Form 114a is the written authorization you sign to let a third party — typically a CPA, attorney, or enrolled agent — electronically file your Report of Foreign Bank and Financial Accounts (FBAR) on your behalf. It’s also the form spouses use when they want to submit a single joint FBAR instead of two separate ones. You never send it to the government. You and your preparer sign it, each keep a copy, and produce it only if FinCEN or the IRS asks.1Financial Crimes Enforcement Network. FinCEN Introduces New Form for Authorizing FBAR Filing by Spouses and Third Parties
When You Actually Need Form 114a
If you file your own FBAR through the BSA E-Filing System, you don’t need this form at all. It only comes into play when someone else pushes the submit button for you.2Financial Crimes Enforcement Network. Individuals vs CPA, Attorney and Paid Tax Preparers Two situations trigger the requirement:
- A paid preparer with a BSA E-Filing account will transmit your FBAR.
- You and your spouse are eligible for a joint filing and want one spouse to submit for both.
Signing the form does not transfer your legal responsibility for the FBAR’s accuracy to the preparer. You stay the legally obligated filer. The preparer is just authorized to submit.
Filling Out the Form
Form 114a is a fillable PDF on FinCEN’s BSA E-Filing website. It has two parts, and the details in each need to match your other filings because FinCEN and the IRS use this data to tie the authorization to the underlying FBAR.3Financial Crimes Enforcement Network. Record of Authorization to Electronically File FBARs
Part I: Account Owner
Enter your full legal name, taxpayer identification number (SSN, ITIN, or EIN), and current mailing address. If you’re filing jointly with a spouse, your spouse completes their own identifying information in the designated spouse fields within Part I and signs separately. Make sure the address matches what the IRS has on file; a mismatch can trigger unnecessary follow-up.
Part II: Preparer
The preparer enters their full name, firm name, identification details, and a business address for official correspondence. This section pins down exactly who submitted the report, which matters if questions arise later about the filing’s origin.
Signatures
Both the account owner (Part I) and the preparer (Part II) must sign and date the form before the FBAR is transmitted. For joint spousal filings, both spouses sign in Part I. The signatures confirm under penalty of perjury that the information is truthful and that the account owner has authorized the submission.3Financial Crimes Enforcement Network. Record of Authorization to Electronically File FBARs
Digital signatures are acceptable. The form itself states that the owner and preparer signature fields may be digitally signed, which is practical for preparers with clients overseas or across the country. There is no wet-ink requirement as long as both parties have signed before transmission.
What Happens After You Sign
Here’s the part that catches people off guard: you never upload or mail Form 114a anywhere. The signed original stays in the records of both the account owner and the preparer. When the preparer submits your FBAR through the BSA E-Filing portal, they check a box certifying that a signed Form 114a is on file. That checkbox is the entire mechanism.1Financial Crimes Enforcement Network. FinCEN Introduces New Form for Authorizing FBAR Filing by Spouses and Third Parties
Federal recordkeeping regulations require both parties to keep the form for at least five years from the date of filing.4eCFR. 31 CFR 1010.430 – Nature of Records and Retention Period If FinCEN or the IRS opens a review, the preparer needs to produce the form to prove authorization existed. Store it somewhere accessible — a locked filing cabinet or an encrypted digital folder — not mixed in with tax documents you might discard.
Joint Spousal Filings
The BSA E-Filing System accepts only one digital signature per FBAR, so spouses who want to file jointly must use Form 114a to designate which spouse will sign and submit.5Financial Crimes Enforcement Network. Filing for Spouse The non-filing spouse signs the form authorizing the other to file on their behalf.
A joint FBAR only works when all three of these conditions are met:
- Every foreign account the non-filing spouse is required to report is jointly owned with the filing spouse.
- The filing spouse reports those jointly owned accounts on an FBAR submitted by the deadline with a valid electronic signature.
- Both spouses have completed and signed Form 114a, and both retain a copy.
If any of those conditions falls through — for instance, one spouse also holds a foreign account individually — both spouses must file separate FBARs. Each separate report must include the full value of any jointly owned accounts, not half. This trips up more couples than almost any other FBAR rule.
Entities and Trusts
When a corporation, partnership, LLC, or trust has FBAR obligations, an authorized official of that entity signs Form 114a to allow a third-party preparer to file. FinCEN’s instructions don’t list specific corporate titles that qualify; they require an “authorized official” of the entity or, for consolidated reports, an authorized official of the parent entity.6Financial Crimes Enforcement Network. BSA Electronic Filing Requirements For Report of Foreign Bank and Financial Accounts (FinCEN Form 114) In practice this is a corporate officer, managing partner, or trustee — whoever has legal authority to act for the entity. The entity remains the legally obligated filer, and the preparer acts under its documented authorization.
Do You Need a New Form Each Year?
FinCEN’s filing instructions don’t say whether a single Form 114a covers multiple years or must be renewed annually.6Financial Crimes Enforcement Network. BSA Electronic Filing Requirements For Report of Foreign Bank and Financial Accounts (FinCEN Form 114) Because of that silence, most practitioners have clients sign a fresh form for each filing year. The conservative approach costs nothing and eliminates any ambiguity about whether authorization was current at the time of submission. If your preparer asks you to sign again each year, that’s standard practice.
Fitting It Into Your FBAR Timeline
The FBAR deadline is April 15, matching the individual income tax deadline. Missing it triggers an automatic extension to October 15; you don’t need to request the extension or file any additional paperwork.7Financial Crimes Enforcement Network. Due Date for FBARs Your preparer should have the signed Form 114a in hand before they submit, so treat signing as part of your tax prep rather than a last-minute detail.
Why the Form Matters
FBAR penalties fall on the account owner, not the preparer, and they are steep: up to $10,000 per non-willful violation and the greater of $100,000 or 50 percent of the account balance for willful ones, with both figures adjusted for inflation each year.8Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties A properly signed Form 114a will not shield you from penalties for a late or inaccurate FBAR. What it does is protect both you and your preparer from a separate recordkeeping failure that could complicate an audit. Treat it as a required part of the filing, not paperwork your accountant can skip.