Guide
Key FBAR and FATCA Deadlines for Expats
The FBAR (FinCEN Report 114) is due April 15 with an automatic extension to October 15 that nobody has to request. Form 8938 is attached to your income tax return, so it is due whenever the return is due, extensions included. U.S. citizens and residents living abroad on April 15 get an automatic two-month extension to June 15 to file, but interest runs on unpaid tax from April 15.
Americans abroad deal with two reporting systems on two calendars: FinCEN's calendar for the FBAR, and the IRS calendar for the return and everything attached to it, including Form 8938. The dates below are for calendar-year filers. Where a statutory date falls on a weekend or legal holiday it moves to the next business day; none of the dates listed for late 2026 and 2027 do. For how the two forms differ, see our FBAR vs. Form 8938 guide.
FBAR (FinCEN Report 114): April 15
Best for: Anyone whose foreign financial accounts together exceeded $10,000 at any time in the calendar year
The FBAR is an annual report due April 15 following the calendar year reported. It is filed electronically through FinCEN's BSA E-Filing System, not with your tax return. The $10,000 test is the aggregate of all foreign accounts at their highest point during the year, not a per-account or year-end figure.
- Calendar 2026 FBAR: due Thursday, April 15, 2027
- Filed with FinCEN, separately from Form 1040
- Covers accounts you only have signature authority over
FBAR automatic extension: October 15
Best for: Filers who miss April 15
FinCEN grants every filer who misses April 15 an automatic extension to October 15, and says specific requests for it are not required. It is not tied to your income tax extension and does not depend on living abroad. The 2025 FBAR, if not yet filed, is due on the extended date of Thursday, October 15, 2026.
- No form or request needed
- Calendar 2025 FBAR: extended due date October 15, 2026
- Calendar 2026 FBAR: extended due date Friday, October 15, 2027
- FinCEN may extend further for declared disaster areas
Form 1040 for filers abroad: June 15
Best for: U.S. citizens and resident aliens living outside the U.S. and Puerto Rico on the regular due date
If you live outside the United States and Puerto Rico on April 15, the IRS allows an automatic two-month extension to June 15. You claim it by attaching a statement to the return explaining which situation qualified you. It extends the time to file, but interest is charged on any tax not paid by April 15.
- 2026 return: due Tuesday, June 15, 2027 if abroad on April 15, 2027
- Attach the qualifying statement to the return
- Interest runs from April 15 on unpaid tax
Form 8938: due with the return
Best for: Taxpayers whose specified foreign financial assets exceed the Form 8938 threshold for their filing status and residence
Form 8938 has no separate due date. It is attached to your income tax return and is due on the date of that return, including any extension, so for most expats it is June 15 or October 15. The thresholds are much higher for people who qualify as living abroad, and they drop in the year you move home. Filing an FBAR does not satisfy Form 8938, or the other way round.
- Follows the return: April 15, June 15 or October 15
- Penalty of up to $10,000 for failure to disclose, plus more after IRS notice
- Check the current thresholds on the IRS comparison page
Form 4868 extension: October 15
Best for: Expats who cannot file by June 15
If you cannot meet June 15, you can request an additional extension to October 15 by filing Form 4868 before the automatic June 15 date, checking the box that says you are out of the country. For 2025 returns already on extension, the deadline is Thursday, October 15, 2026.
- File Form 4868 by June 15 if you are relying on the abroad extension
- 2025 extended returns: October 15, 2026
- 2026 extended returns: Friday, October 15, 2027
Discretionary extension: December 15
Best for: Taxpayers abroad who still cannot file by October 15
Publication 54 describes a further two-month extension to December 15 for taxpayers abroad. It is not automatic: you send the IRS a letter explaining why you need the extra time, and the letter must go by October 15. Treat it as a last resort rather than a plan.
- Request by letter, sent by October 15
- Discretionary, not automatic
- 2025 returns: December 15, 2026 (a Tuesday)
Form 2350: extension to qualify for the exclusion
Best for: People in their first year abroad who will meet the bona fide residence or physical presence test only after the return is due
Form 2350 extends the filing date so you can wait until you meet the bona fide residence test or the physical presence test before claiming the foreign earned income exclusion. It must be filed by the due date of the return, which for most calendar-year filers living abroad is June 15.
- Used to wait for a qualifying period to finish
- File by the return's due date
- Relevant only if you plan to claim the exclusion
Form 3520 and Form 3520-A
Best for: U.S. persons who received large gifts or bequests from foreign persons, or who deal with foreign trusts
Form 3520 reports certain transactions with foreign trusts and receipt of certain large foreign gifts or bequests. It is due on the 15th day of the fourth month after your tax year ends (April 15), moved to June 15 for citizens and residents living abroad. Form 3520-A, the foreign trust's own return, is due by the 15th day of the third month after the trust's year ends, which is March 15, 2027 for a calendar-year trust.
- Form 3520: April 15, or June 15 if you live abroad
- Form 3520-A: March 15, 2027 for calendar-year trusts
- Filed with the IRS in Ogden, not attached to Form 1040
Estimated tax payments
Best for: Expats with income that has no withholding and is not fully covered by an exclusion or credit
Living abroad does not change the estimated tax calendar. Payments for 2026 are due April 15, June 15 and September 15, 2026, and January 15, 2027. Publication 54 says to leave out amounts you expect to exclude, but to work out the tax on the rest at the rates that would apply without the exclusion.
