Do I have to file an FBAR for a UK company account I sign on but do not own?

Yes, if the aggregate value of all your foreign accounts crossed $10,000 at any point in the year. Signature or other authority means you can control the disposition of assets in the account by direct communication with the bank, and 31 CFR 1010.350 makes that reportable whether or not you own any of the money and whether or not you ever gave an instruction. The account is reported in Part IV of FinCEN Form 114, where you identify the company as owner and state your title, rather than in Part II, which is for accounts you own.

Does signature authority count toward the $10,000 FBAR threshold?

It does, at the full maximum value of the account rather than any share of it. The test asks whether the aggregate value of accounts in which you have a financial interest or over which you have signature or other authority exceeded $10,000 at any time during the calendar year. This is why one company mandate can create a missed FBAR across your whole position: once the aggregate is breached, every reportable account must be listed, including personal accounts that were individually well below the threshold and that you had correctly treated as not requiring a report.

Am I covered by the officer or employee exception as a director of a UK limited company?

Almost certainly not. The exception in the FinCEN Form 114 instructions applies to officers and employees of specified employers: banks examined by the US federal banking regulators, financial institutions registered with and examined by the SEC or CFTC, Authorized Service Providers, entities with equity listed on a US national securities exchange, US subsidiaries included in a listed parent's consolidated FBAR, and entities registered under section 12(g). A privately owned UK limited company is none of these, so its US-person directors and finance staff report their signature authority in Part IV.

Does my UK employer's FBAR filing cover me?

Only administratively. An employer holding documented authority from you on FinCEN Form 114a can sign and submit your FBAR through a single BSA E-Filing institutional account, but the report remains yours and any failure is recorded against you. It will not cover accounts outside the group, such as a portfolio company, joint venture or charity, and it will not cover your personal accounts. Employer programmes also tend to start prospectively, so earlier years in which you held a mandate usually remain unreported and have to be filed separately.

Do I have to report my spouse's UK account if I am named on the mandate?

Yes. If you can instruct the bank on an account held in your spouse's sole name, you have signature authority and the account belongs in Part IV of your own FBAR at its full maximum value, while your spouse reports it as owner if she is also a US person. The spousal shortcut cannot be used, because it requires that every account the non-filing spouse must report is jointly owned with the filing spouse, and a sole-name account you merely sign on is not jointly owned. Two separate reports are required.

How do I fix missed FBAR years where I only had signature authority?

An authority-only account generates no income for you, so where your returns were otherwise correct there is usually nothing for a streamlined submission to fix. The IRS position is to file the late FBARs electronically as soon as possible, provided it has not already contacted you and you are not under investigation, selecting a reason for filing late and giving a concise statement of the facts. No penalty is asserted where the failure was not willful, was due to reasonable cause and the accounts are properly reported. If a streamlined submission is being made anyway, six years of FBARs travel with it.

Missed FBAR: Signature Authority Over UK Accounts

A missed FBAR is not only a problem for money you own. If you are a US person who can tell a UK bank to move funds out of an account, you have signature or other authority over that account and FinCEN Form 114 must report it, even where your financial interest in the money is precisely nil. Directors of UK limited companies, finance directors of UK subsidiaries, members of an LLP, charity and club treasurers, and anyone named on a spouse's or parent's bank mandate all fall inside the rule, and the rule is measured by what you are able to instruct rather than by what you own.

This is the most common cause of a missed FBAR among wealthy US persons in the United Kingdom, because an authority-only account looks nothing like a personal asset. No statement arrives in your name, no income lands on your Form 1040, and your UK self assessment return never mentions it. The consequences are structural: authority-only accounts are aggregated at full value against the $10,000 test, so they routinely drag personal accounts you correctly believed were below the line into the report as well.

What does signature or other authority mean for a missed FBAR?

Signature or other authority is the authority of an individual, alone or in conjunction with another individual, to control the disposition of assets held in a foreign financial account by direct communication, whether in writing or otherwise, to the bank or other financial institution that maintains the account. That definition sits in 31 CFR 1010.350 and is repeated verbatim in the FinCEN Form 114 filing instructions. Three features do the work. It is about disposition, meaning getting assets out or moving them on. It is about direct communication with the institution, not internal company process. And it is about authority rather than activity: the test is what the bank will act on if you instruct it, so an authority you have never exercised still creates a reportable account.

