Has the FBAR filing deadline or form changed for 2025 and what form number is required?
Executive summary
The FBAR form for reporting foreign accounts remains FinCEN Form 114; guidance across government and tax-practice sources repeatedly identifies the FBAR as FinCEN Form 114 [1] [2] [3]. Multiple 2025-era sources state the FBAR annual due date is April 15 (for the prior calendar year) with an automatic six‑month extension to October 15 — no separate extension request required [1] [4] [5] [6].
1. Deadline: April 15 with an automatic October 15 extension — consistently reported
In 2025 reporting and practitioner guides, the FBAR deadline is described as April 15 following the calendar year reported, with an automatic extension to October 15 if you miss April 15; taxpayers need not request the extension (FinCEN/IRS and multiple tax firms) [1] [4] [5] [6]. Industry pieces and law‑firm advisories aimed at U.S. expats and advisors repeat the same calendar: the 2024 FBAR (for calendar year 2024) was due April 15, 2025, with an automatic extension to October 15, 2025 [7] [8] [9].
2. Who says what: government sources and private practitioners align
FinCEN and the IRS materials explicitly call the FBAR an annual report due April 15 with an automatic extension to October 15 (FinCEN/IRS pages summarized by the IRS and practitioner write‑ups) [1] [10] [6]. Tax firms, law firms and specialist sites echo that rule and caution that deadlines have changed historically and could change again, advising filers to re‑check each year [11] [12] [5].
3. Form number: it’s FinCEN Form 114 — not an IRS form
All authoritative and practitioner sources name the FBAR as FinCEN Form 114 (a Financial Crimes Enforcement Network filing under the Bank Secrecy Act); filing is electronic through the BSA E‑Filing System [1] [2] [10]. Several guides emphasize that the FBAR is sent to FinCEN (not filed on a Form 1040), and that preparers acting for clients must register as BSA e‑filers [10] [13].
4. Edge cases and recent extensions: one narrow extra extension for some signature‑authority filers
KPMG noted a specific, more limited extension announced for individuals with signature authority over foreign accounts in special circumstances — but for most U.S. individuals the due date remained April 15, 2025 with the automatic October 15, 2025 extension [14]. This underscores that while the general rule applied broadly, targeted administrative relief has been offered selectively in the past and can affect particular classes of filers [14].
5. Penalties and enforcement context that affect timing choices
Practitioner analyses cite increased penalty figures and recent Supreme Court decisions affecting how penalties are applied — all reasons advisers urge timely filing even with the automatic extension available [15] [16]. The Delinquent FBAR Submission Procedures and other IRS frameworks are presented as remediation options but come with caveats; penalties cited in 2025 guidance can be substantial [15].
6. What the sources don’t say (and the practical implication for filers)
Available sources do not mention any permanent change to the FBAR form number or a switch away from FinCEN Form 114 for 2025 filings; none of the cited official or practitioner pages indicate a new form designation or a new filing portal supplanting the BSA E‑Filing System [1] [2] [10]. Sources do note that deadlines have changed in the past and that authorities reserve the right to change them again, so filers should verify each filing year [11] [5] [12].
7. Practical takeaway and recommended next steps
Treat FBAR as FinCEN Form 114, file electronically via the BSA E‑Filing System, and plan for the April 15 due date with the safety net of the automatic October 15 extension when needed [1] [2]. If you hold signature authority only, or your facts are complex, review the specific guidance and any special relief notices [14]. For late‑filing remediation consider the IRS’s delinquent procedures but consult a tax professional because penalties and recent court rulings change enforcement risk [15] [5].
Limitations: this summary is drawn only from the provided government and practitioner sources; available sources do not mention any alternate 2025 form number or a formal replacement of FinCEN Form 114 beyond the cited materials [1] [2].