FinCEN Form 114a: complete guide to the FBAR authorization form (2026)
FBAR Form 114a is the Record of Authorization to Electronically File FBARs – a companion document that authorizes a third party, such as a CPA, enrolled agent, or spouse, to submit FinCEN Form 114 on your behalf through the BSA E-Filing System.
Form 114a is not filed with FinCEN or the IRS. It is retained by you and the authorized filer as a record of authorization, and produced only if FinCEN or the IRS requests it during an FBAR examination.
For the 2026 filing season, the FBAR covering tax year 2025 foreign accounts was due April 15, 2026, with an automatic extension to October 15, 2026 – no extension request required.
This guide covers who needs Form 114a, how to complete it, spousal and entity rules, deadlines, record retention, and what happens when the form is missing.
What is FinCEN Form 114a? A plain-English definition
FinCEN Form 114a is the official authorization record that permits someone other than you to electronically file your FBAR. The form’s full title is “Record of Authorization to Electronically File FBARs,” and it is administered by the Financial Crimes Enforcement Network, a bureau of the US Treasury.
Form 114a is not an IRS form. Despite the connection to foreign account reporting, the form belongs to FinCEN’s BSA filing framework – not the IRS. The IRS enforces FBAR penalties and examines compliance, which is why many filers assume it is an IRS document. It is not.
The form does one thing: it documents that you, as the account holder or person with the FBAR filing obligation, authorized a specific third party to complete and submit the FBAR on your behalf.
The authorization also covers receiving FinCEN communications and resolving issues related to the submission.
What Form 114a is not:
- It is not an FBAR. The FBAR itself is FinCEN Form 114 – see our FBAR filing guide for the full filing process.
- It is not a tax form and does not calculate any tax liability.
- It is not filed electronically or mailed to any government agency. You keep it in your records.
If you file your own FBAR directly through the BSA E-Filing System without a preparer, you do not need Form 114a. The system captures your electronic signature directly.
Form 114a preview
Who needs to complete Form 114a?
Any US person who authorizes a tax professional, spouse, or other third party to electronically file their FBAR must complete Form 114a.
The form applies whenever the person clicking “submit” in the BSA E-Filing System is not the person who has the filing obligation.
Three categories of filers use Form 114a:
- Individual account holders using a paid preparer. If your CPA, enrolled agent, or tax attorney files the FBAR on your behalf, you sign Form 114a before they submit. The preparer must be registered with FinCEN’s BSA E-Filing System as an institution – they cannot use the individual filer option.
- Spouses authorizing each other for jointly held foreign accounts. When all foreign accounts are jointly held, one spouse can file a single FBAR for both – but only after both spouses complete and sign Form 114a.
- Entities authorizing an officer or agent. A corporation, partnership, LLC, trust, or estate with foreign accounts designates an authorized signer on Form 114a to permit a preparer to file on the entity’s behalf.
The underlying trigger is the same as for the FBAR itself: if the aggregate value of your foreign financial accounts exceeded $10,000 at any point during the calendar year, you have an FBAR obligation.
When someone else files that FBAR for you, Form 114a is part of the process.
The $10,000 threshold is set by FinCEN regulation and is not adjusted for inflation.
Form 114a vs. filing the FBAR directly: key differences
The FBAR itself goes to FinCEN; Form 114a stays with the filer and preparer and is not transmitted to any government agency unless requested.
The following table clarifies how the two forms differ in practice:
| Feature | Direct FBAR filing | Filing via Form 114a authorization |
|---|---|---|
| Who submits | You file your own FBAR through the BSA E-Filing System | A preparer, spouse, or other authorized third party submits on your behalf |
| Signature method | You sign electronically during submission | You sign Form 114a before the authorized filer submits; the filer signs the FBAR electronically |
| Record retention | You retain a copy of the filed FBAR and BSA confirmation for five years | Both you and the authorized filer retain the signed Form 114a, the filed FBAR, and the BSA confirmation for five years |
| When it applies | You have direct access to the BSA E-Filing System and no preparer involvement | A paid preparer files for you, a spouse files under the joint-account exception, or an entity authorizes an agent |
Step-by-step instructions for completing Form 114a
Form 114a instructions require seven steps, from downloading the current form to retaining the signed copy for the required period. Complete and sign the form before the authorized filer submits the FBAR.
