FBAR Filing Instructions: What Documents You Need Before You Start

FBAR

Written by

Anthony N. Verni

Published on

December 22, 2025
fbar filing instructions

Filing the Foreign Bank Account Report (FBAR) feels a lot easier when you start with the right documents on your desk. Most people open the form first and then keep stopping because a detail is missing or a statement is sitting in another folder. And that stop-and-start routine can get tiring pretty quickly. So before you even log in to the filing system, it helps to know what you should gather, why it matters, and how it saves you time later. 

Once you have everything about the FBAR filing instructions ready, the whole process moves in a smooth, steady line instead of feeling like a half-finished task.

FBAR Filing Instructions

FBAR filing goes through the Financial Crimes Enforcement Network (FinCEN) instead of the IRS, and the rules come straight from federal law. So before you jump into the form, it helps to have a simple idea of what the government looks for and what you’ll need to report. Here’s everything explained in an easy, steady way, so you know what to expect right from the start.

What Is an FBAR and Who Has to File?

The FBAR Form 114 or FinCEN Form 114 is basically a yearly report for people in the U.S. who hold foreign bank or investment accounts. It doesn’t change your taxes or decide what you owe; it just tells the U.S. Treasury that these accounts exist.

You have to file an FBAR if you’re a U.S. person and the total value of all your foreign accounts went over 10,000 dollars at any point during the year. Even one day over the limit counts.

A “U.S. person” can be:

  • A citizen.
  • A green card holder.
  • Someone living in the U.S.
  • Or a business entity formed in the U.S., like a corporation, partnership, trust, estate, or Limited Liability Company (LLC).

The types of accounts that fall under this rule usually include foreign bank accounts, brokerage accounts, mutual funds, or really any financial account held outside the United States.

Where and How Do You File the FBAR?

The FBAR is filed online only through the FinCEN BSA E-Filing System. You don’t attach it to your tax return, and you don’t mail it with your Form 1040. It’s truly a separate filing.

In rare situations where someone honestly can’t file online, FinCEN allows you to request a paper-filing exception, but you need approval first before sending anything through the mail.

Information You Need to Enter on the FBAR

When you’re filling out the form, FinCEN asks for some basic details about each foreign account. You’ll need things like:

  • The name on the account.
  • The account number.
  • The bank or institution’s full name and address.
  • The type of account.
  • And the highest balance the account reached during the year.

This highest balance is important; it’s not the balance on the last day of the year but the peak amount the account hit at any time.

You also have to keep these account records for five years, just in case the government ever needs to review them.

Important Rules to Keep in Mind

A few rules show up every year, and they’re pretty straightforward:

  • You must file an FBAR even if the account didn’t earn any income.
  • The 10,000-dollar limit is based on the total of all your accounts combined, not one account at a time.
  • Filing the FBAR doesn’t replace your tax return; it’s just an FBAR reporting requirement for the Treasury.

FBAR Deadlines

The FBAR is due on April 15, right around tax season, but FinCEN gives everyone an automatic extension until October 15. You don’t have to request this FBAR extension; it happens on its own.

Fixing or Amending an FBAR

If you filed an FBAR before and notice a mistake later, or you forgot to file when you should have, you can still correct it. You just file a new FBAR and check the box that marks it as “Amended.”

FinCEN will also ask for your Prior BSA Identifier, which is basically the confirmation number from your earlier filing.

Knowing the FBAR form filing instructions is only part of the process. You also need certain details ready before you start, because the form asks for very specific FBAR account information. Having the right documents gathered ahead of time makes everything smoother.

What Documents Are Needed Before You Start FBAR Filing?

Before you file the FBAR, it’s a good idea to gather a few key documents so you’re not stopping halfway through the form trying to find details. The FBAR asks for very specific information about each foreign account, so having everything in front of you makes the whole process much smoother.

Here’s what you’ll usually need before you begin:

1. Basic Bank or Account Statements

The FBAR asks for the highest balance your account reached during the year, not the balance on December 31. So you’ll want:

  • Yearly bank statements.
  • Monthly or quarterly statements.
  • Or any document that shows the peak balance.

These statements also help you confirm the account number and the name on the account.

