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.

Missed Your FBAR? How to Catch Up Without Penalties

You're Not Alone

Millions of Americans with foreign accounts don't file FBARs. The IRS estimates that over 9 million people should file, but fewer than 2 million do. The gap isn't tax evasion — it's mostly people who never heard of the requirement.

Three Paths to Compliance

The IRS offers different programs depending on your situation. Choosing the right one matters.

1. Delinquent FBAR Submission Procedures (DFSP)

Best for: People who properly reported all foreign income on their tax returns but simply missed the FBAR filing.

How it works: - File all delinquent FBARs through the BSA E-Filing system - Include a statement explaining why you're filing late - On the cover page, select a reason for the late filing

Penalties: Typically none, as long as: - All foreign income was properly reported on your US tax returns - You're not under IRS examination or criminal investigation - You haven't been contacted by the IRS about the delinquent FBARs

This is the simplest path. If your only lapse was the FBAR itself (not your taxes), this is likely your route.

2. Streamlined Filing Compliance Procedures

Best for: People who have both unfiled FBARs AND unreported foreign income (or unfiled/incorrect tax returns).

There are two versions:

Streamlined Foreign Offshore Procedures (SFOP) — for US taxpayers living abroad: - File 3 years of amended tax returns + 6 years of FBARs - No penalty - Must certify that non-compliance was non-willful - Must have lived outside the US for at least 330 days in one of the last 3 years

Streamlined Domestic Offshore Procedures (SDOP) — for US taxpayers living in the US: - File 3 years of amended tax returns + 6 years of FBARs - 5% penalty on the highest aggregate balance of unreported foreign accounts - Must certify that non-compliance was non-willful

3. Voluntary Disclosure Practice

Best for: People who willfully failed to report foreign accounts or income.

Full disclosure to IRS Criminal Investigation
Penalties are steep but you avoid criminal prosecution
Only use this if you intentionally hid accounts or income

Which Path Is Right for You?

Ask yourself two questions:

1. Did you report all foreign income on your tax returns? - Yes → Delinquent FBAR Submission Procedures - No → Streamlined Procedures

2. Did you know about the FBAR and intentionally skip it? - No (non-willful) → DFSP or Streamlined - Yes (willful) → Voluntary Disclosure Practice

What "Non-Willful" Means

Non-willful means your failure was due to negligence, inadvertence, or honest misunderstanding. Examples:

You didn't know the FBAR existed
You thought it only applied to large accounts
You assumed your CPA handled it
You confused FBAR with FATCA and thought filing one satisfied both

Important: Don't Wait

The IRS programs for catching up exist now, but they're discretionary — the IRS can modify or end them. Every year you wait adds another year of non-compliance.

For current-year filings, start with FBAR File ($29, 12 minutes). For prior years with complex circumstances, consult a tax professional who specializes in international compliance.