Form 8966 at a glance
March 31due date in the year after the calendar year reported
90 daysautomatic extension with Form 8809-I; a second 90 days for hardship
Any numbera financial institution must e-file, however few reports it files
11filer category codes for Part I, line 1b
5 partseach filer completes only the parts the chart assigns
45 daysbefore the due date to request an e-file waiver on Form 8508-I
Line Identifier: Three-digit identifier (paper filers only)A unique numeric number of exactly three digits for each original paper Form 8966 filed for the year, such as 001. An amended, corrected or voided paper report uses the number of the original.Click to open the row in the table belowLine Checkboxes: Corrected, Amended, Voided report; No accounts to reportCorrected answers an IRS notification. Amended fixes an error the IRS has not contacted you about. Voided marks a copy of the original filed with an amended report. No accounts is used by a Direct Reporting NFFE (or its Sponsoring Entity) with no substantial U.S. owners, which completes Part I only; it is optional for others.Click to open the row in the table belowPart I: Identification of FilerAll filers complete lines 1a through 3c. Lines 4 through 10 follow the line instructions.Click to open the row in the table belowPart I, 1a: Name of filerA Direct Reporting NFFE, Sponsoring Entity or trustee identifies itself here as the filer.Click to open the row in the table belowPart I, 1b: Filer categoryEnter one code: 01 PFFI, 02 RDCFFI, 03 limited branch or limited FFI, 04 Reporting Model 2 FFI, 05 QI, WP or WT, 06 Direct Reporting NFFE, 07 Sponsoring Entity of a Sponsored FFI, 08 Sponsoring Entity of a Sponsored Direct Reporting NFFE, 09 trustee of a Trustee-Documented Trust, 10 withholding agent, 11 Territory Financial Institution treated as a U.S. person.Click to open the row in the table belowPart I, 2 to 3c: Filer's mailing addressInclude country and postal code. A PFFI gives the address of the branch that maintains the account. Use a P.O. box only if mail is not delivered to a street address.Click to open the row in the table belowPart I, 4: GIINUse the GIIN of the branch that maintains the account, if applicable. A Sponsoring Entity or trustee enters its Sponsoring Entity or trustee GIIN.Click to open the row in the table belowPart I, 5: TINEnter a U.S. TIN only if no GIIN is on line 4, except a QI, WP or WT enters its QI, WP or WT EIN in addition to the GIIN. “Do not enter a foreign TIN.” Leave blank if the filer has no U.S. TIN.Click to open the row in the table belowPart I, 6: Name of sponsored entity or intermediaryOnly for a Sponsoring Entity, a trustee, or a filer paying a Territory Financial Institution or a certified deemed-compliant FFI acting as an intermediary.Click to open the row in the table belowPart I, 7 to 8c: Address of that entitySame rules as lines 2 to 3c.Click to open the row in the table belowPart I, 9: GIIN of that entityThe sponsored entity's GIIN for a Sponsored FFI (other than a sponsored, closely held investment vehicle) or Sponsored Direct Reporting NFFE. Never the Sponsoring Entity's or trustee's GIIN, which goes on line 4.Click to open the row in the table belowPart I, 10: TIN of that entityOnly if no GIIN is on line 9. A Territory Financial Institution with no IRS TIN reports the EIN its territory assigned.Click to open the row in the table belowPart II: Account Holder or Payee InformationNot completed by a Direct Reporting NFFE or its Sponsoring Entity. Each holder of a jointly held account that is a specified U.S. person goes on a separate Form 8966.Click to open the row in the table belowPart II, 1a: Name of account holder or payeeThe specified U.S. person, passive NFFE or ODFFI.Click to open the row in the table belowPart II, 1b: Individual or entityCheck one box.Click to open the row in the table belowPart II, 2 to 3c: Residence addressIf a residence address cannot be reported, use the mailing address the FFI or withholding agent uses. For a U.S. address, enter only the 9-digit ZIP code (ZIP + 4) on line 3c.Click to open the row in the table belowPart II, 4: TINEnter the account holder's or payee's TIN if one has been assigned; otherwise leave blank.Click to open the row in the table belowPart II, 5: Entity typeOwner-Documented FFI with specified U.S. owner(s), Passive NFFE with substantial U.S. owner(s), Non-Participating