Streamlined Filing Procedures 2026: What Has Changed and What Hasn't

The streamlined filing procedures 2026 picture is simple: the IRS program is still open, on the same terms, with no announced end date as of October 3, 2026. A submission made in late 2026 normally covers tax returns for 2023 to 2025 and FBARs for 2020 to 2025. What did change this year sits next to the program, not inside it.

Our full guide to the Streamlined Procedures explains how the program works from start to finish. This article is the 2026 status check: what we verified on IRS.gov today, which years to file if you submit before the end of the year, which forms are current, and the mid-2026 change that makes the Streamlined route more relevant for people who thought they only had a late FBAR problem.

Are the Streamlined Filing Procedures 2026 rules any different?

No. The core rules of the Streamlined Filing Compliance Procedures are the same in 2026 as they were in 2025. We checked the IRS pages on October 3, 2026, and nothing in the eligibility rules, the look-back periods or the penalty terms has moved.

Here is what we found, with the "page last reviewed" date the IRS shows on each page:

• The main Streamlined Filing Compliance Procedures page was last reviewed on July 11, 2026. It still describes the program as available, with no closing date.
• The Streamlined Foreign Offshore Procedures page was last reviewed on July 11, 2026, and the Streamlined Domestic Offshore Procedures page on July 10, 2026. Both carry the same terms as before.
• The IRS options page for undisclosed foreign financial assets was updated on June 30, 2026. It now lists three options: the IRS Criminal Investigation Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures and the Delinquent International Information Return Submission Procedures.
• We found no IRS news release in 2026 announcing an end date or a change to the Streamlined Procedures. The IRS did publish a proposal in December 2025 to revise its separate Voluntary Disclosure Practice, with comments closing on March 22, 2026; that proposal does not mention the Streamlined Procedures.

That stability is useful, but it is not a promise. The program has been modified before, and the IRS can change or close it without a long notice period. If you qualify today, the safest time to use it is while the terms are known.

What changed in 2026 around the program?

The real 2026 change is that the IRS took down its Delinquent FBAR Submission Procedures page. That page, archived as late as June 2026 with a "last reviewed" date of February 19, 2026, said the IRS would not impose a penalty for late FBARs if you had reported and paid tax on all the income from the accounts and had not been contacted about an examination. As of October 3, 2026 the page returns "not found," and the IRS options page no longer lists it.

Late FBARs can still be filed. The IRS FBAR page, last reviewed July 30, 2026, now says that if the IRS has not contacted you and you are not under civil or criminal investigation, you should file late FBARs as soon as possible to keep potential penalties to a minimum, and explain the reason for filing late. What has gone is the published statement that no penalty would follow.

For Americans in the UK this matters. Many people who had paid their US tax correctly but never filed FBARs used to choose the lighter delinquent FBAR route. That choice now carries more uncertainty, and for someone who also missed any foreign income, Form 8938 or other information returns, the Streamlined Foreign Offshore Procedures, with their explicit waiver of FBAR penalties, are now the clearer path. Our guide to FBAR requirements for expats covers which UK accounts count.

Which years do you file for a late-2026 submission?

For a Streamlined submission made between October 16 and December 31, 2026, you normally file tax returns for 2023, 2024 and 2025 and FBARs for 2020 through 2025. The rule is the IRS definition of the covered periods, and the years follow from the due dates.

The IRS defines the covered tax return period as the most recent 3 years "for which the U.S. tax return due date (or properly applied for extended due date) has passed," and the covered FBAR period as the most recent 6 years for which the FBAR due date has passed. So the question for each year is simply: has its deadline gone by on the day you submit?

