FBAR Late Filing Explanation: What to Write (2026)

The form itself

Where the explanation goes

People search for an “FBAR cover letter” or a “late filing sample letter” because the old IRS procedure talked about giving a reason. Since July 2026 that IRS page no longer exists, and the mechanics have not changed in any case: the explanation lives inside the FBAR form, not in a letter. When you file FinCEN Form 114 through the BSA E-Filing System after the due date, page one asks for the reason the report is late. You select one of the listed reasons, or you select “Other” and type your own. The Internal Revenue Manual (IRM 4.26.16.3.11) describes the “Other” option as a 750 character text box.

That box is the only explanation FinCEN receives with the report. The same manual section tells IRS examiners that a penalty will not be asserted for an account where the failure to report it on time was not willful, was due to reasonable cause, and the account was properly reported on the delinquent FBAR. The manual is internal guidance and can change; it is not a promise. But it tells you what the explanation is for: to show, briefly and truthfully, that the lateness was a genuine mistake and that you have now put it right.

This guide is for you if

You have worked out that you should have filed an FBAR for one or more past years and are about to file them
The income from those accounts was on your US returns, so your problem is the missing report, not unreported income
You are filing through the FinCEN system yourself, or you want to understand what we will write on your behalf

Choosing a reason

Pick a listed reason if one is true

The list on the form covers the ordinary reasons a report is missed, including not knowing that you had to file, believing the accounts were under the threshold, or not realising that a particular account counted as foreign. If one of those describes your situation accurately, select it. A listed reason needs no extra wording, and an accurate short answer is better than a long one.

Choose “Other” when your facts do not fit the list, or when more than one reason applies and you want the record to be complete. Two situations where “Other” is usually right: you relied on an adviser who never raised the FBAR, or you only learned that UK pensions, ISAs or a joint account counted when you changed accountant.

What to write

The four things a good explanation contains

1. What the accounts are. Ordinary UK current and savings accounts, an ISA, a workplace pension, a joint account with a non US spouse. One line.

2. Why the report was missed. The real reason, in one or two sentences. You did not know a report was required. You believed the combined balances were under $10,000. Your previous adviser did not raise it. You did not realise a UK pension counted.

3. How and when you found out. The event that changed things, with a month and year. You engaged a cross border accountant in a given month. You read about it when applying for a mortgage. A bank asked for a US tax form.

4. What you have done about it. That you have now filed every year that was due, that the income from the accounts was reported on your US returns, and that you will file on time from now on.

Written out, that is three to five sentences and comfortably inside 750 characters. It should read like a person explaining what happened, not like a legal submission.

Worked examples

Two examples of the shape, not a template to copy

These show the structure. The facts are invented. Yours must be your own, and if a sentence here is not true of you, it does not belong in your statement.

Example A, did not know. “I am a US citizen living in the UK since 2019. The accounts are my UK current and savings accounts and an ISA. I did not know that non US accounts had to be reported to FinCEN until my new accountant explained the requirement in September 2026. The interest from the accounts was included on my US returns for each year. I have now filed the FBARs for 2020 to 2025 and will file on time in future.”

Example B, pension and joint account not counted. “I filed FBARs for my UK bank accounts each year but did not include my UK workplace pension or the joint account I hold with my British wife, because I understood neither counted. I learned otherwise in August 2026 when I changed accountant. I have filed amended FBARs for 2021 to 2025 including all accounts. All income from the accounts was reported on my US returns.”

Each is under 600 characters, names the accounts, gives the reason and the date of discovery, and confirms that the gap is closed.

What to leave out

Five things that make a statement worse

Arguing the law. The box is for facts. Citing cases or the Bank Secrecy Act does not help and reads as if you had something to defend.

Blaming others at length. Saying an adviser never raised it is a fact worth stating. A paragraph about how unreasonable that was is not.

Saying more than you know. Do not state that balances were under a threshold unless you have checked. An inaccurate statement is far more damaging than a late one.

Leaving a year out to make the picture tidier. File every year that was due and say so.

Copying a template. Most sample letters online were written for the old IRS procedure and describe someone else’s facts. A statement that does not match your own records is the one thing that can turn a routine late filing into a question.

