FinCEN Form 114: FBAR form filing instructions, who must file, and what to report
FBAR (FinCEN Form 114) is the Report of Foreign Bank and Financial Accounts – a disclosure 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.
For the 2026 filing season, the FBAR Form 114 deadline is April 15, 2026, with an automatic extension to October 15, 2026.
If you need help filing correctly or catching up on missed years, see our FBAR filing service.
| Field | Detail |
|---|---|
| What it is | Report of Foreign Bank and Financial Accounts – FBAR (FinCEN Form 114) |
| Who files | US persons – citizens, green card holders, resident aliens, and certain entities – with foreign financial accounts exceeding $10,000 in aggregate |
| Threshold | $10,000 combined across all foreign accounts at any point during the year |
| Where filed | Electronically through the BSA E-Filing System – not attached to Form 1040 |
| Due date | April 15, 2026 |
| Automatic extension | October 15, 2026 – no request needed |
| Administered by | FinCEN, a bureau of the US Treasury – not the IRS |
What is FinCEN Form 114, and why does it matter to US persons overseas
There is no difference between FBAR and FinCEN 114. FinCEN Form 114 is the Report of Foreign Bank and Financial Accounts, required under the Bank Secrecy Act.
It is a disclosure form – it does not calculate tax, does not determine what you owe, and is not attached to your Form 1040.
The IRS enforces FBAR penalties and examines compliance, which is why many filers assume it is an IRS Form 114. It is not – FinCEN administers the form, and you file it through the BSA E-Filing system, not through IRS.gov or with your tax return.
References to federal form 114 point to the same report. FinCEN is a bureau of the US Treasury, separate from the IRS, and the distinction matters if you need to contact the right agency about a filing question or a late submission.
Why it matters:
The US government uses FBAR reporting to support anti-money-laundering enforcement and offshore transparency. US persons with reportable foreign financial accounts must disclose them, and penalties for not filing – or filing incorrectly – can be significant:
- Non-willful violations carry a maximum civil penalty of $16,536 per report, for assessments on or after January 17, 2025
- Willful violations can reach $165,353 or 50% of the account balance, whichever is greater
Filing an FBAR does not itself create a tax liability. It reports the existence and maximum value of your foreign accounts – nothing more.
Who should pay attention:
- US citizens and green card holders abroad have FBAR obligations regardless of how long they have lived overseas or whether they owe US tax
- Joint account holders each report the full value of the account, not half
- A US person with signing power on an employer’s foreign account may need to file even if none of the money is theirs
US expats with missed FBAR filings can often resolve late returns and outstanding FBARs through a single multi-year process.
See our guide to Streamlined Filing Compliance Procedures for eligibility and how it works.
Our FBAR filing guide covers the full filing process, including who must file, which accounts to report, and how the $10,000 threshold works.
FinCEN Form 114 – who must file it?
If you are a US person and you have a financial interest in – or signature or other authority over – one or more foreign financial accounts, you must file FinCEN Form 114 if the aggregate value of those accounts exceeds $10,000 at any time during the calendar year.
The filing obligation applies whether or not the accounts produce taxable income.
The FinCEN Form 114 requirements break down into three conditions – all three must be met:
- US person status. You are a US citizen, lawful permanent resident, resident alien under the substantial presence test, or a US entity such as a corporation, partnership, LLC, trust, or estate.
- Financial interest or authority. You own the account, hold legal title, have an indirect ownership interest through a controlled entity, or can direct the bank to move funds.
- Aggregate value over $10,000. The combined maximum value of all your reportable foreign accounts crossed $10,000 at any point during the calendar year. This is an aggregate test – even small accounts count.
Who does not need to file:
The following are generally exempt from FBAR filing, based on the FinCEN FBAR instructions:
- Accounts at US military banking facilities, regardless of physical location
- IRA owners and beneficiaries for foreign accounts held within a qualifying IRA – this does not exempt a foreign pension or retirement account held directly
- Participants in and beneficiaries of plans described in IRC sections 401(a), 403(a), or 403(b)
- Trust beneficiaries where the trust, trustee, or agent is a US person that files an FBAR disclosing the trust’s foreign accounts
- Correspondent or nostro accounts used solely for bank-to-bank settlements
- Accounts owned by governmental entities or international financial institutions
Certain entities are also covered. LLCs, corporations, partnerships, trusts, and estates can have their own FBAR obligations when they meet the same three-part test.
What counts as a foreign financial account?
A foreign financial account is any account at a financial institution physically located outside the United States. The location of the institution determines whether the account is foreign – not the currency it holds.
