FBAR Filing Guide: Complete Requirements for 2026
Professional guidance on FinCEN Form 114 reporting requirements for U.S. persons with foreign bank accounts. Understand the $10,000 threshold, filing deadlines, and how to avoid penalties up to $165,353.
What You Need to Know About FBAR
The FBAR (FinCEN Form 114) is required if you had a financial interest in, or signature authority over, foreign financial accounts with an aggregate value exceeding $10,000 at any point during the calendar year. This is separate from your tax return and filed directly with FinCEN. Penalties for non-compliance can reach $165,353 or 50% of account balances for willful violations.
Key Takeaways: FBAR at a Glance
- Who files: U.S. citizens, residents, and entities with foreign accounts exceeding $10,000 aggregate
- Threshold: $10,000 combined maximum value across ALL foreign accounts at any time during the year
- Deadline: April 15, with automatic extension to October 15 (no form needed)
- 2026 non-willful penalty: Up to $16,536 per violation
- 2026 willful penalty: Greater of $165,353 or 50% of account balance per violation
- Filed with: FinCEN (Treasury), NOT the IRS. Electronic filing only at bsaefiling.fincen.gov
FBAR vs Form 8938: Quick Comparison
| Feature | FBAR (FinCEN 114) | Form 8938 (FATCA) |
|---|---|---|
| Filed With | FinCEN (Treasury Dept.) | IRS (with tax return) |
| Threshold (US Resident) | $10,000 | $50,000 (single) / $100,000 (MFJ) |
| What’s Reported | Foreign bank/financial accounts only | All foreign financial assets |
| Filing Method | Electronic only (BSA E-Filing) | Attached to Form 1040 |
Complete FBAR Filing Coverage
What is FBAR (FinCEN Form 114)?
FBAR stands for “Report of Foreign Bank and Financial Accounts.” The official form is FinCEN Form 114, filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury. Despite what many assume, FBAR is not an IRS form and is not part of your tax return.
The FBAR requirement dates back to the Bank Secrecy Act of 1970, originally designed to combat money laundering and tax evasion. Today, it serves as a key tool for U.S. government visibility into Americans’ overseas financial holdings.
FBAR Is Not Part of Your Tax Return
Unlike Form 8938 (FATCA), which is attached to your Form 1040, FBAR is filed separately through the BSA E-Filing System. Filing your tax return does NOT satisfy your FBAR obligation, and vice versa. Many taxpayers are unaware they need to file both.
Why FBAR Compliance Matters
The IRS and FinCEN have significantly increased enforcement of FBAR requirements. Information-sharing agreements with foreign countries (including FATCA and Common Reporting Standard) mean the U.S. government often already knows about your foreign accounts before you file. Non-compliance is increasingly likely to be detected.
Beyond detection risk, FBAR penalties are among the most severe in tax law. Non-willful penalties can reach $16,536 per violation (2026 inflation-adjusted). Willful violations can result in penalties of $165,353 or 50% of account balance, whichever is greater, plus potential criminal prosecution.
Who Must File an FBAR
The FBAR filing requirement applies to “U.S. persons” with foreign financial accounts. This definition is broader than many expect and includes:
U.S. Citizens
- Citizens living in the U.S.
- Expats living abroad
- Dual citizens (regardless of residence)
- Citizens who have never lived in the U.S.
U.S. Residents
- Green card holders (lawful permanent residents)
- Individuals meeting substantial presence test
- Those who elect to be treated as residents
- Resident aliens for tax purposes
U.S. Entities
- Corporations formed under U.S. law
- Partnerships organized in U.S.
