FBAR: Who Needs to File and What Happens If You Miss It?
If you are a U.S. person with bank accounts, investment accounts, or other qualifying financial accounts outside the United States, you may have an important annual reporting obligation that is separate from your federal income tax return.
This filing is known as the FBAR — Report of Foreign Bank and Financial Accounts, filed electronically through FinCEN using FinCEN Form 114.
For 2026, the regular FBAR filing deadline is April 15, 2026, for reportable foreign accounts held during calendar year 2025.
However, taxpayers who miss the April 15 deadline automatically receive an extension until October 15, 2026. No separate extension request is required for the FBAR.
If you have financial accounts in Brazil or another foreign country, understanding the FBAR rules is especially important.
Here is what you need to know about the 2026 FBAR filing deadline.
What Is the FBAR?
FBAR stands for Report of Foreign Bank and Financial Accounts.
It is a reporting requirement established under the Bank Secrecy Act for certain U.S. persons who have financial interests in, or signature or other authority over, foreign financial accounts.
The FBAR is filed using FinCEN Form 114 and is submitted electronically through the FinCEN BSA E-Filing System.
It is important to understand that the FBAR is not filed with your federal income tax return and is not submitted directly to the IRS. It is filed with the Financial Crimes Enforcement Network, or FinCEN, which is part of the U.S. Department of the Treasury.
Who Needs to File an FBAR?
A U.S. person generally must file an FBAR when:
They have a financial interest in or signature or other authority over at least one financial account located outside the United States; and
The aggregate maximum value of all reportable foreign financial accounts exceeds $10,000 at any time during the calendar year.
The $10,000 threshold applies to the combined maximum value of the accounts, not to each individual account.
For example, imagine you have:
A Brazilian bank account with a maximum balance of $6,000;
A Brazilian investment account with a maximum balance of $3,000;
Another foreign account with a maximum balance of $2,000.
Even though none of the individual accounts exceeded $10,000, their combined maximum value was $11,000.
That can trigger an FBAR filing requirement.
What Is Considered a U.S. Person?
For FBAR purposes, a U.S. person can include:
U.S. citizens;
U.S. residents;
Domestic corporations;
Partnerships;
LLCs;
Trusts;
Estates.
Therefore, FBAR obligations are not limited to individuals.
A business or other U.S. entity can also have FBAR reporting responsibilities when it meets the applicable requirements.
This is particularly relevant for business owners who maintain foreign accounts or have financial interests in businesses outside the United States.
What Types of Accounts May Need to Be Reported?
The FBAR can apply to various types of foreign financial accounts.
These may include:
Bank accounts;
Savings accounts;
Checking accounts;
Brokerage accounts;
Securities accounts;
Mutual funds;
Certain foreign financial accounts held through other institutions.
The key question is generally whether the account is a reportable financial account located outside the United States and whether the taxpayer meets the FBAR reporting requirements.
For example, a Brazilian taxpayer living in the United States may need to report qualifying:
Brazilian checking accounts;
Brazilian savings accounts;
Brazilian investment accounts;
Other qualifying financial accounts maintained in Brazil.
Does the Account Have to Generate Income to Be Reported?
No.
Whether the foreign account generated taxable income does not determine whether it must be reported on an FBAR.
A foreign financial account can be reportable even if it:
Earned no interest;
Generated no dividends;
Produced no capital gains;
Was not used during most of the year.
The FBAR requirement is based primarily on the taxpayer's relationship to the account and its maximum value during the year.
This is one reason why taxpayers should not assume that an inactive or low-income foreign account can automatically be ignored.
What Is the FBAR Deadline for 2026?
For accounts held during calendar year 2025, the regular FBAR deadline is:
April 15, 2026
However, taxpayers automatically receive an extension to:
October 15, 2026
The FBAR automatic extension is different from the standard income tax extension process.
You do not need to file Form 4868 or submit a separate extension request just to receive the FBAR extension.
If you miss the April 15 FBAR deadline, you generally have until October 15 to file without needing to request an additional extension.
Is October 15 the Final FBAR Deadline?
For most calendar-year taxpayers, October 15 is the automatic extended deadline.
