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FBAR (FinCEN Form 114): Who Files and How

By The Ledgerism Editorial Team · The Ledgerism Brief Editorial Team produces original, methodology-disclosed accounting and tax research—data trackers, databases, and reference guides built to be the most-cited source in the field. Every figure is verified against primary sources including FASB, the IRS, the PCAOB, NASBA, the AICPA, and state boards of accountancy.

The FBAR (Report of Foreign Bank and Financial Accounts, filed on FinCEN Form 114) is required from any U.S. person whose foreign financial accounts, added together, exceeded $10,000 at any point during the calendar year. You file it electronically through the Financial Crimes Enforcement Network (FinCEN), not with the IRS, and not with your tax return. The 2025 return year FBAR is due April 15, 2026, with an automatic extension to October 15, 2026.

Who Must File an FBAR

A U.S. person must file an FBAR if they had a financial interest in, or signature or other authority over, at least one foreign financial account and the aggregate value of all such accounts exceeded $10,000 at any time during the calendar year. “U.S. person” is broad: it covers citizens, resident aliens, and U.S. entities.

The filing obligation reaches individuals and organizations alike. The IRS lists U.S. citizens, U.S. residents, corporations, partnerships, limited liability companies, trusts, and estates as potential filers.

Signature authority alone can trigger the requirement. An employee who can direct the disposition of funds in an employer’s foreign account may have to file even with no ownership stake, though certain officer and employee exceptions can apply depending on the arrangement.

The $10,000 Aggregate Threshold

The threshold is $10,000, measured in aggregate across every foreign account, at the highest point during the year, not the year-end balance. You add the maximum values of all foreign accounts together. If that combined figure passed $10,000 for even a single day, the filing requirement applies for the whole year.

This trips up people with several small accounts. Four accounts holding $3,000 each never individually reach $10,000, but their $12,000 combined maximum crosses the line.

A brief spike counts. A payroll deposit, a property sale, or a temporary transfer that pushed the aggregate over $10,000 for one day may create the obligation, even if balances fell back the next week. Values in foreign currency are converted to U.S. dollars using the Treasury year-end exchange rate.

What Counts as a Foreign Financial Account

Foreign real estate and directly held foreign stock do not go on the FBAR, though directly held foreign securities may still be reportable on Form 8938. That distinction matters, because the two forms often apply to the same taxpayer for different reasons. Foreign accounts holding digital assets raise their own questions; our overview of crypto tax accounting and Form 8949 reporting covers how those balances are tracked for tax purposes.

How to File: E-Filing Through the BSA System

The FBAR is filed electronically through FinCEN’s BSA E-Filing System, separate from the IRS and separate from your income tax return. There is no paper form to mail in the ordinary case. Filers use the online FinCEN Form 114 or the downloadable PDF version submitted through the same system.

Follow these steps:

1. Gather account details for each foreign account: institution name, address, account number, account type, and the maximum value during the year.
2. Convert each maximum value to U.S. dollars using the Treasury Reporting Rates of Exchange for December 31 of the year reported.
3. Go to the BSA E-Filing System at bsaefiling.fincen.gov and choose the individual FBAR filing option (no account registration is required for individuals).
4. Complete FinCEN Form 114, listing each account and the filer’s identifying information.
5. Submit and save the confirmation. Retain records for five years from the due date.

A spouse can sometimes be included on one FBAR, but only if all foreign accounts are jointly owned and other conditions are met. Otherwise each spouse files separately. A third party filing on your behalf (a tax preparer) uses FinCEN Form 114a to document that authorization; Form 114a is kept in your records, not submitted.

The April 15 Deadline and Automatic October 15 Extension

The FBAR is due April 15 following the calendar year reported, the same date as the individual income tax return. Filers who miss April 15 receive an automatic extension to October 15 with no request, no form, and no action required.

You do not file Form 4868 or any other extension request to get the October 15 FBAR date; the extension is granted automatically. This differs from the income tax return, where an extension must be requested. For anyone weighing a broader delay, see our guide to filing a personal tax extension on Form 4868.