A dollar account at a bank in London is foreign. A euro account at a bank in New York is not.
The following accounts are generally reportable on the FBAR when the $10,000 aggregate threshold is met:
| Usually reportable | Usually not reportable |
|---|---|
| Foreign checking and savings accounts | Directly held foreign real estate |
| Foreign brokerage and securities accounts | Vehicles, art, jewelry, and collectibles |
| Foreign mutual funds | Domestic mutual funds investing in foreign stocks |
| Foreign retirement and pension accounts | Foreign currency held directly |
| Cash-value life insurance at a foreign institution | Precious metals held directly |
| Fintech accounts at foreign-located entities, such as Wise or Revolut | Social Security–type benefits from a foreign government |
| Accounts closed during the year – reported with peak value before closure | IRA and qualifying retirement plan accounts |
The IRS comparison of Form 8938 and FBAR requirements confirms that directly held real estate, personal property, and foreign currency are not reportable on the FBAR.
For fintech accounts, the determining factor is where the legal entity holding your funds is located. See our guide to reporting Wise and Revolut accounts on FBAR.
Joint ownership and signature authority
Joint accounts, employer accounts, and signing power over a family member’s foreign account can all trigger an FBAR filing obligation, even if the money is not yours.
Joint accounts: If you co-own a foreign account with your spouse, each of you reports the full maximum value – not half. A narrow exception allows one spouse to file on behalf of both, but only when all accounts are jointly owned with the filing spouse, the filing spouse reports every account on a timely FBAR, and both spouses sign FinCEN Form 114a. If either spouse holds an individual account outside the joint pool, separate FBARs are required.
Signature authority: If you can instruct a foreign bank to move funds – whether in writing, by phone, or electronically – you have signature authority and may need to file, even if you have no ownership stake. This commonly applies to corporate officers, finance managers, employees authorized to pay overseas vendors, and adult children managing a parent’s account abroad.
Certain officers and employees of qualifying entities – such as US publicly traded companies, banks examined by federal regulators, and SEC- or CFTC-registered financial institutions – may be exempt from reporting signature-authority-only accounts.
These exceptions are narrow and apply only when the filer has no financial interest in the account.
For a deeper look, see our guides to FBAR signature authority and filing FBAR jointly.
FinCEN Form 114 due date and extension – 2026 filing season deadline
For the 2026 filing season, the FBAR deadline covers calendar year 2025 foreign accounts. You have two dates to track.
2026 FinCEN 114 deadline
The FinCEN Form 114 due date for calendar year 2025 accounts 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.
The deadline was set by the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.
Pre-deadline checklist: gather all account statements, calculate each account’s maximum value during 2025, confirm your account list is complete, and submit through BSA E-Filing.
For the full set of expat filing deadlines – including the June 15 and October 15 income tax extensions – see our 2026 US tax deadlines guide.
2026 FinCEN 114 extension
If you miss April 15, you get an automatic extension to October 15, 2026 – no request needed, no form to file, and no notification to FinCEN required.
The FBAR extension is independent of Form 4868. Filing Form 4868 extends your income tax return deadline but has no effect on the FBAR. Likewise, the automatic June 15 extension for US taxpayers living abroad applies to Form 1040 – not to the FBAR.
Filing any time before October 15 – even months after April 15 – is timely under the automatic extension and carries no penalty.
The extension does not change the reporting year. You are still reporting calendar year 2025 accounts using December 31, 2025, exchange rates.
If you also need more time for your federal return, our guide to filing for a tax extension covers the separate Form 4868 process.
NOTE! The FBAR official line item instructions can be found in the FinCEN filing PDF.
FinCEN Form 114 PDF, blank form, and downloads: what’s actually available
You cannot print and mail an FBAR. The PDF references you may find online generally point to informational documents or the offline preparation workflow – not a standalone paper form you submit by post.
FBAR is filed electronically through the BSA E-Filing system. You have two ways to complete it:
- Online form: Enter the information directly in the BSA system through your browser
- PDF preparation: Download and complete an Adobe-enabled FinCEN 114 PDF offline, then upload and submit it through BSA E-Filing
What you can download vs. what you cannot submit on paper:
| Available for download | Not available |
|---|---|
| FBAR line item filing instructions – the official guidance for completing the form | A printable, mail-in FBAR form – the FBAR is not filed on paper unless FinCEN grants a specific exemption |
| FinCEN Form 114a – authorization form, retained in your records | A “blank Form 114” intended for print-and-mail submission |
| The Form 114 PDF preparation file, available under the “PDF Form” option in BSA E-Filing | Any form submitted through IRS.gov – the FBAR goes to FinCEN, not the IRS |
FinCEN Form 114 filing instructions: step-by-step guide
The FBAR filing process is easier when you treat it as a checklist. The steps below walk through each part of the filing for the 2026 filing season, covering calendar year 2025 accounts.
