FBAR is due April 15 for the previous calendar year.⁸ If you miss it, you automatically get until October 15. You do not need to request the extension or file any paperwork.¹ The same deadline applies whether you live in the U.S. or abroad. When FEMA designates an area for disaster assistance and the IRS extends tax deadlines there, FinCEN automatically matches the extension for FBARs.⁹

Penalties for not filing are steep. Non-willful violations carry a statutory penalty of up to $10,000 per violation (currently around $16,536 per account after inflation adjustments), and willful violations can reach the greater of roughly $165,353 or 50 percent of the account balance, per account, per year.¹⁰ Willful failures can also be prosecuted criminally.¹¹

If You Missed Prior Years

If you should have filed in past years and didn’t, the IRS has two catch-up paths. Coming forward before the IRS contacts you materially improves your position.

The Delinquent FBAR Submission Procedures fit filers who have no unreported income. You qualify if you are not under civil examination or criminal investigation and the IRS has not already contacted you about the missing FBARs. If you properly reported and paid tax on all income from the foreign accounts on your U.S. returns, the IRS generally will not impose a penalty for the late FBARs.¹²

The Streamlined Filing Compliance Procedures fit filers who also failed to report income from the foreign accounts. The Streamlined Domestic Offshore Procedures require that your failure was non-willful, meaning negligence, inadvertence, or a good-faith misunderstanding, and that you filed returns for the most recent three years if you were required to.¹³ You amend three years of returns, file six years of delinquent FBARs, and pay a miscellaneous offshore penalty. A parallel version exists for taxpayers living abroad.

Keep Your Records for Five Years

Records for each reported account have to be kept for five years from April 15 of the year following the reported calendar year, or from the actual filing date if you filed late.⁴ Records supporting a 2025 FBAR (due April 15, 2026) must be retained until at least April 15, 2031.

For each account, hold on to:¹

The name on the account.
The account number.
The name and address of the foreign institution.
The account type.
The maximum value during the year.

Keep a copy of the submitted FinCEN Form 114 and the confirmation email with your BSA Identifier. The records need to be produced in a reasonable time if the government asks.¹⁴

Filing the FBAR Does Not Cover Form 8938

Filing FinCEN Form 114 does not satisfy the separate FATCA reporting obligation on IRS Form 8938, and filing Form 8938 does not satisfy the FBAR.³ The FBAR goes to FinCEN through the BSA E-Filing System; Form 8938 is attached to your income tax return. The FBAR threshold is $10,000 aggregate at any time during the year, while Form 8938 thresholds are higher and vary by filing status and residence. If your accounts exceed both thresholds, you file both forms and report the accounts on each.

1
Internal Revenue Service. Report of Foreign Bank and Financial Accounts (FBAR)
2
Financial Crimes Enforcement Network. Report Foreign Bank and Financial Accounts
3
Internal Revenue Service. Comparison of Form 8938 and FBAR Requirements
4
Financial Crimes Enforcement Network. FBAR Line Item Filing Instructions
5
eCFR. 31 CFR 1010.350 – Reports of Foreign Financial Accounts
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Financial Crimes Enforcement Network. Filing Requirement for Virtual Currency
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Financial Crimes Enforcement Network. Filing for Spouse
8
Financial Crimes Enforcement Network. Due Date for FBARs
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Financial Crimes Enforcement Network. FinCEN Provides FBAR Filing Relief to Victims of Hurricane Helene
10
Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
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Office of the Law Revision Counsel. 31 USC 5322 – Criminal Penalties
12
Internal Revenue Service. Delinquent FBAR Submission Procedures
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Internal Revenue Service. U.S. Taxpayers Residing in the United States
14
eCFR. 31 CFR 1010.430 – Nature of Records and Retention Period