Disaster relief can push the date further for filers in federally declared disaster areas. FinCEN typically posts specific relief notices when this applies.

FBAR vs Form 8938: Two Different Filings

The FBAR and Form 8938 (Statement of Specified Foreign Financial Assets) are separate obligations with different agencies, thresholds, and scope. Filing one does not satisfy the other. Many taxpayers abroad file both. Form 8938 goes to the IRS with your Form 1040; the FBAR goes to FinCEN on its own.

The scope differs beyond the numbers. Form 8938 captures assets the FBAR ignores, such as foreign stock or securities held directly (not through an account) and interests in certain foreign entities. If you cross both sets of thresholds, you report the overlapping accounts on both forms. Owners of foreign corporations may face a separate layer of reporting entirely; see our guide to Form 5471 for U.S. persons with foreign corporation interests.

FBAR Penalties

Penalties depend on whether the failure to file was non-willful or willful, and the caps are adjusted for inflation. For penalties assessed on or after January 17, 2025, the non-willful maximum is $16,536 per report, and the willful maximum is the greater of $165,353 or 50% of the account balance at the time of the violation.

The Supreme Court’s 2023 decision in Bittner v. United States established that the non-willful penalty applies per annual FBAR report, not per account. A filer with 10 unreported accounts on one late FBAR faces one non-willful penalty for that year, not 10.

Willful violations carry far higher exposure and can, in serious cases, bring criminal charges. The 50% option means a large unreported account can generate a penalty tied to its balance rather than a fixed cap.

Reasonable cause can reduce or eliminate a non-willful penalty. Filers who simply did not know about the requirement may qualify for the Delinquent FBAR Submission Procedures (filing late with a reason statement) or the Streamlined Filing Compliance Procedures, depending on the facts. Both are IRS/FinCEN programs, and eligibility depends on the specific circumstances.

Frequently Asked Questions

Do I file the FBAR with my tax return?

No. The FBAR (FinCEN Form 114) is filed separately from your federal income tax return, and it goes to FinCEN through the BSA E-Filing System, not to the IRS. Even if a preparer handles both, the FBAR is submitted on its own. Attaching foreign account information to Form 1040, or filing Form 8938, does not satisfy the FBAR requirement.

What is the FBAR filing threshold?

You must file if the aggregate value of all your foreign financial accounts exceeded $10,000 at any time during the calendar year. It is a combined figure across every account, measured at the highest point in the year, not the year-end balance. A short-lived spike above $10,000, even for one day, can trigger the requirement for the entire year.

When is the FBAR due?

The FBAR is due April 15 following the reported calendar year. Filers who miss that date receive an automatic extension to October 15 with no request or form required. For the 2025 calendar year, that means April 15, 2026, extended automatically to October 15, 2026. Disaster relief may extend the date further in some cases.

Do I have to file both the FBAR and Form 8938?

Often, yes. They are separate requirements with different thresholds, agencies, and scope, so many taxpayers with foreign accounts file both. The FBAR threshold ($10,000 aggregate) is far lower than Form 8938 thresholds ($50,000 and up, higher for those living abroad), so you can owe an FBAR without owing Form 8938, or both at once.

What happens if I file the FBAR late?

A late FBAR filed before the IRS contacts you, with no unreported income, may qualify for the Delinquent FBAR Submission Procedures, which can avoid penalties when there is a reasonable explanation. Otherwise, a non-willful failure carries a penalty up to $16,536 per report (2025 figure), while willful failures can reach the greater of $165,353 or 50% of the account balance.

Does signature authority alone require filing?

It can. If you have signature or other authority over a foreign account, meaning you can control the disposition of its funds, you may have to file even without any ownership interest. Certain exceptions exist for officers and employees of some entities, so the outcome depends on the specific arrangement and the type of employer involved.

Reviewed by The Ledgerism Editorial Team. Last reviewed: July 2026.

Related guides

• Form 8938 Explained
• Form 3520
• Form 5471 Explained