Delinquent FBAR cover letter: a free template and three samples
A delinquent FBAR cover letter is the short statement that explains why your FBARs are late. FBARs are filed online now, so it doesn't go in the mail: you type it into the late-filing reason on each FBAR, under "Other". Keep it to a few factual sentences: why you didn't file, how you found out, and that the income from the accounts was on your U.S. returns.
The short version
- The Delinquent FBAR Submission Procedures ask for a statement explaining why your FBARs are late.
- FBARs are filed online, so the statement goes inside each late FBAR: you pick a late-filing reason, or choose "Other" and type your explanation.
- Keep it short, specific and true: why you didn't file, how you found out, and that the income from the accounts was on your U.S. returns.
- It only works if that income was reported. If it wasn't, the Streamlined procedures are usually the right route instead.
1Where does a delinquent FBAR cover letter go?
Back when FBARs were paper forms, a late one went in the mail with a statement attached, which is where the idea of a cover letter comes from. Today FBARs are filed electronically through FinCEN's BSA E-Filing System, so there's nowhere to send a letter. The explanation goes inside the FBAR itself.
- On the cover page of each late FBAR, the form asks why it's being filed late.
- You choose a reason from a short list. If none of them explains it, you choose "Other" and write your explanation in the box provided, as FinCEN's filing-late instructions describe.
- Each year's FBAR is a separate filing, so each one gets its own reason.
The listed reasons are a single line each. Choosing "Other" lets you explain in a few sentences, which is closer to the statement the procedures ask for. Space is limited, so aim for a short paragraph. All three samples below fit.
2What should the letter include?
- Why you didn't file. The real reason, in plain words. For most people abroad, it's that they didn't know the FBAR existed.
- A little context. Where you live, since when, and what the accounts are, such as your everyday current and savings accounts.
- How and when you found out. A news story, a friend, your bank asking about your citizenship, a new accountant.
- That the income was reported. Interest and other income from the accounts was on your U.S. returns, and the tax was paid. This is what the no-penalty treatment rests on.
- What you're doing now. Filing the missing years, and filing on time from here on.
Specific and short beats long and vague.
3What should you not say?
- Anything that isn't true, or that you couldn't back up if asked.
- Legal labels for your own conduct, like "willful" or "negligent". Those are conclusions the IRS draws. Describe what happened instead.
- A bare "I didn't know" with nothing around it. A sentence or two of facts is what makes it believable.
- Guesses and arguments about what the IRS should do, or why the rule is unfair. Just the facts.
- Account numbers and balances. Those are already in the FBAR itself.
4Three sample delinquent FBAR cover letters
Each one is short enough for the "Other" box. Swap in your details, and keep only the sentences that are true for you.
I am a U.S. citizen and have lived in [country] since [year]. I did not know that U.S. citizens living abroad had to file FBARs for their foreign accounts. The accounts are [my everyday current and savings accounts in my country of residence]. All income from these accounts was reported on my U.S. tax returns, and the tax was paid. I learned about the FBAR requirement in [month and year], when [how you found out]. I am now filing the missing FBARs for [years] and will file on time going forward.
I am a U.S. citizen living in [country]. I filed FBARs for [years filed], but I missed [years missed] because [the reason, for example: I moved that year and lost track of the deadline]. The accounts did not change, and all income from them was reported on my U.S. tax returns, with the tax paid. When I noticed the missing years in [month and year], I gathered my account statements, and I am now filing the FBARs for [years]. I have set up a reminder to file on time every year.
I am a U.S. citizen living in [country or state]. In [year], I inherited [an account, or a share of an account] at [bank] in [country] from my [relationship], who died that year. I did not realize that an inherited account abroad had to be reported on an FBAR. All income from the account was reported on my U.S. tax returns, and the tax was paid. I learned about the requirement in [month and year], when [how you found out]. I am now filing the FBARs for [years] and will file on time going forward.
