These FBAR and Form 8938 reminders for 2026 matter most if you hold bank, brokerage, retirement or investment accounts in India or Canada while you are a U.S. citizen, green card holder or resident alien. The extended FBAR date for 2025 accounts is Thursday, October 15, 2026, and the thresholds and penalties below apply to the 2025 reports.
Who needs these FBAR and Form 8938 reminders for 2026?
The FBAR applies to U.S. persons, including citizens, residents, corporations, partnerships, LLCs, trusts and estates. File it electronically through FinCEN's BSA E-Filing System, not with your tax return. Form 8938 applies only if you also have to file an income tax return.
| Filer | Year-end threshold | Any-time threshold |
|---|---|---|
| Single, living in the U.S. | Over $50,000 | Over $75,000 |
| Married filing jointly, living in the U.S. | Over $100,000 | Over $150,000 |
| Single, living abroad | Over $200,000 | Over $300,000 |
| Married filing jointly, living abroad | Over $400,000 | Over $600,000 |
You count as living abroad if your tax home is in a foreign country and you were present there at least 330 days in a 12-month period. Step-by-step instructions are in our FBAR guide and Form 8938 guide.
Which accounts should you review?
- India: savings, NRE, NRO and FCNR accounts, fixed deposits, demat and brokerage accounts, and mutual fund holdings. See NRE, NRO and FCNR accounts.
- Canada: chequing, savings, brokerage, RRSP, TFSA and RESP accounts held with a financial institution.
- Joint and signature accounts: accounts you only sign for, such as a parent's account, can count for the FBAR.
- Non-account assets: some foreign assets belong on Form 8938 only, such as shares held outside a financial institution.
Provident fund and pension balances need a case-by-case review, because the answer depends on how the account is held.
What does a late or missing filing cost?
| Report | Penalty source | Amount |
|---|---|---|
| Form 8938 | IRS | $10,000, plus up to $50,000 for continued failure after IRS notice |
| FBAR, non-willful | 31 CFR 1010.821 | Up to $16,536 per violation (assessed on or after January 17, 2025) |
| FBAR, willful | 31 CFR 1010.821 | Up to $165,353, or a share of the account balance under the statute |
| T1135 late filing | CRA | $25 a day up to 100 days, minimum $100, maximum $2,500 |
The IRS may waive penalties for reasonable cause, and omissions of more than $5,000 of income from a specified foreign asset can extend the assessment period to six years. Read foreign reporting penalties before you respond to any letter.
What should you do this month?
- Check whether your 2025 FBAR was filed. If not, file before October 15 through BSA E-Filing.
- List every account with its opening and closing dates, and the highest balance during 2025 in local currency.
- Convert to U.S. dollars using the year-end rate the FBAR instructions prescribe, and keep the source.
- Reconcile with your India Annual Information Statement and your T1135 position if you are also a Canadian resident.
- Start 2026 tracking now. Record the highest balance for each account through December 31; the 2026 FBAR is due April 15, 2027, with the same automatic extension.
Which mistakes recur most often?
- Reporting only the year-end balance instead of the maximum balance.
- Leaving out accounts closed during the year or accounts held jointly.
- Assuming Form 8938 satisfies the FBAR.
- Filing U.S. forms that do not match what the Indian return discloses; see Schedule FA and Black Money Act disclosure and the three-country reporting comparison.
How we can help
We prepare FBARs and Form 8938 from our base in the Aurora, Illinois area and coordinate with your Canadian CPA and Indian Chartered Accountant so the three disclosures agree. See foreign account and asset reporting. More background is in our cross-border guides.
Frequently asked questions
Do I need to request an FBAR extension?
No. The IRS gives an automatic extension to October 15 for anyone who misses April 15.
If I file Form 8938, do I still file the FBAR?
Usually yes. The two forms have different rules, and some accounts appear on only one of them.
Is the $10,000 FBAR threshold per account?
No. It is the combined highest value of all your reportable foreign accounts at any point in the year.
What if I missed the FBAR for earlier years?
Do not ignore it. File as soon as possible and keep notes explaining the cause, and talk to us about how to document reasonable cause before any IRS letter arrives.
Official sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR)
- IRS: Summary of FATCA reporting for U.S. taxpayers
- eCFR: 31 CFR 1010.821, penalty adjustment table
- CRA: Foreign income verification statement (T1135)
- CRA: Table of penalties for foreign reporting
- Income Tax Department e-Filing portal: Latest news
This page summarizes public guidance in plain language. If anything here differs from the official source, the official source controls.
General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.