Full guide: FBAR filing requirements and deadlines in 2025

Whether you live in the US or abroad, if you hold an account in a foreign bank — whether savings, pension, or investment — you may be required to comply with FBAR (Report of Foreign Bank and Financial Accounts) filing requirements. Many Americans are unaware that simply having a foreign bank account can trigger FBAR obligations.

The US government enforces foreign account reporting through international agreements, requiring foreign banks to share details on US account holders. So, don’t assume your accounts will go unnoticed.

In this article, we explain everything you need to know about foreign bank account reporting (FBAR).

What is FBAR?

The Foreign Bank and Financial Accounts Report (FBAR) helps the US government detect tax evasion and money laundering involving foreign bank accounts. FBAR is filed using FinCEN Form 114.

You must file an FBAR if the combined balance of your foreign bank accounts exceeded $10,000 at any time during the calendar year. This includes:

• personal accounts in foreign banks
• securities and brokerage accounts
• mutual funds
• insurance or annuity policies with a cash value

FBAR is not a tax form, and its filing is not based on tax rates. However, income earned from foreign bank accounts is subject to US taxation and may also be taxed in the country where the accounts are held.

Who is required to file an FBAR?

You must file an FBAR if all three of these apply:

The $10,000 threshold applies to the total of all accounts combined, not to each account individually.

Financial interest includes direct ownership or indirect interests, such as bank accounts held through entities you control or trusts where you are a beneficiary.

Signature authority means you can control account assets, such as managing a parent’s bank account or handling a corporate account. Note that even if you don’t own the account, you may still have an FBAR filing obligation if you have the authority to direct transactions, access funds, or make decisions on behalf of the account holder.

How to file FBAR

You can file FBAR yourself or authorize a tax professional to file for you. To grant authorization, you’ll need to sign FinCEN Form 114a. You should keep this form in your records in case FinCEN or the IRS requests it.

Where to file FBAR

You must file FBAR electronically using the BSA E-Filing System:

1. Create a BSA E-Filing account to file FBAR.
2. Complete FinCEN Form 114 with details about each account, including account numbers, institution names, and maximum balances during the year.
3. Submit the FinCEN Form 114 electronically.

If you want to file a paper FBAR, you must request an exemption by calling FinCEN’s Resource Center. Paper filing is allowed only if FinCEN approves it for you.

What to include on the FBAR

Report all foreign bank accounts if their combined value exceeded $10,000 at any point in the year. Reportable accounts include:

• foreign bank accounts and investment accounts
• retirement and pension accounts
• foreign mutual funds
• life insurance or annuities with cash value
• foreign bank accounts at US bank branches abroad

How to report joint accounts

If you share an account with your spouse, they can authorize you to file for both of you by signing FinCEN Form 114a.

If your spouse has separate foreign bank accounts, they must file their own FBAR. Joint accounts should appear on both FBARs if you file separately.

What records to keep

You must maintain records for each account reported on the FBAR, including account holder’s name, account number, bank name and address, type of account, and maximum balance during the year.

You can keep bank statements or copies of filed FBARs containing this information. Records must be kept for five years from the due date of the FBAR.

FBAR deadline

FBAR must be filed by April 15 of the year following the calendar year being reported.

If you miss this due date, an automatic extension is granted until October 15 to file FBAR – no request required.

Penalties for not filing FBAR

Failing to file an FBAR can lead to serious consequences. If the violation is non-willful – caused by negligence or misunderstanding – the penalty can be up to $10,000 per violation, adjusted for inflation (currently $12,921).

Willful violations, where there is intentional or reckless disregard, carry much steeper penalties: the greater of $100,000 or 50% of the account balance at the time of the violation.

In the most severe cases, willful violations can also result in criminal charges, with fines up to $250,000 and/or up to five years in prison.

Missed the FBAR deadline?

If the IRS hasn’t contacted you yet, file FBAR as soon as possible to reduce potential penalties. Waiting too long increases the risk of costly fines, but at Taxes for Expats we can help you navigate the process stress-free.

If you qualify, our team can guide you through the IRS Streamlined Compliance Procedures – a penalty-free way to catch up on past filings. We handle everything, from preparing the necessary forms to crafting a strong explanation for late FBAR submission, ensuring you stay compliant with minimal hassle.

FBAR vs. FATCA (Form 8938): key differences

FATCA (Foreign Account Tax Compliance Act) is another reporting requirement for Americans with foreign financial assets. Although FBAR and FATCA (Form 8938) both involve foreign bank account reporting, they serve different purposes and have distinct requirements.

Consult the table below for key differences between FATCA and FBAR:

Need help with FBAR filing?

FBAR filing requirements can be complex, especially when managing multiple foreign accounts or dealing with intricate financial situations. At Taxes for Expats, we understand the challenges of expat tax filing and are here to help guide you through every step.

Our team of tax experts specializes in both US tax returns and FBAR filings, ensuring that everything is completed correctly and submitted on time.