FFI, or Specified U.S. Person. PFFIs, including Reporting Model 2 FFIs, should not check Non-Participating FFI.Click to open the row in the table belowPart III: Owner InformationFile a separate report for each U.S. owner that is a specified U.S. person: substantial U.S. owners of a passive NFFE or Direct Reporting NFFE, and specified U.S. persons holding certain interests in an ODFFI.Click to open the row in the table belowPart III, 1: Name of ownerThe U.S. owner's name.Click to open the row in the table belowPart III, 2 to 3c: Owner's residence addressFor a U.S. address, enter only the 9-digit ZIP code (ZIP + 4) on line 3c.Click to open the row in the table belowPart III, 4: TIN of ownerSSN, ITIN or EIN of the U.S. owner.Click to open the row in the table belowPart IV: Financial InformationRules differ for PFFI filers, withholding agents, and Direct Reporting NFFEs.Click to open the row in the table belowPart IV, 1: Account numberThe number the PFFI uses for the account, or a unique serial number. Enter NANUM if there is no account numbering system, if a withholding agent's payment is not made to an account, or if the filer is a Direct Reporting NFFE.Click to open the row in the table belowPart IV, 2: Currency codeA valid three-character ISO 4217 code for the amounts on lines 3a and 4a to 4d; USD if reported in U.S. dollars.Click to open the row in the table belowPart IV, 3a: Account balanceAverage calendar year balance or value if reported to the account holder, otherwise year-end balance. A withholding agent enters 0 for a passive NFFE or a payment not made to an account. A Direct Reporting NFFE enters the value of the owner's equity interest.Click to open the row in the table belowPart IV, 3b: Account closed during the yearCheck if the account was closed or transferred in its entirety. Not checked for a rollover within the same FFI. Withholding agents and Direct Reporting NFFEs do not check it.Click to open the row in the table belowPart IV, 4a: InterestAggregate gross interest paid or credited for the year (for a withholding agent, interest that is a withholdable payment).Click to open the row in the table belowPart IV, 4b: DividendsAggregate gross dividends paid or credited for the year.Click to open the row in the table belowPart IV, 4c: Gross proceeds/RedemptionsAggregate gross proceeds from sale or redemption of property paid or credited.Click to open the row in the table belowPart IV, 4d: OtherAll other income, reduced by amounts on 4a to 4c. Certain debt or equity interests, cash value insurance and annuity contracts, and partnership interests are reported here only, with nothing on 4a to 4c.Click to open the row in the table belowHover over a line for what goes on it; click to open its row in the table below. On a touch screen, tap the line to jump to the row.
Part V: Pooled Reporting TypeFor PFFIs reporting recalcitrant account holders (or, for a Reporting Model 2 FFI, non-consenting U.S. accounts) on an aggregate basis. A separate Form 8966 for each pool type. Direct Reporting NFFEs do not complete Part V.Click to open the row in the table belowPart V, 1: Pooled reporting typeCheck one: recalcitrant account holders with U.S. indicia, dormant accounts, recalcitrant account holders that are U.S. persons, without U.S. indicia, or that are passive NFFEs. PFFIs should not check Non-Participating FFI.Click to open the row in the table belowPart V, 2: Number of accountsTotal number of accounts in the pool.Click to open the row in the table belowPart V, 3: Aggregate payment amountDo not complete this line.Click to open the row in the table belowPart V, 4: Aggregate account balanceAggregate balance or value of the pooled accounts at the end of the year.Click to open the row in the table belowPart V, 5: Currency codeISO 4217 code for the amounts on Part V; USD if in U.S. dollars.Click to open the row in the table belowIn this guide
Who files Form 8966
The 2025 instructions list these filers: a participating FFI (PFFI), a U.S. branch of an FFI not treated as a U.S. person, a registered deemed-compliant FFI (RDCFFI), a related entity or branch described in a Model 2 IGA, a Reporting Model 2 FFI, a QI, WP or WT, a Direct Reporting NFFE, a Sponsoring Entity, a trustee of a Trustee-Documented Trust, a U.S. branch treated as a U.S. person, and a Territory Financial Institution treated as a U.S. person.