5Which sample fits you?
| Your situation | Start from | Watch for |
|---|---|---|
| You never knew the FBAR existed | Sample 1 | Say how you found out, and when |
| You filed some years and missed others | Sample 2 | Give the actual reason for the gap |
| The account came to you from a relative | Sample 3 | Form 3520, for a large inheritance from abroad |
| A preparer handled your returns and never asked | Sample 1, plus a line about the preparer | Name what you were asked, and what you weren't |
| The income from the accounts wasn't on your returns | None of them | Streamlined fits instead |
Lines you might add, if they're true for you:
- "My U.S. returns were prepared by a tax preparer who never asked about foreign accounts."
- "I thought the $10,000 limit applied to each account separately, not to all my accounts added together."
- "I didn't realize that my [pension, or joint account with my spouse] counted as a foreign account."
The FBAR threshold is the combined total of all your foreign accounts, so the second line is a common, honest mix-up. The FBAR threshold checker adds them up for you.
6A filled-in example
Robin is a U.S. citizen who has lived in Lisbon since 2017, filed U.S. returns every year with the interest from two Portuguese accounts on them, and never filed an FBAR. Robin's bank asked about U.S. citizenship in March 2026. Here's sample 1, filled in:
"I am a U.S. citizen and have lived in Portugal since 2017. I did not know that U.S. citizens living abroad had to file FBARs for their foreign accounts. The accounts are my everyday current and savings accounts at my bank in Lisbon. All income from these accounts was reported on my U.S. tax returns, and the tax was paid. I learned about the FBAR requirement in March 2026, when my bank asked me to confirm my U.S. citizenship. I am now filing the missing FBARs for 2020 to 2025 and will file on time going forward."
7Download the Word template
The template has all three samples with the blanks marked, the checklist of what to include and what to leave out, and space for the fuller signed version to keep with your records. It's free.
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8Check the route fits first
A good explanation only helps if the Delinquent FBAR Submission Procedures fit your situation:
- All the income from the accounts was on your U.S. returns, and the tax was paid.
- You're not under IRS examination or criminal investigation.
- The IRS hasn't already contacted you about the missing FBARs.
If the interest, dividends or growth on those accounts never made it onto your U.S. return, a statement won't cover that. The Streamlined Foreign Offshore Procedures usually will, with no penalty if you qualify. If you haven't filed U.S. returns at all, start with our guide for people who never filed. You can also see every IRS catch-up option, compared.
Common questions
Do I mail a cover letter to the IRS?
No. FBARs are filed online with FinCEN, and your explanation goes in the late-filing reason on each FBAR. There's no separate letter to send.
Is a cover letter the same as a reasonable cause statement?
Close. Both explain why you didn't file on time. Under the Delinquent FBAR procedures it's a short statement in the FBAR itself; a fuller reasonable cause statement is what you'd give the IRS if it ever asked.
Do I need a different explanation for each year?
Each late FBAR asks for its own reason, but the story is usually the same for every year, so the same explanation can go on each one.
Can I just pick a reason from the list?
You can, and one of them may be true for you. But a listed reason is a single line, and a short explanation in your own words gives the fuller picture the procedures ask for.
Is it the same under the Streamlined procedures?
No. Under Streamlined, each FBAR's late-filing reason is "Other", with "Streamlined Filing Compliance Procedures" typed in the box, and your explanation goes on Form 14653 or 14654 instead. How the Streamlined Foreign Offshore Procedures work.
Do I need a CPA or a lawyer to write it?
No. It's a few sentences in your own words. What a professional adds is checking that this route fits before you file, which matters more than the wording: if the income from the accounts wasn't reported, the best-written statement won't help.
Can my spouse and I use the same explanation?
Only if it's true for both of you. Each FBAR's explanation should describe that filer's own situation.
How many years of late FBARs should I file?
The procedures don't set a number. In practice, filing the last six years covers the period the IRS can generally penalize.
Will the IRS reply to my explanation?
Usually not. FBARs filed this way aren't automatically audited, but they can be selected like any filing.
Can you file the FBARs for me?
Yes. Our late FBARs package is $499 flat for the last six years: we work out each balance, write the explanation with you, and e-file the FBARs once you sign FinCEN Form 114a.
Missing a few FBARs? We'll handle them, explanation included.
Tell us what you have. Our tax team will check this route fits before anything is filed.
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