The word conjunction matters for UK company accounts. A mandate requiring two signatories does not halve anyone's position; each of the two has authority over the whole account, and each files. A UK operating company with four authorised signatories, two of them US persons, produces two separate FBARs reporting the same account at its full maximum value. There is no apportionment anywhere in the FBAR regime.

Two carve-outs in the Internal Revenue Manual at 4.26.16 are narrower than people hope. A person whose authority runs only to buying and selling investments inside an account, without power to disburse assets out of it, does not have signature authority. Nor does a person whose role is supervisory over those who communicate with the institution acquire it merely by approving a disbursement a subordinate then orders. This is where the line between real signature authority and a mere power to sign as an agent lives. If you countersign an internal payment schedule that your finance team transmits, and the bank has no record of you and will not act on your instruction, you are outside the definition. If your name is on the mandate, or the bank's platform gives you a payment-release entitlement, you are inside it, whatever your job title and whether or not you use the access.

Signature authority must also be distinguished from financial interest, because the two go to different parts of the form. You have a financial interest where you are the owner of record or holder of legal title; where the owner of record is an agent, nominee, attorney or other person holding the account on your behalf; or where you own more than 50 percent of a corporation by value or voting power, more than 50 percent of a partnership's profits or capital, or more than 50 percent of the voting power, value or profits of any other entity. The direction of the agency relationship decides it. If a UK adviser holds an account on your behalf, that is your financial interest. If you hold the mandate on someone else's account, that is signature authority.

Which UK roles create signature authority? A role-by-role audit

Rather than reason from first principles each time, work through the roles. These are the positions that produce reportable authority in our FBAR preparation work, and the part of Form 114 each lands in.

Director or officer of a UK limited company named on the bank mandate: authority, Part IV. Being a director alone does not do it; being on the mandate or holding payment rights on the bank's platform does.
Director or officer who also owns more than 50 percent of the company by value or votes: financial interest under the indirect ownership rule, so the accounts go in Part II or Part III. Majority owners often file this the wrong way round.
CFO, finance director, treasurer, financial controller or payments manager at a UK subsidiary who can release payments to the bank: authority, Part IV, however junior the release limit. There is no de minimis by payment size.
Member or designated member of a UK LLP who can instruct the LLP's bankers: authority, Part IV, where profit and capital shares are 50 percent or less. More than 50 percent of profits or of capital is a financial interest instead.
Treasurer, chair or committee member of a UK charity, sports club, school association or residents' association with cheque-signing or online payment rights: authority, Part IV. Small community accounts are the most frequently missed category of all.
Named signatory or attorney on a spouse's, parent's or adult child's UK account where you are not an owner of record: authority, Part IV. The account is reportable by you and by its owner simultaneously.
Signatory on a portfolio company, joint venture or special purpose vehicle account: authority, Part IV, with each entity a separate owner requiring its own Part IV entry.
Company secretary, executive assistant or family office employee holding online banking credentials that can move money: authority, Part IV. Delegated access the bank recognises is authority.

Evidence the conclusion rather than asserting it. The documents that settle it are the bank mandate, the board minute or LLP resolution appointing the signatories, and the entitlement report from the bank's platform showing who can initiate and who can release payments. For a missed FBAR filed for an earlier year, those documents fix the position as at that year, which matters where mandates changed mid-period or where you resigned from a board and nobody told the bank.

How can one authority-only account create a missed FBAR across all your accounts?

This is the trap that turns a small omission into a wide one. The filing test is not applied account by account, and not category by category. A US person must file if the aggregate value of the foreign financial accounts in which he has a financial interest, or over which he has signature or other authority, exceeded $10,000 at any time during the calendar year. Authority-only accounts enter that aggregate at their full maximum value, not at a notional share, even though you own none of the money. Once the aggregate crosses the line, every reportable account must be listed, including personal accounts that were comfortably below $10,000 on their own.

So the reader with a modest current account and a small savings account, who concluded years ago that no FBAR was due, is wrong the moment he is a signatory on a company account that touched $500,000 in March. The company account is reportable in Part IV. The two personal accounts, which would otherwise never have appeared anywhere, become reportable in Part II. One mandate has converted a nil-filing position into a multi-account report, and every year the mandate existed is a missed FBAR year.