- Final 2026 payment: Friday, January 15, 2027
- 2027 payments start April 15, 2027
- The June 15 filing extension does not move estimated payments
The calendar at a glance
| Date | What is due | Applies to |
|---|---|---|
| Thursday, October 15, 2026 | Extended 2025 FBAR; 2025 Form 1040 and Form 8938 on a Form 4868 extension | Anyone who used the automatic FBAR extension or filed Form 4868 |
| Tuesday, December 15, 2026 | 2025 return under the discretionary letter extension | Taxpayers abroad whose letter request was sent by October 15 |
| Friday, January 15, 2027 | Fourth 2026 estimated tax payment | Anyone making estimated payments |
| Monday, March 15, 2027 | Form 3520-A for calendar-year foreign trusts | Foreign trusts with a U.S. owner |
| Thursday, April 15, 2027 | 2026 FBAR; 2026 Form 1040, Form 8938 and tax payment for filers in the U.S.; payment deadline for everyone; first 2027 estimate | All U.S. persons |
| Tuesday, June 15, 2027 | 2026 Form 1040 and Form 8938 for filers abroad; Form 2350 and Form 4868 requests; Form 3520 for filers abroad | Citizens and residents living outside the U.S. and Puerto Rico on April 15 |
| Friday, October 15, 2027 | Extended 2026 FBAR; 2026 Form 1040 and Form 8938 on a Form 4868 extension | Extended filers |
Three rules that cause most missed deadlines
- Filing time is not paying time. Every extension on this page, including the automatic June 15 extension for people abroad, extends the time to file. Interest on unpaid tax runs from April 15.
- The FBAR and the return are separate. The FBAR goes to FinCEN through the BSA E-Filing System; filing your Form 1040 on time does not file your FBAR, and an FBAR extension does not extend your return.
- Form 8938 is only as late as the return. Because it is attached to the return, a return on extension carries Form 8938 with it, but a late return makes Form 8938 late too.
If you have missed one of these dates
A missed FBAR or Form 8938 is not the end of the road, but the route back depends on whether income was properly reported and whether the failure was non-willful. Read our guide to the Streamlined and other delinquent filing procedures before filing anything late, and if there is any question of willfulness, or the IRS has already been in touch, speak to a tax attorney first. Haigler CPA Group handles expatriate returns and FBAR and FATCA compliance as part of our personal tax work, remotely or in Charleston.
Sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR)
- FinCEN: FBAR due date clarification
- IRS: Comparison of Form 8938 and FBAR requirements
- IRS: Automatic 2-month extension of time to file for citizens and residents abroad
- IRS: Taxpayers living abroad
- IRS Publication 54, Tax Guide for U.S. Citizens and Resident Aliens Abroad
- IRS: Instructions for Form 3520
- IRS: Estimated tax due dates for individuals
The information on this site is general in nature and is not tax, legal, or accounting advice for your situation. Tax law changes and the right answer depends on facts we would need to review with you. Please speak with a qualified professional before acting on anything you read here.
Questions people ask about this
When is the FBAR due in 2027?
The FBAR for calendar year 2026 is due Thursday, April 15, 2027. Anyone who misses that date gets an automatic extension to Friday, October 15, 2027, without making a request.
Does the June 15 extension for Americans abroad also extend the FBAR?
No. The June 15 extension applies to the income tax return, and to Form 8938 because it is attached to the return. The FBAR follows FinCEN's own calendar: April 15, with an automatic extension to October 15 for everyone.
Is Form 8938 due on April 15?
Only if your return is due on April 15. Form 8938 is attached to the income tax return and is due on the date of that return, including extensions, so it moves to June 15 or October 15 with the return.
Do I have to pay by June 15 if I live abroad?
The tax itself is due April 15. The automatic two-month extension lets you file by June 15, but the IRS charges interest on any tax not paid by the regular April due date.
What if I have already missed an FBAR deadline?
There are established procedures for late FBARs and late information returns. Which one fits depends on whether your income was reported and whether the failure was non-willful, so it is worth reviewing the options before filing anything late.
Keep reading
- Best International Tax CPAs for U.S. Expats (2026)Haigler CPA Group's 2026 list of tax firms for Americans abroad, covering expat returns, FBAR and FATCA reporting and catch-up filings, and how to choose one.
- Best Tax Tips for U.S. Citizens Living AbroadTen U.S. tax tips for Americans abroad: filing when nothing is owed, the June 15 extension, FBAR, Form 8938, exclusion vs. credit and self-employment tax.
- Best Tax Records to Keep and for How LongHow long to keep tax records: the IRS 3, 6 and 7-year rules, 4 years for payroll, 5 for FBAR, property basis records and South Carolina's 36-month limit.
- FBAR vs. Form 8938The FBAR is a FinCEN filing covering foreign financial accounts once they exceed $10,000 in aggregate at any time in the year. Form 8938 is an IRS form attached to your return, covering specified foreign financial assets at much higher thresholds that depend on filing status and whether you live abroad. Filing one does not satisfy the other.
- Streamlined and other delinquent filing pathsThere is no single route back. The Streamlined procedures require certifying that the failure was non-willful, and split into a Foreign version with no penalty and a Domestic version carrying a 5% penalty. Separate procedures exist for late FBARs and late information returns where income was properly reported. Which one fits is a facts question, not a preference.
- Personal Tax1040 preparation, tax-saving strategy, and multi-state or expatriate filings.
- Tax Deadline CalendarThe federal dates that matter, in order, with what each one actually requires.
- All Charleston tax & accounting guidesEvery list, choosing a CPA and the tax reference lists.
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