- Download the current Form 114a from FinCEN. The form is available as a PDF on fincen.gov. Confirm you have the most recent version by checking the revision date in the footer – the current version is Rev. 10.7, dated May 2015.
- Enter the filer’s information – Part I. Fill in your name and taxpayer identification number – SSN, ITIN, or EIN for entities – and check the TIN type box. Part I has no address or date of birth field. If both spouses are completing the form, each spouse fills in their information in Part I.
- Identify the authorized third-party filer – Part II. Enter the preparer’s or filing spouse’s name, PTIN if they have one, and address. If the preparer works for a firm, use the firm’s address and add the employer’s name and EIN. When a spouse is acting as the authorized filer, the FinCEN Form 114a instructions printed on the form specifically call for completing Part II “in its entirety” – not with shorthand like “see above.” Completing Part II in full is good practice for any preparer.
- Specify the tax year covered. The form has a single field for the filing year ending December 31 of the calendar year being reported. Enter the applicable year – for example, 2025 for FBARs filed during the 2026 season.
- Sign and date the form. The account owner signs Item 7 and dates Item 8. A spouse who is a joint owner signs Item 11 and dates Item 12. The authorized filer signs Item 26. The form may be digitally signed, and FinCEN names no specific technical standard for any of these signatures.
- Provide a copy to the authorized filer before submission. The authorized filer needs the signed Form 114a in their possession as documented authority to file. FinCEN’s guidance ties the preparer’s authority to having this form on hand.
- Retain the original for five years. Both the filer and the authorized preparer keep a copy of the signed Form 114a for five years from the FBAR due date, per 31 CFR 1010.430(d). Digital copies are acceptable if they remain legible and accessible.
Form 114a for spouses: jointly held foreign accounts
A married couple with only jointly held foreign accounts can file a single FBAR if one spouse completes Form 114a authorizing the other to file on their behalf.
This eliminates the need for two separate filings and is the most common use of Form 114a outside paid preparer situations.
The spousal exception applies when all three 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 all jointly owned accounts on a timely filed FBAR.
- Both spouses complete and sign Form 114a.
“Jointly held” under BSA rules means both spouses appear on the account as co-owners. If either spouse holds any account individually – even a small savings account in one name only – the exception fails, and both spouses must file separate FBARs. Each spouse’s separate FBAR must include the jointly held accounts at their full value.
Income tax filing status has no effect on this exception. Married-filing-jointly on Form 1040 does not determine whether spouses can file a joint FBAR.
Based on a common TFX client scenario: Sarah and James are US citizens living in Singapore. They share a joint HSBC checking account and a joint DBS savings account. Neither holds any individual foreign accounts. Sarah completes Part I of Form 114a, James completes Part I and Part II, and James files one FBAR covering both accounts. One filing, one form.
If Sarah also had a separate brokerage account in her name only, the exception would not apply. Both would file separate FBARs, and each would report the full value of the joint accounts plus their individual accounts.
See our guide to FBAR joint filing for married couples for a detailed breakdown of the rules.
Tax professionals and third-party filer authorization
When a CPA, enrolled agent, or tax attorney files an FBAR on a client’s behalf, the client must sign Form 114a before the preparer submits. FinCEN’s guidance makes the preparer’s authority to file depend on having this documented authorization.
A tax preparer who files an FBAR without a signed Form 114a on file is not following FinCEN’s third-party filing guidance, regardless of whether the FBAR itself is accurate.
FinCEN’s FAQ for preparers states that without Form 114a, the authority to file “is not provided” and “the filings must be signed and submitted by the client.”
Preparer obligations:
- Obtain a signed Form 114a from every client whose FBAR you file electronically.
