FBAR for Americans abroad: who must file

If you are a U.S. person living abroad, you must file an FBAR (FinCEN Form 114) when your foreign financial accounts together exceeded $10,000 at any time in the calendar year. It is filed electronically with FinCEN, not with your tax return, and is due April 15 with an automatic extension to October 15.
The IRS describes these rules on its FBAR page. If you are also checking income-tax relief, read our guide to the 2027 foreign earned income exclusion and the US-Italy totalization agreement.
TL;DR
- Threshold: more than $10,000 in aggregate across all foreign financial accounts at any time in the year.
- It is a Bank Secrecy Act report, filed with FinCEN, not with Form 1040.
- Due April 15, automatic extension to October 15.
- Accounts count even if they earn no taxable income.
- File late FBARs as soon as possible if the IRS has not contacted you.
Who must file
The IRS says a U.S. person (including a citizen, resident, corporation, partnership, LLC, trust and estate) must file an FBAR to report a financial interest in, or signature or other authority over, at least one financial account located outside the United States, if the aggregate value of those accounts exceeded $10,000 at any time during the calendar year.
Generally, an account at a financial institution located outside the United States is a foreign financial account. The $10,000 test looks at the combined value, so no single account has to exceed it.
Accounts you do not need to report
The IRS lists several exclusions, including accounts that are:
- correspondent or nostro accounts;
- owned by a governmental entity or an international financial institution;
- maintained on a U.S. military banking facility;
- held in an individual retirement account (IRA) of which you are an owner or beneficiary;
- held in a retirement plan of which you are a participant or beneficiary;
- part of a trust of which you are a beneficiary, if a U.S. person files an FBAR reporting those accounts.
You also do not need to file if all your foreign accounts are reported on a consolidated FBAR, or if you jointly own all of them with your spouse and your spouse reports them on a timely, signed FBAR after you completed FinCEN Form 114a.
Deadline and how to file
The FBAR is an annual report due April 15 following the calendar year reported. You get an automatic extension to October 15 and do not need to ask for it. The government may extend the date further for people affected by natural disasters.
You must file electronically through FinCEN's BSA E-Filing System. Paper filing needs an exemption requested from FinCEN's Resource Center. If someone files for you, use FinCEN Report 114a to authorize them; keep it for your records instead of submitting it.
Records to keep
For each reported account, keep the name on the account, the account number, the name and address of the foreign bank, the type of account and the maximum value during the year. The law does not specify the document type: bank statements or a copy of the filed FBAR can work if they contain this information. Keep them generally for five years from the due date.
Late or missing FBARs
The IRS states that filing late or not at all is a violation and may lead to civil and/or criminal penalties, and that assertion of penalties depends on facts and circumstances. Civil penalty maximums are adjusted annually for inflation, so check the current figures in the IRS materials.
If the IRS has not contacted you about a late FBAR and you are not under civil or criminal investigation, the IRS advises filing late FBARs as soon as possible, explaining the reason for filing late. If you use a compliance option such as the Streamlined filing compliance procedures, follow the instructions for that option.
FAQ
Who must file? U.S. persons with foreign accounts above $10,000 in aggregate at any time in the year.
Is it part of my tax return? No, it is filed separately with FinCEN.
When is it due? April 15, with automatic extension to October 15.
Do non-interest accounts count? Yes, taxable income is irrelevant.
General information, not tax or legal advice. Check the IRS and FinCEN pages or a qualified professional for your situation.
Sources
Consulted on 9 November 2026.