Is there an IRS program called the 'foreign disclosure program'?

No. The IRS publishes several offshore compliance routes — the Streamlined Filing Compliance Procedures (foreign and domestic), the delinquent international information return procedures and the Criminal Investigation Voluntary Disclosure Practice, and late FBARs are filed with FinCEN with a reasonable-cause statement (the IRS withdrew its published Delinquent FBAR Submission Procedures on July 1, 2026) — but none is called the foreign disclosure program. People searching that phrase are usually looking for the Streamlined Foreign Offshore Procedures.

Is the 'streamlined foreign disclosure program' the same as the Streamlined Foreign Offshore Procedures?

In practice, yes — the search phrase is a lay name for the IRS's Streamlined Foreign Offshore Procedures, the route for non-willful taxpayers outside the United States who need to file or amend three years of returns and six years of FBARs with a Form 14653 certification.

Did the Offshore Voluntary Disclosure Program end?

Yes. The 2014 OVDP closed on September 28, 2018. It was the route for potentially willful conduct and was replaced by the IRS Criminal Investigation Voluntary Disclosure Practice. The Streamlined procedures for non-willful taxpayers were kept open by the same announcement and remain published as of September 17, 2026.

Which route applies if I only missed FBARs?

If your returns reported the income from the accounts and the tax was paid, you file the missed FBARs with FinCEN with the reason and a reasonable-cause statement — the IRS withdrew its published Delinquent FBAR Submission Procedures, and their printed no-penalty assurance, on July 1, 2026; the filing and the IRM 4.26.16 examiner standard are unchanged. If those accounts also produced income that was never reported, the question is a Streamlined one. The FBAR threshold is $10,000 in combined non-US accounts at any point in the year.

Can this page tell me whether I qualify?

No, and it does not try to. It sorts your situation into the IRS route the facts point at and hands you to the page or tool that asks the published criteria — residency, non-willfulness, examination status, a valid TIN. Eligibility is fact-specific and, for Streamlined, certified by you under penalties of perjury.

Offshore compliance · which route

Looking for the IRS ‘foreign disclosure program’? It is one of five routes.

There is no IRS programme by that name. The phrase usually means the Streamlined Filing Compliance Procedures — most often the foreign version, for non-willful taxpayers abroad — but depending on your facts it can mean the delinquent FBAR route, the late information-return route, or the voluntary disclosure practice for willful conduct. Two questions below sort which.

Most often meant: Streamlined Foreign Offshore
Routes checked: September 17, 2026
Verified against: IRS Streamlined, delinquent-FBAR and voluntary-disclosure pages

Sort my situation Check the Streamlined criteria

Which route is yours

Two questions, one direction.

Each answer routes to the Atamatax page or free tool that asks the published criteria for that route. Nothing here decides eligibility — it tells you which door to read.

1. Which of these is closest to your situation?

Pick the one that fits best. If several apply, pick the one about the years or the returns first.

I never filed US tax returnsOr not for many years — and nothing was reported.I filed returns but missed foreign accounts or incomeThe returns went in; the foreign side did not.I only missed FBARsIncome was reported and tax paid; the FinCEN report was not filed.I'm not sure my conduct was non-willfulYou knew something was owed, or you are not sure what you knew.I own a foreign companyA non-US corporation, partnership or one-person entity.I hold foreign ETFs or fundsUCITS, a local index fund, a savings product that holds a fund.I received a foreign inheritance or giftFrom a non-US person or estate, or via a foreign trust.I'm not sure which of these is meSeveral apply, or none clearly does.

The routes behind the phrase

Five published routes, one that closed.

The programme most people remember — the Offshore Voluntary Disclosure Program — closed on September 28, 2018. Everything below is currently published by the IRS, as checked on September 17, 2026; the current-status page keeps that date.