1. The 2025 tax return. It was due April 15, 2026. An American abroad gets an automatic 2-month extension to June 15, 2026, and can extend further to October 15, 2026, according to IRS Publication 54. By October 16, 2026, every one of those dates has passed, so 2025 is inside the window and the three years are 2023, 2024 and 2025.
2. The December 15 exception. Publication 54 also describes a discretionary additional extension to December 15 for taxpayers out of the country, which must be requested. If you properly obtained it for 2025, the 2025 extended due date has not passed until December 15, 2026, so a submission before then covers 2022, 2023 and 2024, and the 2025 return is filed on its own by December 15.
3. The 2025 FBAR. The FBAR is due April 15 with an automatic extension to October 15, so the 2025 FBAR's final date was October 15, 2026. After that date, the six most recent FBAR years are 2020 through 2025, whichever date you treat as the due date.
4. The 2026 year. The 2026 tax return and 2026 FBAR are not due until 2027, so they are never part of a 2026 submission. They are your first ordinary filings after you catch up.

Timeline: which years a 2026 submission covers

Submission date in 2026	Tax returns (3 years)	FBARs (6 years)	Notes
January 1 to April 15	2022, 2023, 2024	2019 to 2024	The 2025 return and FBAR were not yet due.
April 16 to October 15	2023, 2024, 2025 (or 2022 to 2024 if 2025 was properly extended and the extended date has not passed)	2019 to 2024, plus the 2025 FBAR by October 15	The 2025 FBAR is still within its automatic extension, so file it on time alongside the submission.
October 16 to December 15	2023, 2024, 2025 (2022 to 2024 only if the December 15 extension for 2025 was properly obtained)	2020 to 2025	The usual late-2026 position.
December 16 to December 31	2023, 2024, 2025	2020 to 2025	Every 2025 deadline has passed.

Two practical points follow. A year that falls out of the window is not reported under the program, so a 2022 return is not part of a typical late-2026 foreign submission. And the window moves on April 15, 2027, when the 2026 return comes due, so a submission prepared in December and mailed in late April could end up covering the wrong years. Prepare for the date you will actually send it.

Illustrative example: Dana is a US citizen who has lived in Manchester since 2014, pays UK tax through PAYE and has never filed a US return or an FBAR. She has a current account, a cash ISA and a workplace pension. She submits under the Streamlined Foreign Offshore Procedures on November 20, 2026, without any extension for 2025. Her submission is three original Forms 1040 for 2023, 2024 and 2025, six FBARs for 2020 to 2025, and a signed Form 14653. Her UK salary is covered by the Foreign Tax Credit or the foreign earned income exclusion, so any tax due is likely to come from the cash ISA interest, which the US taxes even though the UK does not. She owes no penalties. This is a simplified illustration, not advice for any specific person.

Which forms and certifications are current?

As of October 3, 2026, the current revisions on IRS.gov are:

• Form 14653 (Rev. 3-2025), Certification by U.S. Person Residing Outside of the U.S. for the Streamlined Foreign Offshore Procedures. It is signed under penalties of perjury and contains the non-willful narrative.
• Form 14654 (Rev. 9-2017), Certification by U.S. Person Residing in the U.S. for the Streamlined Domestic Offshore Procedures. It also includes the calculation of the 5% penalty.

The submission mechanics are unchanged. Foreign Offshore returns are marked "Streamlined Foreign Offshore" in red at the top of each return and mailed with Form 14653 to the address on the IRS page. Domestic Offshore filers use Form 1040-X amended returns marked "Streamlined Domestic Offshore." FBARs for both versions are filed electronically through FinCEN's BSA E-Filing System, selecting "Other" as the late-filing reason and entering "Streamlined Filing Compliance Procedures." All tax and interest is paid with the submission. The IRS does not acknowledge receipt and does not sign a closing agreement; returns are processed like any other return and can still be selected for audit.

Who is still eligible, and who is barred?

Eligibility in 2026 rests on the same four tests: non-willful conduct, a valid taxpayer identification number, no open IRS examination or investigation, and, for the foreign version, the non-residency test.

The bars

• Civil examination. If the IRS has started a civil examination of your returns for any tax year, you cannot use either version, even if the audit has nothing to do with foreign accounts.
• Criminal investigation. Anyone under investigation by IRS Criminal Investigation is also ineligible.
• Willful conduct. The program is only for failures caused by negligence, inadvertence, mistake or a good faith misunderstanding of the law. Willful cases belong in the Criminal Investigation Voluntary Disclosure Practice, and borderline facts deserve a review by an IRS tax controversy specialist before anything is certified.

