- Form
- FinCEN Form 114
- Fee
- No filing fee
- Time
- April 15, 2027; automatic extension to October 15, 2027
- Where
- BSA E-Filing System
For U.S. persons reporting 2026 foreign-account activity, the regular filing date is April 15, 2027, and the automatic extension runs through October 15, 2027. A separate notice gives some people with signature authority but no financial interest in certain 2025 accounts until April 15, 2027.
The annual extension requires no request and applies separately from any extension of your income tax return. The special date concerns a limited set of 2025 filings, so account year and eligibility determine which deadline applies.
For background on the annual rule and filing steps, see FBAR Deadlines 2026: Extensions, Requirements, and Filing Steps.
If a filing is required, submit FinCEN Form 114 through the BSA E-Filing System; no request is needed for the general automatic October 15 extension. See FBAR Filing Essentials: Form 114 Due April 15 with 6-Month Extension for the filing route.
Americans living in the UK or UAE should use the same reporting-year distinction as other U.S. persons. Living abroad does not by itself remove the filing obligation or alter the ordinary annual extension.
The report is a Treasury financial-account filing, not an income tax calculation. The sections below explain which accounts and people are generally covered, how to submit, and what to consider if an earlier report is late.
| Filing situation | Reporting period | Regular date | Extended date or special deadline |
|---|---|---|---|
| General annual filing | 2026 account activity | April 15, 2027 | October 15, 2027, automatically |
| Limited signature-authority relief | Certain 2025 accounts | April 15, 2026, under the general rule | April 15, 2027, for eligible filers under the notice |
| Other 2025 filing | 2025 account activity | April 15, 2026 | October 15, 2026, automatically |
The annual October date and the special April date cover different reporting years
The normal annual cycle begins with an April 15 due date. FinCEN gives filers who miss that date an automatic extension to October 15 each year. You do not submit a separate extension request or wait for approval. For 2026 activity, that puts the regular filing date in April 2027 and the extended date in October 2027.
The special notice, FIN-2025-NTC3, has a different purpose. Dated December 8, 2025, it addresses certain people whose 2025 filing concerns signature or other authority over accounts, rather than a financial interest in them. The notice’s April 15, 2027 date is tied to that limited group and to certain deadlines extended by earlier FinCEN notices.
An income-tax filing extension does not determine the date for this separate report. Likewise, the ordinary automatic extension does not require you to file an income-tax extension request. If the deadline falls on a weekend or legal holiday, the filing date moves to the next business day.
Submit the report electronically, apart from your income tax return
FinCEN Form 114 is filed electronically through the BSA E-Filing System. Individuals can use the system’s no-registration option. Do not attach the report to Form 1040: it is a separate filing, carries no filing fee and is not an income-tax computation.
- Gather the account details: account number, financial institution name and address, account type and the highest value during the calendar year.
- Convert foreign-currency amounts using the applicable year-end Treasury Reporting Rate of Exchange. For 2025 account values, the research instructions specify the December 31, 2025 rates.
- Enter separately owned accounts in Part II, joint accounts in Part III, and accounts where you have authority but no financial interest in Part IV.
- Submit the report electronically and save the filing acknowledgement.
- Keep the supporting records for five years from the report’s due date.
FinCEN advises filers to submit as complete a report as possible by the deadline if some information is missing, then amend it when the missing details become available. No PDF attachments are allowed. Report the largest value reached during the year for each account, not simply its balance at year-end.
The $10,000 test adds foreign accounts together
A U.S. person generally must file when the combined value of reportable foreign financial accounts exceeded $10,000 at any time during the calendar year. The test applies to the total across accounts, rather than separately to each account, and it is based on balances rather than income earned.
| Account in the example | Value at the same point in March |
|---|---|
| Checking | $3,500 |
| Savings | $3,000 |
| Investment | $4,500 |
| Combined value | $11,000 |
The three balances total $11,000, so they cross the filing threshold even though none individually exceeds $10,000. If their combined value later falls to $8,000 in December, that decline does not undo the earlier crossing. The report requires each account’s maximum value for the year.
Use the applicable year-end Treasury exchange rate to convert foreign-currency values to U.S. dollars. The obligation can apply even if an account produced no income or you owe no U.S. tax. Income reporting and the account-reporting threshold are separate questions.
U.S. person status and authority can trigger a filing without ownership
The general category of U.S. persons includes U.S. citizens, green card holders, resident aliens under applicable rules, and domestic entities such as corporations and trusts. A U.S. citizen living abroad may still have an FBAR reporting obligation. A genuinely nonresident alien generally is not a U.S. person for this purpose.
You may have to report an account even when you do not own its funds. Signature authority means you can, alone or with another person, direct the disposition of account assets through communication with the financial institution. An employee or corporate officer authorized to act on an employer’s account can have that authority; so can someone permitted to act on a relative’s account.
Some employee exceptions are available only when regulatory conditions are met. Certain exceptions depend on an employer filing that covers the accounts at issue, so check both the individual’s role and the employer’s actual reporting. Authority alone can trigger this account report, but it does not by itself create a Form 8938 filing obligation, which requires a financial interest.