IRS offshore compliance routes compared
Route	Who it is for	What is filed	Penalty
Streamlined Foreign Offshore Procedures	Non-willful taxpayers who meet the non-residency test in at least one of the three return years.	3 return years · 6 FBAR years · Form 14653 · tax + interest	None on an eligible, complete submission
Streamlined Domestic Offshore Procedures	Non-willful taxpayers who filed a return for each of the three years but do not meet the non-residency test.	3 return years · 6 FBAR years · Form 14654 · tax + interest	5% miscellaneous offshore penalty
Late FBAR filing with a reasonable-cause statement	Income reported and tax paid; only the FBARs were missed. The IRS withdrew the published "Delinquent FBAR Submission Procedures" page on July 1, 2026; the filing is unchanged.	The missed FBARs, filed with FinCEN with the reason and a reasonable-cause statement	Discretionary; IRM 4.26.16 directs none where non-willful, reasonable cause, properly reported
Delinquent international information return procedures	Returns filed; an information return (Forms 3520, 5471, 8865, 8858…) was not.	The late form with a reasonable-cause statement	Assessed unless reasonable cause is accepted
IRS Criminal Investigation Voluntary Disclosure Practice	Taxpayers whose conduct may have been willful, coming forward before the IRS contacts them.	Form 14457 preclearance, then a full disclosure	Civil penalties apply; the aim is to avoid criminal referral

Why the name is fuzzy

Disclosure, catch-up and compliance are three different words for one decision.

“Disclosure” is the older word: the Offshore Voluntary Disclosure Program ran from 2009 to 2018 and is what most articles from that era describe. “Streamlined” is the procedure that replaced it for the far larger group whose failure was an honest one, and “catch-up” is what preparers call the same work. A reader who arrived from any of those words is usually asking one question: which published route fits my facts, and what does it require.

The facts that decide it are few. Whether returns were filed at all. Whether the missed piece was income, an account report or an information return. Whether you meet the foreign procedure’s non-residency test in any of the three years. Whether you can honestly call the failure non-willful. And whether the IRS has already opened an examination — which closes the Streamlined door regardless of everything else.

Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.

The five routes

Once the route is named:

How does the Streamlined route work?
Eligibility, scope, the three tiers and where to start.
Is the procedure ending?
What the IRS has actually published, and when we last checked.
Do I only have missing FBARs?
Returns filed but FBARs missed is a different, lighter procedure than Streamlined.
Do foreign ETFs or funds change the case?
A non-US fund adds a Form 8621 to every open year — the count decides the tier.
Check my catch-up path
Eight questions on the published gates, free, no account.

From where you live

Can I still use Streamlined if I live in the Netherlands, Germany or Spain?

Yes, in principle: the foreign procedure is written for taxpayers residing outside the United States, and the country is not one of its gates. What the country changes is the content of the submission — which local accounts count toward the FBAR, and which local investment wrapper adds a Form 8621 to every open year. Each desk below states that in one sentence and continues into the catch-up route for that country.

Streamlined from the Netherlands
Dutch bank, savings and brokerage accounts count toward the FBAR aggregate whatever Box 3 already taxed, and a Dutch or UCITS fund adds a Form 8621 to every open year — which is usually what turns a simple catch-up into a tiered one.
Streamlined from Germany
A Girokonto, Tagesgeld, Depot and most Bausparverträge count toward the FBAR aggregate, and the Abgeltungsteuer already withheld satisfies nothing on the US side; an ETF-Sparplan adds a Form 8621 to every open year.
Streamlined from Spain
Spanish bank and brokerage accounts count toward the FBAR aggregate and a Modelo 720 filing does not satisfy it; a fondo de inversión or a Spanish-listed UCITS ETF adds a Form 8621 to every open year.
Streamlined from France
French current accounts, the livrets, a PEA and an assurance-vie (a cash-value contract is an FBAR account) all count toward the FBAR aggregate; the funds inside a PEA or an assurance-vie are commonly PFICs, which adds a Form 8621 to every open year.
Streamlined from Switzerland
Swiss bank, PostFinance and pillar 3a accounts count toward the FBAR aggregate, and a fund-based pillar 3a or a UCITS ETF adds a Form 8621 to every open year — the count of funds, not the size of the balance, is what sets the tier.
Streamlined from the United Kingdom
UK current and savings accounts, cash and stocks-and-shares ISAs, a SIPP and an app account held by a non-US entity all count toward the FBAR aggregate; the funds inside a stocks-and-shares ISA are commonly PFICs, which adds a Form 8621 to every open year.
Streamlined from Canada
Canadian bank accounts, a TFSA, an RRSP, an RESP and a RRIF are all foreign financial accounts for the FBAR even when their income is deferred; a Canadian mutual fund or ETF held outside an RRSP adds a Form 8621 to every open year.
Streamlined from Italy
Italian conti correnti, deposito titoli and Poste Italiane accounts count toward the FBAR aggregate and a Quadro RW filing does not replace it; fondi comuni and the UCITS ETFs on Borsa Italiana are commonly PFICs, which adds a Form 8621 to every open year.