The non-residency test

For US citizens and green card holders, the Foreign Offshore version requires that in at least one of the three most recent years for which the return due date has passed, you had no US abode and were physically outside the United States for at least 330 full days. For people who are not citizens or green card holders, the test is that you did not meet the substantial presence test in at least one of those years. Fail it, and the Domestic Offshore version is the alternative, which requires that you already filed returns for each of the three years.

What does each route cost in penalties?

The Foreign Offshore version still carries no penalty at all: no failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties. The Domestic Offshore version still carries a miscellaneous offshore penalty equal to 5% of the highest aggregate year-end balance or value of the foreign financial assets subject to the penalty, which are assets that should have been on an FBAR or Form 8938 but were not, or whose income was not reported, during the covered period.

Route in 2026	Who it fits	Penalty position
Streamlined Foreign Offshore	Non-willful, passes the non-residency test	No penalties
Streamlined Domestic Offshore	Non-willful, US resident, filed original returns	5% miscellaneous offshore penalty
Late FBARs only	All income reported and tax paid, only the FBAR missed	No published penalty-free assurance since mid-2026; penalties discretionary
Delinquent international information returns	Income reported, only forms like 5471 or 3520 missed	Penalties may be assessed; reasonable cause statement considered
CI Voluntary Disclosure Practice	Willful conduct	Civil penalties under that practice's own framework

The Delinquent International Information Return Submission Procedures page, last reviewed April 19, 2026, is still live. It is for people who reported all their income but missed forms such as Form 5471 or Form 3520, who are not under examination or investigation, and who have not been contacted about the missing returns. A reasonable cause statement can be attached, but the IRS warns that penalties may be assessed without considering it first, except for Forms 3520 and 3520-A. If unreported income is part of the picture, the IRS points to the Streamlined Procedures instead.

Does the IRS still accept a quiet disclosure?

The IRS position on quiet disclosure has not changed. A quiet disclosure, meaning late or amended returns filed outside any program in the hope that nobody asks questions, gives no penalty protection at all. The Streamlined page says people who made a quiet disclosure can still use the Streamlined Procedures if they are otherwise eligible, but "any penalty assessments previously made with respect to those filing will not be abated."

In practice that means a quiet disclosure only ever adds risk. If you qualify for the Streamlined Procedures, filing through the program gives you the penalty terms in writing. If you already filed quietly, the program is still open to you for the remaining exposure, but the earlier filings stay as they are.

Is the foreign earned income exclusion relevant in 2026?

Yes, for the years in the submission, but not in the way most people expect. The three Streamlined returns can claim the foreign earned income exclusion on Form 2555, or the Foreign Tax Credit, just as an on-time return could. According to the IRS page on figuring the foreign earned income exclusion, the maximum is $130,000 per qualifying person for tax year 2025 and $132,900 for tax year 2026. The 2023 and 2024 limits are set out in the Form 2555 instructions for those years.

For most people working in the UK, the Foreign Tax Credit is the better tool, because UK tax rates on salary usually exceed US rates and unused credits carry forward. The exclusion does nothing for investment income, which is where Streamlined balances usually come from: cash ISA interest, ISA investment gains and UK funds that the US treats as PFICs. The choice between the two is made year by year and has knock-on effects, so it is worth modeling before you file.

How we help with a 2026 Streamlined submission

US/UK Cross Border Tax is a team of US CPAs and UK tax advisers working as one team, with offices in London, Manchester, New York and San Francisco. Our streamlined filing procedures 2026 service starts by confirming which version you qualify for and which years your submission date puts in scope, then prepares the three returns, six FBARs and the Form 14653 or 14654 narrative. If you are an American living in the UK or an accidental American who has only just learned about US filing, the program is designed for exactly your situation.

If you want a joined-up view of both tax systems, our US and UK tax specialists page explains how we work. When you are ready, contact us for a fixed quote and an eligibility review before any work begins.