What is Delinquent FBAR Submission?

Definition

The Delinquent FBAR Submission Procedures allowed taxpayers who had missed required FBARs to file them late without penalty, provided they were not under civil examination or criminal investigation, had not already been contacted by the IRS about the delinquent FBARs, and had properly reported and paid tax on the income from those accounts. On July 1, 2026 the IRS removed the page describing this procedure from IRS.gov, with no press release and no explanation, and the links pointing to it were taken down at the same time. The IRS has not said whether this reflects a policy change or a website cleanup. Late FBARs can still be filed through FinCEN's BSA E-Filing System with a reason for filing late, and FBAR penalties were never automatic — the statute provides that the IRS may impose one, and in practice a penalty is considered during an examination. What no longer exists is a published IRS assurance of relief, so a documented, fact-specific reasonable-cause statement now carries the weight the procedure used to carry. Where there is also unreported income, the Streamlined Filing Compliance Procedures remain the route; where the conduct may have been willful, the Voluntary Disclosure Practice does.

Related Forms

Common Mistakes to Avoid

• 1Using this procedure when there is also unreported income (use Streamlined instead)
• 2Not including a reasonable cause statement with each delinquent FBAR
• 3Filing under this procedure while under IRS examination
• 4Not filing for all delinquent years

Related Terms