Is the FBAR deadline really April 15 like taxes, or is there an extension?
Both. FinCEN Form 114 is due April 15 — and FinCEN grants an automatic extension to October 15 with no request needed. The extension is written into the form's instructions ("specific requests for this extension are not required"), so unlike the tax return, there's nothing to file to get it.
The deadline table
| Filing | Due | Extension |
|---|---|---|
| FBAR (FinCEN Form 114) | April 15 | Automatic to October 15 |
| Form 1040 (abroad) | April 15 | Automatic to June 15; to Oct 15 via Form 4868 |
The confusion is understandable — but the two extensions are independent systems. Extending your 1040 does not extend your FBAR (it doesn't need to — the FBAR extends itself). And the FBAR is filed in FinCEN's BSA E-Filing system, not with your tax return, so your CPA's e-file confirmation for the 1040 says nothing about the FBAR.
Why people still file late
- They never knew it existed. The FBAR isn't part of the 1040 package; nobody's software prompts first-timers reliably.
- They waited for "all the documents." The FBAR needs maximum balances, not statements — you can usually reconstruct them from online banking.
- They assumed the 1040 extension covered it. It doesn't (though the outcome — October 15 — often coincides).
How to actually file it
The FBAR is filed electronically through FinCEN's BSA E-Filing system (bsaefiling.fincen.gov) — not through IRS e-file, not on paper. You'll need each account's maximum value during the year, the institution name and address, and the account numbers. First-timers should start in September, not October 14: the system requires creating an account, and reconstructing a year of maximum balances always takes longer than expected.
Keep a copy of every filed FBAR with your tax records. If you ever need the streamlined procedures for prior missed years, having clean current-year filings strengthens your position considerably.
Frequently asked questions
What if I already missed October 15?
File as soon as possible. Penalties scale with willfulness — non-willful violations have far lower exposure, and the IRS's streamlined procedures exist for exactly this situation. Don't compound it by skipping another year.
Does the automatic extension apply every year?
Yes — it's structural, not something FinCEN announces annually.
I'm not a US citizen, just a green-card holder living abroad. Same deadline?
Same. "US person" for FBAR includes resident aliens (green card or substantial presence test), wherever they live.
Sources
- https://www.facebook.com/groups/727773131690156/permalink/1814635163003942/
- FinCEN Form 114 General Instructions (automatic extension to October 15) — https://bsaefiling.fincen.gov/docs/FinCENFBARHelp.pdf
- IRS FBAR guidance — https://www.irs.gov/newsroom/report-of-foreign-bank-and-financial-accounts-fbar-1