How can you complete your FBAR filing on time?

To finish your FBAR on time, collect your account information early, check it before you open the filing form, and set your own submission date. This FBAR filing checklist takes you from a list of accounts to a saved filing confirmation. If you have missed earlier years, first check which steps are appropriate for catching up.

An FBAR is a report of certain financial accounts outside the United States. You submit it using FinCEN Form 114. FinCEN is the U.S. Treasury agency that receives the report. This guide focuses on preparing your own annual filing.

1. Choose the reporting year and set your dates

Your FBAR covers a calendar year, from January 1 to December 31. You file it the following year. Write that reporting year at the top of your checklist and use it when requesting bank records.

The regular deadline is April 15, with an automatic extension to October 15. No separate extension request is needed. The FBAR is filed separately from your U.S. income tax return. Check FinCEN’s notices for any special deadline relief that applies to you.

Use the following suggested preparation schedule. These are planning targets, not extra legal deadlines.

If you start later, use the same order. Give each task an actual date and name the person responsible: you, your bank or your preparer. If your applicable deadline has already passed, read the section on missed years below.

2. Make one list of your accounts

Start with bank, savings and investment accounts outside the U.S. Include accounts you shared with someone else and accounts you closed during the reporting year. Closing an account does not remove it from that year’s review.

Also flag accounts where you can instruct the bank to move money for someone else, either alone or together with another person. This is called signature authority and can create a reporting obligation even if the money is not yours. Pensions, insurance products, business accounts and accounts held for another person may need closer assessment. Do not decide solely from the name on the account.

A U.S. person includes a U.S. citizen or resident and certain U.S. entities. This guide focuses on individuals. A U.S. person generally must file when the combined value of reportable foreign accounts exceeds $10,000 during the year. The limit is not $10,000 per account. Review the IRS FBAR reference guide for account types, ownership rules and exceptions.

3. Gather the documents before filling in the form

Create a secure folder for the reporting year. For each account, collect:

• The account holder’s name and account number, such as an IBAN where applicable.
• The financial institution’s name, address and country.
• The account type and whether it is owned individually, jointly or controlled for someone else.
• Statements or transaction records that show the highest value during the year.
• Details of any joint owner needed for the relevant form section.

Keep your own identifying details ready too, including your U.S. taxpayer identification number if you have one. Follow the form instructions if you do not. Do not enter an invented number.

An annual bank summary can be a useful starting point, but a summary showing only the closing balance may not establish the year’s highest value. Request missing records now, rather than waiting until you are ready to submit.

4. Work out the account values

Use a separate line for each account and work through these steps:

1. Find the annual maximum. Work out the account’s highest value during the reporting year in its own currency. Statements may be used if they fairly reflect that maximum.
2. Convert it to dollars. Use the Treasury exchange rate for December 31 of the reporting year. If no Treasury rate exists, use another verifiable rate and identify its source.
3. Round up. Report the dollar value rounded up to the next whole dollar.

Follow the FinCEN instructions for maximum account values. Do not replace this calculation with today’s exchange rate or only the December 31 balance.

A simple example

This hypothetical example uses an invented exchange rate of EUR 0.90 per U.S. dollar to show the calculation. It is not a rate to use for your own filing. Alex is a U.S. citizen with two reportable foreign accounts and no applicable filing exception.

The combined maximum values exceed $10,000, so Alex reports both accounts. The highest value of each account goes on its own line in the FBAR. Those maximum values may occur on different dates. If you moved money between accounts, keep both accounts on your checklist and follow FinCEN’s instructions rather than leaving one out.

Save your calculation with the statements and exchange-rate source so you can explain how you reached each figure.

5. Decide whether to file yourself or get help

Self-filing may suit you if your annual filings are up to date, your account position is straightforward and you understand the instructions. Consider help if ownership is unclear, you control accounts for others, records are missing or earlier years were not filed.

When requesting help with FBAR filing, send an account count and a list of unresolved questions through the agreed secure channel. Ask for a written fee, the documents required and a realistic completion date. Confirm who will submit the report and who will check the acknowledgement. Agree a completion date after the preparer has reviewed your account list.

