FBAR filing requirements and deadlines in 2026

If you are a US citizen, green card holder, or resident alien with financial accounts outside the United States, you may need to file an FBAR – the Report of Foreign Bank and Financial Accounts – each year. The FBAR is required under the Bank Secrecy Act and is filed separately from your federal tax return on FinCEN Form 114.

The filing trigger is straightforward: if the combined value of all your foreign financial accounts exceeded $10,000 at any point during 2025, you generally have an FBAR filing obligation. That threshold is aggregate – three accounts with peak balances of $4,000 each produce a $12,000 total, so all three must be reported.

Even Americans who owe no US tax are required to declare overseas bank accounts on FinCEN Form 114 once the $10,000 aggregate threshold is crossed. Many people overlook the requirement because the FBAR is not an IRS form and is not attached to Form 1040.

Key takeaways

The FBAR covers 2025 calendar-year accounts and is due April 15, 2026, with an automatic six-month extension to October 15, 2026.

 

FBAR is filed separately through FinCEN, a bureau of the US Treasury, and there is no fee to file.

What is FBAR?

FBAR stands for the Report of Foreign Bank and Financial Accounts – officially, FinCEN Form 114. It is administered by the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury, under the authority of the Bank Secrecy Act.

FBAR in one sentence: If the combined value of your foreign financial accounts exceeded $10,000 at any point during 2025, you must report them to FinCEN on Form 114 by April 15, 2026.

The FBAR is not an FBAR tax form. It does not calculate tax, does not determine what you owe, and is not attached to Form 1040. It is an information return that discloses the existence and maximum value of foreign financial accounts.

The FinCEN foreign bank account reporting system covers accounts held at foreign financial institutions – bank accounts, securities and brokerage accounts, mutual fund accounts, and certain cash-value insurance or annuity contracts.

Directly held foreign stocks or bonds are generally not reportable merely because they are foreign; however, a foreign brokerage account holding them may be.

The IRS distinguishes foreign accounts reported on the FBAR from the broader category of foreign financial assets reported on Form 8938.

For a side-by-side comparison, see how FBAR differs from FATCA.

Who needs to file an FBAR? Quick decision test

Before reviewing the detailed eligibility rules, run this three-question test. If all three answers are yes, you generally have an FBAR obligation.

1. Are you a US person? This includes US citizens (at home or abroad), green card holders, resident aliens who meet the substantial presence test, and US entities such as corporations, partnerships, LLCs, trusts, and estates.
2. Do you have a financial interest in – or signature or other authority over – at least one foreign financial account? Direct ownership is the most common trigger, but the obligation also covers indirect interests and authority over accounts you do not own.
3. Did the combined value of all your foreign financial accounts exceed $10,000 at any time during 2025? The test looks at aggregate peak value across all accounts, not each account individually.

If all three answers are yes, you generally must file. If you are uncertain about your status as a US person, clarify that question first – the answer determines the rest.

Who is required to file an FBAR?

The FBAR requirements are broader than many taxpayers expect. Even if you owe no US tax, live permanently abroad, or the account produces no income, the filing obligation applies once the $10,000 aggregate threshold is crossed.

The following subsections break down each element of the FBAR reporting requirements.

Who is a US person?

For FBAR purposes, a “US person” includes US citizens (including those living abroad), lawful permanent residents (green card holders), and resident aliens who meet the substantial presence test. It also includes domestic corporations, partnerships, LLCs, trusts, and estates.

A US citizen living in Germany, a green card holder in Canada, and a foreign national who passes the substantial presence test all qualify. The foreign bank account filing requirements apply regardless of where the person lives or whether they owe US income tax.

Financial interest

You have a financial interest in a foreign account if you are the owner of record or hold legal title, regardless of whether the account is for your benefit. You also have a financial interest if the owner of record is an entity in which you hold a greater-than-50% interest, or a corporation of which you are a more-than-50% shareholder.

