The non-equilibrium zero bias anomaly (ZBA) in the tunneling density of states of a diffusive metallic film is studied. An effective action describing virtual fluctuations out-of-equilibrium is derived. The singular behavior of the equilibrium ZBA is smoothed out by real processes of inelastic scattering.PACS numbers: 73.40.Gk, 73.50.Td The suppression of tunneling current at low bias due to electron-electron interaction is known as the zero bias anomaly (ZBA). The theory of ZBA for disordered metals at thermal equilibrium has been developed, on a perturbative level, by Altshuler and Aronov [1,2]. The nonperturbative generalization of this theory was achieved by Finkelstein [3]. Measurements of the tunneling density of states (DOS) in biased quasi-one-dimensional wires [4] call for an extension of the theory to non-equilibrium setups. In this work we study the ZBA for disordered metallic films out of equilibrium, in both the perturbative and the non-perturbative (in interaction) limits.Besides the experimental motivation, the problem of ZBA in a non-equilibrium system is of fundamental theoretical interest. At equilibrium, the distribution of electrons in phase space has a single edge at the Fermi surface. The Coulomb interaction between the tunneling electron and the electrons in the Fermi sea excites virtual particle-hole pairs around the Fermi edge, leading to the suppression of the tunneling DOS, similarly to the Debye-Waller factor. The suppression gets stronger when the electron energy approaches the Fermi energy. Out of equilibrium, the distribution of particles may have several sharp edges rather than a single one at the Fermi surface, which poses important questions addressed in this work: How will the excitation of electron-hole pairs in this situation affect the tunneling DOS? Will there be an interpaly between the two edges? We show that the two edges are not independent: one edge affects the ZBA near the other via real interaction-induced scattering processes governing the dephasing of electrons in the non-equlibrium regime. From this point of view the problem we are considering is a representive of a class of phenomena that involve renormalization away from thermal equilibrium, such as the Fermi edge singularity [5] and the Kondo effect [6].What makes the ZBA particularly interesting is its deep connection to various conceptually important phenomenological ideas. At equilibrium, the nonperturbative results [3] have been reproduced by quantum hydrodynamical methods [7], and, within the framework of the theory of dissipation [8], by methods that rely on the fluctuation-dissipation theorem. Our work