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FBAR Extension: Key Deadlines, Rules, and Penalties

Jul 21, 2025 | FBAR and FATCA, Personal U.S. expat taxes

The FBAR deadline is April 15, but if you miss it, you automatically get an extension to October 15. You don’t need to file a form or take any action — the extension applies by default. This article explains the rules, deadlines, and what happens if you still don’t file on time.

When Is the FBAR Due?

The annual FBAR filing deadline is April 15, the same date as your federal tax return. However, the Treasury Department offers an automatic extension until October 15 for anyone who misses the April deadline. You don’t need to file a separate form or request the extension — it is automatic.

So yes, you can file FBAR after April 15 — as long as it’s done before October 15. If you miss this extended deadline, you may face significant penalties. Learn more about FBAR penalties here.

Who Must File the FBAR?

You must file the FBAR if:

  • You’re a U.S. person (including citizens, residents, and certain entities), and
  • You had a financial interest in or signature authority over one or more foreign financial accounts, and
  • The aggregate value of all your foreign accounts exceeded $10,000 at any time during the calendar year.

This includes not only foreign bank and savings accounts, but also brokerage accounts, mutual funds, retirement accounts, and other foreign accounts held at foreign financial institutions.

Individuals with signature authority, even without a financial interest, must file an FBAR if the above threshold is met.

What Types of Accounts Must Be Reported?

The FBAR filing requirements apply to a broad range of financial accounts, including:

  • Foreign bank accounts (checking and savings accounts)
  • Brokerage accounts held overseas
  • Mutual funds
  • Retirement accounts, including individual retirement accounts held abroad
  • Certain foreign financial accounts where you have signature authority or other authority
  • Foreign assets held through foreign financial institutions
  • Bank and financial accounts held in any foreign country

You must include details such as account numbers, the maximum value during the calendar year, and the name and address of the financial institutions.

How to File the FBAR

You must file the FBAR electronically using the BSA E-Filing System, maintained by the Financial Crimes Enforcement Network (FinCEN), a bureau of the Treasury Department. The form is known as FinCEN Form 114, and it must be filed electronically — paper submissions are not accepted.

Anyone who must file an FBAR is required to electronically file through the e-filing system on the FinCEN website.

Can You Request an FBAR Extension?

Technically, no separate request is needed. The IRS grants an automatic extension to October 15 for all taxpayers who don’t file by the April 15 deadline. This policy was confirmed by the Financial Crimes Enforcement Network and applies to every tax year.

If you’re impacted by a natural disaster, the IRS may further extend the fbar deadline for affected regions, similar to federal tax return extensions. But under normal circumstances, no action is needed to benefit from the extension.

What If You File FBAR Late?

Failing to file the FBAR on time may result in delinquent FBARs, which can trigger:

  • Civil penalties of up to $10,000 per account per year for non-willful violations
  • Criminal penalties of up to $250,000 and five years in prison for willful violations
  • Extended audit exposure for the entire tax year

However, if you have reasonable cause for late filing, and you file the FBAR voluntarily using the Delinquent FBAR Submission Procedures, you may avoid penalties. It is essential to consult a tax professional to assess whether you qualify.

Filing Scenarios for Expats

U.S. expats often hold a mix of bank and financial accounts in various countries. If you live abroad and meet the filing requirements, you must file the FBAR regardless of your income tax filing status (e.g., married filing jointly or married filing separately).

Keep in mind:

  • Only one spouse needs to file the FBAR if all accounts are jointly owned.
  • If accounts are not jointly owned, both spouses must file separately.
  • Expats must report all foreign bank and financial holdings, even if those accounts are held in their country of residence.

The aggregate value of your foreign accounts includes the maximum value of each account over the calendar year, converted into U.S. dollars.

Common Mistakes That Lead to Penalties

  • Not knowing you need to file
  • Thinking only taxable income triggers reporting (it doesn’t)
  • Confusing foreign income with foreign financial accounts
  • Missing the extended deadline because you thought an FBAR wasn’t needed
  • Underreporting the aggregate value of your bank accounts
  • Assuming retirement accounts or mutual funds don’t count

What U.S. Expats Should Know About the FBAR Due Date Extension

If you meet the filing requirements for FBAR reporting, you must file the FBAR through the BSA E-Filing System by April 15. Thanks to an automatic extension, you have until October 15 to comply. This extension applies automatically each calendar year.

We charge $100 per FBAR regardless of the number of accounts you have. Contact us today and become tax compliant.

Kasia Strzelczyk, EA

Kasia Strzelczyk, EA

A certified accountant and IRS enrolled agent with over 8 years of experience working with US expats. With a deep understanding of the unique financial challenges faced by expats, Kasia is dedicated to helping clients navigate complex tax laws and regulations.

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