FBAR preparation checklist

An FBAR is a calendar-year report of certain foreign financial accounts. Good preparation starts with a complete inventory, not with typing values into a form. Use this checklist to gather the categories of information that a filing may require, then confirm the official instructions and any exceptions that apply to you.

Keep sensitive data out of public contact forms. This checklist names the records you may need later. Do not send account numbers, financial-institution names, exact balances, statements, tax returns, identity documents, or taxpayer numbers through the FBAR HQ inquiry.

1. Identify the reporting year and deadline status

FBARs report calendar years. Write down each year you are evaluating and whether its applicable deadline remains open, it is already late, or it was previously filed but may be incomplete. The annual due date is April 15 after the calendar year reported, with an automatic extension generally available through October 15 without a separate request.

Do not assume an income-tax return extension changes the FBAR rule; the FBAR has its own automatic extension. If a past year is late, an amendment may be needed, or an agency has contacted you, treat that as a scope question rather than a routine timely preparation request.

2. Build a broad list of foreign financial accounts

Start wider than the accounts you expect to report. The IRS identifies examples such as foreign bank accounts, brokerage accounts, and mutual funds. Include accounts you owned alone, owned jointly, or may have had signature or other authority over. Whether an account produced taxable income does not decide whether it is a foreign financial account for FBAR purposes.

For the first inventory, record only enough information in your own secure files to avoid omissions:

• the type of account;
• the country where the financial institution is located;
• whether your relationship was ownership, joint ownership, or signature or other authority;
• the dates the account existed or your authority applied; and
• whether another person may report a jointly held account under an available rule.

Official definitions and exceptions matter. A professional inventory is not a substitute for resolving whether a particular arrangement falls within a reportable category.

3. Test the aggregate threshold

A U.S. person generally must file when the aggregate value of covered foreign financial accounts exceeded $10,000 at any time during the calendar year. “Aggregate” means looking across the covered accounts together. Several accounts that each stayed below $10,000 can still cross the threshold in total.

The test concerns the maximum combined value during the year, not only the December 31 balance. When values are held in another currency, follow the FBAR instructions for converting the maximum value to U.S. dollars. Keep the working records that support how you arrived at the reported amounts.

4. Gather the required account-level details privately

For each account that must be reported, the IRS says records generally include:

• the name on the account;
• the account number or other designation;
• the name and address of the foreign financial institution;
• the type of account; and
• the maximum value during the year.

That information is sensitive. Assemble it in your own secure record set and provide it only through the private method specified for an accepted engagement. The public FBAR HQ form deliberately asks only for the reporting year, timing, and approximate account-count band.

5. Confirm filer identity and ownership relationships

Prepare accurate filer details and note joint ownership, spouse filing arrangements, signature authority, or accounts connected to an entity. These relationships can change both the reporting analysis and how an FBAR is completed. Entity matters, more than 25 accounts, and uncertain authority or ownership questions begin with a consultation at FBAR HQ.

6. Review, authorize, and retain

Before submission, compare the prepared FBAR with your inventory and resolve unanswered items. When another person electronically files on your behalf, FinCEN Form 114a records your authorization. The form is not submitted with the FBAR; it is kept and made available if FinCEN or the IRS asks for it.

After filing, keep the submission confirmation and the records supporting each reported account. The IRS says those records generally must be retained for five years from the FBAR due date.

A concise final check

1. Every relevant year has been identified.
2. The account inventory includes ownership and signature-authority relationships.
3. The aggregate threshold was evaluated using maximum values, not only year-end balances.
4. Foreign-currency values follow the applicable official instructions.
5. The prepared filing has been reviewed before authorization.
6. Confirmation and supporting records have a five-year retention plan.

Need the service scope rather than the checklist? See fixed-price FBAR preparation or compare every tier on the pricing page.