U.S. withholding agents file too. A withholding agent that is not an FFI and makes a withholdable payment to a passive NFFE with a substantial U.S. owner, or a designated withholding agent paying an owner-documented FFI (ODFFI) with a specified U.S. owner, must report those owners on Form 8966. The owner information usually comes from the payee's Form W-8BEN-E. A withholding agent is not required to report a payment to a PFFI or RDCFFI that is allocated to such a payee on an FFI withholding statement with the required certification, unless it knows or has reason to know the certification is incorrect or unreliable.
Some FFIs do not file. “Reporting Model 1 FFIs do not file Form 8966 directly to the IRS.” They report to their own tax authority under the IGA. Sponsored FFIs and Sponsored Direct Reporting NFFEs do not file if a Sponsoring Entity reports for them. A U.S. payor reporting payments to U.S. non-exempt recipients on Form 1099 does not need Form 8966 for those payments.
The form reports accounts and owners, not tax. “Form 8966 is not used to report any tax withheld under chapter 4 to the IRS.” Withholding goes on Form 1042 and Form 1042-S.
Line by line
| Line | What it is | Notes |
|---|---|---|
| Identifier | Three-digit identifier (paper filers only) | A unique numeric number of exactly three digits for each original paper Form 8966 filed for the year, such as 001. An amended, corrected or voided paper report uses the number of the original. |
| Checkboxes | Corrected, Amended, Voided report; No accounts to report | Corrected answers an IRS notification. Amended fixes an error the IRS has not contacted you about. Voided marks a copy of the original filed with an amended report. No accounts is used by a Direct Reporting NFFE (or its Sponsoring Entity) with no substantial U.S. owners, which completes Part I only; it is optional for others. |
| Part I | Identification of Filer | All filers complete lines 1a through 3c. Lines 4 through 10 follow the line instructions. |
| Part I1a | Name of filer | A Direct Reporting NFFE, Sponsoring Entity or trustee identifies itself here as the filer. |
| Part I1b | Filer category | Enter one code: 01 PFFI, 02 RDCFFI, 03 limited branch or limited FFI, 04 Reporting Model 2 FFI, 05 QI, WP or WT, 06 Direct Reporting NFFE, 07 Sponsoring Entity of a Sponsored FFI, 08 Sponsoring Entity of a Sponsored Direct Reporting NFFE, 09 trustee of a Trustee-Documented Trust, 10 withholding agent, 11 Territory Financial Institution treated as a U.S. person. |
| Part I2to3c | Filer's mailing address | Include country and postal code. A PFFI gives the address of the branch that maintains the account. Use a P.O. box only if mail is not delivered to a street address. |
| Part I4 | GIIN | Use the GIIN of the branch that maintains the account, if applicable. A Sponsoring Entity or trustee enters its Sponsoring Entity or trustee GIIN. |
| Part I5 | TIN | Enter a U.S. TIN only if no GIIN is on line 4, except a QI, WP or WT enters its QI, WP or WT EIN in addition to the GIIN. “Do not enter a foreign TIN.” Leave blank if the filer has no U.S. TIN. |
| Part I6 | Name of sponsored entity or intermediary | Only for a Sponsoring Entity, a trustee, or a filer paying a Territory Financial Institution or a certified deemed-compliant FFI acting as an intermediary. |
| Part I7to8c | Address of that entity | Same rules as lines 2 to 3c. |
| Part I9 | GIIN of that entity | The sponsored entity's GIIN for a Sponsored FFI (other than a sponsored, closely held investment vehicle) or Sponsored Direct Reporting NFFE. Never the Sponsoring Entity's or trustee's GIIN, which goes on line 4. |
| Part I10 | TIN of that entity | Only if no GIIN is on line 9. A Territory Financial Institution with no IRS TIN reports the EIN its territory assigned. |
| Part II | Account Holder or Payee Information | Not completed by a Direct Reporting NFFE or its Sponsoring Entity. Each holder of a jointly held account that is a specified U.S. person goes on a separate Form 8966. |
| Part II1a | Name of account holder or payee | The specified U.S. person, passive NFFE or ODFFI. |
| Part II1b | Individual or entity | Checkbox |
| Part II2to3c | Residence address | If a residence address cannot be reported, use the mailing address the FFI or withholding agent uses. For a U.S. address, enter only the 9-digit ZIP code (ZIP + 4) on line 3c. |
| Part II4 | TIN | Enter the account holder's or payee's TIN if one has been assigned; otherwise leave blank. |
