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The short answer
The Delinquent FBAR Submission Procedures were the IRS route for people who missed FBARs but had reported all their income and paid the tax: you file the late FBARs electronically with a statement explaining the delay, and the IRS said it would not impose a penalty if conditions were met. In 2026 the procedure's status is uncertain, as a July 2026 report says the IRS removed its page; if you also left Nigerian income off your returns, the streamlined procedures are the route to look at.
Who this is for
Many Nigerians in the US only learn about the FBAR years after opening a US life, with savings, rent or pension accounts still running at home. If the accounts together passed $10,000 at any time in a year and you did not file, you have a late FBAR problem. What route fits depends on one question: was all the income from those accounts reported on your US returns?
| Your situation | Route to look at |
|---|---|
| All income reported, tax paid, only FBARs missing | Delinquent FBAR submission (status uncertain in 2026; see below) |
| Income from Nigerian accounts or property left off returns, not wilful | Streamlined domestic offshore procedures (if you live in the US) |
| Wilful failure, or already contacted by the IRS | Speak to a tax lawyer before filing anything |
What the delinquent procedure was
The procedure let people with no unreported income file the FBARs they had missed through FinCEN's BSA E-Filing System and explain why they were late. FinCEN's filing instructions say that if a report is filed after 15 October of the year after the reporting year, you choose a reason for late filing from a drop-down list, or "other" with an explanation. Where the procedure applied, the IRS said it would not impose a penalty.
Its status in 2026
Kaufman Rossin, a US accounting firm, reported on 27 August 2026 that the IRS removed the Delinquent FBAR Submission Procedures page from its website on 1 July 2026 without an announcement, and that the Internal Revenue Manual still says no penalty is imposed where requirements are met and there is reasonable cause. When we checked in October 2026 the old IRS address still returned the earlier text to a fetch, possibly from a cache. Treat the procedure as uncertain and ask a preparer what the IRS currently accepts before relying on it.
The streamlined alternative
If income was also missed, for example Nigerian interest, rent or dividends, the IRS page for US taxpayers residing in the United States (reviewed July 2026) describes the Streamlined Domestic Offshore Procedures:
- For people who do not meet the non-residency test, have filed US returns for the past three years, and whose failure was not wilful.
- You file amended returns (Form 1040-X) for the three most recent years and FBARs for the six most recent years.
- You pay a 5% miscellaneous offshore penalty on the highest year-end aggregate balance of the foreign assets in the period.
- You sign Form 14654 certifying non-wilful conduct, and mail the package to the address the IRS gives.
- On each late FBAR you select "Other" as the reason and enter "Streamlined Filing Compliance Procedures".
- The IRS page gives no end date for the procedures.
A worked example
Example only. Kunle has lived in Atlanta since 2019. He has two Nigerian accounts whose combined maximum passed $10,000 in 2020 to 2025. He reported his only Nigerian income, a small amount of interest, every year. He has missed six FBARs but has no unreported income. He is a candidate for late filing with a reasonable-cause statement, subject to the 2026 uncertainty above.
His sister Ada had the same accounts but never reported ₦2,000,000 a year of Lagos rent. She has unreported income, so late FBARs alone do not fix her position; the streamlined route, with amended returns, is the one she would look at. If her highest year-end aggregate balance was $40,000, the 5% penalty would be $2,000.
What an explanation should cover
Whichever route applies, you will be explaining why the FBARs were not filed. Keep it factual and short. Say when you opened the Nigerian accounts, what they were used for, when and how you learned about the FBAR, and what you did next. Mention that the income from the accounts was on your returns, if it was. Avoid general statements such as "I did not know" without the surrounding facts. If you had help from a preparer who never asked about foreign accounts, say so. Remember too that Schedule B of Form 1040 asks about foreign accounts on line 7a; if you answered "No" in earlier years, that is part of what a preparer will review.
Why it matters
The same Kaufman Rossin report says the non-wilful FBAR penalty can reach $16,536 per report, and notes the Supreme Court's 2023 decision in Bittner v. United States that the non-wilful penalty applies per report, not per account. Several missed years can add up. The IRS FBAR page itself says civil penalties are adjusted for inflation.
Steps before you file
- List every foreign account for each missed year, with maximum values converted at the Treasury year-end rate.
- Check whether all income from those accounts was on your returns.
- Write a short, factual explanation of why you did not file.
- Ask a preparer which route the IRS currently accepts for your facts.
- Keep records for five years, as the FBAR rules require.
For the basics, see do you need to file an FBAR for Nigerian accounts and FBAR penalties and catching up. This is general information, not tax or legal advice.
Where Pryme fits
Catching up means finding balances for every year. Pryme customers can download a statement for any period, including a verifiable version through VerifyDoc.ai, and hold naira and dollars in one multicurrency account, which makes future FBARs simpler.
Questions people ask
Can I file a late FBAR without a penalty?
Possibly, if all income from the accounts was reported and you have reasonable cause. The IRS delinquent submission procedure was the usual route, but a July 2026 report says its page was removed, so check its current status with a preparer.
What is the reason for late filing on an FBAR?
FinCEN's e-filing form gives a drop-down list of reasons, with "Other" and an explanation if none fits. Streamlined filers select Other and enter "Streamlined Filing Compliance Procedures".
What if I also did not report Nigerian income?
Late FBARs alone do not fix unreported income. If you live in the US and were not wilful, the Streamlined Domestic Offshore Procedures, with three years of amended returns and six FBARs, may apply.
What is the FBAR penalty for not filing?
Kaufman Rossin reports the non-wilful penalty can reach $16,536 per report, applied per report rather than per account after the Bittner decision. Penalties are adjusted for inflation.
Sources
- Kaufman Rossin: Delinquent FBAR submission procedures (27 Aug 2026) · accessed Oct 2026
- IRS: US taxpayers residing in the United States, streamlined domestic offshore procedures (reviewed 10 Jul 2026) · accessed Oct 2026
- FinCEN: BSA E-Filing FBAR line item filing instructions · accessed Oct 2026
- IRS: Report of Foreign Bank and Financial Accounts (FBAR) (reviewed 30 Jul 2026) · accessed Oct 2026
- IRS: Instructions for Schedule B (reviewed 30 Apr 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.