Living somewhere else? The procedure is the same; the country desks cover the local products, and the eligibility check does not ask where.

FAQ

Foreign disclosure program questions

Is there an IRS program called the 'foreign disclosure program'?: No. The IRS publishes several offshore compliance routes — the Streamlined Filing Compliance Procedures (foreign and domestic), the delinquent international information return procedures and the Criminal Investigation Voluntary Disclosure Practice, and late FBARs are filed with FinCEN with a reasonable-cause statement (the IRS withdrew its published Delinquent FBAR Submission Procedures on July 1, 2026) — but none is called the foreign disclosure program. People searching that phrase are usually looking for the Streamlined Foreign Offshore Procedures.
Is the 'streamlined foreign disclosure program' the same as the Streamlined Foreign Offshore Procedures?: In practice, yes — the search phrase is a lay name for the IRS's Streamlined Foreign Offshore Procedures, the route for non-willful taxpayers outside the United States who need to file or amend three years of returns and six years of FBARs with a Form 14653 certification.
Did the Offshore Voluntary Disclosure Program end?: Yes. The 2014 OVDP closed on September 28, 2018. It was the route for potentially willful conduct and was replaced by the IRS Criminal Investigation Voluntary Disclosure Practice. The Streamlined procedures for non-willful taxpayers were kept open by the same announcement and remain published as of September 17, 2026.
Which route applies if I only missed FBARs?: If your returns reported the income from the accounts and the tax was paid, you file the missed FBARs with FinCEN with the reason and a reasonable-cause statement — the IRS withdrew its published Delinquent FBAR Submission Procedures, and their printed no-penalty assurance, on July 1, 2026; the filing and the IRM 4.26.16 examiner standard are unchanged. If those accounts also produced income that was never reported, the question is a Streamlined one. The FBAR threshold is $10,000 in combined non-US accounts at any point in the year.
Can this page tell me whether I qualify?: No, and it does not try to. It sorts your situation into the IRS route the facts point at and hands you to the page or tool that asks the published criteria — residency, non-willfulness, examination status, a valid TIN. Eligibility is fact-specific and, for Streamlined, certified by you under penalties of perjury.

Authorities cited

IRS Streamlined Filing Compliance Procedures — Streamlined filing compliance procedures — eligibility, including that a taxpayer under a civil examination for any year is not eligible
IRS Streamlined Foreign Offshore Procedures — U.S. Taxpayers Residing Outside the United States — Streamlined Foreign Offshore Procedures
IRS Delinquent FBAR Submission Procedures (withdrawn 1 July 2026) — Delinquent FBAR Submission Procedures — the IRS page removed on 1 July 2026 (archived copy, last reviewed by the IRS 19 Feb 2026)
IRS Delinquent International Information Return Procedures — Delinquent International Information Return Submission Procedures — reasonable-cause statement route for late information returns
IRS Criminal Investigation Voluntary Disclosure Practice — IRS Criminal Investigation Voluntary Disclosure Practice — the route for taxpayers whose conduct was willful (Form 14457)
IRS IR-2018-52 — IRS to end Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018 — Streamlined Filing Compliance Procedures remain available
IRS Form 14653 — About Form 14653 — Certification by U.S. Person Residing Outside of the United States (Streamlined Foreign Offshore)

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

Free preliminary result · a few questions

Build your catch-up filing map

Knowing which route the phrase means is not the same as knowing which years and forms are yours. A few questions show which filings your own situation points at and what would settle the parts still open.

Answer a few questions about the years you missed and what you hold abroad. See which filings may apply, whether the Streamlined route looks consistent with your facts, and what to gather first.

Build my catch-up filing mapNo signup. Answers stay yours.