Your own file

Write a fuller reasonable cause note and keep it

The 750 characters on the form are a summary. On the same day, write a dated note for your own records that tells the whole story: the accounts and their highest balances by year, when and how you learned of the requirement, who advised you and what they said, which years were filed and when, and that the income was on your returns. Store it with your tax papers. This is the document you would produce if the IRS ever asked why the reports were late, and the reasonable cause standard is judged on exactly these facts. Nobody can promise that a late report escapes a penalty, but a clear, contemporaneous record is the strongest position you can hold.

In order

Writing and filing the late FBAR

01
1. Confirm the income was reported
Check that interest, dividends and any pension growth from each account appeared on your US returns. If not, stop: the Streamlined Foreign Offshore Procedures are the route, and the statement you need is Form 14653, not this box.
02
2. List the years and accounts
For each missed year, every non US account you owned, co owned or could sign on, with its highest balance converted to dollars at the Treasury year end rate. An FBAR was due for any year the combined total exceeded $10,000.
03
3. Draft the explanation
Four elements, three to five sentences, under 750 characters. Read it back against your records.
04
4. Write the reasonable cause note
The fuller, dated version for your own file.
05
5. E-file each year through FinCEN
One FinCEN Form 114 per missed year, selecting the reason or entering the explanation on each. Keep every confirmation number.

At a glance

Cover letter: None. The explanation is a box on the form
Where: FinCEN Form 114, page one, reason for filing late
Options: Listed reasons, or "Other" with a text box
Length: Up to 750 characters (IRM 4.26.16.3.11)
Keep on file: A dated reasonable cause note with the full facts
If income unreported: Streamlined route and Form 14653 instead

Not sure how this applies to you?

Email us a few lines about your situation

Sources

Primary sources used for this guide

IRS, Internal Revenue Manual 4.26.16, Report of Foreign Bank and Financial Accounts (manual transmittal 26 August 2025), section 4.26.16.3.11 on delinquent FBAR filing and the reason for late filing.
IRS, Report of Foreign Bank and Financial Accounts (FBAR), last updated 30 July 2026.
IRS, Streamlined Foreign Offshore Procedures, updated 11 July 2026, and Form 14653.
FinCEN, BSA E-Filing System and the FinCEN Form 114 instructions.

This guide is general information for US persons living in the UK, written on 20 October 2026. It is not advice on your circumstances and the examples are illustrations of structure, not statements to copy.

Related guides and services

Delinquent FBAR guideThe three routes after the IRS removed its procedures page, penalties, and which UK accounts count.FBAR filing servicePreparation and e-filing of current, late and amended FBARs.Streamlined Filing serviceFor non willful cases where income was also unreported.How to amend an FBARWhen an account was left off a report you did file.FBAR checkerWork through the $10,000 threshold test.

Frequently asked questions

No. The FBAR is e-filed through the FinCEN BSA E-Filing System and nothing is posted. The form itself asks why the report is late. You pick a reason from a list or choose "Other" and type a short explanation. That box is the only explanation FinCEN receives, so there is no letter to attach.

The form offers a drop down list of standard reasons, such as not knowing that a report was required, and an "Other" option. The Internal Revenue Manual (IRM 4.26.16.3.11) notes that "Other" opens a text box of up to 750 characters. If one of the listed reasons is accurate for you, choose it. Use "Other" only when none of them describes your facts.

Four things, in plain words: what the accounts are, why the report was not filed on time, how and when you found out, and that you have now filed every year that was due. Keep it to the facts. Do not argue the law, do not overstate, and do not leave out a year.

No. The box on the form is a short statement of why the report is late. Reasonable cause is the legal standard the IRS applies if it ever considers a penalty, and it is judged on all the facts. Write a fuller, dated reasonable cause note for your own records at the same time, and keep it with your tax papers. You would produce it only if the IRS asked.

No. The Streamlined Foreign Offshore Procedures require a separate signed statement, Form 14653, explaining why your conduct was non willful. That is a longer narrative signed under penalties of perjury and it goes to the IRS with three years of returns and six years of FBARs. The box on the FBAR form is a different, much shorter thing. If income from the accounts was never reported, Streamlined is the route, not a late FBAR on its own.

If the income from the accounts was on your US returns and you simply missed the report, many people write the explanation and file themselves. Take advice first if income was not reported, if balances were large, if you are unsure which UK accounts count (pensions, ISAs, joint or business accounts), or if the IRS or FinCEN has already written to you. The wording is rarely the problem; choosing the wrong route is.

Not sure what your explanation should say?

Email us which years are missing and whether the income was on your US returns. We will tell you which route applies and what the statement needs to cover, and quote in writing before any work begins.