US·UK Accountants

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. Filing a delinquent FBAR on its own, with the reason for late filing and a reasonable-cause record, is for the narrower case where income was fully reported but the foreign-account report was overlooked. Until mid-2026 the IRS published Delinquent FBAR Submission Procedures promising no penalty in that case; that page has been withdrawn, and the IRS now says a late FBAR may attract a penalty depending on the facts.

Streamlined Filing

For unreported income
For missed FBARs only
Amended / back tax returns involved
Non-willful certification
Best when all income was already reported
Written IRS no-penalty assurance

Late FBAR with reasonable cause

For unreported income
For missed FBARs only
Amended / back tax returns involved
Non-willful certification
Best when all income was already reported
Written IRS no-penalty assurance

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, filing the late reports with a documented reasonable cause is typically the proportionate fix — see our delinquent FBAR guide for the current position.

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
Late FBAR with reasonable cause
For missed FBARs where income was reported
Deciding factor
Was any income unreported?
Certification
Streamlined requires a non-willful statement

Not sure how this applies to you?

Email us a few lines about your situation

Frequently asked questions

Streamlined Filing is for taxpayers who need to correct unreported income or missed returns and can certify non-willful conduct; a qualifying submission carries no FBAR or late-filing penalties. Filing late FBARs on their own, with the reason for late filing and a reasonable-cause record, is for taxpayers who reported and paid tax on all the income and only missed the report. The IRS removed its published Delinquent FBAR Submission Procedures page in early July 2026, so that second route now rests on reasonable cause rather than a written safe harbour.

That situation typically points to filing the late FBARs through FinCEN with the reason for late filing, and keeping a dated reasonable-cause note. A penalty is not automatic; the IRS assesses FBAR penalties only after an examination and its manual says a non-willful penalty should not be imposed where there was reasonable cause and accurate late FBARs are filed.

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 (Form 14653). Filing late FBARs on their own asks only for the reason for late filing on the FinCEN form, but you should keep a fuller reasonable-cause note on file in case the IRS asks.

Not sure which catch-up route fits?

We assess your history and recommend the safest compliant route back.