Comparison
Streamlined Filing vs Delinquent FBAR Procedures
Streamlined Filing and the Delinquent FBAR submission procedures are two separate IRS catch-up routes. Streamlined Filing corrects unreported income and missed returns with a non-willful certification; the Delinquent FBAR procedures are for people who reported all their income but simply missed the FBAR. The right route depends on whether income was left unreported.
The short answer
Two catch-up routes for two different gaps
Both routes bring you back into compliance, but they solve different problems. Streamlined Filing is built for under-reported income and missed returns. The Delinquent FBAR procedures exist for the narrower case where income was fully reported but the foreign-account report was overlooked.
| Streamlined Filing | Delinquent FBAR | ||
|---|---|---|---|
| For unreported income | |||
| For missed FBARs only | |||
| Amended / back tax returns involved | |||
| Non-willful certification | |||
| Best when all income was already reported |
- For unreported income
- For missed FBARs only
- Amended / back tax returns involved
- Non-willful certification
- Best when all income was already reported
Streamlined Filing
- For unreported income
- For missed FBARs only
- Amended / back tax returns involved
- Non-willful certification
- Best when all income was already reported
Delinquent FBAR
- For unreported income
- For missed FBARs only
- Amended / back tax returns involved
- Non-willful certification
- Best when all income was already reported
How to tell which one applies
The deciding question is usually simple: was any income left off your US returns? If yes, and you can certify the omission was non-willful, Streamlined Filing is generally the route. If your income was always reported and paid, and the only thing missing was the FBAR, the Delinquent FBAR procedures are typically the cleaner fit.
Because the facts matter, we look at your full history before recommending a path — the wrong route can create more work or expose you unnecessarily.
This comparison helps if you
- Have missed US filings while living in the UK
- Are unsure whether your situation involves unreported income
- Filed returns but never filed an FBAR
- Want to understand your options before speaking to an advisor
At a glance
- Streamlined Filing
- For unreported income + missed returns
- Delinquent FBAR
- For missed FBARs where income was reported
- Deciding factor
- Was any income unreported?
- Certification
- Streamlined requires a non-willful statement
Related resources
Frequently asked questions
Streamlined Filing is for taxpayers who need to correct both unreported income and missed information returns and can certify their conduct was non-willful. The Delinquent FBAR procedures are for taxpayers who reported and paid tax on all income but simply missed the FBAR itself.
That situation typically points to the Delinquent FBAR submission procedures, because the only gap is the missing foreign-account report rather than unreported income.
If you have unfiled returns or unreported income, the Streamlined Filing compliance procedures are usually the relevant route, provided you can certify non-willful conduct.
Streamlined Filing requires a signed non-willful certification. The Delinquent FBAR procedures ask for a reason for filing late and are used when there is no unreported income and no examination underway.
Not sure which catch-up route fits?
We assess your history and recommend the safest compliant route back.