What replaced the delinquent FBAR submission procedures?
Nothing formally replaced the published procedure after the IRS removed it on July 1, 2026. Late FBARs can still be filed through FinCEN. The statutory reasonable-cause exception also remains: no non-willful penalty shall be imposed when reasonable cause and proper reporting of the account balance are established.
What survived the withdrawal
Two things. The BSA E-Filing system still accepts late FBARs with a reason for filing late, including a free-text explanation capped at 750 characters. And the Internal Revenue Manual still directs examiners not to assert a penalty where the failure was non-willful, due to reasonable cause, and the account was properly reported on the late FBAR (IRM 4.26.16.3.11, carried forward verbatim in the manual's August 26, 2025 retransmittal).
What actually changed
The published procedure is gone, but the statute was not withdrawn. Whether a taxpayer establishes reasonable cause is a facts-and-circumstances determination; once the statutory conditions are established, the command that no penalty be imposed is mandatory. When returns are also behind, Streamlined remains a published option for taxpayers who satisfy all of its requirements.
Reference information, not legal or tax advice. Figures come from our verified fact base and are checked against superseded values on every site update.