FBAR Record Keeping: What to Save and for How Long
The 5-Year Retention Rule
Under 31 CFR 1010.420, you must keep records related to your FBAR filing for 5 years from the due date of the FBAR. For a 2025 FBAR due April 15, 2026, keep records until at least April 15, 2031.
This is separate from (and longer than) the IRS's general 3-year statute of limitations for tax returns.
What Records to Keep
Account Records - Bank statements showing the maximum balance during the year (all 12 months if possible, or at least the month with the highest balance) - Account opening/closing documents — useful if an account was opened or closed during the year - Account numbers — keep a record of account numbers reported (especially for closed accounts)
Filing Records - BSA tracking ID — your proof of filing, issued after submission - PDF copy of your filed FBAR — FBAR File provides this automatically - XML file submitted to BSA E-Filing (if you used one)
Currency Conversion Records - Treasury exchange rates used for conversion - Documentation of how you determined maximum values — especially for securities accounts where the value fluctuates
Supporting Documents - Form 114a (if filing for a spouse) — Record of Authorization to Electronically File FBARs - Any correspondence with FinCEN or IRS about your FBAR - Power of attorney documentation if someone filed on your behalf
What You Don't Need to Keep
- Transaction histories for every transaction in the account
- Tax returns (these are governed by separate IRS retention rules)
- Account statements from years not covered by the 5-year window
How to Organize
A simple folder structure works:
``` FBAR Records/ ├── 2025/ │ ├── BSA-Tracking-ID.txt │ ├── FBAR-2025-filed.pdf │ ├── FBAR-2025-filed.xml │ ├── Bank-Statements/ │ │ ├── HSBC-UK-Jan-Dec-2025.pdf │ │ └── Deutsche-Bank-Jan-Dec-2025.pdf │ └── Treasury-Rates-2025.pdf ├── 2024/ │ └── ... ```
Store digitally (cloud storage with encryption is fine) and keep a backup.
Why 5 Years Matters
If FinCEN or the IRS questions your filing, you need to produce these records. Without them, you can't demonstrate the accuracy of your reported values. The burden of proof is on you.
What FBAR File Provides
After filing through FBAR File, you receive: - PDF receipt of your completed FinCEN Form 114 - BSA tracking ID as proof of submission - Filing stored in your dashboard for future reference and auto-fill
We recommend downloading and keeping your own copies as well — don't rely solely on any service for long-term record retention.