For trusts, a financial interest exists if you are the grantor with an ownership interest in the trust for US tax purposes, or if you hold a present beneficial interest in more than 50% of the trust’s assets or receive more than 50% of its income for the year.

A US person who owns 60% of a foreign LLC that holds a bank account in the UK has a financial interest in that account. The account must be reported even though it is not in the individual’s name.

Signature or other authority

Signature or other authority means you can control the disposition of assets in a foreign account by direct communication with the financial institution – whether in writing, by phone, or electronically.

Common examples include an employee with signing authority on an employer’s foreign account, an adult child managing a parent’s foreign account, or a corporate officer who can authorize transfers.

Even if you do not own the account, you may still need to file if you have the authority to direct transactions, access funds, or make financial decisions on behalf of the account holder. The obligation is not limited to account owners – anyone meeting the US person, interest-or-authority, and $10,000 tests generally must file.

Nonresident alien FBAR obligations

A person who is genuinely a nonresident alien – someone who does not hold a green card and does not meet the substantial presence test – generally does not file an FBAR. The obligation applies to US persons, and a nonresident alien is generally not a US person.

A FBAR resident alien, however – a non-citizen who holds a green card or passes the substantial presence test – does have filing obligations.

Filing Form 1040-NR alone does not determine whether you are a US person for FBAR purposes. Classification depends on the green card test and the substantial presence test, not on which income tax return you file.

What to report on an FBAR

The range of reportable accounts is wider than many filers expect. The deciding factor is where the financial institution is located – not the currency the account holds. A dollar-denominated account at a bank in London is foreign; a euro-denominated account at a bank in New York is not.

The following table lists common FBAR account types and whether they are generally reportable.

 

FBAR reporting covers every foreign financial account you own, co-own, or control – including accounts that earned no income and accounts closed during the year.

Accounts generally exempt from FBAR reporting

The following accounts are generally not reportable, based on the FinCEN FBAR instructions:

• Accounts at US military banking facilities, regardless of the facility’s physical location
• IRA-type accounts of which you are the owner or beneficiary, held in a qualifying retirement plan
• Accounts in a trust for which a US-person trustee already files a consolidated FBAR
• Correspondent or “nostro” accounts maintained by banks for interbank transactions
• Accounts owned by governmental entities or international financial institutions

These exemptions are narrow. A foreign pension that falls outside a qualifying US retirement plan exception is generally still reportable. Foreign bank account reporting rules favor inclusion – the consequences of over-reporting are far less severe than the consequences of under-reporting.

How the $10,000 FBAR threshold works

The $10,000 threshold is an aggregate test across all of your foreign financial accounts. There is no FBAR minimum account balance for any individual account – even an account with $500 must be reported if your total across all accounts crosses the line.

The test asks whether the combined value of all reportable accounts exceeded $10,000 at any point during the calendar year. In most cases, adding each account’s peak balance gives a quick and conservative answer – if the sum exceeds $10,000, file.

A single moment above $10,000 triggers reporting for every foreign account you held during the year.

 

The aggregate briefly exceeded $10,000 in March. That single moment triggers the obligation for the entire year, and all three accounts must be reported – including Account C, which never individually exceeded $5,000.

The FBAR highest balance you report for each account is its maximum value at any point during 2025, converted to US dollars using the Treasury Reporting Rates of Exchange for December 31, 2025.

Foreign accounts over $10,000 in 2025? Get your FBAR filed correctly.

Get started

FBAR filing deadlines for 2026

The FBAR filing date for 2025 calendar-year accounts is April 15, 2026. If you miss that date, an automatic extension pushes the deadline to October 15, 2026 – no application, no Form 4868, and no request to FinCEN needed.

The following four dates define the 2025 FBAR timeline.

 

The June 15 automatic extension for US taxpayers living abroad applies to your federal income tax return, not to your FBAR. Form 4868 extends your income tax filing deadline but has no effect on FinCEN Form 114.