However, special relief can apply in certain situations.
For example, taxpayers affected by federally declared natural disasters may receive additional time to file their FBAR depending on the specific relief announced by the government.
Certain financial professionals with signature or other authority over foreign accounts but no financial interest can also be subject to special filing extensions under specific rules.
Therefore, taxpayers affected by special circumstances should verify the deadline applicable to their situation.
How Do You File an FBAR?
The FBAR is filed electronically through the FinCEN BSA E-Filing System.
Unlike your Form 1040, the FBAR is not attached to your federal income tax return.
Individuals can generally file their own FBAR electronically, while tax professionals filing on behalf of clients must follow FinCEN's applicable BSA E-Filing requirements.
When preparing the FBAR, taxpayers generally need information such as:
Financial institution name;
Account number;
Account type;
Account address;
Maximum account value during the year;
Ownership or authority information.
Keeping accurate records throughout the year can make the filing process significantly easier.
How Is the $10,000 Threshold Calculated?
The $10,000 threshold is based on the aggregate maximum value of reportable foreign financial accounts during the calendar year.
This means you should not simply look at the balance of your accounts on December 31.
Instead, you generally need to determine the maximum value of each reportable account during the year and consider the combined amount.
For foreign-currency accounts, the maximum account value must be converted into U.S. dollars using the applicable exchange-rate rules.
FinCEN generally directs filers to use the Treasury's Financial Management Service exchange rate for the last day of the calendar year when converting foreign currency values, when available.
This is especially important for taxpayers with accounts denominated in Brazilian reais, euros, Canadian dollars, or other currencies.
What Happens If You Miss the FBAR Deadline?
Missing the FBAR deadline can create compliance problems.
The consequences depend on the circumstances, including whether the failure was non-willful or willful.
Civil penalties can apply when a required FBAR is not properly filed.
For certain non-willful violations, the civil penalty can be significant. Willful violations can result in substantially higher penalties, and criminal penalties may also apply in appropriate cases.
Because penalties can be serious, taxpayers should not ignore an FBAR filing requirement simply because the deadline has passed.
The appropriate response depends on the taxpayer's facts and the reason the FBAR was not filed.
What If You Forgot to File an FBAR?
If you discover that you should have filed an FBAR but did not, the best next step depends on your individual circumstances.
Do not assume that simply filing the missing report without reviewing the situation is always the appropriate solution.
A tax professional may need to determine:
Whether you were actually required to file;
Which years are affected;
Whether the failure was intentional or unintentional;
Whether other international information returns were required;
Whether all foreign income was properly reported;
Whether any penalties or corrective procedures may apply.
In some situations, taxpayers may have access to specific IRS compliance procedures or penalty relief programs, depending on their circumstances.
The appropriate procedure should be evaluated carefully before filing delinquent or amended international forms.
FBAR vs. Form 8938: Are They the Same?
No.
FBAR and Form 8938 — Statement of Specified Foreign Financial Assets are separate reporting requirements.
A taxpayer may have to file:
FBAR only;
Form 8938 only;
Both;
Neither.
The filing thresholds, definitions, filing locations, and types of assets covered are different.
For example, the FBAR generally uses a $10,000 aggregate account threshold, while Form 8938 has different thresholds depending on factors such as filing status and whether the taxpayer lives inside or outside the United States.
Importantly, filing Form 8938 does not replace the FBAR.
Likewise, filing an FBAR does not eliminate a taxpayer's potential Form 8938 obligation.
What About Brazilians Living in the United States?
FBAR compliance is particularly relevant to Brazilian immigrants, entrepreneurs, and investors living in the United States.
For example, a Brazilian who becomes a U.S. citizen or U.S. tax resident may continue to maintain:
Brazilian bank accounts;
Brazilian investment accounts;
Brokerage accounts;
Foreign financial assets;
Accounts connected to family or business activities in Brazil.
If the applicable FBAR requirements are met, those accounts may need to be reported to FinCEN.
The fact that the account is located in Brazil does not exempt it from U.S. reporting requirements.
At the same time, FBAR reporting does not necessarily mean that the underlying account balance is taxable income.
