Exhibit 8.1

[Letterhead of Brooks, Pierce, McLendon, Humphrey & Leonard, L.L.P.]

October 7, 2026

The Board of Directors of

First Bancorp

205 SE Broad Street

Southern Pines, NC 28387

The Board of Directors of

First Carolina Bancshares Corporation

185 West Evans Street

Florence, SC 29501

Ladies and Gentlemen:

We have served as counsel to First Bancorp in connection with the Agreement, pursuant to which it is contemplated that First Carolina will, subject to the terms and conditions set forth therein, merge with and into First Bancorp (the “Merger”), so that First Bancorp is the surviving corporation in the Merger, as more fully described in the Proxy Statement/Prospectus, which constitutes a part of the Registration Statement on Form S-4 (File No. 333-299108) filed by First Bancorp with the Securities and Exchange Commission, as amended or supplemented through the date hereof (the “Registration Statement”). The opinion set forth herein concerning Federal income tax consequences is being rendered at your request pursuant to Section 8.1(g) of the Agreement, and in connection with the Registration Statement. All capitalized terms herein, unless otherwise specified, have the meanings assigned to them in the Registration Statement and the Agreement.

At the Effective Time, subject to the terms of the Agreement, all of the shares of common stock, no par value per share, of First Carolina (“First Carolina Common Stock”) will be converted into the right to receive (i) 14.5340 shares (which we refer to as the “exchange ratio”) of First Bancorp’s common stock, no par value per share (“First Bancorp Common Stock”) and (ii) cash in the amount of $294.94, less any applicable withholding. In addition, cash will be paid in lieu of fractional shares of First Bancorp Common Stock.

In providing our opinion, we have examined and, with your permission, have relied on the representations and warranties contained in and the facts described in (i) the Agreement, (ii) the Registration Statement, (iii) certain written representations and covenants of First Carolina and First Bancorp (the “Company Certificates”), and (iv) such other records, documents, and other instruments as we have deemed appropriate for the purposes of this letter.

October 7, 2026

Page 2

In rendering our opinion, we have also relied, with your consent, upon the following assumptions:

In rendering our opinion, with your permission, we have not undertaken any independent investigation or verification of any fact or matter set forth in any document or materials or any assumption upon which we have relied (including, without limitation, any statement or representation contained in the Company Certificates), and we expressly disclaim any intent, undertaking, or obligation to make any such investigation or verification. In the course of preparing our opinion, nothing has come to our attention that would lead us to believe that any of the information upon which we have relied in rendering our opinion is incorrect.

Based on and subject to the foregoing and the other limitations, assumptions, qualifications and exclusions set forth in this letter, we are of the opinion that (i) the Merger will be treated for Federal income tax purposes as a reorganization within the meaning of Section 368(a) of the Code, (ii) First Bancorp and First Carolina will each be a party to that reorganization within the meaning of Section 368(b) of the Code, and (iii) that the U.S. Federal income tax consequences of the Merger to certain U.S. holders of First Carolina Common Stock will be as described in the Registration Statement under the heading “U.S. Federal Income Tax Consequences of the Merger and Opinion of Tax Counsel.”

October 7, 2026

Page 3

Except as set forth above, we express no opinion as to the tax consequences to any party, whether Federal, state, local, or foreign, of the Merger or of any transactions related to the Merger or contemplated by the Agreement.

The foregoing opinion is being furnished solely for the purpose referred to in the first paragraph of this letter. The opinion set forth herein is made as of the date hereof, and we assume no obligation to supplement this letter if any applicable laws change after the date hereof or if we become aware after the date hereof of any facts that might change the opinion expressed herein.

The foregoing opinion is effective as of the date hereof; it is based on current provisions of the Code and Treasury regulations promulgated thereunder, pertinent judicial authorities, published rulings and other administrative pronouncements of the Internal Revenue Service (the “IRS”), and such other authorities as we have considered relevant. It should be noted that statutes, regulations, judicial decisions, and administrative pronouncements are subject to change at any time, and, in certain circumstances, with retroactive effect. Any change in applicable laws or the facts and circumstances surrounding the Merger or any inaccuracy in the factual statements, representations, or warranties upon which we have relied, including those contained in the Agreement, Registration Statement, or the Company Certificates, may affect the continuing validity of the opinion set forth herein.

An opinion of counsel is not binding upon the IRS or the courts. There can be no assurance that the IRS will agree with the opinion set forth herein, or that if challenged by the IRS, the opinion will be sustained by the court.

We hereby consent to the inclusion of this form of letter as an exhibit to the Registration Statement and to the reference to our firm name therein. In giving this consent, we do not thereby admit that we come within the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended, or the rules and regulations of the Securities and Exchange Commission promulgated thereunder.