FBAR Filing Requirements 2025: What US Taxpayers Need to Know

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title: "FBAR Filing Requirements 2025: What US Taxpayers Need to Know" description: "A comprehensive guide to FBAR (FinCEN Form 114) filing requirements for 2025, including who must file, deadlines, penalties for non-compliance, and step-by-step filing instructions." date: "2025-12-08" author: "FedTaxUSA" category: "International Tax" readTime: "10 min read" featured: true

If you're a U.S. person with financial accounts in foreign countries, you may be required to file an annual Report of Foreign Bank and Financial Accounts (FBAR). Understanding these requirements is crucial because the penalties for non-compliance can be severe—even for unintentional violations. This guide explains everything you need to know about FBAR filing requirements for 2025.

What Is an FBAR?

The FBAR, officially known as FinCEN Form 114, is a report that U.S. persons must file with the Financial Crimes Enforcement Network (FinCEN) to disclose their financial interest in or signature authority over foreign financial accounts. The FBAR is not a tax form—it's a disclosure requirement under the Bank Secrecy Act.

The FBAR exists to help the U.S. government identify taxpayers who may be using foreign accounts to evade taxes and to track money laundering and other financial crimes.

Who Must File an FBAR?

You must file an FBAR if you meet all of the following criteria:

You Are a "United States Person"

A U.S. person includes:

• U.S. citizens, regardless of where they live
• U.S. resident aliens (green card holders)
• Domestic entities (corporations, partnerships, LLCs, trusts, and estates formed under U.S. law)

You Have a Financial Interest or Signature Authority

You must file if you have:

• Financial interest: You own or have partial ownership of a foreign account, or you have sufficient control over an entity that owns a foreign account
• Signature authority: You can control the disposition of assets in a foreign account, even if you don't personally own the account

The Aggregate Value Exceeds $10,000

If the combined value of all your foreign financial accounts exceeds $10,000 at any time during the calendar year, you must file an FBAR. This threshold is based on the maximum value during the year, not the year-end balance.

Important: The $10,000 threshold is an aggregate total. If you have three accounts with maximum values of $4,000, $3,500, and $3,000 respectively, you must file because the aggregate exceeds $10,000.

What Accounts Must Be Reported?

Foreign financial accounts that must be reported on the FBAR include:

Bank Accounts

• Checking accounts
• Savings accounts
• Time deposits (CDs)

Securities Accounts

• Brokerage accounts
• Securities accounts held with foreign financial institutions

Other Financial Accounts

• Mutual funds
• Accounts with a financial agency (insurance companies, investment companies)
• Accounts where you've invested money in a commingled fund
• Certain types of retirement accounts in foreign countries

Accounts Often Overlooked

Many taxpayers forget to report:

• Foreign pension accounts
• Accounts in the names of their children
• Accounts over which they have signature authority for business purposes
• Accounts held through foreign LLCs or other entities

What Accounts Are Exempt?

Certain accounts don't need to be reported on the FBAR:

• Accounts owned by a government entity
• Accounts owned by international financial institutions
• Individual Retirement Accounts (IRAs)
• U.S. military banking facilities
• Correspondent accounts or nostro accounts (accounts used by financial institutions for transactions)

FBAR Filing Deadline for 2025

For the 2024 calendar year, the FBAR is due on April 15, 2025. However, if you miss this deadline, you automatically receive an extension to October 15, 2025. No action is required to receive this automatic extension—you don't need to file any paperwork.

Key dates to remember:

• January 1, 2025: Start of the filing period for 2024 FBAR
• April 15, 2025: Original due date
• October 15, 2025: Extended due date (automatic, no request needed)

How to File an FBAR

FBARs must be filed electronically through the FinCEN BSA E-Filing System. Paper filing is generally not accepted except in limited circumstances.

Step-by-Step Filing Process

Step 1: Gather Account Information

For each reportable account, collect:

• Name on the account
• Account number
• Name and address of the foreign bank or financial institution
• Type of account
• Maximum value during the calendar year
• Currency in which the account is denominated

Step 2: Convert Foreign Currency

Convert the maximum account value to U.S. dollars using the Treasury Department's end-of-year exchange rate. The official rates are published on the Treasury website.

Step 3: Access the FinCEN BSA E-Filing System

Go to the FinCEN BSA E-Filing website. You don't need to create an account to file—you can file as an individual without registration.

Step 4: Complete the Form

Fill out all required information:

• Part I: Filer information
• Part II-IV: Account information (repeat for each account)
• Part V: Signature and certification

Step 5: Submit and Save Confirmation

After submitting, you'll receive a confirmation. Save this for your records—it's your proof of filing.

Third-Party Filing

If you want a tax professional to file on your behalf, you'll need to provide written authorization. The filer can then submit the FBAR using their own BSA E-Filing account.

