The U.S. Treasury requires U.S. citizens and green card holders to declare their non-U.S. financial accounts and remain compliant with FBAR (Foreign Bank Account Report, FinCEN Form 114) filings for the past six years.
FBARs are required only if the aggregate balance of your non-U.S. financial accounts exceeded $10,000 at any point during the year, even if only for one day.
If you filed your U.S. tax returns but have not filed FBARs, your options depend on whether all interest income from your foreign accounts was reported and whether you are subject to additional reporting requirements:
All interest reported on original returns → File the late FBARs with a reasonable-cause statement (the route formerly known as Delinquent FBAR Submission Procedures). No amended tax returns are required.
Interest not reported on original returns → File three amended tax returns + six FBARs through the Streamlined Foreign Offshore Procedures.
Form 8938 (FATCA) was required but not filed → File three amended returns, Forms 8938, and six FBARs through the Streamlined Foreign Offshore Procedures.
For more details, refer to Difference between FinCEN Form 114 and Form 8938.
If you are not up to date on U.S. tax returns (not current with U.S. income tax reporting), you may be able to take advantage of the following IRS amnesty programs:
Delinquent international information return submission procedures (if you filed tax returns but never filed Forms 5471, 5472, 3520, 3520-A, 8865)
What happened to the Delinquent FBAR Submission Procedures?
Until July 1, 2026, the IRS published the Delinquent FBAR Submission Procedures (DFSP) for people who missed only FBARs but reported all related income on their U.S. tax returns. The IRS has removed that page. Since July 2026, the IRS no longer publishes a no-penalty guarantee; penalties are discretionary; reasonable-cause relief remains available under 31 U.S.C. §5321.
You can still file late FBARs electronically, with an explanation of why they are late. Residency does not matter: both U.S. residents and taxpayers abroad can file this way. For more information, please refer to Delinquent FBAR Submission Procedures: how to file late FBARs now.
When late FBAR filing alone is enough
Filing late FBARs without amending your tax returns fits your case if:
You did not file one or more required FBARs in prior years.
You properly reported all taxable income from your foreign accounts on your U.S. tax returns.
You are not currently under IRS audit or investigation.
The IRS has not yet notified you about delinquent FBARs.
If all of the above apply, file the late FBARs with a reasonable-cause statement. Penalty relief is not guaranteed, but filing before the IRS contacts you keeps the risk low.
Filing with TFX
To file past-due FBARs with TFX, follow these steps:
Ensure that all related income from your foreign accounts was included on your prior tax returns.
Electronically file delinquent FBARs directly through your TFX account using our automated FBAR filing service.
⚠ Note: The address reflected on the FBAR should be your current address.
Pay the fee: $85 per tax year.
⚠ Note: The 20% multi-year discount does not apply to FBAR filings.
By filing through TFX, you ensure your FBARs are submitted correctly and securely — without having to navigate FinCEN’s BSA e-filing system on your own.