What Is FinCEN Form 114 and How Do I File It?

FinCEN Form 114 is the electronic form used to report foreign financial accounts to the U.S. Treasury Department. You must file it through the BSA E-Filing System if your combined foreign accounts exceeded $10,000 at any point during the year. The form requires detailed account information, proper currency conversions, and specific formatting that can trigger rejection if entered incorrectly.

According to FinCEN’s filing requirements, the form is due April 15, 2026 (for the 2025 tax year), with an automatic extension to October 15, 2026. Common filing challenges include:

Format requirements (account numbers, phone numbers must have no spaces or dashes)
Exchange rate conversions (must use December 31 Treasury rates)
Maximum balance calculations (not year-end balance, but the highest point during the year)

Do You Need to File an FBAR This Year?

If your foreign accounts exceeded $10,000 at any time, you likely do.

Here’s what you need to know about FinCEN Form 114 and why many taxpayers choose professional filing.

Understanding FinCEN Form 114

FinCEN Form 114 is the official name for what many people still call the “FBAR” (Foreign Bank Account Report). The form was originally a paper form (TD F 90-22.1) but was converted to electronic-only filing in 2013.

Important

You cannot download a PDF version of this form. It exists only within the BSA E-Filing System at bsaefiling.fincen.treas.gov. There is no paper filing option available.

The form reports foreign financial accounts to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury. This is separate from your tax return, which goes to the IRS.

If you’re unsure whether you need to file, see our complete FBAR requirements guide. This article focuses on the form itself and the filing process.

What Information Does Form 114 Require?

FinCEN Form 114 requires detailed information about you and each of your foreign financial accounts.

Personal Information

Full legal name (exactly as it appears on your SSN or ITIN)
Taxpayer Identification Number (SSN or ITIN)
Date of birth
Complete mailing address
Contact information

For Each Foreign Account

Information Required	Common Challenge
Financial institution name and address	Must be a complete street address, not just a country
Account number	Must remove all spaces, dashes, and special characters
Account type	Must select the correct category (bank, securities, other)
Maximum account value	Must convert to USD using the December 31 rate, not the year-end balance

For Joint Accounts

If you share ownership of any account, you must also provide:

Full name of each joint owner
SSN or ITIN of joint owner (if applicable)
Date of birth of the joint owner
Address of the joint owner

Joint account holders each file separately and report the full balance of jointly owned accounts (not their proportional share).

Why Form 114 Filing Is Challenging

While FinCEN Form 114 may seem straightforward, several technical requirements can lead to errors that result in rejections or penalties.

Challenge 1: Strict Formatting Requirements

The BSA E-Filing System has rigid formatting rules:

Phone numbers: Must be entered as 1234567890, not (123) 456-7890 or 123-456-7890 SSN/ITIN: Must be entered as 123456789, not 123-45-6789 Account numbers: No spaces, dashes, or special characters allowed

Even experienced filers make formatting errors that cause form rejections.

Challenge 2: Maximum Balance vs. Year-End Balance

The most common mistake on Form 114 is reporting the wrong account balance.

You must report: The highest balance your account reached at any point during the calendar year Not: The balance on December 31

Example:

Sarah’s UK account had:

January 1: £8,000
July 15: £12,500 (highest point)
December 31: £9,200

Correct reporting: Convert £12,500 to USD (the maximum balance)

Common mistake: Converting £9,200 (the year-end balance)

This requires reviewing all your account statements from the entire year to identify the peak balance, not just your year-end statement.

Challenge 3: Currency Conversion Rules

All amounts must be reported in U.S. dollars using the Treasury’s official exchange rate for December 31 of the reporting year.

The complexity:

You must use the December 31 rate even if your maximum balance occurred in March
You must round UP to the next whole dollar ($10,000.01 becomes $10,001)
If no Treasury rate exists for your currency, you must find and document an alternative verifiable rate

Challenge 4: Multiple Account Reporting

If you have multiple foreign accounts, you must enter each one separately. For someone with 8 foreign accounts across 3 countries, this means:

Logging maximum balances for 8 different accounts
Converting 8 different maximum balances using appropriate exchange rates
Entering 8 sets of bank information with perfect formatting
Ensuring no accounts are missed

One missed account or one formatting error can trigger penalties.

Challenge 5: Joint Account Complexity

Joint account rules create confusion:

Scenario: You and your spouse have a joint checking account in France with €20,000 plus you each have separate savings accounts.

Correct filing: Each spouse files their own Form 114 reporting:

The joint account (full €20,000 balance, not €10,000)
Their individual account

Common mistake: Filing one joint form, or reporting only 50% of the joint account balance.

The BSA E-Filing System

Form 114 must be filed through the BSA E-Filing System, which requires:

Creating an account with email verification
Logging into the system each year
Completing the electronic form field by field
Addressing validation errors (the system flags formatting issues)
Electronically submitting the form
Saving your confirmation (no paper confirmation is mailed)

The system has no “save as draft” feature for individual filers. Once you start a form, you should complete it in one session, or you may lose your work.

Common Form 114 Filing Errors

The BSA E-Filing System validates certain fields and will reject submissions with errors:

Error Type	What Triggers It	Impact
Invalid TIN format	Entering SSN with dashes	Form rejected
Invalid phone format	Including parentheses or spaces	Form rejected
Missing required field	Leaving the bank address incomplete	Form rejected
Invalid account number format	Including spaces or dashes	Form rejected
Maximum value is zero	Not entering the account balance	Form rejected

Each rejection requires you to restart the form and re-enter all information correctly.