- Register with FinCEN’s BSA E-Filing System as an institution. The individual filer option is not available for third-party filings.
- Retain the signed form for five years from the FBAR due date.
For a broader look at who has filing authority over foreign accounts, see our guide to FBAR signature authority.
Client rights:
- You can revoke the authorization at any time by notifying the preparer in writing.
- The FBAR remains your legal responsibility. Form 114a states that the filing obligation stays with you, “not that of the preparer listed in Part II.”
BSA E-Filing System: how Form 114a fits in
All FBARs must be filed electronically through the BSA E-Filing System at bsaefiling.fincen.gov. Form 114a is the authorization record that makes third-party electronic submission permissible under FinCEN’s framework.
If you file your FBAR directly through the BSA E-Filing System without a preparer, you do not need Form 114a. The system captures your electronic signature during submission, and no separate authorization is required.
Form 114a comes into play only when someone other than the person with the filing obligation submits the FBAR.
Individual vs. institutional filing
The BSA E-Filing System distinguishes between individual filers – who file their own FBARs – and institutional filers – preparers, firms, and organizations filing on behalf of clients. Preparers must register as institutions before they can submit FBARs for clients.
The system itself does not check whether a Form 114a exists. Filing goes through regardless. The form is a compliance record – it matters during an examination or inquiry, not during the electronic submission.
See our FBAR filing guide for a full walkthrough of the BSA E-Filing submission process.
Form 114a due date and FBAR filing deadlines
Because Form 114a must exist before the FBAR is filed, expats using a preparer should sign and return the authorization form well before the filing deadline.
The FBAR for tax year 2025 follows this timeline:
- April 15, 2026 – original FBAR deadline, now passed.
- October 15, 2026 – automatic extended deadline. No extension request is required, and no form needs to be filed with FinCEN. Filing at any point before this date is timely.
- After October 15, 2026 – the FBAR is late. See our guide to delinquent FBAR filing for the available options.
The Form 114a due date is effectively the same as the FBAR submission date. There is no separate deadline for the authorization form – it simply needs to be signed and in the preparer’s hands before they click submit.
The FBAR deadline is independent of your income tax return. The automatic June 15 extension for US taxpayers living abroad and Form 4868 extensions apply to Form 1040 only – not to the FBAR.
One exception: under FinCEN Notice FIN-2025-NTC3, individuals filing solely to report signature authority over certain foreign accounts have a separate extension through April 15, 2027, for calendar year 2025. This does not apply to most individual filers.
Form 114a country code reference
The Form 114a country code field – Item 23 in Part II – requires a two-letter country code for the authorized filer’s address, or their employer’s address if the preparer works for a firm. Part I, the account owner’s section, has no country code field.
Both forms follow the ISO 3166-1 alpha-2 standard. On the FBAR, using the wrong code can trigger a processing error in the BSA E-Filing System, so verify each code before filing.
NOTE! Form 114a is never submitted to the BSA E-Filing System, so a processing error can only come from the FBAR.
Common country codes for US expats:
- GB – United Kingdom
- DE – Germany
- CA – Canada
- AU – Australia
- SG – Singapore
- CH – Switzerland
- FR – France
- JP – Japan
- NL – Netherlands
- ES – Spain
Note that the United Kingdom uses “GB” – derived from “Great Britain” – not “UK.” This is the single most common country code error TFX sees on Form 114a and FBAR filings.
Record retention requirements for Form 114a
Both the filer and the authorized preparer must retain a copy of the signed Form 114a for five years from the FBAR due date, under 31 CFR 1010.430(d).
For a calendar year 2025 FBAR due April 15, 2026, that means keeping records until at least April 15, 2031.
The five-year record retention rule for Form 114a mirrors the FBAR record retention requirement – both the account holder and the preparer share this obligation.
Retention applies to:
- The signed Form 114a itself.
- The filed FBAR and BSA confirmation.
- Supporting account records – statements showing maximum balances, exchange-rate documentation, and account details.
- Digital copies are acceptable provided they remain legible and accessible.
