The IRS Took Down Its Delinquent FBAR Page, But Your Options Have Not Changed

The IRS Took Down Its Delinquent FBAR Page, But Your Options Have Not Changed

The IRS has removed its Delinquent FBAR Submission Procedures page, the guidance that told Americans how to file late foreign bank account reports, and it has published no announcement, revenue procedure, or replacement. The IRS never gave a takedown date, and outside reporting has not settled on one, placing it in early July 2026. The last working copy preserved in the Internet Archive is dated June 23, 2026. Removing a page does not repeal a law or change the FBAR rules, which the IRS still confirms on its main FBAR page. Here is what changed, what is still in effect, and what to do if you are behind.

Greenback is tracking this story.

At the time of publication, the page is still down, with no announcement, revenue procedure, or replacement from the IRS. We check it daily and will update this article the moment that changes.

What Changed on IRS.gov

Two things happened together, and both are verifiable.

First, the dedicated Delinquent FBAR Submission Procedures page was removed. Its address now returns a hard “Page Not Found” error rather than redirecting to a renamed page. The last working copy preserved in the Internet Archive is dated June 23, 2026.

Second, the IRS’s options page for taxpayers with undisclosed foreign financial assets no longer lists the delinquent FBAR procedure. That page still names the Criminal Investigation Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, and the Delinquent International Information Return Submission Procedures. The delinquent FBAR procedure is no longer there. One sibling page, the Delinquent International Information Return page, still references it, so that internal link now points to the dead page.

The IRS has published no statement explaining the removal.

What the Removed Page Used to Say

The Delinquent FBAR Submission Procedures were written for one specific situation: a taxpayer who had failed to file one or more FBARs but had already reported all income from the foreign accounts on their U.S. tax returns and paid the tax, was not under IRS examination or criminal investigation, and had not already been contacted by the IRS about the missing FBARs.

For that taxpayer, the page carried an unusually direct assurance. It stated the IRS would not impose a penalty for failing to file the delinquent FBARs if the income had been properly reported and taxed and the taxpayer had not already been contacted about an examination or delinquent returns for those years. That was a categorical statement, not an invitation to argue for relief. That specific published assurance is what is now gone. Our guide on catching up on delinquent FBARs explains how that route worked.

What Is Still in Effect

Removing a web page does not repeal a statute or amend a regulation. The following all remain in force and remain published on the IRS’s live FBAR pages or in the governing law:

  • FBAR reporting threshold. A U.S. person must file an FBAR (FinCEN Form 114) when their foreign financial accounts exceed $10,000 combined at any point during the calendar year. The FBAR reports the accounts; it does not tax them.
  • FBAR filing deadline. The FBAR is due April 15, with an automatic extension to October 15 that requires no request. A “delinquent” FBAR is simply one filed after that window for a prior year.
  • The filing method. Late FBARs are still filed electronically through FinCEN’s BSA E-Filing System, with the reason for the late filing selected on the cover page and a brief explanation attached.
  • The reasonable-cause defense. The FinCEN Form 114 instructions state that if there is reasonable cause for a failure to file and the balance is properly reported, no penalty will be imposed. This defense is grounded in the penalty statute itself, 31 U.S.C. section 5321, not in the administrative page that was removed. It did not depend on that page, and it did not go away with it.
  • The broader relief programs. The Streamlined Filing Compliance Procedures remain available and continue to carry no penalty for qualifying taxpayers who live abroad. The IRS Criminal Investigation Voluntary Disclosure Practice remains available for willful cases, and the wider set of IRS relief programs is intact.

The One Real Difference for Late Filers

The removed page offered a categorical promise: meet the stated conditions and no penalty would be imposed. The reasonable-cause defense that remains is a facts-and-circumstances standard, where the IRS weighs your specific explanation and decides. In practice, a taxpayer who reported and paid tax on their foreign-account income and comes forward before any IRS contact has a strong reasonable-cause position, and these cases have routinely resulted in no penalty.

What changed is the level of published certainty, not the availability of relief. The path is still open; the written guarantee that used to sit at its front is not. The IRS’s general FBAR guidance reflects this shift in tone: it still tells taxpayers who have not been contacted and are not under examination to file late FBARs as soon as possible, but it now frames late filing as a violation that may subject the filer to penalties, rather than repeating the old page’s assurance that it would not.

What to Do If You Have Unfiled FBARs

If you are behind, switching to a web page does not alter your best move: come forward before the IRS contacts you. Here is where to start.

  • File your late FBARs as soon as you can. Coming forward before IRS contact remains the single biggest factor in keeping penalties low.
  • Include a clear, reasonable-cause statement explaining why the reports were late, the same step the removed page always called for.
  • Check whether Streamlined fits you. If you also have unreported income or unfiled returns, it handles everything at once and certifies your conduct on Form 14653.
  • Report the right figure, using the highest balance during the year, not the year-end balance.
  • Skip “quiet disclosure.” Filing outside a recognized process and hoping no one notices raises your risk, not lowers it.
  • Get a professional read on your facts, since the right route depends on whether your income was reported and tax paid.

If you have already started a delinquent submission, keep your records and confirmation. The BSA E-Filing System is unchanged, and you can still amend an FBAR to correct one. This matters most for late filers whose returns are otherwise accurate and for anyone who recently learned about the reporting rule.

Greenback has tracked FBAR rules and IRS relief programs for years, from our guides on FBAR filing and FBAR penalties to the full range of IRS amnesty options. Our expat tax accountants can help you choose the right path with confidence.

Frequently Asked Questions

Is the Delinquent FBAR Submission Procedures program gone for good?

We do not know. The web page describing it is down at the time of publication, and it has been dropped from the IRS’s options page for undisclosed foreign assets, but no revenue procedure has formally ended the program. We are checking daily and will update this article if that changes.

Can I still file late FBARs the way I did before?

Yes. The filing method through the BSA E-Filing System, including a reasonable-cause statement, is unchanged, and the Streamlined path remains open.

I already started a delinquent FBAR filing. Is it still valid?

Yes. Keep your records and confirmation. The filing steps are unchanged, and a reasonable-cause explanation still supports your submission.

Does this removal make FBAR penalties automatic?

No. Nothing about the page removal makes penalties automatic. See our guide on FBAR penalties for how they are assessed.

Behind on FBARs? You still have options.

Greenback helps Americans abroad file late foreign account reports the right way.

The information in this article is for general informational purposes only and does not constitute tax, legal, or financial advice. Tax rules are complex and change frequently. Consult a qualified tax professional regarding your specific situation before taking any action.