FinCEN Form 114 requirements: Who must file and what to report
FBAR (FinCEN Form 114) is the Report of Foreign Bank and Financial Accounts – and it’s filed separately from your federal income tax return through FinCEN’s BSA E-Filing system, not with the IRS. If the aggregate value of your foreign financial accounts exceeds $10,000 at any time during the calendar year, you generally must file.
If you want help getting it done correctly (or catching up if you missed past years), you can learn more about our FBAR filing service.
What is FinCEN Form 114, and why does it matter to US persons overseas
There’s no difference between FBAR and FinCEN 114.
FinCEN Form 114 = Report of Foreign Bank and Financial Accounts (FBAR) required under the Bank Secrecy Act.
A common point of confusion is the phrase “IRS Form 114.” You may also hear it called “114 tax form,” but the filing itself is FinCEN’s responsibility, and the report is submitted through the BSA E-Filing system – not attached to Form 1040.
Why it matters: The US government uses FBAR reporting to combat money laundering and tax evasion, and it expects US persons with reportable foreign financial accounts to disclose them. The penalties for not filing – or filing incorrectly – can be significant, so it’s worth getting the filing right, especially if you’re correcting missed FBARs.
FinCEN Form 114 – who must file it?
The official rule is straightforward:
If you are a US person and you have a financial interest in – or signature/other authority over – one or more foreign financial accounts, you must file FinCEN Form 114 (FBAR) if the aggregate value of those accounts exceeds $10,000 at any time during the calendar year.
This also covers certain entities. In addition to individuals, some LLCs, corporations, partnerships, trusts, and estates can have FinCEN Form 114 filing requirements when they meet the same basic test (US person + reportable relationship to foreign financial accounts + over the threshold).
In other words, when people ask “FinCEN Form 114 who must file?” the answer is: a US person with a financial interest or authority over foreign accounts that cross the FinCEN 114 threshold.
FinCEN Form 114 due date and extension (2026 filing season deadline)
2026 FinCEN 114 deadline
For the 2026 filing season (reporting tax year 2025 / calendar year 2025 accounts), the FinCEN Form 114 due date is April 15, 2026. This is the standard Form 114 due date, and it applies even though the FBAR is not part of your federal return.
2026 FinCEN 114 extension
If you miss April 15, you get an automatic extension – no request needed. The FinCEN 114 extension pushes the deadline for filing FinCEN Form 114 to October 15, 2026. Many people call this the Form 114 extension.
NOTE! The FBAR official line item instructions can be found in the filing PDF.
FinCEN Form 114 PDF, blank form, and downloads: what’s actually available
You may come across terms like “FinCEN Form 114 PDF,” “blank Form 114,” or “download FinCEN Form 114.” Here’s what’s actually true:
FBAR is filed electronically through the BSA E-Filing system. You generally have two ways to complete it:
- Online form (in your browser): You enter the information directly in the BSA system.
- PDF FBAR option: You can prepare an FBAR using an Adobe-enabled PDF workflow and then upload/submit it through BSA E-Filing.
What you should not expect to find is a random “blank IRS form” that you print and mail. Even when people refer to “114 form IRS” or “IRS FinCEN Form 114,” the official process is still electronic submission through FinCEN.
FinCEN Form 114 filing instructions: step-by-step guide
The FBAR filing process is easier when you treat it like a checklist and keep your records organized. The IRS reminds taxpayers that the FBAR is filed separately from the tax return and that you should keep supporting documentation.
Step 1: Gather your account details
Before you start, collect the core data for each reportable account. You will generally need: the name(s) on the account, account number, financial institution name, financial institution address, account type, and the maximum value during the year.
Step 2: Determine the maximum value for each account (then aggregate)
A frequent mistake is adding up “end-of-year balances” or using the same day for every account. FBAR rules focus on the maximum value of each account during the calendar year, and then you test whether the aggregate exceeds $10,000 at any time.
For currency conversion, use a consistent method. IRS and FinCEN materials commonly point filers to Treasury’s published exchange rates (Treasury Reporting Rates of Exchange) for year-end conversion, and they also indicate that if a Treasury rate isn’t available, you should use another verifiable rate and keep the source.
Step 3: Choose your filing method (online vs PDF FBAR)
Individuals can file using the no registration option in BSA E-Filing. If you’re filing as an institution (for example, a CPA, attorney, or enrolled agent filing for clients), the institution must register and use the appropriate account type.
Step 4: Complete each account entry carefully
Work account by account. If you’re reporting joint accounts, signature authority, or entity-owned accounts, make sure the “owner” and “relationship” fields match the real-world facts.
Step 5: Submit, save the confirmation, and keep records
After you submit, save the BSA confirmation and keep your supporting records (statements, max-balance notes, and exchange-rate support). FBAR recordkeeping rules generally require retaining these records for 5 years and providing them to FinCEN or the IRS upon request.