| Part II5 | Entity type | Owner-Documented FFI with specified U.S. owner(s), Passive NFFE with substantial U.S. owner(s), Non-Participating FFI, or Specified U.S. Person. PFFIs, including Reporting Model 2 FFIs, should not check Non-Participating FFI. |
| Part III | Owner Information | File a separate report for each U.S. owner that is a specified U.S. person: substantial U.S. owners of a passive NFFE or Direct Reporting NFFE, and specified U.S. persons holding certain interests in an ODFFI. |
| Part III1 | Name of owner | The U.S. owner's name. |
| Part III2to3c | Owner's residence address | For a U.S. address, enter only the 9-digit ZIP code (ZIP + 4) on line 3c. |
| Part III4 | TIN of owner | SSN, ITIN or EIN of the U.S. owner. |
| Part IV | Financial Information | Rules differ for PFFI filers, withholding agents, and Direct Reporting NFFEs. |
| Part IV1 | Account number | The number the PFFI uses for the account, or a unique serial number. Enter NANUM if there is no account numbering system, if a withholding agent's payment is not made to an account, or if the filer is a Direct Reporting NFFE. |
| Part IV2 | Currency code | A valid three-character ISO 4217 code for the amounts on lines 3a and 4a to 4d; USD if reported in U.S. dollars. |
| Part IV3a | Account balance | Average calendar year balance or value if reported to the account holder, otherwise year-end balance. A withholding agent enters 0 for a passive NFFE or a payment not made to an account. A Direct Reporting NFFE enters the value of the owner's equity interest. |
| Part IV3b | Account closed during the year | CheckboxCheck if the account was closed or transferred in its entirety. Not checked for a rollover within the same FFI. Withholding agents and Direct Reporting NFFEs do not check it. |
| Part IV4a | Interest | Aggregate gross interest paid or credited for the year (for a withholding agent, interest that is a withholdable payment). |
| Part IV4b | Dividends | Aggregate gross dividends paid or credited for the year. |
| Part IV4c | Gross proceeds/Redemptions | Aggregate gross proceeds from sale or redemption of property paid or credited. |
| Part IV4d | Other | All other income, reduced by amounts on 4a to 4c. Certain debt or equity interests, cash value insurance and annuity contracts, and partnership interests are reported here only, with nothing on 4a to 4c. |
| Part V | Pooled Reporting Type | For PFFIs reporting recalcitrant account holders (or, for a Reporting Model 2 FFI, non-consenting U.S. accounts) on an aggregate basis. A separate Form 8966 for each pool type. Direct Reporting NFFEs do not complete Part V. |
| Part V1 | Pooled reporting type | Check one: recalcitrant account holders with U.S. indicia, dormant accounts, recalcitrant account holders that are U.S. persons, without U.S. indicia, or that are passive NFFEs. PFFIs should not check Non-Participating FFI. |
| Part V2 | Number of accounts | Total number of accounts in the pool. |
| Part V3 | Aggregate payment amount | Do not complete this line. |
| Part V4 | Aggregate account balance | Aggregate balance or value of the pooled accounts at the end of the year. |
| Part V5 | Currency code | ISO 4217 code for the amounts on Part V; USD if in U.S. dollars. |
Due dates
| What | Due | Notes |
|---|---|---|
| Form 8966 for calendar year 2026 | March 31, 2027 | The rule is March 31 of the year after the calendar year reported; a weekend or U.S. legal holiday moves it to the next business day. A Reporting Model 2 FFI uses the same date unless its IGA sets another. The 2026 instructions have not been issued. |
| Automatic extension | By the Form 8966 due date | Form 8809-I gives an automatic 90-day extension. Each branch requesting an extension files a separate Form 8809-I. |
| Additional hardship extension | Before the end of the first extended due date | A second Form 8809-I can request another 90 days under hardship conditions (Treas. Reg. 1.1471-4(d)(3)(vii))Treas. Reg. 1.1471-4Treasury regulations, Cornell LII. |
| Model 2 non-consenting U.S. accounts | Date set by the Model 2 IGA | “No extension of time to file is permitted for Forms 8966 filed by a Reporting Model 2 FFI to report a non-consenting U.S. account.” |
| E-file waiver request | At least 45 days before the due date | Submit Form 8508-I. |
Penalties
The 2025 instructions do not set out a dollar penalty table for Form 8966. They do state that a filer required to file electronically that fails to do so, without an approved waiver on record, may be subject to penalties under sections 6721 through 6724.