Review the FinCEN 114a instructions printed on the form for confirmation: “The person(s) listed in Part I, and the person listed in Part II as authorized to file on behalf of the person(s) listed in Part I, should retain copies of this record of authorization and the filing itself, both for a period of 5 years.
How Form 114a relates to FATCA and Form 8938
Form 114a is a BSA/FinCEN authorization document. It is entirely separate from FATCA reporting on IRS Form 8938.
Having a preparer file your FBAR using Form 114a does not automatically authorize them to file your Form 8938. The FBAR authorization covers only FinCEN Form 114 and related communications. Form 8938 is filed with your income tax return, and your preparer’s authority to e-file it comes from the return’s e-file signature authorization – Form 8879, not Form 114a.
The two reporting regimes differ in three important ways:
- Form 114a authorizes FBAR filing – FinCEN jurisdiction, $10,000 aggregate account threshold.
- Form 8938 is filed with the IRS as part of your tax return – IRS jurisdiction, with higher thresholds starting at $200,000 year-end / $300,000 at any time for single filers living abroad (2025).
- Different authorized-filer rules. Power of attorney for IRS representation requires Form 2848, which is separate from both Form 114a and Form 8879.
Many expats with foreign accounts need to file both an FBAR and Form 8938 in the same year. Having your preparer handle both forms requires two separate authorizations – Form 114a for the FBAR, and Form 8879 for the tax return, which covers Form 8938.
See our guide to FBAR vs. Form 8938 for a full side-by-side comparison of thresholds, reporting scope, and penalties.
Common scenarios requiring Form 114a: expat examples
Form 114a is required any time the person who signs the authorization is not the same person who clicks submit in the BSA E-Filing System. The following four TFX scenarios illustrate the most common situations.
- American in Germany using a US-based CPA. He has three German bank accounts exceeding $10,000 in aggregate. His US-based CPA files the FBAR on his behalf through the BSA E-Filing System. David completes Part I, signing Item 7 and dating Item 8, and provides the signed form to the CPA before submission. The CPA completes Part II – including the firm’s US address and country code – and retains the signed form for five years.
- Married couple in Singapore with a joint HSBC account. Both spouses are US citizens. All foreign accounts are jointly held. One spouse signs Form 114a authorizing the other to file a single FBAR covering both. This avoids two separate filings – but only because no individually held accounts exist.
- US business owner with a foreign subsidiary. A US LLC owner authorized her CFO to work with the company’s CPA to file a consolidated FBAR for the entity’s foreign accounts. The LLC’s authorized officer signs the FBAR 114a authorization on behalf of the entity, designating the CPA as the filer.
- Expat switching to a preparer mid-year. An American in London self-filed FBARs for the past three years. This year, she hired a tax professional. Even though she filed before without a preparer, the transition year requires a signed Form 114a because someone other than her is now submitting.
Electronic signature requirements for Form 114a
FinCEN accepts digital signatures on Form 114a. The form states that Items 7, 11, and 26 “may be digitally signed,” and no specific technical standard is named.
An electronic signature on Form 114a is valid for remote authorization, so Americans living overseas can sign without mailing a paper form. Standard e-signature platforms work. A wet ink signature is not required.
FinCEN has not published specific technical requirements beyond stating that digital signatures are acceptable. What matters is that the signed record can be produced if FinCEN or the IRS requests it.
Best practices for e-signing Form 114a:
- Use a method that records identity, intent, and a timestamp.
- Retain the signed PDF for five years from the FBAR due date.
- A scanned wet signature saved as a PDF meets the same standard as a digitally applied signature – the key is that the document is legible, complete, and accessible.
Penalties for FBAR non-compliance and how Form 114a fits in
A missing or unsigned Form 114a does not itself trigger an FBAR penalty, but it can undermine a preparer-authorization defense if the IRS or FinCEN questions who filed the report. The penalties below apply to the FBAR filing obligation itself, not to the authorization form.