- LLCs (including single-member)
- Trusts and estates under U.S. jurisdiction
Financial Interest vs. Signature Authority
FBAR filing is required if you have either:
- Financial Interest: You own the account, or the account is held by an entity you own more than 50% of, or you’re the beneficiary of a trust that owns the account
- Signature Authority: You can control the disposition of funds in the account, even if you have no financial interest (common for business officers, trustees, attorneys-in-fact)
Common Misconception: “I Don’t Owe Taxes on the Account”
FBAR is an information return, not a tax form. You must file even if the accounts generate no income, you owe no U.S. tax on the income, or the accounts are in a tax-free country. The reporting obligation is separate from any tax liability.
Understanding the $10,000 Threshold
The FBAR threshold is deceptively simple: you must file if the aggregate maximum value of all foreign financial accounts exceeded $10,000 at any point during the calendar year. However, several aspects of this rule catch taxpayers off guard.
Key Points About the Threshold
- Aggregate Value: You add together ALL your foreign accounts. If you have 10 accounts each with $2,000, you exceed the threshold.
- Maximum Value: Use the highest balance at any point during the year, not the year-end balance
- Any Single Day: If accounts combined exceeded $10,000 for even one day, you must file
- All Accounts Reported: Once you exceed the threshold, you report ALL foreign accounts, including those with small balances
Example: Threshold Calculation
On June 15, you had $6,000 in a UK bank account and $5,000 in a Canadian account. Your aggregate maximum was $11,000 that day, even though each account was under $10,000. You must file an FBAR and report both accounts, along with any other foreign accounts you held during the year.
Accounts That Count Toward the Threshold
- Bank accounts (checking, savings, time deposits)
- Securities accounts (brokerage, custody accounts)
- Mutual funds and similar pooled investments
- Accounts with financial value you can withdraw from
- Foreign insurance policies with cash value
- Foreign pension accounts (in many cases)
What Accounts Must Be Reported
Once you determine you exceed the $10,000 threshold, you must report all foreign financial accounts. The definition of “foreign financial account” is broad.
Accounts Requiring FBAR Reporting
Bank Accounts
- Checking and savings accounts
- Time deposits and CDs
- Foreign currency accounts
- Accounts with any withdrawal rights
Securities Accounts
- Brokerage accounts
- Custody accounts
- Margin accounts
- Any account holding securities
Other Financial Accounts
- Foreign mutual funds
- Unit investment trusts
- Foreign-issued insurance with cash value
- Commodity futures/options accounts
Accounts NOT Required on FBAR
- Accounts at U.S. military banking facilities
- Correspondent/nostro accounts of banks
- IRA accounts investing in foreign securities through U.S. institutions
- Foreign accounts held by U.S. government entities
- Real property held directly (not through an account)
Cryptocurrency and FBAR
FinCEN has indicated that virtual currency held at foreign exchanges may be reportable on FBAR. While the rules are still evolving, many tax professionals recommend reporting cryptocurrency held on foreign platforms. Proposed regulations would explicitly require this. Consult a tax professional for guidance on your specific situation.
FBAR Filing Deadlines for 2026
The FBAR deadline aligns with the tax filing deadline, but with an important automatic extension provision.
Key 2026 FBAR Dates
| Event | Date | Notes |
|---|---|---|
| FBAR Due Date | April 15, 2026 | For 2025 calendar year accounts |
| Automatic Extension | October 15, 2026 | No form required to request |
| Signature Authority Exception | April 15, 2027 | For accounts with signature authority only (no financial interest) |
Automatic Extension: No Form Required
Unlike tax return extensions, the FBAR extension to October 15 is automatic. You do not need to file any form or notify FinCEN. Simply file by October 15, and your filing is timely. However, this does not extend any tax return deadlines.
What Happens If You Miss the Deadline
Missing the FBAR deadline (including the automatic extension) can trigger penalties. The severity depends on whether the IRS determines the failure was willful or non-willful:
- Non-willful: Up to $16,536 per violation (2026)
- Willful: Greater of $165,353 or 50% of account balance
- Criminal: Up to $500,000 and 10 years imprisonment
How to File FBAR Online
FBARs must be filed electronically through the BSA E-Filing System. Paper filing is not permitted. Here’s the step-by-step process:
Determine Filing Requirement
Calculate aggregate maximum value of all foreign accounts during the year. If it exceeded $10,000 on any day, you must file.