FBAR Penalties

FBAR penalties can be severe, especially for willful violations:

Non-Willful Violations

If you failed to file or filed an incorrect FBAR without intent to violate the law, penalties can be up to $10,000 per violation. Each unreported account can constitute a separate violation.

Willful Violations

If you willfully failed to file or filed a false FBAR, penalties can be up to $100,000 or 50% of the account balance at the time of the violation, whichever is greater. Criminal penalties may also apply.

Criminal Penalties

In egregious cases, criminal prosecution can result in:

• Fines up to $250,000
• Imprisonment up to 5 years
• Both fines and imprisonment

Reasonable Cause Exception

If you can show that your failure to file was due to reasonable cause and not willful neglect, you may be able to avoid penalties. Reasonable cause might include:

• Reliance on professional advice
• Lack of knowledge about the filing requirement (in limited circumstances)
• Circumstances beyond your control

FBAR vs. FATCA (Form 8938)

Many taxpayers confuse the FBAR with Form 8938, Statement of Specified Foreign Financial Assets, which is a separate requirement under FATCA (Foreign Account Tax Compliance Act). Here's how they differ:

| Feature | FBAR (FinCEN 114) | Form 8938 | |---------|-------------------|-----------| | Filing agency | FinCEN | IRS | | Filing method | Electronically via BSA E-Filing | With your tax return | | Threshold (individuals in U.S.) | $10,000 aggregate | $50,000 on last day or $75,000 at any time | | Threshold (individuals abroad) | $10,000 aggregate | $200,000 on last day or $300,000 at any time | | What's reported | Foreign financial accounts | Foreign financial assets (broader) | | Penalties | Up to $10,000 (non-willful) or 50% of balance (willful) | Up to $10,000 for failure to file, plus accuracy penalties |

Important: You may need to file both forms. Meeting the FBAR filing requirement doesn't exempt you from Form 8938, and vice versa.

Common FBAR Mistakes to Avoid

Not Filing Because You Didn't Owe U.S. Tax

The FBAR requirement is independent of your tax liability. Even if you owe no U.S. tax, you must still file the FBAR if you meet the threshold.

Using the Wrong Exchange Rate

Always use the Treasury Department's official end-of-year exchange rate, not the rate on the date of the maximum value or an average rate.

Forgetting About Joint Accounts

If you share a foreign account with your spouse, both of you may need to file FBARs (though special rules apply for jointly filed FBARs).

Overlooking Signature Authority Accounts

Even if you don't own an account, having signature authority requires FBAR filing. This commonly affects corporate officers, trustees, and employees with authority over business accounts.

Missing the Maximum Value

The FBAR requires the maximum value during the year, not the year-end balance. Review statements throughout the year to identify the peak value.

Streamlined Filing Compliance Procedures

If you've missed filing FBARs in prior years but the failure was not willful, you may qualify for the IRS Streamlined Filing Compliance Procedures. This program allows eligible taxpayers to come into compliance with reduced penalties.

Streamlined Domestic Offshore Procedures

For U.S. residents who:

• Failed to report foreign income
• Failed to file FBARs
• Were non-willful

This program requires filing amended returns for 3 years, FBARs for 6 years, and paying a 5% miscellaneous offshore penalty.

Streamlined Foreign Offshore Procedures

For U.S. taxpayers living abroad who:

• Have been outside the U.S. for at least 330 days in one of the past 3 years
• Were non-willful

This program requires similar filings but with no miscellaneous penalty.

Record-Keeping Requirements

You must keep records of your foreign accounts and FBAR filings for at least 5 years from the due date of the FBAR. Records should include:

• Account statements
• Documentation of account ownership
• Records of transfers into and out of the account
• Copies of filed FBARs and confirmation receipts

Planning Tips for FBAR Compliance

Keep Organized Records Year-Round

Don't wait until filing season to gather account information. Keep a running log of your foreign accounts and update maximum values as statements arrive.

Set Calendar Reminders

Mark key dates on your calendar to ensure you don't miss the filing deadline.

Review Your Accounts Annually

Take time each year to review all your foreign accounts and ensure nothing has been overlooked.

Consult a Tax Professional

Given the complexity of FBAR requirements and the severity of penalties, working with a tax professional experienced in international tax matters is often worthwhile.

Conclusion

FBAR compliance is not optional—it's a legal requirement with serious consequences for non-compliance. If you have foreign financial accounts, take the time to understand your obligations, gather the necessary information, and file on time.

If you're unsure whether you need to file an FBAR, or if you've missed filings in prior years, consult with a qualified tax professional who can evaluate your situation and help you achieve compliance while minimizing potential penalties.

Remember: The goal of the FBAR is disclosure, not taxation. Filing an FBAR doesn't necessarily mean you owe additional taxes. But failing to file can result in significant penalties that far exceed any potential tax liability.