FBAR penalties are set by the Bank Secrecy Act under 31 USC § 5321 and adjusted annually for inflation. For assessments on or after January 17, 2025, the maximums are:
- Non-willful violations: up to $16,536 per annual FBAR report. Per the Supreme Court’s 2023 ruling in Bittner v. United States, non-willful penalties apply per report, not per account. May be waived entirely under a reasonable-cause showing.
- Willful violations: up to the greater of $165,353 or 50% of the account balance at the time of the violation, per account. No reasonable-cause defense.
- Criminal penalties: fines up to $250,000 and/or imprisonment up to five years under 31 USC § 5322. Reserved for intentional concealment or fraud.
These penalty figures remain in effect for 2026. In OMB Memorandum M-26-11, OMB canceled the 2026 penalty inflation adjustments for all federal agencies, including FinCEN, so the 2025 amounts carry over unchanged.
Where Form 114a fits: if FinCEN or the IRS examines who filed the FBAR and why, having a properly signed Form 114a on file demonstrates that the preparer had documented authority. A missing form creates a gap in the compliance record that could complicate a reasonable-cause argument.
For a detailed breakdown of FBAR penalty ranges and mitigation, see our guide to FBAR penalties.
How to download the Form 114a PDF and where to find it
Always download Form 114a directly from fincen.gov to make sure you have the current version – third-party PDF copies may be outdated.
To download the FinCEN Form 114a PDF:
- Go to the FinCEN website at fincen.gov.
- Download the current Form 114a PDF directly. The current version is Rev. 10.7, dated May 2015.
- Verify the revision date in the footer before signing.
- Save a copy for your records before completing and signing the form.
The Form 114a PDF is also accessible from the BSA E-Filing FBAR page, where it is listed alongside the FBAR filing options.
Do not upload the completed Form 114a to the BSA E-Filing System. The form is retained in your records – it is not part of the electronic FBAR submission.
Catching up on missed FBARs: Streamlined Procedures and Form 114a
Expats using the Streamlined Procedures to file multiple years of delinquent FBARs must provide a separate Form 114a authorization for each tax year their preparer submits. The form has a single calendar-year field and does not support multi-year authorization.
Expats who have not filed FBARs for prior years have two main catch-up paths:
- Streamlined Foreign Offshore Procedures – SFOP: for non-willful filers living abroad. Covers three years of tax returns plus six years of FBARs, with a 0% offshore penalty. The filer certifies non-willful conduct on Form 14653.
- Streamlined Domestic Offshore Procedures – SDOP: for non-willful filers living in the US. Same filing scope, with a 5% miscellaneous offshore penalty using Form 14654.
When a tax professional files the delinquent FBARs through the BSA E-Filing System, each FBAR year requires its own signed Form 114a – typically six forms for a full Streamlined submission.
See our guide to Streamlined Foreign Offshore Procedures for eligibility, filing requirements, and timeline.
Form 114a for entities: corporations, partnerships, and trusts
For entity filers, Form 114a must be signed by an officer or agent with actual authority to bind the entity – a general employee signature is not sufficient.
Corporations, LLCs, partnerships, trusts, and estates have their own FBAR obligations when they meet the same three-part test as individuals: US person status, financial interest in or authority over foreign accounts, and aggregate value exceeding $10,000.
When an entity uses a tax professional to file its FBAR:
- The entity’s authorized officer or agent completes Part I of Form 114a, entering the entity’s name and EIN.
- The preparer completes Part II.
- The officer signs, confirming they have the authority to authorize filing on the entity’s behalf.
Special considerations for trusts and estates:
- A US trust with foreign accounts files its own FBAR. The trustee signs Form 114a as the authorized person.
- An estate’s personal representative or executor signs on behalf of the estate.
- Trust beneficiaries with a financial interest may have their own individual FBAR obligations, requiring a separate Form 114a for each beneficiary whose FBAR is prepared by a third party.
For corporate groups with majority-owned subsidiaries, see our guide to consolidated FBAR filing.
For the broader entity-level US reporting requirements, see our foreign company tax reporting guide.
