Can spouses file one FBAR if one spouse has signature authority over an employer's foreign account?

Signature authority over an employer's foreign account can require an FBAR even without ownership. Some officers and employees are exempt from reporting it. FinCEN has also extended the due date for certain individuals with signature authority over, but no financial interest in, employer accounts. For the 2025 calendar year, the extended date is April 15, 2027. FinCEN describes the extension as covering the reporting of that signature authority. It doesn't say whether the extension also covers accounts the same person owns, so plan to report the couple's joint accounts by the normal due date.⁠^{[2]Source 2}⁠^{[3]Source 3}⁠^{[4]Source 4}

Two U.S.-person spouses share a foreign bank account. Spouse B can directly instruct a foreign bank to move money from an employer-owned account. If B must report that account, A's FBAR can't cover B under the spousal exception. B files their own FBAR, unless B files and covers A instead.⁠^{[2]Source 2}⁠^{[1]Source 1}

Check whether one of the officer or employee exceptions removes B's obligation to report the employer account. If it does, the spousal exception may still be available. If not, B either files their own FBAR or becomes the filing spouse.⁠^{[2]Source 2}