What is an FBAR and who needs to file?

An FBAR (FinCEN Form 114) is required for any US person — citizens, green card holders, and residents — who has foreign financial accounts that together exceeded $10,000 at any point during the calendar year. This includes Americans living abroad, immigrants maintaining accounts in their home country, and dual citizens. If the total across all your foreign accounts hit $10,000 for even one day, you're required to file.

What's the penalty for not filing?

Non-willful failure to file carries a penalty of up to $16,536 per account, per year. Willful failure can result in penalties up to $165,353 or 50% of the account balance, whichever is greater. Criminal penalties can include up to 5 years imprisonment. The good news: the IRS rarely penalizes taxpayers who come forward voluntarily with non-willful violations.

When is the FBAR deadline?

The FBAR is due April 15 each year, with an automatic extension to October 15. No extension request is needed — it applies automatically. For the 2025 tax year, the October 15, 2026 extension deadline is the current active deadline. We recommend filing as early as possible to stay ahead of the deadline.

How does the FinCEN submission work?

We generate your completed FinCEN Form 114 — both a FinCEN-compliant XML for submission and a PDF copy for your records. We walk you through uploading to the BSA E-Filing system, the same portal CPAs and tax professionals use. The upload takes about 2 minutes. Once submitted, you get a BSA tracking ID as proof of filing, saved in your dashboard alongside your PDF receipt.

How is my data protected?

Your SSN and account numbers are encrypted with AES-256-GCM before they're stored. The encryption architecture means we cannot access your sensitive data in plain text. All traffic uses TLS. Bank statement uploads are encrypted at rest and deleted after data extraction is complete.

What if I have accounts in multiple countries?

You can add as many accounts as you need — there's no per-account charge. We handle currency conversion automatically using Treasury Department exchange rates for the reporting year. Five accounts across three countries is the same $29.

Can I file for previous years?

Yes. You can file for any year going back 6 years. Each year is a separate filing. If you have multiple years of unfiled FBARs, we recommend consulting a tax professional about the Streamlined Filing Compliance Procedures before filing — it can protect you from penalties.

How is this different from using a CPA?

A CPA typically charges $200–500 for FBAR preparation. For straightforward filings, the work involved is primarily data entry — your name, bank details, and account balances. We handle that same process for $29 in about 12 minutes, with bank-grade encryption. For complex situations like delinquent filings, FATCA Form 8938, or tax treaty issues, a CPA is the right choice.

Can I file myself for free on the BSA site?

Yes, the BSA E-Filing system at FinCEN is free and open to the public. It's a functional but dated system — no save-and-resume, no currency conversion, and no error checking before submission. Most filers report it takes 45–90 minutes. FBAR File provides a modern interface with automatic currency conversion, error detection, and the ability to save your progress for $29.

Is my data really safe?

We use AES-256-GCM encryption — the same standard used by the US government for classified information. Your SSN and account numbers are encrypted before they're written to our database, using a key derived from your account. We cannot read them in plain text. Bank statement uploads are encrypted at rest and automatically deleted after data extraction.

Does Your Foreign Pension or Retirement Account Require FBAR Reporting?

The General Rule

If you have a financial interest in a foreign retirement account at a financial institution, and the aggregate value of all your foreign accounts exceeds $10,000, the retirement account should be included on your FBAR.

This catches many people off guard — especially immigrants who have pension accounts from their home country.

Types of Foreign Retirement Accounts

Clearly Reportable - Foreign bank-held retirement savings — savings accounts or CDs designated as retirement - Foreign brokerage retirement accounts — investment accounts at foreign financial institutions earmarked for retirement - Provident funds held at financial institutions — common in India (EPF), Singapore (CPF), and other countries

Likely Reportable - Superannuation accounts (Australia) — held at financial institutions, generally reportable - ISAs and SIPPs (UK) — Individual Savings Accounts and Self-Invested Personal Pensions at UK banks/brokerages - RRSP/TFSA (Canada) — Registered Retirement Savings Plans and Tax-Free Savings Accounts

Gray Area - Government-administered pensions — some tax professionals argue that accounts administered directly by a foreign government (not a financial institution) fall outside the FBAR definition - Social security equivalents — government social insurance programs are generally not reportable - Employer-managed pension funds — depends on whether the fund is held at a "financial institution"

The Tax Treaty Complication

Some US tax treaties provide favorable treatment for certain foreign retirement accounts (e.g., UK pensions under the US-UK tax treaty). However, tax treaty benefits apply to your tax return, not to the FBAR. Even if a treaty exempts account income from US taxation, the account may still be FBAR-reportable.

How to Determine Maximum Value

For retirement accounts that don't provide regular statements:

Request an annual statement from the fund administrator
Use the most recent statement and note the date
For accounts you can't access (e.g., locked pension funds), use the most recent valuation available

Common Country-Specific Scenarios

India (EPF/PPF): Employee Provident Fund and Public Provident Fund balances are held at financial institutions and should be reported. Check your annual statement from the EPFO or bank.

UK (Pension/ISA): Workplace pensions held at financial institutions, ISAs at banks or brokerages, and SIPPs are generally reportable. State Pension is a government benefit, not an account.

Canada (RRSP/TFSA): These are held at Canadian financial institutions and are reportable on the FBAR.

Australia (Superannuation): Super funds are held at financial institutions. Report the balance.

When to Consult a Professional

Foreign retirement accounts often involve complex interactions between FBAR, FATCA (Form 8938), and tax treaty provisions. If your foreign retirement account represents a significant value, or if you're unsure about the reporting requirement, a tax professional specializing in international tax can clarify your specific situation.

Filing with FBAR File

FBAR File supports reporting retirement accounts as a "securities" or "other" account type. Enter the financial institution, country, account details, and maximum value. We handle the rest.