Aggregate every account once: personal, joint, entity accounts where you hold more than 50 percent, and every authority-only account.
Use each account's full maximum value during the year, never a percentage share and never the year-end balance if a higher figure occurred earlier.
Test the aggregate at its highest point in the year, not at 31 December. A single large receipt into a company account on one day is enough.
Convert each maximum to US dollars at the Treasury rate for the last day of the calendar year and round up to the whole dollar.
Do not net internal transfers between accounts you control: both the sending and the receiving account count at their own maximum, which is why aggregates look inflated and the threshold is crossed more often than expected.
With fewer than 25 accounts and no way to establish a value, use the amount unknown box at item 15a; the account is still reported.

Where do these accounts go: Part IV versus Part II and Part III?

Form 114 separates ownership from authority by design. Part II records accounts owned separately by the filer. Part III records accounts owned jointly, identifying the principal joint owner. Part IV records accounts where the filer has signature or other authority but no financial interest. Part V is for a consolidated report by an entity owning more than 50 percent of another reporting entity. Putting an employer's account in Part II because it was quicker is not a formatting slip: Part II is an affirmative statement that you own the account, and on a late filing made years afterwards the part you chose is the record of what you claimed. A company account sitting in Part II invites questions about undeclared ownership and undeclared income that a correctly placed Part IV entry never raises.

For each Part IV account, items 15 to 23 capture the account information: maximum value, account type, account number, and the name and address of the UK institution. Items 34 to 42 then identify the owner of the account by name, address and identifying number. Where the owner is an entity such as a UK limited company, the name goes in item 34 and the individual name fields stay blank. Where more than one person owns the account, you give the principal joint owner excluding yourself. Item 43 asks for your title with that owner, which is where director, treasurer, designated member or authorised signatory belongs. Part IV is repeated for each owner, so five signatory positions across five UK companies produce five Part IV entries, not one.

What reduced information does Part IV allow?

Two reliefs cut the work down, and both are routinely missed by filers preparing their own late reports. First, if you have signature authority only, with no financial interest, over 25 or more foreign financial accounts, you check yes at item 14b, enter the total number of accounts, and complete only items 34 to 43 of Part IV for each person on whose behalf you hold authority. The account-level detail comes off the form but not off your obligations: FinCEN's instructions require all information omitted from Parts II, III, IV or V to be provided if FinCEN or the IRS asks, and the records must be kept for five years from the April 15 following the year reported.

Second, and specifically useful for US persons living in the United Kingdom, there is a short-form rule for employees. A United States person who resides outside the United States, is an officer or employee of an employer physically located outside the United States, and has signature authority over an account owned or maintained by that employer completes only Part I and items 34 to 43 of Part IV, with Part IV completed once using the employer's information. A US citizen in London who signs on nine of her UK employer's accounts therefore files one Part IV naming the employer, with no maximum values and no account numbers. Note the limits: it covers accounts of your own employer, not a portfolio company, joint venture or charity, and it does not remove the need to report your personal accounts in Part II.

A recordkeeping concession goes with it. An officer or employee who files an FBAR to report signature authority over an employer's foreign financial account is not required to retain records for those accounts personally; that sits with the employer. It is the one respect in which the regime accepts that you do not control the paperwork of an account you do not own.

Who qualifies for the officer or employee exception, and who does not?

There is an exception from reporting signature authority, but it is an exception for financial-sector and US-listed employers rather than for employees generally. The FinCEN instructions and 31 CFR 1010.350 list it as follows, in each case only where the individual has no financial interest in the account.

An officer or employee of a bank examined by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of Thrift Supervision or the National Credit Union Administration, for an account owned or maintained by that bank.
An officer or employee of a financial institution registered with and examined by the Securities and Exchange Commission or the Commodity Futures Trading Commission, for an account owned or maintained by that institution.
An officer or employee of an Authorized Service Provider, for an account owned or maintained by an investment company registered with the Securities and Exchange Commission.
An officer or employee of an entity with a class of equity securities, or American depository receipts, listed on a United States national securities exchange, for a foreign financial account of that entity.
An officer or employee of a United States subsidiary, for an account of that subsidiary, where the United States parent has equity listed on a US national securities exchange and the subsidiary is included in the parent's consolidated FBAR.
An officer or employee of an entity with a class of equity securities registered under section 12(g) of the Securities Exchange Act, for a foreign financial account of that entity.