The FBAR has its own April 15 / October 15 timeline, and knowing when to file FBAR means tracking these dates independently from your 1040.

Filing any time before October 15 – even months after April 15 – is timely under the automatic extension and carries no penalty.

For the full set of expat filing deadlines, see 2026 tax deadlines for US citizens abroad.

Penalties for not filing FBAR

Under the Supreme Court’s 2023 Bittner decision, non-willful FBAR penalties apply per annual report – not per unreported account – which significantly reduced exposure for filers with multiple accounts.

 

The $16,536 and $165,353 amounts are inflation-adjusted maximums effective for penalties assessed on or after January 17, 2025, per the FinCEN inflation adjustment rule. These penalties are not automatic – the IRS has discretion, and actual amounts depend on the facts of each case.

FBAR late filing penalties are separate from income tax penalties. Missing the FBAR deadline triggers penalties under Title 31 – not the failure-to-file or failure-to-pay penalties under the income tax code.

FBAR tax filing obligations are independent: filing your FBAR on time has no effect on your income tax status, and vice versa.

For a deeper look at penalty ranges and mitigation strategies, see FBAR penalties in 2026 and the IRS FBAR examination guidelines.

Missed the FBAR deadline?

If you have missed one or more FBAR filings, your next step depends on your specific situation. Do not file a “quiet FBAR disclosure” by submitting late FBARs without using a recognized compliance procedure – the IRS has warned against this approach, and it may increase penalty exposure.

Scenario 1 – Income fully reported, only FBAR missing. If you reported all income from your foreign accounts on your federal returns and simply failed to file the FBAR, you may qualify for Delinquent FBAR Submission Procedures. This route generally does not result in penalties if you file before the IRS contacts you.

Scenario 2 – Tax returns and FBARs both incomplete. If you missed both income tax returns and FBARs, and the failure was non-willful, you may qualify for the IRS Streamlined Filing Compliance Procedures. The foreign offshore version (SFOP) generally waives all penalties for qualifying non-US residents. The domestic version (SDOP) generally imposes a 5% miscellaneous offshore penalty.

Scenario 3 – Willfulness concern or prior IRS contact. If the IRS has already contacted you, or if there is any question of willfulness, the Streamlined procedures are generally not available. The IRS Criminal Investigation Voluntary Disclosure Practice may be the appropriate route.

Scenario 4 – FBAR filed but inaccurate. File a corrected FinCEN Form 114 as soon as possible. Check the “amended” box and enter the BSA ID of the original submission.

Which late-filing procedure applies?

The following table summarizes the main compliance paths for late or missing FBARs.

 

The FBAR submission deadline for the current year remains October 15, 2026. If you have past-year FBARs to file, address them through the appropriate compliance path.

Each path has different eligibility rules and penalty outcomes – the Streamlined Filing Compliance Procedures alone distinguish between foreign and domestic filers, willful and non-willful conduct, and FBAR-only gaps versus full return delinquency.

TFX compares all available options in IRS tax amnesty programs for expats.

FBAR vs. FATCA (Form 8938) – key differences

FBAR and FATCA are separate US foreign-account reporting regimes that overlap in coverage but differ in almost every operational detail. Filing one does not satisfy the other.

FBAR is filed with FinCEN and covers foreign financial accounts; Form 8938 is filed with the IRS as part of your tax return and covers a broader range of specified foreign financial assets.

 

The FBAR reporting requirements focus on foreign financial accounts, while Form 8938 covers a broader category of specified foreign financial assets. A directly held foreign stock that is not in a custodial account may be reportable on Form 8938 but not on the FBAR.

Conversely, a foreign account where you have only signature authority triggers an FBAR obligation but generally does not require Form 8938.