Reporting an account and paying tax on income are two different concepts.
What About Brazilian Business Owners?
Business owners can face additional complexity.
A U.S. person who owns or controls foreign businesses may have additional international reporting requirements beyond the FBAR.
Depending on the structure and ownership, forms such as:
Form 5471;
Form 8865;
Form 8858;
Form 8938;
may also be relevant.
For example, a Brazilian entrepreneur living in Florida who owns a Brazilian company may have both foreign financial account reporting obligations and additional information-reporting requirements related to the foreign business.
These requirements should be analyzed separately.
What Records Should You Keep?
Taxpayers should maintain records supporting the information reported on their FBAR.
For each reportable account, records generally need to contain information such as:
Name on the account;
Account number;
Name and address of the foreign financial institution;
Type of account;
Maximum value of the account during the year.
The IRS states that taxpayers must keep these records and generally retain them for five years from the due date of the FBAR.
Keeping monthly or quarterly statements can make it easier to determine the highest balance during the year.
Common FBAR Mistakes to Avoid
1. Thinking the $10,000 threshold applies to each account
The threshold applies to the aggregate maximum value of qualifying foreign accounts.
2. Looking only at the December 31 balance
The calculation considers maximum account values during the year.
3. Assuming an account must generate income to be reported
FBAR reporting is not dependent on whether the account produced taxable income.
4. Filing FBAR with Form 1040
The FBAR is filed separately through the FinCEN BSA E-Filing System.
5. Assuming Form 8938 replaces FBAR
These are separate reporting requirements.
6. Forgetting foreign investment accounts
Brokerage and other qualifying financial accounts may also be subject to FBAR reporting.
7. Ignoring old accounts
A previously closed account may still need to be reported if it was open during the year and the FBAR requirements were met.
8. Waiting until the last minute
International reporting often requires information that can take time to obtain from foreign financial institutions.
What Should You Do Before the 2026 FBAR Deadline?
If you have foreign financial accounts, start by reviewing all of your accounts and determining whether your aggregate maximum value exceeded $10,000 at any point during 2025.
A practical checklist includes:
1. List all foreign financial accounts.
2. Identify the maximum value of each account during 2025.
3. Convert foreign-currency values into U.S. dollars using the applicable rules.
4. Calculate the aggregate maximum value.
5. Determine whether you had a financial interest or signature or other authority.
6. Identify whether any exceptions apply.
7. Gather account numbers and financial institution information.
8. Check whether Form 8938 or other international forms may also be required.
9. File the FBAR electronically through FinCEN.
10. Keep supporting records for your files.
If you already know you are subject to FBAR reporting, do not wait until the last day to begin gathering information.
How AES Accounting Can Help
For U.S. taxpayers with international financial interests, FBAR compliance is an important part of broader international tax planning.
AES Accounting can help individuals and business owners review their U.S. tax reporting requirements and identify situations that may require additional international forms.
Services can include:
Tax Return preparation;
International Tax Planning;
FBAR reporting support;
Form 8938 considerations;
Business Tax Returns;
LLC and business compliance;
Bookkeeping;
Cross-border tax considerations;
Review of foreign financial information.
For Brazilian entrepreneurs and investors living in the United States, coordinating U.S. reporting requirements with foreign financial activities can help reduce the risk of missed filings and unexpected compliance issues.
Conclusion
The 2026 FBAR filing deadline is an important date for U.S. persons with qualifying foreign financial accounts.
For accounts held during 2025, the regular FBAR deadline was April 15, 2026, with an automatic extension to October 15, 2026 if the regular deadline was missed. No separate extension request is generally required.
If you have bank accounts, investment accounts, or other qualifying financial accounts outside the United States, do not assume that a relatively small account balance means you have no reporting obligation.
The $10,000 threshold applies to the combined maximum value of qualifying foreign financial accounts, and additional international reporting requirements may apply depending on your situation.
Understanding the rules, gathering your records, and filing correctly can help you stay compliant with U.S. international reporting requirements.
AES Accounting. Specialists in Tax Planning, Tax Return preparation, Compliance, Bookkeeping, and international tax solutions for individuals and businesses in the United States.
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