Gather Account Information
For each foreign account, you’ll need: bank name, bank address, account number, account type, and maximum value during the year.
Convert to U.S. Dollars
Use the Treasury Department’s year-end exchange rate to convert foreign currency maximum values to USD.
Access BSA E-Filing System
Go to bsaefiling.fincen.gov. You can file without creating an account, though registration allows you to save and track filings.
Complete FinCEN Form 114
Enter personal information and details for each foreign account. Complete all required fields for each account held during the year.
Submit and Save Confirmation
Review for accuracy, submit electronically, and save the confirmation number. Keep records for at least 5 years.
Information Needed for Each Account
FBAR vs Form 8938 (FATCA)
Many taxpayers confuse FBAR with Form 8938 or assume filing one satisfies both requirements. These are separate forms with different rules, thresholds, and filing requirements. Many people must file both.
Detailed Comparison
| Feature | FBAR (FinCEN 114) | Form 8938 (FATCA) |
|---|---|---|
| Filed With | FinCEN (Treasury) | IRS (with tax return) |
| Governing Law | Bank Secrecy Act | FATCA (IRC 6038D) |
| Threshold (US Resident Single) | $10,000 | $50,000 year-end / $75,000 any time |
| Threshold (US Resident MFJ) | $10,000 | $100,000 year-end / $150,000 any time |
| Threshold (Expat Single) | $10,000 | $200,000 year-end / $300,000 any time |
| Assets Covered | Foreign bank/financial accounts only | All foreign financial assets (broader) |
| Filing Method | Electronic only (BSA E-Filing) | Attached to Form 1040 |
| Deadline | April 15 (auto extension to Oct 15) | With tax return (extensions apply) |
| Penalty (Non-Willful) | Up to $16,536 per violation | $10,000 per failure |
Filing One Does NOT Satisfy the Other
FBAR and Form 8938 are completely separate obligations. If you meet the thresholds for both, you must file both forms with their respective agencies. Failure to file either can result in separate penalties.
For a complete comparison including when each applies and how to determine your requirements, see our detailed FBAR vs Form 8938 comparison guide.
FBAR Penalties and Relief Options
FBAR penalties are among the most severe in tax law. The IRS distinguishes between willful and non-willful violations, with dramatically different consequences.
2026 FBAR Penalty Structure
Per violation, depending on willfulness
Non-Willful Violations
A non-willful violation is due to reasonable cause, not intentional disregard. The penalty for 2026 is up to $16,536 per violation. A “violation” can be interpreted as per account or per FBAR, depending on the examiner and circumstances.
Willful Violations
Willful violations involve intentional disregard or reckless conduct. Penalties are the greater of $165,353 or 50% of the account balance at the time of the violation. This penalty applies per account, per year. Criminal prosecution is also possible, with penalties up to $500,000 and 10 years imprisonment.
Penalty Relief Options
- Reasonable Cause: If you can show reasonable cause for failure to file, penalties may be waived
- Delinquent FBAR Submission Procedures: For taxpayers who missed FBARs but had no unreported income from the accounts
- Streamlined Filing Compliance Procedures: For non-willful taxpayers with unreported income, reduced penalties
- IRS Voluntary Disclosure: For willful violations, a path to compliance with potential penalty mitigation
For detailed information on penalty relief programs and how to qualify, see our FBAR Penalties and Relief Guide.
Missed Prior Years? Your Options
If you’ve discovered you should have filed FBARs in prior years, you have several options. The right choice depends on your specific circumstances, particularly whether you have unreported income from the accounts.