A foreign bank account on a tax return is reported through Form 8938 if it crosses the FATCA thresholds – and separately on the FBAR through FinCEN if it crosses $10,000. These are parallel obligations, not alternatives. Many US expats with foreign accounts need to file both in the same year.

The IRS comparison of Form 8938 and FBAR requirements confirms that both forms can apply in the same tax year, even when the same account appears on each.

For a full breakdown with worked examples, see FBAR vs. Form 8938 – key differences and thresholds.

Special FBAR situations

Several common situations raise questions that the general rules do not fully answer. The following six summaries cover the most frequent special cases, each with a link to deeper guidance.

Joint accounts and non-US spouses

If you co-own a foreign account with a non-US spouse, the full account value counts toward your $10,000 threshold – not half. Your non-US spouse does not have an FBAR obligation unless they are also a US person.

If both spouses are US persons and all accounts are jointly owned, a single joint FBAR may be filed – but only when the filing spouse reports every account, and both spouses sign Form 114a. If either spouse holds a separately owned account, separate FBARs are required.

See how to file FBAR jointly.

Employer accounts and signature authority

If you are an officer or employee with signature authority over your employer’s foreign financial account, you generally must report it on your own FBAR – even if the employer files its own FBAR for the same account. This applies to corporate officers who can authorize wire transfers, finance managers with signing rights, and anyone with direct communication authority over the account.

Certain exceptions exist for officers and employees of publicly traded companies, banks, and SEC-registered entities. Check the FinCEN instructions to confirm whether an exception covers your specific role.

Minors

A US-citizen child with a financial interest in a foreign account is subject to the same FBAR rules as an adult. If the child cannot file, a parent or guardian must file the FBAR on the child’s behalf.

The child’s accounts are counted separately from the parent’s for threshold purposes – but if a parent has signature authority over the child’s account, that account may also need to appear on the parent’s own FBAR.

US businesses and trusts

US corporations, partnerships, LLCs, trusts, and estates can have FBAR obligations independent of the individuals who own or manage them. A US LLC with a foreign bank account must file its own FBAR.

Trust beneficiaries may have a financial interest that creates an individual filing duty as well. Entities with 25 or more accounts may use the simplified reporting option but must still maintain – and produce on request – complete records for every account.

Closed accounts

An account that was open at any time during 2025 – even for a single day – counts toward the aggregate threshold and must be reported if the threshold is met. FBAR closed accounts are reported with their maximum value before closure. Closing the account does not remove the reporting obligation for the year it was open.

If you closed an account in January and the aggregate exceeded $10,000 at any point during the year, that account still belongs on the FBAR.

Cryptocurrency and fintech accounts

Under FinCEN Notice 2020-2, foreign accounts holding only virtual currency are not currently reportable on the FBAR. However, if a foreign crypto exchange account also holds fiat currency or other reportable assets, the entire account becomes reportable once the $10,000 aggregate threshold is met. FinCEN has indicated it may expand the definition of “account” to include virtual currency in future rulemaking.

The regulatory landscape is actively shifting – check the current guidance before assuming a foreign crypto account is exempt.

See crypto FBAR requirements for the latest position.

Common FBAR filing mistakes

The following seven mistakes are the ones TFX CPAs see most often. Each is avoidable.

Need help with FBAR filing?

Not every FBAR needs professional help – a filer with one or two straightforward foreign accounts can generally handle it through FinCEN’s BSA E-Filing System.

Professional review adds the most value in these six situations: six or more years of missing FBARs, unreported income from foreign accounts, entity or trust ownership, signature authority over employer or family accounts, 25 or more foreign accounts, and uncertainty about whether past non-filing was willful.

At Taxes for Expats, our CPAs and EAs handle both current-year filings and catch-up procedures, including Streamlined Foreign Offshore and Delinquent FBAR submissions.

See our pricing or start with a free intro consultation. For additional questions, see the TFX FAQ page.

FREE

Missing FBARs keeping you up at night?

Get a clear path to compliance.

Schedule my free call