2. Bank or Financial Institution Details

FinCEN requires the full name and address of the foreign bank or institution.
So make sure you have documents that show:

  • Bank’s legal name.
  • Branch or headquarters address.
  • Institution code (if applicable).

Most people find this easily on their account statements or through the bank’s online portal.

3. Owner Information for Each Account

You will need documents that confirm:

  • The exact name on the account.
  • Whether you own the account or only have signature or other authority.
  • Any joint owner details (if another person shares the account).

This helps you enter everything correctly on the form since the FBAR separates ownership types.

4. Account Number for Each Foreign Account

The FBAR requires the complete account number exactly as it appears on the bank record. 

So make sure you have a document that clearly shows it; usually your statements or online dashboard will have this.

5. Currency Conversion Information

The FBAR must report balances in U.S. dollars, and FinCEN requires you to use the Treasury’s official year-end exchange rate.

To keep this simple, gather:

  • Your account balance in local currency.
  • The Treasury’s official exchange rate for that year (you can download it from the Treasury website).

This helps you calculate the correct maximum value in USD.

6. Any Documents Showing Signature or Authority Over an Account

If you don’t own the account but have authority to sign or control it, such as a work-related account, you should have:

  • Proof of your authority.
  • Documentation from the employer or financial institution.
  • Any written agreement or appointment letter.

This helps you answer the FBAR’s questions about “signature authority.”

7. Records You Must Keep for Five Years

Even after filing, the Internal Revenue Service (IRS) expects you to keep certain records for at least five years.
So it’s helpful to keep the following in one place:

  • Account ownership proof.
  • Account statements.
  • Documents showing the maximum balance.
  • Bank details and addresses.
  • Any correspondence showing authority over the account.

You don’t need to upload these to FinCEN; just keep them in case you’re ever asked.

FBAR Penalties for Late or Missed Filing

Missing the FBAR deadline can lead to FBAR penalties, and the amount depends on whether the government sees your situation as an honest mistake or something you should have known about. Here is a simple breakdown of how these penalties work and what they actually mean.

  1. Non-willful violations (honest mistakes): This applies when you didn’t know you had to file, or you made a genuine error. The non-willful penalty can be up to 12,921 dollars per violation, but it may be waived if you can show you had a reasonable cause for missing the filing.
  2. Willful violations (intentional or knowing): This is for situations where someone knew about the FBAR filing requirement and chose not to comply. The penalty is the greater of 129,210 dollars or 50% of the account’s highest balance for each year the FBAR wasn’t filed. These willful penalties are extremely high because FBAR rules fall under the Bank Secrecy Act.
  3. Failure to keep required records: You are expected to keep your foreign account records for five years. If you don’t, there can be a penalty of up to 10,000 dollars, even if the FBAR was filed.
  4. Criminal penalties (only in serious, intentional cases): Criminal charges are rare but possible when there is a clear intent to hide foreign accounts. In these cases, penalties can include fines of up to 250,000 dollars and up to five years in prison.

In simple words, honest mistakes usually lead to smaller penalties and sometimes none at all. Intentional violations, however, can become very costly.

How to Correct or Amend an FBAR Filing?

FinCEN allows you to correct an FBAR if you filed it with mistakes or if you realized later that something was missing. The process is straightforward, but you do need to follow the specific steps FinCEN requires.

Here’s what you need to do when fixing or updating an FBAR:

  1. File a new FBAR through the FinCEN BSA E-Filing System: You cannot fix an FBAR by emailing, calling, or attaching a note. The only way is to submit a completely new form online.
  2. Check the “Amended” box on the form: When you start the new filing, the form will ask whether this is a regular submission or an amendment. Select “Amended,” so FinCEN knows you are correcting a previous report.
  3. Enter the Prior BSA Identifier: Every FBAR you file receives a unique confirmation number called the BSA Identifier. When you amend the form, FinCEN requires you to enter the identifier from the original or most recent filing. This links your correction to the earlier report.
  4. Update the account information that was incorrect or missing: You don’t have to rewrite the entire form unless multiple parts were wrong. Just fix the specific accounts, balances, or details that need to be corrected.
  5. Keep the updated records for five years: Amended filings follow the same record-keeping rule as regular FBAR filings. Keep your corrected information and supporting documents for at least five years.

