Missed FBARs? Late Filing Guide (2025 Update)

What to do if you missed FBAR filings for several years — penalties, how many years to file, and practical solutions for expats.

1. What Happens If You Don’t File FBARs?

The FBAR is enforced by FinCEN. Penalties can be severe:

  • Non-willful violation: up to $10,000 per account per year.
  • Willful violation: up to 50% of the account balance or $100,000, whichever is greater.

Most expats who simply didn’t know about FBAR are considered non-willful.

2. How Many Years Back Do You Need to File?

The statute of limitations for FBAR is 6 years. In practice:

  • If you missed 10+ years, you usually file the last 6 years.
  • Under Streamlined Foreign Offshore Procedures (SFOP), you also file 3 years of amended tax returns.

3. Options for Late FBAR Filing

Delinquent FBAR Submission

If no income was unreported, you can file late through the BSA E-Filing System with a short explanation. Penalties are often waived.

Streamlined Foreign Offshore Procedures (SFOP)

For expats whose failure was non-willful. Requires:

  • 6 years of FBARs
  • 3 years of amended returns
  • A non-willful certification statement

Reasonable Cause Statement

If outside Streamlined, you may file late FBARs with an explanation. IRS considers reasonable cause before applying penalties.

4. Step-by-Step: How to File Late FBARs

  1. Make an inventory of all non-U.S. accounts (banks, pensions, brokerage, joint accounts).
  2. Find each account’s maximum balance for each year.
  3. Convert balances to USD using Treasury year-end exchange rates.
  4. Prepare the FBAR forms. The official PDF is safest for archiving.
  5. File the last 6 years, and keep records for 5 years as required.

5. Tools That Can Help

FBAR prep is tedious due to currency conversion and balance tracking. To simplify:

  • Official PDF Form — most reliable for long-term record-keeping.
  • SafeFBAR — free helper spreadsheets (offline, anonymous) with up to 10 years of FX rates and a web calculator.

6. FAQs

Do I need to file FBAR if I missed 10 years?

Practically, you file the last 6 years, which is the statute of limitations.

What if I lost my old FBAR copy?

FinCEN does not provide retrieval of past filings. You are required to keep your own records for 5 years (31 CFR 1010.420). If you have the BSA Confirmation Number, FinCEN/IRS can locate your filing internally. If both PDF and confirmation number are lost, keep bank statements and workpapers to demonstrate good faith. In some cases, you may re-file an Amended FBAR using the confirmation number with a note that you are re-submitting for recordkeeping.

Is online FBAR filing safe?

Yes. Both the online form and the PDF upload go through FinCEN’s secure BSA E-Filing System. What matters is that you save the final PDF and confirmation number after submission. If you cannot produce records later, there may be compliance risk.

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