Missed the 15 October FBAR Deadline? What to Do About Your 2025 FBAR Now

FBARs for calendar year 2025 were due on 15 April 2026, with an automatic extension — no request needed — to 15 October 2026. That second date has now passed. Every year a surprising number of Americans in the UK discover the FBAR exists only after it is late, usually when a bank asks about their US status or a new accountant asks an old question. Here is where you actually stand.

Short answer

File as soon as possible — the exposure runs until you do, and doing nothing is the one option with no upside. If all the income from your foreign accounts was reported on your US tax returns and you are not under IRS examination, late FBARs are filed electronically through FinCEN's BSA e-filing system with an explanation of why they are late. If income went unreported too — interest on a UK savings account, gains in a GIA, a pension you did not know was reportable — the Streamlined Foreign Offshore Procedures exist for exactly that situation and, for those who qualify, are the cleanest route back.

First, confirm you actually had to file

A US person files an FBAR when the combined value of their non-US financial accounts exceeded $10,000 at any point in the year. The threshold is aggregate, not per account, and it includes accounts you merely have signature authority over. Checking, savings, ISAs, most UK pensions with account values, and joint accounts all count; whether the accounts produced taxable income is irrelevant. At 2026 exchange rates, a UK current account plus a modest savings pot clears $10,000 easily — this filing catches far more ordinary people than it does anyone with something to hide.

Route one: income was all reported

If your returns were right and only the FBAR is missing, the fix is administrative. FinCEN's e-filing system accepts late FBARs and asks you to select a reason for late filing. File the delinquent years, keep the confirmation, and keep your explanation consistent and honest — "I did not know the form existed" is, for most people, the truth.

The IRS has historically not pursued penalties where the related income was reported, tax was paid, and the failure was an oversight — but that is a practice pattern, not something anyone can promise you in advance. What you control is speed and completeness.

Route two: income went unreported

If the accounts also produced income that never reached your Form 1040 — and for UK accounts even small interest or dividend amounts count — a bare late FBAR does not fix the returns behind it. This is what the Streamlined Foreign Offshore Procedures (SFOP) are for. Under the IRS's published terms, a filer who qualifies submits:

• the last 3 years of delinquent or amended US tax returns, with all required information returns;
• the last 6 years of FBARs, filed electronically and marked as Streamlined filings; and
• Form 14653, certifying that the failures resulted from non-willful conduct — negligence, inadvertence, or a good-faith misunderstanding of the law.

For those who meet the non-residency requirement (for citizens and Green Card holders, broadly: at least one of the last three years with no US abode and 330+ full days physically outside the US), the IRS's published terms impose no failure-to-file, failure-to-pay, accuracy-related, information-return or FBAR penalties — tax and interest are paid, penalties are not. Whether you qualify is a question of your facts, especially the non-willfulness certification, and that is where the work is. Willfulness is judged on conduct: ignoring professional advice, moving money to avoid reporting, or signing returns that tick "no foreign accounts" while holding them all look very different from simply never having heard of FinCEN.

What not to do

Do not "quietly" start filing from this year forward. A first-ever FBAR landing with no history invites the question of the prior years, with none of the protections a proper submission carries. Do not guess at penalty exposure from internet figures — the civil penalty maximums are normally inflation-adjusted each year (there was no 2026 adjustment), and after the Supreme Court's 2023 decision in Bittner, non-willful penalties apply per late report, not per account — so the arithmetic is case-specific. And do not wait for a letter: every compliance route narrows once the IRS has contacted you or FATCA data from your UK bank has triggered a review.

How TaxStone handles this

We prepare the full package — the returns, the FBARs, the Form 14653 narrative and the eligibility analysis behind it — for you to review, sign and submit. Scoping starts with the full picture: every account, every income source, every year since the problem started, because a quote based on half the facts helps no one. It is email-first, documented, and quoted before work begins.

Sources

• IRS — Report of Foreign Bank and Financial Accounts (FBAR) (deadline, automatic extension, who must file)
• IRS — Streamlined procedures for US taxpayers residing outside the United States (SFOP terms, Form 14653, penalty treatment)
• 31 CFR 1010.821 (current FBAR civil penalty maximums: $16,536 per report non-willful; greater of $165,353 or 50% of balance willful, for penalties assessed on or after 17 January 2025)
• FinCEN — Report Foreign Bank and Financial Accounts (BSA e-filing)

Covers FBARs for US calendar year 2025, filed in 2026. General information, not advice on your facts.