Last verified: August 31, 2026. Extended deadline: October 15, 2026. Not tax or legal advice.
If you are a US person and the aggregate value of your foreign financial accounts exceeded $10,000 at any point during 2025, you were required to file the Foreign Bank Account Report (FinCEN Form 114, commonly "FBAR"). The initial deadline was April 15, 2026, but an automatic extension to October 15, 2026 applies without any request. For NRIs with Indian accounts, that's the real deadline.
Here is what NRIs must actually do before October 15.
Who Must File
You must file FBAR if you are a US person (citizen, green card holder, or resident alien for tax purposes) AND you had:
- Financial interest in, or signature authority over, one or more foreign financial accounts, AND
- The aggregate value of those accounts exceeded $10,000 USD at any point during the calendar year (not just year-end).
"Aggregate" means combined maximum value across all accounts. If you have three Indian accounts each peaking at $4,000, that's $12,000 aggregate — FBAR required even though no single account crossed $10K.
What Counts as a "Foreign Financial Account"
- NRE, NRO, NRE/NRO joint accounts in Indian banks.
- FCNR deposits.
- Indian mutual fund folios (equity, debt, ELSS, hybrid).
- Indian brokerage / demat accounts holding shares.
- Public Provident Fund (PPF).
- Sukanya Samriddhi Yojana (SSY) for a child.
- National Pension System (NPS) — Tier 1 and Tier 2.
- Employee Provident Fund (EPF) if inherited from Indian employment.
- Insurance policies with cash value (ULIPs, endowment plans).
- Cryptocurrency wallets held on foreign exchanges (WazirX, CoinDCX historical).
What does NOT count: retail Indian pension schemes with no cash value, physical gold, real estate, non-monetary assets.
What Values to Report
Report the maximum value in the account during the calendar year 2025, converted to USD at the year-end (December 31, 2025) exchange rate published by the US Treasury.
Maximum value is not the year-end balance. If your balance peaked at INR 15 lakh in July and dropped to INR 3 lakh by December, report the July peak in USD terms.
How to File
1. Register at BSA E-Filing System
Go to bsaefiling.fincen.treas.gov. Create an account (individual, not entity). This is a US Treasury system, not the IRS website.
2. File Form 114 (FBAR)
The form is straightforward. For each account, provide:
- Account type
- Financial institution name + address
- Account number (or last 4 digits)
- Maximum account value during 2025
- Whether you had signature authority only vs financial interest
Joint accounts: file separately by each US person who has interest. Do not double-report.
3. Submit electronically before October 15, 2026 at 11:59 PM ET
Get the confirmation number. Save it for your records.
Penalties for Non-Filing
FBAR penalties are severe:
- Non-willful violation: Up to $10,000 per year per unreported account (adjusted for inflation, actually higher).
- Willful violation: Up to $100,000 or 50% of account balance per year, whichever is greater. Plus potential criminal prosecution.
- Reasonable cause defense is available for non-willful violations if you can document why you did not know about the requirement.
The IRS treats FBAR seriously. Do not assume "no one will notice" — the US has data-sharing agreements with India under FATCA.
FBAR vs FATCA (Form 8938)
Both are required if applicable; they are separate obligations.
- FBAR (FinCEN 114): filed with Treasury; $10,000 threshold; covers financial accounts.
- FATCA (Form 8938): filed with IRS as part of Form 1040; higher thresholds ($200,000+ single overseas, $50,000+ single in-US); covers broader asset categories including some real estate held via entities.
Many NRIs need to file both. The forms overlap in reported accounts but are separately mandatory.
Common Mistakes
- Not aggregating across accounts — treating each account separately below $10K.
- Reporting year-end balance instead of maximum during year.
- Missing signature-authority-only accounts (child's NRE account, parent's account you can operate).
- Missing PPF, EPF, NPS.
- Reporting in INR instead of USD converted at year-end Treasury rate.
- Late filing without paying penalty.
What If You Have Never Filed FBAR (Streamlined Procedures)
If you should have filed in prior years but did not, the IRS's Streamlined Filing Compliance Procedures allow non-willful filers to catch up with reduced penalties. This is a specialized process — consult a licensed tax attorney or CPA experienced with FBAR before filing back-year forms.
Companion Reading
- US NRI Money & Compliance Hub 2026
- NRI Tax Filing 2026: The US-India Calendar, RNOR Rules and the Mistakes That Cost You
- NRI Annual Compliance Calendar 2026
- October 15, 2026 US 1040 Extended Return Deadline: NRI Cross-Border Filing Guide
This is a procedural overview, not tax or legal advice. FBAR non-filing has severe consequences; if you are behind on filings or unsure whether you're required to file, consult a licensed tax attorney or CPA with cross-border experience before acting.