If someone files for you, FinCEN Form 114a records your authorization. Keep it with your records; it is not submitted with the FBAR.

6. Complete and submit FinCEN Form 114

Open the official FinCEN individual FBAR filing page. Individuals filing their own FBAR do not need to create a BSA E-Filing account.

1. Choose a method. The online form is for preparation and submission online and does not require Adobe Reader. The PDF option requires Adobe Reader and allows you to save your work while preparing it.
2. Select the reporting year. Check that it matches your records, rather than the year in which you are submitting.
3. Enter your details and accounts. Use the relevant sections for individual ownership, joint ownership and signature authority.
4. Review the entries. Compare every account number and dollar value with your checklist. Resolve the form’s validation messages.
5. Sign and submit. Follow the selected route through to its submission confirmation. Saving or signing a PDF alone does not submit it.

Keep bank statements in your records. They are not attachments to the FBAR. If the PDF does not open correctly, check the PDF route’s software requirements or use the online option if suitable. For technical problems, use FinCEN’s technical support guidance. Do not email a completed FBAR or other sensitive information to the help desk.

7. Save the confirmation and check the follow-up

Save your submitted report, confirmation and tracking details. Check your email, including the spam folder, for the later acknowledgement and BSA Identifier, the reference number for the filing. FinCEN’s electronic filing guide describes acknowledgement within two business days. If it does not arrive, contact technical support with your tracking details rather than assuming the report was processed.

The IRS generally requires the account records to be kept for five years from the FBAR due date. As a practical precaution, keep the complete file for at least five years from the later of the due date or your actual filing date. Add a reminder for next January while the process is still fresh.

What if something is missing or you have missed earlier years?

Missing statements: ask for archived statements, a transaction export or bank confirmation of the maximum value. Check whether the records fairly show the annual maximum. If a value remains unavailable, follow the official instructions for the amount-unknown field or obtain help. Do not put zero merely because you cannot find a figure.

Joint accounts: do not assume that a joint tax return or your partner’s FBAR automatically covers you. A limited spouse exception has specific conditions, including Form 114a. Check eligibility before relying on it.

Missed years: make a list of the missing FBARs and tax returns and arrange a prompt assessment. The appropriate route depends on what was omitted and your circumstances. The Streamlined Procedure may help eligible people whose failures were non-willful, meaning caused by matters such as mistake or a good-faith misunderstanding. It is not the automatic answer to every late FBAR, and eligibility conditions apply.

Do not wait until the next annual deadline to address a backlog. At the same time, do not assume that filing an unexplained set of old reports resolves every tax or reporting issue.

If you need help deciding where to start, Americans Overseas can explain the available next steps and connect you with a suitable specialist.

Get Informed with Americans Overseas

We, the founders of Americans Overseas, were born in the Netherlands and received our American citizenship through our (American) mother.

When we first learned about the U.S.–Netherlands tax treaty around 2013, we felt disbelief (“this can’t be true”), anger (“how can they do this?”), fear (“will I get fined or have problems?”), and panic (“what should I do?”).

Unfortunately, it is true that there is a U.S. tax obligation for Dutch citizens who acquired American nationality by birth. There was no information from local authorities, the U.S. consulate referred us to the IRS, and the IRS itself was impenetrable.

That is why we started this initiative: to help others with reliable information, to prevent unnecessary panic, and to offer free, no‑obligation assistance. When needed, we can connect you with a network of affordable professionals (accountants) who can help you meet your U.S. tax obligations.

Contact us for more information

Sources

• IRS: FBAR requirements, deadlines and recordkeeping
• IRS Publication 5569: FBAR reference guide
• FinCEN: reporting rules and deadline notices
• FinCEN: instructions for completing Form 114
• FinCEN: individual FBAR filing portal
• FinCEN: electronic filing and acknowledgement guide
• FinCEN: technical help
• IRS: Streamlined Filing Compliance Procedures