Delinquent FBAR Submission Procedures
If you have no unreported income from your foreign accounts, you may qualify for the simplest remedy:
- File late FBARs through BSA E-Filing
- Include a statement explaining why FBARs were late
- No penalty typically assessed if requirements are met
- Must not be under IRS examination
- IRS must not have already contacted you about delinquent FBARs
Streamlined Filing Compliance Procedures
For non-willful taxpayers with unreported income from foreign accounts:
- File 3 years of amended tax returns
- File 6 years of FBARs
- Pay tax and interest on unreported income
- 5% miscellaneous offshore penalty (domestic) or no penalty (foreign residents)
- Certify non-willfulness under penalty of perjury
Act Before the IRS Contacts You
These relief programs are only available if you come forward before the IRS initiates an examination or contacts you about delinquent FBARs. Once the IRS reaches out, your options become more limited and expensive.
For step-by-step guidance on resolving delinquent FBARs, see our Delinquent FBAR Filing Guide.
FBAR Exchange Rate Conversions
FBAR values must be reported in U.S. dollars. The Treasury Department publishes official year-end exchange rates that must be used for FBAR conversions.
Which Rate to Use
- Use the Treasury Department’s year-end exchange rate for the year being reported
- Apply this rate to convert the maximum account value during the year
- Do not use the exchange rate on the day of maximum balance
- The same rate applies to all accounts in the same currency
Where to Find Official Exchange Rates
Treasury Department year-end rates are published at fiscal.treasury.gov. Use these rates, not bank rates or daily rates, for FBAR reporting purposes.
For current and historical exchange rates and conversion examples, see our FBAR Exchange Rate Guide.
Common FBAR Mistakes to Avoid
FBAR filings are often incorrect or incomplete, leading to potential penalties or IRS scrutiny. Here are the most common errors:
Top 10 FBAR Filing Mistakes
- Not knowing FBAR exists: Many taxpayers learn about FBAR only after receiving IRS correspondence
- Thinking FBAR and Form 8938 are the same: These are separate requirements with different rules
- Using year-end balance instead of maximum value: Report the highest balance at any point during the year
- Omitting closed accounts: Accounts open any time during the year must be reported, even if closed
- Ignoring signature authority accounts: You must report accounts you can sign on, even without financial interest
- Wrong exchange rate: Must use Treasury year-end rate, not daily or bank rates
- Missing the deadline: April 15 is the deadline, with automatic extension to October 15
- Not reporting all accounts: Once you exceed $10,000 aggregate, ALL accounts must be reported
- Incomplete account information: All fields should be completed for each account
- Thinking foreign residence exempts you: U.S. citizens and residents must file regardless of where they live
Professional Preparation Reduces Errors
Given the complexity of FBAR rules and severity of penalties, many taxpayers choose to work with CPAs experienced in international tax reporting. Professional preparation helps ensure accuracy and proper documentation. View our FBAR filing services.
Professional FBAR Preparation Services
Why Work With SDO CPA for FBAR Compliance
Our team helps U.S. persons with foreign accounts navigate FBAR requirements, from routine filings to complex penalty relief situations. View pricing and services →
FBAR Preparation
Complete FinCEN Form 114 preparation with accuracy verification
Requirement Analysis
Determine which accounts require reporting and proper thresholds
Currency Conversion
Proper exchange rate application for multi-currency accounts
Delinquent Filing
Assistance with prior-year filings and relief procedures
FATCA Coordination
Ensure both FBAR and Form 8938 requirements are met
Ongoing Compliance
Year-round support for international reporting obligations
Our Professional Credentials
- Licensed CPA firm in Texas serving clients nationwide
- 18+ years experience including Big Four background (EY, KPMG)
- Focus on international tax compliance
- Experience with FBAR penalty relief programs
- Clear communication and responsive service
Note on Professional Standards
SDO CPA adheres to all AICPA professional standards and Texas State Board of Public Accountancy regulations. We provide professional tax compliance services based on current law and regulations. Results depend on individual circumstances and proper documentation.