Secure Trusted Support for Your U.S. and Overseas Filing Needs!

For many taxpayers, the real challenge with FBAR filing isn’t the form itself; it’s the uncertainty. 

You may have accounts in different countries, in different currencies, or spread across multiple banks. Sometimes, the real concern is whether your reporting matches what the Treasury expects. That is when the right guidance matters.

Verni Tax Law supports taxpayers who want that clarity.

Anthony N. Verni brings a rare combination of experience as an Attorney, CPA, and MBA. He regularly works with U.S. individuals, businesses, and expats who need to file their taxes in the U.S. while managing FBAR filing instructions for financial accounts abroad.

Speak directly with Anthony N. Verni, who handles these obligations every day.

FAQs

FBAR filing online through the FinCEN BSA E-Filing System, and that is the filing method almost everyone must use. Paper filing is only allowed in very limited situations, and even then, you cannot simply mail a paper form. You first need to contact the FinCEN Regulatory Helpline and request permission. If FinCEN reviews your situation and agrees that you cannot file online, they will give you written approval to submit a paper FBAR.

Without that approval, the paper form is not accepted. So the first step is always to try the electronic system, and if it is truly not possible for you, FinCEN will tell you how to move forward with the paper option.

You can still file the FBAR even if you do not have a Social Security Number or an Individual Taxpayer Identification Number (ITIN). FinCEN allows you to enter the word “Unknown” in the SSN or ITIN field when the filer does not have a number. This keeps your filing compliant and lets you report your foreign accounts without delay.

It is still a good idea to apply for an SSN or ITIN if you are required to have one for other tax purposes, but the lack of a number does not stop you from filing the FBAR itself. The key point here is that FinCEN will not reject your FBAR solely because you do not have an identifying number.

FBAR and the Foreign Account Tax Compliance Act (FATCA) both deal with foreign financial accounts, but they serve different purposes and follow different rules. FBAR is a Treasury requirement handled through FinCEN, while FATCA reporting is handled by the IRS. 

Here is a simple way to understand the difference:

  • FBAR is filed through the FinCEN BSA E-Filing System.
  • FATCA is filed on Form 8938 with your tax return.
  • FBAR has a $10,000 total threshold for all foreign accounts.
  • FATCA has much higher filing thresholds that depend on your filing status and whether you live in the United States or abroad.
  • Some accounts may appear on both forms, while others may only appear on one, depending on your situation.

The two filings are separate, and filing one does not replace the other. If you meet both FATCA and FBAR requirements, you must file both.

Most people who meet the filing threshold must file, but there are a few narrow exceptions. Some common ones include:

  • Foreign accounts held by a bank or financial institution where you work, if you only have signature authority, and the employer already files the required reports.
  • Certain accounts are owned by a U.S. government entity.
  • Foreign accounts owned by an international organization where you serve in an official role.
  • Retirement plans or trusts that already file their own foreign account reports.
  • Consolidated filings are where a business files on behalf of entities it owns.

These exceptions do not apply to most individuals, so it is important to look closely at your specific situation rather than assume you fall into an exception.

Filing the FBAR reports for past years is still possible if you missed the initial filing. FinCEN accepts FBAR late filings through the same online system, and you can choose the specific year you want to correct. When you submit a late FBAR, you follow the same steps you would for a regular submission. If you already understand the Fbar 114 filing instructions, the process feels pretty straightforward because you’re entering the same information for each year you missed.

The IRS investigates the reason for the late filing. If it was an honest mistake, the penalty can be very low, or in some cases, it is not imposed at all. On the contrary, if the IRS thinks that the failure to file was deliberate, it can impose hefty FBAR penalties. This is one reason why many people prefer to clear up old FBARs so they do not have several years of unfiled returns.

The most significant action to take is to fill in the missing years. After those reports are made, the IRS can assess your situation and determine the course of action regarding the collection of any possible penalties.

Author

Anthony N. Verni

ATTORNEY AT LAW, J.D., CPA, MBA
With 20+ years of experience practicing before the IRS, I bring a rare combination of legal and financial expertise as both an Attorney and a Certified Public Accountant.
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