Yes—if you had a financial interest in at least 25 distinct foreign accounts during the reporting year, check Yes in Part I, Item 14a, enter the count, and leave Parts II and III blank.
“I have over 25 foreign accounts this year because several matured, closed, and were replaced by new ones. If I check 'Yes' to having more than 25 accounts on Part I, Question 14 of the FBAR, am I supposed to file with just Part I filled and leave Part II and Part III empty?”
Summary
You do not have to type 25-plus owned accounts into Parts II and III just because some closed and new ones opened. You still need an accurate count and a full record of each distinct account.
The deciding question is how many distinct accounts you had a in during the reporting year—not how many remained open at year-end.
Check Yes in Part I, Item 14a, and enter the total number. Leave Parts II and III blank and keep their account details. If you have no separate signature-only accounts or consolidated-entity reporting, Part I is the only part you complete. The rule says **25 or more**, not more than 25. [IRS FBAR Reference Guide, page 5](https://www.irs.gov/pub/irs-pdf/p5569.pdf); [31 CFR 1010.350(g)(1)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-C/section-1010.350)
Do not check Yes in Item 14a merely because owned and signature-only accounts together exceed 25. Complete Part II for separately owned accounts and Part III for jointly owned accounts. If you also have accounts with but no financial interest, address Part IV separately. [FinCEN Form 114 instructions, Parts II–IV](https://www.fincen.gov/sites/default/files/shared/FBAR%20Line%20Item%20Filing%20Instructions.pdf)
For 25 or more accounts over which you have but no financial interest, use Item 14b, enter that count, and complete Part IV, Items 34–43, for each person on whose behalf you have that authority. This does not replace any Parts II or III needed for accounts you own. [FinCEN Item 14 instructions](https://www.fincen.gov/reporting-financial-interest-25-or-more-foreign-financial-accounts)
These routes assume you meet the FBAR filing threshold; account count alone does not establish that. [IRS FBAR filing guidance](https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar)
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Next steps
These steps establish the right account count, preserve the omitted details, and get the correct FBAR filed.
Before selecting Item 14a
Count the distinct accounts for the reporting year
List each foreign account in which you had a financial interest at any point in the calendar year, including one closed during that year. Count a replacement separately if it was genuinely a new account; do not treat a continuation of the same account as a proven second account. If the resulting financial-interest count is at least 25, use Item 14a’s Yes box and enter that count. [31 CFR 1010.350(a), (g)(1)](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-C/section-1010.350); [IRS FBAR Reference Guide](https://www.irs.gov/pub/irs-pdf/p5569.pdf)
Requirements
Even though Parts II and III stay blank
Prepare and retain the account records
Keep these details for every reportable account for five years and provide the omitted information if FinCEN or the IRS requests it. [31 CFR 1010.420](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-X/part-1010/subpart-D/section-1010.420); [FinCEN Item 14 guidance](https://www.fincen.gov/reporting-financial-interest-25-or-more-foreign-financial-accounts)
Requirements
For 2026 accounts: by October 15, 2027, under the automatic extension
File FinCEN Form 114 online
Submit the FBAR to FinCEN at https://bsaefiling.fincen.gov/file/fbar/html; individual filers need not register. For the 2026 reporting year, the regular deadline is April 15, 2027, automatically extended to October 15, 2027 without a request. If filing for 2025 instead, the automatic extended deadline is October 15, 2026. The fetched official filing pages did not specify a self-filing fee. [FinCEN filing instructions](https://bsaefiling.fincen.gov/file/fbar); [IRS deadline guidance](https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar)
Requirements
Legal sources
This answer draws on FinCEN’s FBAR instructions, the FBAR regulations, and the IRS FBAR Reference Guide and filing guidance.
31 CFR 1010.350(a)
FBAR reporting follows the year in which an account relationship existed, rather than just the accounts still open at year-end.
(a)
Each United States person having a financial interest in, or signature or other authority over, a bank, securities, or other financial account in a foreign country shall report such relationship to the Commissioner of Internal Revenue for each year in which such relationship exists and shall provide such information as shall be specified in a reporting form prescribed under 31 U.S.C. 5314 to be filed by such persons.
31 CFR 1010.350(g)(1)
The reduced-detail rule starts at 25 accounts in which the filer has a financial interest.
(g)(1)
A United States person having a financial interest in 25 or more foreign financial accounts need only provide the number of financial accounts and certain other basic information on the report, but will be required to provide detailed information concerning each account when so requested by the Secretary or his delegate.
IRS Publication 5569, FBAR Reference Guide
The IRS tells a 25-or-more financial-interest filer exactly which box to check and which parts to omit.
page 5, Modified Reporting Requirements
A U.S. person with a financial interest in 25 or more foreign financial accounts should check the ‘Yes’ box in Part I, Item 14a, and record the number of accounts in the space provided. The U.S. person shouldn’t complete Part II or Part III of the report but keep records of the information.
FinCEN Form 114 line-item instructions
The form assigns separately owned, jointly owned, and signature-only accounts to different parts.
Part II
Part II records information on accounts owned separately by the filer. It should not be used to record information on jointly-owned accounts (Part III), signature authority but no financial interest accounts (Part IV), or accounts involved in a consolidated report (Part V).
31 CFR 1010.420
Even when account details are omitted from the FBAR, the filer must retain specified information for each account for five years.
Such records shall contain the name in which each such account is maintained, the number or other designation of such account, the name and address of the foreign bank or other person with whom such account is maintained, the type of such account, and the maximum value of each such account during the reporting period. Such records shall be retained for a period of 5 years and shall be kept at all times available for inspection as authorized by law.
FinCEN Form 114, Item 14 guidance
A signature-only filer with 25 or more such accounts uses Item 14b and supplies identifying information in Part IV.
Item 14
If the filer has signature authority only (no financial interest), over 25 or more foreign financial accounts check the yes box, and enter the total number of accounts in 14b. Complete only items 34-43 of Part IV for each person on whose behalf the filer has signature authority.
FinCEN Form 114, consolidated FBAR guidance
The Part-I-only answer does not apply to a consolidated FBAR for entities.
Item 14
If filing a consolidated FBAR, the United States person should not complete Part II or Part III but should complete Part V, Items 34-42, for each United States entity included in the consolidated FBAR.
FinCEN Form 114, Item 14 guidance
FinCEN or the IRS can require the account information that the 25-account filer left off the report.
Item 14
Any person who reports 25 or more foreign financial accounts in item 14a or item 14b, must provide all the information omitted from Parts II, III, IV or V, as appropriate, if the information is requested by FinCEN or the IRS.
FinCEN Form 114 line-item instructions
The number of accounts does not replace the monetary threshold for filing.
General Instructions
If the maximum account value of a single account or aggregate of the maximum account values of multiple accounts exceeds $10,000, an FBAR must be filed.
IRS FBAR filing guidance
The 2026 reporting year is filed in 2027, and the six-month FBAR filing extension is automatic.
When to file
The FBAR is an annual report, due April 15 following the calendar year reported. You’re allowed an automatic extension to October 15 if you fail to meet the FBAR annual due date of April 15. You don’t need to request an extension to file the FBAR.
FinCEN FBAR Help
The report goes through FinCEN’s electronic filing system, not with a tax return.
How Do I File the FBAR?
The Report of Foreign Bank and Financial Accounts (114) must be filed electronically using the BSA E-Filing System.
These are the official rules as published on the cited dates; rules can change.
This is general information about official processes, not legal advice, and SettleKit is not a law firm.
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