Read against UK facts, almost nobody in the UK private company world is inside that list. A UK limited company with no US-listed equity is not a described entity, so its directors and finance staff report. An LLP is not a described entity. A charity is not. A UK subsidiary of a US-listed group is not caught by the fourth item, which covers an account of the listed entity itself, nor by the fifth, which is written for a United States subsidiary included in the parent's consolidated report. Even inside a genuine financial institution the exception is account-specific: it covers accounts owned or maintained by the institution, so a fund principal signing on an underlying vehicle's UK account is not automatically relieved.

The same narrowness applies to the deadline deferrals people hear about second-hand. FinCEN has issued a long series of notices postponing the FBAR due date for a defined group of employees and officers of specified regulated entities who have signature authority but no financial interest, pending finalisation of rules proposed in 2016; the notice issued in December 2025 moved that group's date to 15 April 2027. It is relief for the same financial-sector population as the exception above. If you sign on a UK trading company, LLP or club account, your date is the ordinary one: 15 April following the calendar year, with an automatic extension to 15 October that requires no request.

Can you rely on your employer's FBAR filing?

Partly, as an administrative convenience, never as a transfer of liability. FinCEN permits a third party to file on behalf of the person legally obliged to file, and an employer holding documented authority from its employee-signatories on FinCEN Form 114a can sign and submit their FBARs through a single BSA E-Filing institutional account. Form 114a is not sent to FinCEN; it is retained and produced to FinCEN or the IRS on request. What does not move is the obligation. The FBAR remains your report, made under penalties of perjury, and if your employer omits an account, files late or files nothing, the failure is recorded against you.

You are not an employee: a non-executive director, consultant or family office adviser is outside any employer-filing arrangement and outside the employee short-form rule.
The account is not your employer's: portfolio companies, joint ventures, special purpose vehicles and charities each have their own owner and require their own Part IV entry from you.
You joined or resigned mid-year: authority for any part of the calendar year makes the account reportable for that whole year, while employer programmes are built around people on the payroll at filing date.
Your employer files only for its own accounts: your personal UK accounts, and any authority held outside the group, are never inside its submission.
No Form 114a exists for you: without documented authority the employer cannot sign for you, and an unsigned report is not a filed report.
Prior years were never covered: employer programmes almost always start prospectively, so the missed years remain yours to fix.

Worked scenario: a London private equity principal with a missed FBAR

Take a US-citizen partner in a London mid-market private equity firm, UK resident for eleven years, who has always filed his Form 1040 and his UK return and has never filed an FBAR. His personal position looks harmless: a UK current account with a maximum value of $7,900 during the year and a savings account at $1,600, aggregating $9,500 and therefore, he assumed, below the line. Then the mandates. He is a director and named signatory on two portfolio companies whose UK operating accounts peaked at $2.4m and $310,000. He is a member of the firm's LLP with a 12 percent profit share and can instruct its bankers on an account that peaked at $520,000. He is treasurer of his children's cricket club, whose account peaked at $18,000. He is named on his wife's sole-name current account, which peaked at $46,000.

The aggregate is not $9,500. It is $9,500 of personal accounts plus $3,294,000 of accounts he only signs on, and the threshold was crossed on the first day of the year. Seven accounts are reportable. The two personal accounts go in Part II at their own maximum values. Five go in Part IV, each with items 15 to 23 completed and each with its own owner block at items 34 to 42: portfolio company A, portfolio company B, the LLP, the cricket club and his wife. His title at item 43 differs in each: director, director, member, treasurer, authorised signatory. The 25-account short cut at item 14b is unavailable because he has five. The employee short-form rule is unavailable for the portfolio companies and the club because they are not his employer.

Two further points fall out of the facts. His 12 percent LLP profit share is well under the more than 50 percent test, so he has authority rather than a financial interest and the LLP account belongs in Part IV; at 55 percent of profits or capital the same account would move to Part II. And his wife, if she is also a US person, reports her own account as owner in Part II on her own FBAR. The spousal shortcut that lets one spouse file for both cannot be used, because it requires that all accounts the non-filing spouse must report are jointly owned with the filing spouse, and a sole-name account the other merely signs on is not jointly owned. Two separate FBARs are required.

How do you fix missed FBAR years for authority-only accounts?