FinCEN Form 114 example
Scenario (tax year 2025): Emma is a US citizen living abroad. She has 3 foreign accounts:
- UK checking: max £6,200
- UK savings: max £4,700
- Germany brokerage: max €1,800
Step 1 – Use each account’s maximum value (not same-day balances).
Step 2 – Convert each max to USD using one consistent exchange-rate method and keep your support.
Assume the USD conversions come out to:
- Checking $7,900
- Savings $6,000
- Brokerage $2,000
Step 3 – Add them to test the FBAR threshold:
$7,900 + $6,000 + $2,000 = $15,900
Because the total exceeded $10,000 at any time in 2025, Emma must file FinCEN Form 114 (FBAR).
What she reports on the FinCEN Form 114 report of foreign bank and financial accounts: For each account, she enters the account type, account number, name on account, bank/broker name and address, and the maximum value (in USD). She uses FinCEN 114 online filing and saves the confirmation as proof of timely submission.
Deadline (2026 filing season): April 15, 2026, with an automatic extension to October 15, 2026 (no request needed).
FinCEN Form 114a (Record of Authorization): when you need it and how to use it
FinCEN Form 114a (Record of Authorization) is not an FBAR itself. It’s the document used to authorize a third party (or, in some cases, a spouse) to electronically file on someone else’s behalf. You do not submit Form 114a to FinCEN – you retain it with your records.
Here’s the simplest way to think about the difference between 114 and 114a:
| Form | What it is | Who completes it | Where it goes |
|---|---|---|---|
| FinCEN Form 114 (FBAR) | The actual FBAR report (sometimes called federal Form 114 or FBAR FinCEN 114) | A US person with reportable accounts (or an authorized filer) | Filed electronically in BSA E-Filing |
| FinCEN Form 114a | Permission form that allows a preparer or spouse to submit an FBAR for the account owner | Account owner(s) authorizing a preparer or spouse | Kept in your records – not sent |
If you have a preparer filing for you, ask for a copy for your file and keep it with the year’s FBAR records. You may also see this document referred to as Form 114A instructions.
NOTE! The most important instruction is: retain it – don’t mail it.
Common pitfalls to avoid
Most FBAR errors come from understandable assumptions – and a few persistent myths.
- First, don’t confuse the filing platforms. FBAR is filed through FinCEN’s BSA E-Filing system, not attached to your tax return. The terms “IRS Form 114” or “federal Form 114” are informal shorthand, but the report is actually administered by FinCEN.
- Second, watch the FBAR vs FATCA Form 8938 confusion. Form 8938 is an IRS form filed with your tax return, and it has different thresholds and definitions. Many taxpayers need one, the other, or both, depending on facts.
- Finally, be careful with account scope and ownership. Joint accounts, accounts where you only have signature authority, and accounts held by certain entities can all trigger FinCEN 114 reporting requirements – even if the money “isn’t really yours” in the everyday sense.
Maximizing your compliance (without losing your sanity)
A calm, repeatable process beats panic every time.
Start by creating a single “FBAR folder” for the year (digital is fine) where you store statements, your maximum-balance notes, and the exchange-rate source you used. This makes it easier to answer questions later and reduces the risk of inconsistent values across years.
If you discover you should have filed in prior years, don’t ignore it. There are IRS pathways designed for taxpayers who need to catch up, and which one fits depends on your facts. The right approach is especially important if you’re also fixing late or amended income tax returns.
Conclusion
Filing FBAR (FinCEN Form 114) doesn’t have to be a Herculean task. Once you understand the threshold, the account-by-account maximum value rule, and the electronic filing process, it becomes a predictable annual step – like renewing your passport.
Do these 3 things each year:
- Track each foreign account’s maximum value and keep proof.
- File by April 15 (or rely on the automatic October 15 extension if needed).
- Save your BSA confirmation and keep your supporting records.
If you want support preparing or catching up on your FBAR filing, Taxes for Expats is here to guide you step-by-step.
FAQs on FBAR FinCEN Form 114 filing
FinCEN Form 114 is the FBAR – the Report of Foreign Bank and Financial Accounts. People sometimes call it IRS Form 114, but the form is administered by FinCEN and filed electronically through the BSA E-Filing system, not attached to your federal income tax return.
A US person with a financial interest in, or signature authority over, foreign financial accounts must file when the aggregate value of those accounts exceeds $10,000 at any time during the calendar year.
The FinCEN Form 114 deadline is April 15, 2026, for calendar year 2025 accounts, with an automatic extension to October 15, 2026.
You report the maximum value of each account during the year, convert foreign currency to US dollars using a consistent method, then aggregate the maximum values to see whether you crossed $10,000 at any time.
FinCEN Form 114a is the Record of Authorization that allows a third party or spouse to electronically file an FBAR on someone else’s behalf. You keep the signed form in your records and do not submit it to FinCEN.
Although often referred to as “Form 114a IRS,” it is not issued by the IRS. It is FinCEN Form 114a used to authorize electronic FBAR filing with the Financial Crimes Enforcement Network.
