Updated November 2026 · VG CPA PC advisors
Who qualifies
You can use the Delinquent FBAR Submission Procedures if you did not file required FBARs, you are not under a civil examination or criminal investigation, the IRS has not already contacted you about the missing FBARs, and you reported all income from the accounts and paid the tax on it.
If any income from the foreign accounts was left off your returns, these procedures are not the right tool. The Streamlined procedures, or the Delinquent International Information Return procedures for forms such as 3520 or 5471, may fit instead.
How to file
File the late FBARs electronically through the BSA E-Filing System, covering the years still open, generally six years. You select a reason for late filing and provide a brief statement explaining why the FBARs were not filed on time.
Keep copies of returns showing the foreign income was reported, in case the IRS asks. No amended returns or penalty payments are filed under this procedure.
What to expect
The IRS states that it will not impose penalties for FBARs filed under these procedures if the conditions are met, though FBARs can still be selected for review. In our experience, a clear, accurate filing closes the issue.
Do not wait for an IRS letter. Once you are contacted, these penalty-free procedures generally are no longer available.