Filing Deadlines and Extensions

Deadline	What It Means
April 15, 2026	Original deadline for 2025 tax year
October 15, 2026	Automatic extended deadline (no form required)

The October 15 extension is automatic. You don’t need to file anything to receive it. However, if you haven’t filed by October 15, you face potential penalties.

Penalties for Filing Errors

Penalties for Form 114 violations depend on whether the IRS considers your error willful or non-willful.

Non-willful violations (honest mistakes):

Up to $16,536 per unfiled form (2025)
May be waived if you show reasonable cause

Willful violations (intentional failure):

Greater of $165,353 or 50% of the account balance per violation
Criminal prosecution is possible in extreme cases

Even formatting errors that cause missed deadlines can potentially trigger penalties if not corrected promptly.

Why Professional FBAR Filing Makes Sense

Given the complexity and strict requirements of Form 114, many taxpayers choose professional filing to ensure:

Accuracy: Professionals know the formatting requirements and avoid common errors
Complete reporting: All accounts are identified and reported correctly
Proper calculations: Maximum balances are calculated accurately with correct exchange rates
Electronic filing: Form is submitted correctly through the BSA E-Filing System
Documentation: Confirmation records are saved for your files
Penalty avoidance: Proper filing eliminates the risk of rejections or mistakes

At Greenback, we handle the entire FinCEN Form 114 filing process for you. Our FBAR filing services include:

Gathering your account information through our secure platform
Calculating maximum balances and currency conversions
Completing and submitting Form 114 electronically
Providing confirmation documentation for your records

Flat-fee pricing: $125 for up to 5 accounts (each additional 5 accounts: $60)

Our CPAs and Enrolled Agents have filed thousands of FBARs and know exactly how to handle complex situations like joint accounts, business accounts, and multi-currency reporting.

Special Filing Situations

Certain situations add additional complexity to Form 114 filing:

Filing for Children or Incapacitated Persons

Parents filing for minor children must complete the form using the child’s information but sign on behalf of the child. This requires careful attention to whose information goes in which fields.

Business Accounts and Signature Authority

If you have signature authority over foreign business accounts you don’t own (like a company account), you must still report them on Form 114. Determining whether you have signature authority and how to properly report these accounts requires expertise.

Consolidated Filing for Businesses

U.S. businesses with foreign subsidiaries may file consolidated reports covering multiple entities. This requires detailed documentation and proper entity designation.

Amended Forms

If you discover errors after filing, you must file an amended Form 114 with all accounts (not just the corrected information). The amended form completely replaces your original filing.

Catching Up on Unfiled Forms

If you’ve missed filing Form 114 in prior years, don’t panic. The IRS offers programs to help you catch up with minimal or no penalties if your failure was non-willful (honest mistake).

Delinquent FBAR Submission Procedures: File up to 6 years of missing FBARs with a statement of reasonable cause.

Streamlined Filing Compliance Procedures: File 3 years of tax returns and 6 years of FBARs with penalty relief.

Greenback’s Streamlined Filing Package ($1,750 flat fee) includes complete preparation of all required FBARs and tax returns to get you fully compliant.

Learn more about catching up on delinquent FBARs.

Form 114a: Authorization for Professional Filing

If you hire a professional to file Form 114, you must complete Form 114a (Record of Authorization to Electronically File FBARs).

This one-page form:

Authorizes your preparer to file electronically on your behalf
Specifies which tax year the authorization covers
Must be signed by you and kept in your records

Form 114a is not submitted to FinCEN. You and your preparer each keep a copy in case of audit.

When you work with Greenback, we handle Form 114a as part of our service and ensure it’s properly completed and stored.

Getting Help with FinCEN Form 114

Filing FinCEN Form 114 requires attention to technical details, proper formatting, and accurate calculations. While it’s possible to file yourself through the BSA E-Filing System, many taxpayers find professional filing worthwhile to ensure everything is done correctly.

When to consider professional help:

You have multiple foreign accounts
You have joint accounts with complex ownership
You’ve never filed Form 114 before
You’re catching up on prior years
You have business accounts or signature authority
You want to avoid formatting errors and rejections

Greenback specializes in FBAR filing for Americans abroad. Our team has filed thousands of FBARs and handles all technical requirements, including:

Determining which accounts must be reported
Calculating maximum balances correctly
Converting currencies using proper exchange rates
Completing Form 114 with correct formatting
Electronic submission through the BSA E-Filing System
Documentation for your records

Our FBAR filing services start at just $125 for up to 5 accounts. We’ll handle everything from gathering information to filing electronically so you can have peace of mind knowing your Form 114 was filed correctly.

If you’re behind on filing, our Streamlined Filing Package gets you caught up on up to 6 years of FBARs with penalty relief.

No matter how late, messy, or complex your situation may be, we can help.

Get started with Greenback today and let our expat tax experts handle your FinCEN Form 114 filing.

Have questions? Contact our Customer Champions for personalized guidance.

Get Your FBAR Filed Correctly and On Time

We’ll prepare and electronically submit FinCEN Form 114 for you.

This article is for informational purposes only and should not be considered tax advice. Tax laws change frequently, and individual circumstances vary. Please consult with a qualified tax professional for advice specific to your situation.

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