For US citizens, green card holders and US residents with foreign accounts, last checked October 30, 2026

FBAR Filing Requirements: Who Files, Which Accounts, Deadline and Penalties

If your foreign bank, investment or other financial accounts together went over US$10,000 at any point in the year, an FBAR (FinCEN Form 114) is due. Here is who must file, which accounts count, the deadline and the penalties, from the FinCEN and IRS rules, and when it is worth getting help.

Over US$10,000 totalFiled with FinCEN, not the IRS returnDue April 15, auto-extended to October 15Keep records 5 yearsMissed years?

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Close to US$10,000?Try the FBAR threshold calculator.

Quick answer

Who has to file an FBAR?

A US person, including a US citizen living in Canada, a green card holder or a US company, whose foreign financial accounts together were worth more than US$10,000 at any time in the calendar year (IRS). It counts accounts you own and accounts you can sign on, and the US$10,000 is the total of every account's highest balance, not a per-account limit. The FBAR is filed electronically with FinCEN, separately from your tax return, by April 15 with an automatic extension to October 15. Missing it can bring penalties, so missed years should be fixed through the right IRS route.

Prepared by Illuminous Accounting · Sources checked October 31, 2026

At a glance

Who files: A US person (citizen, green card holder, US resident or US entity) with foreign financial accounts
Threshold: The highest balances of all foreign accounts added together exceeded US$10,000 at any time in the year
Deadline: April 15, automatically extended to October 15
Where: Electronically with FinCEN, separately from the tax return
Penalty: Up to US$16,536 per report if non-willful; far more if willful
Source: IRS FBAR page, checked October 30, 2026

The US$10,000 test, with an example

Account	Highest balance in the year (US$)
Chequing account in Canada	6,200
Savings account in Canada	3,100
TFSA at a Canadian brokerage	2,400
Total of the highest balances	11,700: over US$10,000, so all three accounts are reported

Add up each account's highest balance during the year, converted to US dollars. If the total is more than US$10,000, every foreign account is reported, even the small ones. Whether the accounts earned income does not matter (IRS). Example figures are illustrative.

Proposed, not yet law

Budget 2026 proposal: Canada's T1135, not the FBAR

Budget 2026 proposes to raise Canada's Form T1135 filing threshold from CAD$100,000 to CAD$200,000 for taxation years that end after 2026. This is a Canadian change only. It does not change the FBAR: the US$10,000 combined test above still applies, and so do the Form 8938 rules. See FBAR vs T1135 for the details.

Checked against Finance Canada budget documents on November 9, 2026: Budget 2026, Tax measures: supplementary information. Budget proposals can change before they become law.

The rules that trip people up

Question	Answer	Source
Who counts as a US person?	US citizens (including those living in Canada), green card holders and other US residents, plus US companies, partnerships, LLCs, trusts and estates	IRS
Which accounts count?	Foreign bank, investment and other financial accounts, including Canadian RRSPs, TFSAs and RESPs. Accounts held in a US IRA or US retirement plan are not reported	IRS
Joint account with my spouse?	Each spouse reports the full value, unless every account is joint and the spouses use Form 114a so that one FBAR covers both	FinCEN instructions
Signature authority only?	Being able to control an account by instructing the bank counts, even with no ownership, for example an employer's or a parent's account. Some officers and employees of regulated or listed companies are excepted	31 CFR 1010.350(f)
25 or more accounts?	Only the number of accounts is reported, but full details must be kept and can be requested	31 CFR 1010.350(g)
Deadline	April 15, automatically extended to October 15 with no request needed. Filed separately from the tax return	IRS
Records to keep	Name on the account, account number, bank name and address, type of account and maximum value, for 5 years	31 CFR 1010.420
Penalties	Up to US$16,536 per report for a non-willful violation (amount for penalties assessed from January 17, 2025), applied per report, not per account. For a willful violation, up to the greater of US$165,353 or 50% of the account balance at the time of the violation	31 CFR 1010.821, 31 U.S.C. 5321(a)(5), Bittner (2023)

What to gather

A list of every foreign account you owned or could sign on during the year, including closed ones
Each bank's name and address, the account number and the account type
Whose name each account is in, and any joint owners
The highest balance of each account during the year (monthly or annual statements)
The Treasury year-end exchange rate used to convert to US dollars
Copies of FBARs filed for earlier years

Common mistakes

Treating US$10,000 as a per-account limit instead of the total
Leaving out RRSPs, TFSAs, small savings accounts or accounts closed during the year
Forgetting accounts you can sign on but do not own
Assuming the FBAR goes in with the tax return
Filing the FBAR for missed years without dealing with unreported income from the same accounts

Missed FBARs

The IRS says that if it has not contacted you and you are not under investigation, you should file late FBARs as soon as possible to keep potential penalties to a minimum (IRS). The IRS no longer lists the separate delinquent FBAR procedure that came without penalties; see what to do now those procedures are gone. When tax returns or income from the accounts were also missed, the Streamlined procedures are usually the route, with returns for 3 years, FBARs for 6 years and a non-willful certification (IRS). See also quiet disclosure vs Streamlined.

When to get help

The FBAR itself is one part of the picture. The cost of getting the route wrong for missed years is far higher than the form, and a licensed US CPA can prepare it together with the related tax filings.

You missed FBARs for earlier years, especially if income from the accounts was also left off your returns
You need to choose between filing late, Streamlined and voluntary disclosure, and sign a non-willful certification
You have many accounts, accounts in several currencies, or accounts held through a company or trust
Your accounts hold Canadian mutual funds or ETFs, which raise separate PFIC reporting; see PFICs in Canada
You received an IRS letter about foreign accounts

Common questions

Do I file the FBAR with my tax return?

No. The FBAR is filed separately and electronically with FinCEN. Form 8938, if you need it, is the form that goes with your tax return.

What is the FBAR deadline?

April 15 after the calendar year, with an automatic extension to October 15. You do not need to request the extension.

Is the US$10,000 per account?

No. It is the total of the highest balances of all your foreign accounts during the year. If that total exceeds US$10,000, every account is reported.

Do US citizens in Canada report RRSPs and TFSAs on the FBAR?

Yes. They are foreign financial accounts. Only accounts held in a US IRA or US retirement plan are on the IRS list of accounts not reported.

Can my spouse and I file one FBAR?

Only if all the accounts you must report are jointly owned with your spouse and you both sign Form 114a so that one spouse can report them on a timely FBAR.

What is the penalty for not filing an FBAR?

Up to US$16,536 per report for a non-willful violation, based on the inflation-adjusted amounts, and more for willful violations. The Supreme Court held in 2023 that the non-willful maximum applies per report, not per account.

What if I never filed an FBAR?

File as soon as possible. If you also missed income or tax returns, look at the Streamlined procedures before filing anything, because the route affects the penalties.

Sources

Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.

Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated October 31, 2026. This page is general information, not tax or legal advice for your situation.

Want it handled for you? For this year, see our yearly US tax package for Americans in Canada. Missed FBARs for past years? See our Streamlined filing service: 3 years of returns and 6 years of FBARs.

Missed FBARs or not sure what to file? Request a quote

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