When to File Your FBAR: Deadlines, Extensions, and Penalties

The FBAR filing deadline is April 15 of the year after the calendar year you’re reporting, with an automatic extension to October 15 if you miss it. No form or request is needed to get that extra six months; it applies by default.¹ You have to file FinCEN Form 114 if the combined value of your foreign financial accounts topped $10,000 at any point during the year, even for a single day.²

The April 15 Deadline and the Automatic Extension

April 15 became the FBAR due date under the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, which aligned it with the federal income tax deadline.¹ If April 15 falls on a weekend or federal holiday, the deadline moves to the next business day.

Everyone who doesn’t file by April 15 gets the automatic extension to October 15. You file nothing to claim it. FinCEN’s guidance confirms the extension applies to all filers, which is useful when foreign banks operate on different reporting calendars and statements arrive late.¹

One point of possible confusion: the underlying regulation at 31 C.F.R. § 1010.306(c) still references a June 30 due date, which was never updated after the 2015 statutory change.³ The operative deadline is April 15. Follow FinCEN’s guidance, not the stale regulatory text.

Who the Deadline Applies To

The April 15 deadline only matters if you’re required to file in the first place. You must file if you are a U.S. person and the total value of your foreign financial accounts exceeded $10,000 at any time during the calendar year.⁴

The $10,000 threshold is aggregate. Add together the highest balance each account reached during the year. Two accounts that each peaked at $6,000 put you over the line. So does a single account that briefly crossed $10,000 in March and dropped to $3,000 by December, because the trigger is the highest balance at any point, not the year-end figure.

“U.S. person” covers citizens, resident aliens, and domestic entities including corporations, partnerships, LLCs, trusts, and estates.⁵ If someone dies during the year and their estate holds foreign accounts over the threshold, the executor files on the estate’s behalf.⁴

The requirement is separate from Form 8938 under FATCA. Form 8938 goes to the IRS with your tax return and has much higher thresholds; the FBAR goes to FinCEN electronically. Filing one does not excuse you from the other, and many people with foreign accounts have to file both.⁶

A Different Deadline for Some Signature-Authority Filers

If you have signature authority over a foreign account but no financial interest in it, you can still trigger the filing requirement when the aggregate value crosses $10,000.⁴ This typically applies to corporate officers and employees who manage company funds held overseas.

For a specific subset of these filers (employees and officers with signature authority over certain employer accounts but no financial interest), FinCEN has repeatedly extended the deadline through a series of notices. The extension has been renewed multiple times, and the IRS points filers to the most recent notice for the current date.⁴ Check the current notice before assuming the April 15 date applies to you.

What Happens if You Miss the Deadline

The penalties for failing to file are steep, and they can apply even when no additional tax is owed on the accounts.

For a non-willful violation (the filer wasn’t acting deliberately), the statutory maximum is $10,000 per violation, adjusted annually for inflation. As of January 2025, the inflation-adjusted maximum is $16,536 per violation.⁷ You can avoid the penalty entirely if you show the violation was due to reasonable cause and the account was properly reported at the transaction level.⁸

A key clarification came in Bittner v. United States (2023), where the Supreme Court ruled that non-willful penalties apply per report, not per account. Before that decision, the IRS sometimes multiplied the penalty by the number of unreported accounts. Now one late FBAR for a given year means one penalty, no matter how many accounts should have been on it.⁹

Willful violations are a different order of severity. The maximum civil penalty is the greater of $100,000 (adjusted for inflation) or 50 percent of the account balance at the time of the violation.⁸ The reasonable cause exception does not apply. For someone with $500,000 in an undisclosed foreign account, that means up to $250,000 for a single year’s failure to file. Willful violations can also carry criminal penalties in egregious cases.¹⁰

Catching Up on Missed Deadlines

If you should have filed for a prior year and haven’t been contacted by the IRS, there are structured ways back into compliance. Which one fits depends on whether you also have unreported income.

Delinquent FBAR Submission Procedures

If you don’t owe additional tax and just need to file missed FBARs, the Delinquent FBAR Submission Procedures are the simplest route. To qualify, you must not be under civil examination or criminal investigation, and the IRS must not have already contacted you about the missing reports.¹¹

You file the late FBARs electronically through the BSA E-Filing System, select a reason for late filing on the cover page, and include a statement explaining why. The IRS has stated it will not impose penalties for delinquent FBARs filed this way if you properly reported all income and paid all associated tax.¹¹

Streamlined Filing Compliance Procedures

If unreported foreign income means you also need to amend tax returns, the Streamlined Filing Compliance Procedures apply. There are two versions.

The Streamlined Domestic Offshore Procedures, for U.S. residents, require amended returns for the most recent three years and delinquent FBARs for the most recent six years. You must certify the failure was non-willful (negligence, mistake, or a good-faith misunderstanding of the law). The cost is a 5 percent miscellaneous offshore penalty on the highest aggregate balance of your unreported foreign financial assets across the covered period.¹²

The Streamlined Foreign Offshore Procedures, for taxpayers living abroad, work the same way but carry no miscellaneous offshore penalty. To qualify, U.S. citizens and green card holders must have been physically outside the United States for at least 330 full days in at least one of the last three tax years and must not have maintained a U.S. home during that time.¹³ For anyone who qualifies, 5 percent versus a 50 percent willful penalty is a significant difference.

Records Tied to the Filing Date

You must keep records for each reportable foreign account for five years from the April 15 due date. The records need to include the account name, account number, the institution’s name and address, the account type, and the maximum account value during the reporting period.¹⁴ Retaining a copy of the filed FBAR can help satisfy this requirement.

If your only reporting obligation is signature authority over an employer’s foreign account, the record-keeping burden shifts to the employer.⁴ For everyone else, keeping year-end statements and exchange-rate documentation is the simplest protection if the IRS asks questions years after the deadline passes.

1
Financial Crimes Enforcement Network. FBAR Filing Requirement for Certain Financial Professionals
2
Financial Crimes Enforcement Network. Report Foreign Bank and Financial Accounts
3
eCFR. 31 CFR 1010.306 – Filing of Reports
4
Internal Revenue Service. Report of Foreign Bank and Financial Accounts (FBAR)
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eCFR. 31 CFR 1010.350 – Reports of Foreign Financial Accounts
6
Internal Revenue Service. Comparison of Form 8938 and FBAR Requirements
7
Federal Register. Inflation Adjustment of Civil Monetary Penalties
8
Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
9
Supreme Court of the United States. Bittner v. United States, No. 21-1195
10
Office of the Law Revision Counsel. 31 US Code 5322 – Criminal Penalties
11
Internal Revenue Service. Delinquent FBAR Submission Procedures
12
Internal Revenue Service. U.S. Taxpayers Residing in the United States
13
Internal Revenue Service. U.S. Taxpayers Residing Outside the United States
14
Financial Crimes Enforcement Network. Record Keeping