Related FBAR Topics
Professional FBAR preparation with transparent pricing and delinquent filing help
Key dates, automatic extensions, and what happens if you miss the deadline
Detailed comparison of requirements, thresholds, and when you need both
2026 penalty amounts and how to qualify for relief programs
Step-by-step process for filing late FBARs and avoiding penalties
Official Treasury rates and how to convert foreign currency balances
U.S. person definition, financial interest, and signature authority rules
Frequently Asked Questions About FBAR
What is the $10,000 FBAR threshold?
You must file an FBAR if the aggregate maximum value of all your foreign financial accounts exceeded $10,000 at any time during the calendar year. This is a combined total across all accounts, not per account. If you had $6,000 in one account and $5,000 in another on any given day, you exceed the threshold and must report all accounts.
When is the FBAR due?
The FBAR is due April 15 following the calendar year being reported. There is an automatic extension to October 15 with no form required. For 2025 accounts, the FBAR is due April 15, 2026, with automatic extension to October 15, 2026.
What is the penalty for not filing FBAR?
For 2026, non-willful FBAR penalties are up to $16,536 per violation. Willful violations can result in penalties of $165,353 or 50% of the account balance (whichever is greater), plus potential criminal prosecution with fines up to $500,000 and 10 years imprisonment.
What’s the difference between FBAR and Form 8938?
FBAR (FinCEN Form 114) is filed with the Treasury Department (FinCEN) and has a $10,000 threshold. Form 8938 is filed with the IRS as part of your tax return and has higher thresholds ($50,000-$600,000 depending on filing status and residence). Many people must file both forms, and the requirements are not identical.
Do I need to file FBAR if I have signature authority over a foreign account?
Yes. You must file an FBAR if you have signature authority or other authority over foreign financial accounts, even if you have no financial interest in the accounts. This commonly affects employees who can sign on company accounts, trustees, and those with power of attorney.
How do I file an FBAR?
FBARs must be filed electronically through the BSA E-Filing System at bsaefiling.fincen.gov. You cannot file a paper FBAR. The form is FinCEN Form 114 (not an IRS form). You will need account numbers, maximum values, and bank information for each foreign account.
What foreign accounts must be reported on FBAR?
FBAR requires reporting of all foreign financial accounts including bank accounts, securities accounts, mutual funds, and other financial accounts maintained at foreign financial institutions. Foreign accounts held by entities you own more than 50% of must also be reported. Certain accounts like correspondent accounts and accounts at U.S. military facilities are exempt.
What if I missed filing FBARs for prior years?
If you have unreported FBARs but no unreported income from those accounts, you may qualify for the Delinquent FBAR Submission Procedures, which typically result in no penalties. If you have unreported income, you may need the Streamlined Filing Compliance Procedures or IRS Voluntary Disclosure. Act before the IRS contacts you.
Are cryptocurrency accounts reportable on FBAR?
Cryptocurrency held on foreign exchanges may be reportable on FBAR if the exchange is a foreign financial institution. The rules are evolving, but FinCEN has indicated that virtual currency held in offshore accounts may be reportable. Consult a tax professional for your specific situation.
What exchange rate should I use for FBAR?
Use the Treasury Department’s year-end exchange rate to convert foreign currency to U.S. dollars for FBAR reporting. These rates are published annually and represent the official conversion rates for FBAR purposes. You must report the maximum value during the year, converted at the year-end rate.
Who is considered a U.S. person for FBAR purposes?
For FBAR purposes, a U.S. person includes U.S. citizens (including dual citizens), U.S. residents (green card holders), and domestic entities (corporations, partnerships, LLCs, trusts, and estates formed under U.S. law). The FBAR obligation follows citizenship/residency status, not where you live.
Is there a statute of limitations on FBAR penalties?
The statute of limitations for FBAR civil penalties is 6 years from the due date of the FBAR. There is no statute of limitations for criminal FBAR violations. The IRS can assess penalties for unfiled FBARs going back 6 years from the current date.
Need Help With FBAR Compliance?
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