Why your FBAR deadline is probably not what you think
The deadline for the FBAR is not April 15.
Tax day for 2025 returns, April 15, 2026, has passed. Most NRIs filed a 1040, perhaps attached a Schedule B, and thought they were done. A separate filing is due if the aggregate maximum value of your foreign financial accounts crossed $10,000 at any point in 2025. That value is the sum of each account's highest balance during the year, not your combined balance today.
Most NRIs do cross that line. NRE and NRO balances count toward it, as do a PPF, an LIC policy and parents' accounts where you are a joint holder.
The filing is called the FBAR, or FinCEN Form 114, and you probably did not file it on April 15.
The automatic extension to October 15
FinCEN, the financial crimes enforcement arm of Treasury, automatically extends the FBAR deadline to October 15 every year. You do not file Form 4868 or send a written request.
The policy has been in place since 2016. It does not appear on a Form 1040 or in any IRS letter, and most NRIs do not know about it.
Your FBAR is not late on April 16. You have six more months.
What counts as a foreign financial account
Most NRIs underestimate what counts as a "foreign financial account" for the FBAR. The list is broader than a bank balance, and omissions from it are where six-figure penalty cases start. Go through 2025 and ask whether any of these applied at any point during the year:
- That old savings account at SBI or ICICI you haven't touched since moving to the US.
- Your PPF (Public Provident Fund).
- Your NPS (National Pension System) account.
- Any account where you have signatory authority, even if it's not "yours". Your parent's account where you're a joint holder counts.
- LIC endowment policies and ULIPs with cash surrender value.
- Mutual fund accounts, demat accounts, and Indian brokerage accounts.
Each of those is a separate account on Form 114, and each one's highest 2025 balance goes into your aggregate calculation. Forgetting one is the most common reason NRIs file an incomplete FBAR. An incomplete FBAR is technically a non-filed FBAR for the omitted accounts.
PPF, NPS, LIC policies with cash value and any account where you are a signatory all count toward your FBAR threshold. Most NRIs miss at least one.
Where the form goes
The FBAR does not go to the IRS, and it does not go in with your 1040. It goes to FinCEN, online, through its BSA E-Filing System. There is no paper form and no fee. Your tax software ticking the foreign-account box on Schedule B is not an FBAR.
For each account, Form 114 wants five things:
- The name and address of the bank or institution.
- The account number.
- The type of account: bank, securities, or other.
- The highest balance during 2025, in US dollars.
- For a joint account, the other holder's name.
The highest balance takes the most time. Indian bank statements do not show it, and you have to go through 12 months of them, account by account.
For a fixed deposit, it is usually the year-end balance with interest added. For a PPF, it is the balance after the March 31 interest credit or your last deposit, whichever is higher.
When you submit, FinCEN sends a confirmation with a tracking ID. Keep it, with the statements behind your numbers, for five years.
If October 15 has passed too
There is no second extension. After October 15, the FBAR is late. What happens next depends on which of three situations is yours.
In the first, you reported the interest and missed only the form. File the late FBAR through the same system. It asks for a reason, and you should give one. When the income was on your return and the tax was paid, the IRS generally does not penalize a late FBAR it has not already asked you about.
In the second, you never reported the interest either. This is the common case. NRE and FD interest is tax-free in India and never made it onto a 1040, but it is taxable in the US.
The route here is the IRS's Streamlined procedures. They require three years of amended returns and six years of FBARs, with a penalty of 5% of the highest year-end balance for US residents. More on that on our Streamlined disclosure page.
In the third, you do nothing. This is the expensive option. A non-willful miss can cost up to $10,000 per year's report, adjusted upward for inflation. A willful one can cost the greater of roughly $100,000 or half the account balance.
Indian banks already report US persons' accounts to the IRS under FATCA. The accounts are not a secret.
The dates
April 15 is the date printed on the form.
October 15 is the real FBAR deadline. Put it in your calendar today if it is not already there.
Playbook Move: List every account before you total anything. That means the dormant SBI account, the PPF, the LIC policy and your mother's joint account. Then find each one's highest balance for the year and add them up. Our free FBAR calculator does the adding and tells you whether you have to file. If you'd rather hand it off, we file it for you for $49 single or $79 joint. If you're not sure how the $10,000 line is drawn, read $10,000.01: the threshold that triggers an FBAR.
From Edition 1 of the NRI Playbook newsletter. For informational purposes only; not financial, tax, or legal advice. For decisions about your specific situation, consult a qualified cross-border tax professional.