Troubleshooting common Form 114a errors
The most common Form 114a mistake is signing the authorization after the FBAR has already been submitted – the form should be signed first, every time. The five errors below cover the issues TFX sees most often.
- Signing after the FBAR is already submitted. The FBAR 114a instructions establish that authorization must be in place before filing. FinCEN’s guidance makes the preparer’s authority depend on having the signed form. If you realize the form was signed late, document the timeline and keep both records.
- Wrong tax year listed. The form covers one calendar year. Verify that the year in the “filing year ending December 31” field matches the FBAR being filed. A 2025 FBAR requires “2025” on the Form 114a – not 2026.
- Missing or illegible signature. FinCEN requires a clear, valid signature on the form – digital or wet. An unsigned or partially signed form leaves the preparer without documented authority.
- Incorrect country code. Cross-check the Item 23 country code in Part II, and every country code on the FBAR itself, against the ISO 3166-1 alpha-2 list. The most common error: using “UK” instead of “GB” for the United Kingdom.
- Preparer fails to retain a copy. Both the filer and the preparer must keep the signed form for five years from the FBAR due date. The preparer cannot rely on the client to produce it later – each party keeps their own copy.
Frequently asked questions
No. Form 114a is required only when a third party or spouse files the FBAR on your behalf through the BSA E-Filing System. If you file directly, the system captures your electronic signature, and no separate authorization is needed.
No. The form is retained by the filer and the authorized preparer. It is not transmitted to FinCEN or the IRS unless they request it during an examination.
Form 114a must be signed before the FBAR is submitted. For tax year 2025, the FBAR was due April 15, 2026, with an automatic extension to October 15, 2026. Follow the FinCEN 114a instructions and get the form signed before your preparer submits.
No. The form has a single calendar-year field. If your preparer files FBARs for multiple years, you need a separate signed Form 114a for each year.
Use “GB” – the ISO 3166-1 alpha-2 code for the United Kingdom. Do not use “UK,” which is not a valid code in FinCEN’s system. Form 114a has no field for your bank’s country. Its only country code field, Item 23, is for the preparer’s address.
Both the filer and the preparer retain the signed form for five years from the FBAR due date. For a 2025 FBAR, that means keeping it until at least April 15, 2031.
Yes, if all foreign accounts are jointly held. One spouse signs Form 114a authorizing the other to file a single FBAR covering both. If either spouse holds an individual account, separate FBARs are required.
The preparer is not following FinCEN’s third-party filing guidance. While this does not automatically trigger an FBAR penalty, it creates a documentation gap that could complicate any future FinCEN or IRS inquiry into the filing.
Related articles
Learn FBAR Form 114 filing requirements, the $10,000 threshold, 2026 deadline, extensions, account reporting rules, and how to file with FinCEN.
Read more
Learn who must file an FBAR in 2026, which foreign accounts to report, how the $10,000 threshold works, and the April and October 2026 deadlines.
Read more
Learn who can file a consolidated FBAR, how signature authority and financial interest rules apply to corporations, and how to complete FinCEN Form 114 correctly.
Read more
Learn how to fix FBAR mistakes with the right correction path, penalty guidance, and filing steps for amended FBARs, delinquent submissions, streamlined procedures, and VDP.
Read more
Understand FBAR signature authority in 2026: definition, exceptions, examples, and how it differs from financial interest. Stay compliant with FinCEN 114 reporting.
Read more
Learn FBAR joint filing rules for married couples, including Form 114a, joint-account reporting, separate accounts, deadlines, and when two FBARs are required.
Read more
Do Wise and Revolut accounts need FBAR reporting? Learn how to report Wise on FBAR, find the correct address, deadlines, and whether these fintechs report to the IRS.
Read more
Compare FBAR vs Form 8938, learn who files each form, review thresholds and deadlines, and avoid costly foreign asset reporting mistakes.
Read more
Do you need to file a crypto FBAR? Learn 2026 cryptocurrency FBAR reporting requirements, thresholds, penalties, and which foreign exchanges trigger FinCEN Form 114.
Read more