Step 1 – Gather your account details
Before you start, collect the core data for each reportable foreign account:
- Account holder name as it appears on the account
- Account number
- Financial institution name and address
- Account type – checking, savings, brokerage, pension, etc.
- Maximum value during calendar year 2025
- Whether the account is jointly owned or held through signature authority
For fintech accounts, see our guide to reporting Wise and Revolut accounts on FBAR.
Step 2 – Determine the maximum value for each account, then aggregate
Report the highest value each account reached at any point during 2025 – not the year-end balance, and not the same-day balance across all accounts. A frequent mistake is using December 31 balances when the peak was in March.
Currency conversion: Convert each account’s maximum value to US dollars using the Treasury Reporting Rates of Exchange in effect on December 31, 2025. If Treasury does not publish a rate for a particular currency, use another verifiable year-end exchange rate and document the source.
Do not use the IRS yearly average rate, a spot rate from the date the account peaked, or your bank’s transaction rate.
After converting, add the USD values. If the aggregate exceeds $10,000 at any time during 2025, every reportable account must appear on the FBAR – including accounts that individually held far less than $10,000.
Our guide to determining the maximum annual account balance for FBAR walks through the calculation step by step, including joint accounts and unknown balances.
For currency conversion details, see which FBAR exchange rate to use.
Step 3 – Choose your filing method – online vs. PDF FBAR
Individuals can file using the no-registration option in BSA E-Filing. No account creation is required – you enter the data and submit.
If you are filing as an institution – for example, a CPA, attorney, or enrolled agent filing on behalf of clients – the institution must register with the BSA E-Filing system and use the appropriate account type.
| Filing option | When to use | How it works |
|---|---|---|
| Self-filing, online | You are filing your own FBAR | No registration needed; enter data directly in BSA E-Filing |
| Self-filing, PDF prep | You prefer working offline | Complete the form in an Adobe-enabled PDF, then upload through BSA E-Filing |
| Preparer-assisted filing | A CPA or attorney files for you | Preparer registers as an institution; you sign Form 114a authorizing the filing |
Step 4 – Complete each account entry carefully
Work account by account, following the instructions for FinCEN 114 field by field. Each qualifying foreign account gets its own entry – you do not combine accounts.
For each account, enter the institution name and address, account number, account type, and the maximum value in USD.
If you are reporting a joint account, make sure the “owner” and “relationship” fields reflect the real-world facts. For accounts where you hold only signature authority, use Part IV of the form.
Common errors at this step include entering year-end balances instead of peak values, misidentifying account ownership on joint accounts, and omitting accounts closed during the year.
Step 5 – Submit, save the confirmation, and keep records
After you submit, save the BSA confirmation – it contains your tracking ID and serves as proof of timely filing. FBAR filing through FinCEN is not complete until you receive this confirmation.
Post-filing checklist:
- Save the BSA acknowledgement and tracking ID
- Download a copy of the filed form
- Retain all supporting documents – account statements, exchange-rate records, maximum-balance calculations, and Form 114a if a third party filed on your behalf
Recordkeeping requirements
FBAR records must be retained for five years from the due date of the FBAR. For calendar year 2025 accounts, that means keeping records until at least April 15, 2031.
The records must be made available to FinCEN or the IRS upon request.
What to retain – a practical checklist based on the FinCEN 114 instructions:
- Account statements showing the maximum balance during the year
- The exchange-rate source you used – the Treasury Reporting Rates of Exchange page or an alternative verifiable rate
- Your maximum-balance calculation for each account
- A copy of the filed FBAR and the BSA confirmation
- FinCEN Form 114a, if a preparer or spouse filed on your behalf
Exception: An officer or employee who files an FBAR solely to report signature authority over an employer’s foreign account is not required to personally retain records for those accounts. The employer keeps the records.
FinCEN Form 114 example
TFX client scenario – tax year 2025: Emma is a US citizen living abroad. She has three foreign accounts:
- UK checking: maximum balance £6,200
- UK savings: maximum balance £4,700
- Germany brokerage: maximum balance €1,800
Step 1 – Use each account’s maximum value, not same-day balances.
Step 2 – Convert each maximum to USD using the Treasury Reporting Rates of Exchange for December 31, 2025 – not a spot rate, not the IRS yearly average, and not your bank’s transaction rate.
