FBAR recordkeeping: what documents must you keep?
Short answer
If you are required to file an FBAR, you must keep records showing five facts for each reported account: who held it, the account number or other designation, the foreign institution's name and address, the account type, and its maximum value during the calendar year. Keep them for five years, counted from April 15 of the year after the reporting year or from the date you filed, if that was later.Source 1Source 2Source 4Source 5
No particular format is required: statements, PDFs or a spreadsheet are all fine if you can produce the information and explain the reported maximum value. A copy of the filed FBAR isn't required, but it is sensible to keep it with the filing acknowledgement. It doesn't replace the evidence for the amounts you reported.Source 2Source 4Source 5
Exactly what FBAR records must contain
For each foreign financial account: (1) the name in which it is maintained, (2) the account number or other identifying designation, (3) the foreign institution's name and address, (4) the type of account, and (5) the maximum value during the reporting period. Those five items are what you must keep. You don't need to keep every transaction.Source 2Source 4
The information can appear in one statement or several records, such as a bank statement plus a separate institution-address note and a maximum-value calculation. If the account is joint, document the holders. If closed, preserve its last statements before the bank removes online access.Source 1Source 2Source 4
- Account register: reporting year, account owner(s), institution/branch location, account identifier and type.Source 1Source 4
- Value evidence: periodic statement(s) reasonably reflecting the highest year value, including securities and cash where held in a brokerage account.Source 1Source 2Source 4
- Calculation notes: date and basis of maximum, original currency amount and Treasury year-end rate or documented alternative, with USD figure.Source 1Source 2
- Submission evidence: the filed FBAR, the BSA acknowledgement and any amended FBAR. Not required, but a useful record of what you reported.Source 2Source 5
How long do I keep the information?
Keep the records for five years. The Form 114 instructions count from April 15 of the year after the reporting year, or from the filing date if you filed after April 15. IRS guidance counts from the FBAR due date; counting from the later date satisfies both. Count from the reporting year's FBAR, not from the date an account closed.Source 1Source 2Source 4Source 5
The IRS has six years from a violation to assess an FBAR penalty, so keeping records for six years or longer is sensible.Source 6
If an audit, administrative matter or other proceeding concerns the records, do not destroy relevant material solely because your routine deletion date has arrived; check applicable preservation requirements with an adviser.Source 2Source 4
Employees and officers who report only signature authority over their employer's foreign accounts don't need to keep records for those accounts personally; the employer keeps them. This doesn't apply to accounts they own.Source 1Source 2
Example: build evidence for a foreign brokerage account
A foreign brokerage statement shows €28,400 at a June valuation date and €20,100 at year end. Save statement evidence for the June peak and the account's identifying details. Convert the reported maximum using the applicable reporting-year rate; do not simply record the December balance. See how to report securities balances.Source 1Source 2Source 4
If the account closed in September, preserve the closing statement too. A closed account still goes on that year's FBAR if you must file. See closed foreign accounts.Source 1Source 2
A realistic annual filing folder
Organize by reporting year, then one subfolder per institution/account. Use predictable file names such as YYYY-bank-account-statement-period.pdf, a notes file for the maximum and conversion, and copies of BSA submission confirmation. Consider encrypted storage and backups appropriate to the sensitivity of account numbers.Source 1Source 4
Do not upload statements or personal account numbers to public calculators merely to check the FBAR threshold. You can use non-sensitive totals for self-help calculations and retain the underlying documents privately.Source 1Source 4
Related questions
How many years do I need to keep FBAR records?
What five details are required for each reported account?
Must I keep all 12 monthly bank statements?
Can I keep the evidence electronically?
Do I need to retain a copy of the FBAR I submitted?
What if the bank closes my access to old statements?
How do I prove the maximum value of shares held in a foreign brokerage account?
Does a joint foreign account require its own supporting records?
Must an employee keep records of the employer's foreign account?
Next pages
Sources
Official sources used for this page.
Source 1: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)
Required FBAR account records, the five years from the due date, and the employee exception.
irs.govChecked Back to text
Source 2: IRS, IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (opens in a new tab)
IRM 4.26.16.4: records kept five years from the due date, copies of filed FBARs not required, and the employee exception.
irs.govChecked Source updated Back to text
Source 3: IRS, Details on reporting foreign bank and financial accounts (opens in a new tab)
Practical examples of evidence and record descriptions.
irs.govChecked Back to text
Source 4: eCFR, 31 CFR § 1010.420 — Records to be made and retained (opens in a new tab)
31 CFR 1010.420 lists the required account record fields and the five-year retention period.
ecfr.govChecked Back to text
Source 5: FinCEN, FinCEN Report of Foreign Bank and Financial Accounts (FBAR) Electronic Filing Requirements (opens in a new tab)
Form 114 instructions: five years from April 15 of the following year, or the filing date if later; keeping a copy of the filed FBAR can help.
bsaefiling.fincen.govChecked Source updated Back to text
Source 6: U.S. Code, 31 U.S.C. § 5321 — Civil penalties (opens in a new tab)
Six-year period for assessing an FBAR civil penalty.
law.cornell.eduChecked Back to text