Start with the two questions that determine the route: were the returns themselves wrong, and is there unreported income. An authority-only account produces no income for you, because you own nothing in it. So in the common case, where the Form 1040 reported everything correctly and the only defect is the unfiled Form 114, there is nothing for a streamlined submission to correct. The IRS position on late FBARs is direct: where it has not contacted you about the delinquent report and you are not under civil or criminal investigation, file the late FBARs electronically as soon as possible. The BSA E-Filing System asks for a reason for filing late, and where the listed options do not fit you select other and give a concise statement of the facts. No penalty is asserted where the failure was not willful, was due to reasonable cause, and the accounts are properly reported on the delinquent filings.

Where the returns are also wrong and a streamlined submission is being made, the FBARs travel inside that package. The Streamlined Foreign Offshore Procedures require delinquent or amended returns for the most recent three years and FBARs for the most recent six years for which the due date has passed, filed through the BSA E-Filing System selecting other and entering Streamlined Filing Compliance Procedures as the reason, with Form 14653 certifying non-willful conduct. Eligibility turns on the non-residency test, which for a US citizen requires that in at least one of the three most recent years for which the return due date has passed he had no US abode and was physically outside the United States for at least 330 full days. Taxpayers who qualify are not subject to FBAR penalties.

Two cautions follow from combining the two. The six FBAR years reach further back than the three return years, so authority-only accounts must be reconstructed for a longer period than the returns; mandates from six years ago are exactly the records nobody keeps, and UK banks will usually produce a historic mandate on request. And the Form 14653 narrative must actually address the authority-only accounts. A certification explaining why a personal savings account was overlooked, silent on the five company mandates that were also unreported, is inconsistent with the FBARs attached to it. Where the streamlined route is unavailable or unnecessary and the FBARs alone are late, filing them on the delinquent basis with a well-evidenced reasonable cause statement is the cleaner and faster answer.

What penalties apply to a missed FBAR where you owned nothing?

The civil framework is in 31 USC 5321(a)(5). For non-willful failures there is a ceiling per violation, with a statutory exception where the failure was due to reasonable cause and the balance in the account was properly reported. For willful failures the measure is the greater of a fixed statutory figure or 50 percent of the balance in the account at the time of the violation, and willful conduct can carry criminal exposure under 31 USC 5322. Do not work from the dollar amounts printed in older articles: civil FBAR penalty maximums in Title 31 are adjusted annually for inflation, with the current figures at 31 CFR 1010.821, so the number applying to your year is not the number in the statute.

Exposure on an authority-only account is easy to underestimate, because the willful measure keys to the balance in the account rather than to your interest in it. Half of a UK operating account that ran at seven figures is a penalty vastly larger than anything the individual ever received from it. That asymmetry is why we treat authority-only omissions as urgent rather than tidy-up work, and why the reasonable cause narrative deserves proper drafting: where there was never any income, never a tax loss and never concealment, non-willfulness is usually demonstrable, but it has to be demonstrated with the mandates, the board minutes and the sequence of events rather than asserted.

How we prepare a missed FBAR covering signature authority

We prepare and file these reports, and the work is inventory and evidence rather than opinion. We begin with a mandate sweep across every UK entity and account you touch, taking bank mandates, board and LLP resolutions and online banking entitlement reports, and we fix the position year by year rather than as at today, because signatories change. Each account is then classified: financial interest into Part II or Part III, authority only into Part IV, with the more than 50 percent tests applied to companies and LLPs so that majority positions are not misfiled as authority. We value each account from the statements at its highest point in the calendar year, convert at the Treasury rate for the last day of that year, and aggregate across all categories to fix which years actually breached $10,000.

We then build the report set: full Part IV entries with owner identification and your correct title at item 43 for each owner, item 14b treatment where you cross 25 authority-only accounts, and the employee short-form treatment where you are a UK-resident employee signing on your own employer's accounts. We prepare the six-year set for a streamlined submission or the delinquent set with a reason for filing late, draft the reasonable cause or Form 14653 narrative so that it is consistent with every account on every report, obtain Form 114a where we file for you, submit through the BSA E-Filing System, and hand over the acknowledgements and the five-year record file. Where mandates remain in place we build the annual FBAR into your ongoing compliance, so the same accounts are reported the same way every year and the question is asked of you before the deadline rather than after it.