Assume the conversions produce:
| Account | Currency | Peak balance | USD equivalent |
|---|---|---|---|
| UK checking | GBP | £6,200 | $7,900 |
| UK savings | GBP | £4,700 | $5,990 |
| Germany brokerage | EUR | €1,800 | $2,000 |
Step 3 – Add the USD values to test the threshold:
$7,900 + $5,990 + $2,000 = $15,890
Because the aggregate exceeded $10,000 at any time in 2025, Emma must file the FBAR.
What Emma reports for each account on her FinCEN Form 114 example: account type, account number, name on account, financial institution name and address, and the maximum value in USD. She files through FinCEN Form 114 online filing and saves the BSA confirmation.
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 is not an FBAR itself. It is the Record of Authorization that allows a third party – or, in certain cases, a spouse – to electronically file an FBAR on someone else’s behalf.
You do not submit Form 114a to FinCEN. You retain it with your records and produce it only if requested.
FinCEN 114a instructions – the key distinction in one table:
| Form | What it is | Who completes it | Where it goes |
|---|---|---|---|
| FinCEN Form 114 – the FBAR | The actual FBAR report | A US person with reportable accounts, or an authorized filer | Filed electronically in BSA E-Filing |
| FBAR Form 114a | Permission form authorizing a preparer or spouse to submit an FBAR | Account owner authorizing the filing | Kept in your records – not sent to FinCEN |
When you need Form 114a:
- Your CPA, EA, or attorney is filing the FBAR on your behalf
- Your spouse is filing a joint FBAR and you are designating which spouse signs the report
- Any third party is authorized to submit the form through BSA E-Filing
If you have a preparer filing for you, ask for a copy of the signed 114a for your records and keep it with the year’s FBAR documentation.
NOTE! The most important FinCEN 114a instructions rule: retain the form – do not mail it to FinCEN or the IRS.
Common pitfalls to avoid
Most FBAR errors come from understandable assumptions – and a few persistent myths. The six mistakes below are the ones we see most often.
1. Confusing the filing platform. FBAR is filed through FinCEN’s BSA E-Filing system, not attached to your tax return. Searching for an IRS FBAR form on IRS.gov will not return a filing option – you need to go to FinCEN’s BSA E-Filing site, and contacting the IRS about a late FBAR will not resolve it.
2. Mixing up FBAR and FATCA Form 8938. Form 8938 is an IRS form filed with your tax return. It covers a broader category of specified foreign financial assets and applies different thresholds from the FBAR. For a single filer living abroad, the filing requirement is triggered if total specified foreign assets exceeded $200,000 at year-end or $300,000 at any point during the year. Either threshold independently requires the form.
3. Using a generic exchange rate. The FinCEN Form 114 instructions require the Treasury Reporting Rates of Exchange for December 31, 2025 – not your bank’s rate, not a spot rate from the date the account peaked, and not the IRS yearly average.
4. Forgetting signature-authority accounts. If you can direct transactions on a foreign account you do not own, you must report it. This catches corporate officers, employees with vendor-payment authority, and adult children managing a parent’s foreign account.
5. Omitting accounts closed during the year. An account open for any part of 2025 counts toward the aggregate threshold and must be reported with its maximum value before closure.
6. Confusing account location with currency. A dollar account at a foreign bank is foreign. A euro account at a US bank is domestic. The institution’s location determines reporting – not the currency.
US expats who realize they have unfiled FBAR years to address can review the full catch-up process through our Streamlined Filing Procedure service.
For a side-by-side comparison of thresholds, reporting scope, and filing locations, see our guide to FBAR vs Form 8938.
FinCEN Form 114 penalties and late filing options
FBAR penalties are set by the Bank Secrecy Act under 31 USC § 5321 and adjusted annually for inflation.
The 2025 penalty levels remain in effect for 2026 assessments after the government cancelled the 2026 inflation adjustment. Penalties are not automatic – the IRS has discretion, and actual amounts depend on the facts of each case.
