Do I have to report a foreign bank account?
A US person must file an FBAR — FinCEN Form 114 — for any calendar year in which the combined value of their foreign financial accounts passed the reporting threshold at any point. It covers accounts you own and accounts you only sign on, it is filed electronically with FinCEN rather than the IRS, and it is separate from your tax return.
For tax year 2025
Key points
- A US person, including a citizen, resident, corporation, partnership, limited liability company, trust, or estate, must file an FBAR when their foreign financial accounts pass the reporting threshold at any time during the calendar year.
- The FBAR threshold is measured on the combined value of all foreign financial accounts, so several small accounts can trigger the report together.
- Signature or other authority over a foreign account counts toward the FBAR requirement even when the filer owns none of the money in it, so a US person with signature authority over foreign accounts whose combined value passes the threshold generally has to file, subject to specific exceptions.
- The FBAR is FinCEN Form 114, filed electronically through FinCEN's BSA E-Filing System and not filed with a federal tax return.
- The FBAR is due April 15 following the calendar year reported, with an automatic extension to October 15 that does not have to be requested.
Who has to file an FBAR?
The Bank Secrecy Act requires a US person to report certain foreign financial accounts to the Treasury Department each year. A US person is broader than most owners assume: it includes citizens, residents, corporations, partnerships, limited liability companies, trusts, and estates, so a company can have its own filing obligation alongside its owner's.
The obligation arises where the person had a financial interest in, or signature or other authority over, at least one financial account located outside the United States, and the combined value of those accounts passed the reporting threshold at any time during the calendar year. Signature authority alone is enough. An owner who can direct the disposition of money in a foreign company account, or a family account, may have to report it even though none of the money is theirs.
Which accounts count toward the threshold?
Generally, an account at a financial institution located outside the United States is a foreign financial account, and bank accounts, brokerage accounts, and mutual funds are all in scope. The threshold is aggregate, so two accounts that each look modest can cross it together. Whether an account produced taxable income has no effect on whether it is reportable, which means a dormant account still counts.
Several categories fall outside the requirement, including correspondent and Nostro accounts, accounts owned by a governmental entity or an international financial institution, accounts maintained on a US military banking facility, accounts held in an individual retirement account of which you are an owner or beneficiary, accounts in a retirement plan of which you are a participant or beneficiary, and accounts held in a trust of which you are a beneficiary where a US person already files an FBAR reporting them.
When and where is the FBAR filed?
The FBAR is an annual report due April 15 following the calendar year reported. If that date is missed, an automatic extension to October 15 applies, and it does not have to be requested. Disaster relief can extend the date further, and a separate extension has been repeatedly granted for certain employees and officers with signature authority but no financial interest.
It is filed electronically through FinCEN's BSA E-Filing System, and it is not filed with a federal tax return. This is the point worth holding on to: Form 114 goes to the Financial Crimes Enforcement Network, a Treasury bureau separate from the IRS, so a complete and accurate tax return says nothing about whether the FBAR was filed. If someone else files on your behalf, they need a signed FinCEN Report 114a, which you keep rather than submit.
What records do you have to keep, and what happens if you get it wrong?
For each account reported, you keep the name on the account, the account number, the name and address of the foreign bank, the type of account, and the maximum value during the year. The law does not specify the document, so bank statements or a copy of the filed FBAR are usually enough, and the records are generally kept for five years from the report's due date. An officer or employee filing only because of signature authority over an employer's account does not have to keep the records personally; the employer does.
Civil monetary penalties and criminal penalties exist for reporting and recordkeeping violations, and whether penalties are asserted depends on the facts and circumstances. Where a filing was missed and the IRS has not contacted you about it and you are not under IRS civil or criminal investigation, the guidance is to file the late reports as soon as possible with the reason for the delay stated. Formal compliance options exist as well, each with its own eligibility conditions and its own instructions, which are followed instead of the general late-filing route.
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