Form 8966 carries no tax, but chapter 4 does. A withholding agent is generally required to withhold 30% of a withholdable payment to a passive NFFE unless the NFFE certifies it has no substantial U.S. owners or identifies them, and that withholding is reported on Forms 1042 and 1042-S, where their own penalties apply.
Corrections
Submit the change on the Form 8966 for the year of the original report.
- Corrected report. Use it when the IRS has notified you of an error. Complete the form as if it were the original and check Corrected report. You do not include a voided copy.
- Amended report. Use it when you find the error yourself and the IRS has not contacted you. Complete the form as if it were the original, check Amended report, and file it with a copy of the original updated by checking Voided report.
- Same channel as the original. A report filed electronically is corrected or amended electronically, and a paper report on paper. “Failure to follow this rule will result in your corrected Form 8966 not being processed by the IRS.”
- Paper identifier. An amended, corrected or voided paper report carries the three-digit identifier of the original.
Where it goes wrong
- Filing on paper as a financial institution. “An entity that is a financial institution is required to file Form 8966 electronically, irrespective of the number of Forms 8966 filed.” Pub. 5124 explains the electronic fields, and Pubs. 5190 and 5188 explain how to submit.
- One report for several owners. A separate Form 8966 is required for each substantial U.S. owner of a passive NFFE, each specified U.S. person with certain interests in an ODFFI, each U.S. holder of a joint account, and each pool type.
- Wrong identifier on line 4 or 5. A GIIN on line 4 means line 5 is left blank, except a QI, WP or WT, which also enters its QI, WP or WT EIN. A foreign TIN is never entered on line 5.
- PFFIs checking Non-Participating FFI. PFFIs, including Reporting Model 2 FFIs, should not check it on Part II line 5 or Part V line 1, and should not complete Part V line 3.
- Wrong code for a U.S. branch. A U.S. branch of an FFI not treated as a U.S. person uses code 01. A U.S. branch treated as a U.S. person uses code 10.
- Reporting a rollover as a closed account. If the holder rolls one account into another at the same FFI during the year, do not report the account twice and do not check line 3b.
- Expecting Form 8966 to report the tax. Chapter 4 withholding goes on Forms 1042 and 1042-S.
Questions people ask about Form 8966
We are a U.S. company, not a bank. Can we owe a Form 8966?
Yes. A withholding agent that is not an FFI files Form 8966 when it makes a withholdable payment to a passive NFFE with a substantial U.S. owner, reporting that owner. It uses filer code 10 and completes Parts I, II, III and IV.
Does Form 8966 report the tax we withheld under FATCA?
No. The instructions say the form is not used to report any chapter 4 tax withheld. That goes on Forms 1042 and 1042-S.
Does a Model 1 IGA bank file Form 8966 with the IRS?
No. Reporting Model 1 FFIs report to their own tax authority under the IGA, not on Form 8966 directly to the IRS. Reporting Model 2 FFIs file Form 8966 directly.
Can we file Form 8966 on paper?
Only if you are not a financial institution or you have a waiver approved on Form 8508-I. Paper reports go with Form 8966-C, Cover Sheet for Form 8966 Paper Submissions, to IRS, FATCA, Stop 6052 AUSC, 3651 South IH 35, Austin, Texas 78741, and each needs a three-digit identifier.
How long can we extend the due date?
Form 8809-I gives an automatic 90 days past March 31. A second Form 8809-I, filed before the first extension runs out, can request another 90 days under hardship conditions.
Other employer, withholding and ACA forms
Payroll and employment tax returns: W-4 · 941 · 941-X · 944 · 943 · 940 · W-2 · W-3 · W-2c · 8027
Withholding returns: 945
Foreign withholding and FATCA returns: 1042 · 1042-T · 8804 · 8805 · 8813 · 8288 · 8288-A
Health coverage (ACA) returns: 1095-C · 1094-C · 1095-B · 1094-B
Paper transmittal: 1096
These forms on the comparison table · Information returns (1099 series)
Sources: Form 8966 (2025, Created 4/30/25); Instructions for Form 8966 (2025, Apr. 16, 2025); IRS.gov About Form 8966 (current revisions).