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Do spouses need Form 114a to file a single FBAR?

Updated

Checked against official sources on How we check

Short answer

Yes, when spouses use the spousal exception. Both spouses complete and sign Part I of Form 114a, and the filing spouse completes Part II. Don't send Form 114a to FinCEN; keep it for five years.⁠Source 1⁠Source 2⁠Source 3

How the rule works

BSA E-Filing accepts only one digital signature on a report, so Form 114a records that the non-filing spouse authorized the filing spouse to file for both. On the FBAR, the joint accounts go in Part III with the non-filing spouse as principal joint owner. Leave the FBAR's third-party preparer section blank: FinCEN's instructions say it isn't required for spouses filing jointly.⁠Source 1⁠Source 4⁠Source 5

Example

Two U.S.-person spouses own only jointly held reportable foreign accounts. They complete and sign Form 114a, designate one filing spouse, and that spouse files a timely FBAR reporting all the joint accounts. They keep the signed authorization in their records for five years.⁠Source 1⁠Source 2

What to check

Check the three conditions of the spousal exception, particularly the timely FBAR. Keep the signed Form 114a; don't attach it. If the other spouse has an account of their own to report, that spouse files a separate FBAR, or becomes the filing spouse.⁠Source 1⁠Source 2

Related questions

Full rules and more examples: Joint accounts, spouses and children

Sources

Official sources used for this page.

  1. Source 1: FinCEN, Filing for Spouse (opens in a new tab)

    Three conditions for reporting jointly owned accounts on one spouse's FBAR and use of Form 114a.

    fincen.govChecked Back to text

  2. Source 2: FinCEN, Form 114a — Record of Authorization to Electronically File FBARs (opens in a new tab)

    Authorization and recordkeeping for spousal or third-party electronic filings.

    fincen.govChecked Source updated Back to text

  3. Source 3: IRS, Internal Revenue Manual 4.26.16 — FBAR (opens in a new tab)

    Financial interests, signature authority, U.S. residency (including 6013(g)/(h) elections and treaties), family attribution, spousal filing, Form 114a parts and amended-FBAR identifiers.

    irs.govChecked Source updated Back to text

  4. Source 4: FinCEN, Reporting Jointly Held Accounts (opens in a new tab)

    Part III instructions, full account values, joint owner count, principal joint owner identity and blank items.

    fincen.govChecked Back to text

  5. Source 5: FinCEN, FinCEN Report of Foreign Bank and Financial Accounts (FBAR) Electronic Filing Requirements (opens in a new tab)

    The third-party preparer section is not required for spouses filing jointly.

    bsaefiling.fincen.govChecked Source updated Back to text