Civil penalty structure – for assessments on or after January 17, 2025:
| Violation | Maximum civil penalty | Key detail |
|---|---|---|
| Non-willful | Up to $16,536 per annual FBAR report | Per-report, not per-account, under the Supreme Court’s 2023 Bittner v. United States decision. May be waived entirely if the filer demonstrates reasonable cause under 31 USC § 5321(a)(5)(B)(ii) |
| Willful | Greater of $165,353 or 50% of the account balance at the time of the violation | Assessed per account, per year. No reasonable-cause defense |
| Criminal | Fine up to $250,000 and/or up to five years’ imprisonment under 31 USC § 5322(a); up to $500,000 and/or 10 years under § 5322(b) in aggravated cases | Reserved for intentional concealment or fraud |
Late filing options – which path fits your situation:
| Situation | Recommended next step |
|---|---|
| Only FBAR missed; all income reported; no IRS contact | File delinquent FBARs as soon as possible with a well-documented reasonable-cause explanation. As of mid-2026, the IRS no longer publishes a no-penalty guarantee for this path |
| Tax returns and FBARs both missed; non-willful; living abroad | Streamlined Foreign Offshore Procedures – three years of returns plus six years of FBARs, with 0% offshore penalty |
| Tax returns and FBARs both missed; non-willful; living in the US | Streamlined Domestic Offshore Procedures – same filings, with a 5% miscellaneous offshore penalty |
| Filed FBAR with material errors | File a corrected FinCEN Form 114 with the “amended” box checked |
| Willfulness concern or prior IRS contact | IRS Criminal Investigation Voluntary Disclosure Practice – consult a tax attorney |
The correct compliance path depends on your facts and filing history. Whichever option applies, filing before the IRS contacts you keeps potential penalties lowest.
Our guide to FBAR penalties covers the full penalty structure, including mitigation and reasonable cause.
Our delinquent FBAR submission guide explains the current options for late filers after the mid-2026 IRS policy change.
Maximizing your compliance – without losing your sanity
A calm, repeatable annual process is the best defense against missed filings.
Annual FBAR compliance plan:
- Set a calendar reminder for February or March to start gathering foreign account statements for the prior calendar year.
- Check every account for peak value – review monthly statements or online transaction history, not just the December balance.
- Review signature authority – if you changed jobs, gained or lost signing power on an employer account, or took over management of a family member’s foreign account, that account may need to appear on your FBAR.
- Check whether FATCA Form 8938 also applies – the FBAR and Form 8938 are separate obligations with different thresholds and definitions. Many expats need both in the same year.
- File and save – submit through BSA E-Filing, save the confirmation, and keep records for five years.
DIY vs. professional help: A filer with one or two simple foreign accounts can generally handle the FBAR through BSA E-Filing at no cost. Professional help adds the most value when you have multiple years of missing FBARs, unreported income from foreign accounts, entity or trust ownership, signature authority over employer accounts, or 25 or more foreign accounts.
The FinCEN 114 form does not require a preparer – but if your situation involves any of the above, working with a CPA who handles international returns can reduce the risk of errors and penalties.
Conclusion
Filing an FBAR does not have to be complicated. Once you understand the threshold, the account-by-account maximum-value rule, and the electronic filing process, it becomes a predictable annual step.
Do these three things each year:
- Track each foreign account’s maximum value during the calendar year and keep proof.
- File FinCEN Form 114 by April 15 – or rely on the automatic October 15 extension if needed.
- Save your BSA confirmation and keep your supporting records for five years.
FBAR filing does not usually create a tax liability. It is a disclosure – and filing it correctly protects you from penalties that can be far more costly than the filing itself.
If you want support preparing or catching up on your FBAR filing, Taxes for Expats can help 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. Despite being called an IRS FBAR form informally, it is administered by FinCEN and filed through the BSA E-Filing system, not attached to your federal 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 FBAR is not a tax form – it does not calculate or create tax owed.
The FBAR 114 deadline is April 15, 2026, for calendar year 2025 accounts, with an automatic extension to October 15, 2026. No request is needed. The deadline applies to the FBAR / FinCEN 114 regardless of whether you also owe US tax.
Report the maximum value each account reached during the year, convert foreign currency to US dollars using the Treasury Reporting Rates of Exchange for December 31, 2025, then aggregate the USD values. If the total exceeds $10,000 at any time, every reportable account goes on the FBAR.
FinCEN Form 114a is the Record of Authorization. It allows a third party or spouse to electronically file an FBAR on someone else’s behalf. You keep the signed form in your records – you do not submit it to FinCEN.
No. The FinCEN report 114 and Form 114a are both FinCEN documents – not IRS forms. Form 114 is the FBAR itself; Form 114a is the authorization to let someone else file it.
The FBAR form – FinCEN Form 114 – reports foreign financial accounts to FinCEN. Form 8938 reports specified foreign financial assets to the IRS. They have different thresholds, cover different asset types, and are filed in different places. Many expats need both.
No. FinCEN FBAR 114 is a disclosure form, not a tax form. Filing it does not create tax owed – it reports the existence and maximum value of your foreign financial accounts under the Bank Secrecy Act.
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