The special April 2027 date is limited to certain 2025 signers
The special extension applies to certain U.S. employees and officers of specified regulated entities, including U.S. publicly traded companies and financial institutions. For the relevant accounts during calendar year 2025, the individuals must have had signature or other authority but no financial interest. Eligibility also depends on specific criteria concerning certain employer-owned foreign accounts.
The notice extends the due date to April 15, 2027 for qualifying individuals. It also covers reporting deadlines carried forward by earlier FinCEN notices beginning in 2011. This is the 16th such extension since 2011. The preceding extension had moved certain filings to April 15, 2026.
The background is a proposed regulatory change issued March 10, 2016, concerning filing requirements for U.S. individuals with signature or other authority over foreign accounts. The proposed regulations had not been finalized in the cited material. The notice’s eligibility conditions matter: having signing authority over an employer account does not by itself establish that an employee qualifies. Founders and owners generally do not fall within this employee-focused relief.
Account location and ownership affect what belongs in the report
The institution’s location, rather than the currency used, helps determine whether an account is foreign. A dollar-denominated account at a London bank is foreign for this purpose; a euro account maintained at a New York bank is not. Foreign bank and brokerage accounts, mutual funds, and some cash-value insurance accounts can be reportable.
| Situation | Reporting consideration |
|---|---|
| Account maintained at a foreign bank or brokerage institution | It may be a reportable foreign account; report its maximum annual value if the rules apply. |
| Account held jointly | Joint holders generally report the full maximum value. A narrow spousal arrangement may use Form 114a if its conditions are satisfied; retain that form rather than submitting it with the report. |
| Account closed during the year | Closing it later does not automatically remove a reporting obligation for the year it was reportable. |
| Signature authority without financial interest | It can create a reporting obligation for this report, subject to exceptions; it does not alone require Form 8938. |
| Foreign financial assets considered for Form 8938 | The IRS form has different asset definitions and thresholds; filing one report does not necessarily satisfy the other. |
For Form 8938, the thresholds stated for people living abroad are $200,000 or $300,000 for a single filer and $400,000 or $600,000 for joint filers. Those figures concern a different reporting regime and do not replace the aggregate account test described above. Assess the two filings separately where both may apply.
The regular 2025 filing window has passed, but a narrow extension remains
As of November 15, 2026, the general extended date for most reports covering 2025 account activity has passed. The regular date was April 15, 2026, followed by the automatic extension through October 15, 2026. No further general extension beyond that October date applies to those filings.
| Reporting group | Regular due date | Extended or special date | Status as of November 15, 2026 |
|---|---|---|---|
| Most filers reporting 2025 activity | April 15, 2026 | October 15, 2026 | General extended date has passed |
| Eligible signature-authority-only filers covered by the special notice | April 15, 2026, under the general schedule | April 15, 2027 | Special date remains ahead |
| Filers reporting 2026 activity | April 15, 2027 | October 15, 2027 | Annual filing period is upcoming |
The annual extension is independent of an extension for your income tax return, including for people living abroad. There is no fee to file. FinCEN’s due-date guidance moves a filing date falling on a weekend or legal holiday to the next business day.
A missed filing calls for a compliance route matched to the facts
A late report can carry civil penalties, and willful violations may also lead to criminal penalties. The applicable outcome depends on the circumstances, including whether the failure was willful. A tax law firm’s guidance lists a non-willful civil penalty of up to $16,536 for assessments on or after January 17, 2025, subject to exceptions and inflation adjustments. For willful violations, it lists up to the greater of $165,353 or 50 percent of the amount determined under the statute, generally the account balance at the time of the violation. Those amounts do not predict what will happen in an individual case.
The available correction paths have different conditions. The Delinquent FBAR Submission Procedures may be relevant when account income was properly reported on tax returns and the tax due was paid. A late submission with an explanation may fit some cases, but eligibility and penalty treatment depend on the facts. Do not assume that filing late outside an applicable procedure will receive a particular penalty outcome.
The Streamlined Filing Compliance Procedures are for eligible taxpayers who can certify that their conduct was non-willful. They generally involve three years of tax returns and six years of reports. Form 14653 applies to the foreign streamlined track, while Form 14654 applies to the domestic track. Eligible foreign streamlined filers generally face a 0% miscellaneous offshore penalty; the domestic track generally applies a 5% penalty to the relevant base. Eligibility requirements differ between the tracks.
The Voluntary Disclosure Practice uses Form 14457 for eligible cases involving potential willful exposure. It is a separate route from the streamlined procedures. A quiet disclosure, meaning late submissions outside an appropriate procedure, may create additional risks. Review the facts and the requirements of the possible route before filing overdue reports, particularly if the IRS has contacted you.
Check the account year and exception before submitting
- Identify the calendar year of the account activity and use the deadline for that year.
- Add together the relevant foreign accounts and include accounts where you had signature authority, even if you did not own them.
- Check whether an employer exception applies and whether the employer filing covered the accounts in question.
- For an overdue report, review which compliance procedure fits before submitting a late filing.
- If a report is due, file FinCEN Form 114 electronically through the BSA E-Filing System and retain the acknowledgement and supporting records.
For 2026 activity, the annual extended date is October 15, 2027; for certain eligible 2025 signature-authority filings, the special date is April 15, 2027.
This article is for informational purposes only and does not constitute tax advice. Consult a qualified tax professional or CPA about your specific situation.
