The short version
- An FBAR is a yearly report of your accounts outside the US. You file it with FinCEN, part of the US Treasury, on FinCEN Form 114. It does not go with your tax return.
- A US person files one if their foreign accounts add up to more than $10,000 at any time in the year. That includes US citizens who live abroad.
- It is due 15 April, with an automatic extension to 15 October. You file it online through FinCEN's BSA E-Filing System.
- Form 8938 is a different form. It goes with your tax return and has higher limits. Some people file both.
What is an FBAR?
An FBAR is a yearly report that tells the US Treasury about the accounts you hold outside the US. The name stands for Report of Foreign Bank and Financial Accounts. The form itself is FinCEN Form 114.
It comes from a US law called the Bank Secrecy Act. The IRS page on the FBAR says that every year you must report certain foreign accounts, such as bank accounts, brokerage accounts and mutual funds, and keep records of them.
Two points are easy to miss. First, the FBAR goes to FinCEN, the Financial Crimes Enforcement Network. That is a bureau of the Treasury, separate from the IRS. Second, it is a report of what you hold, not a tax form. Whether an account earned any taxable income makes no difference to whether you report it.
So the FBAR is a reporting rule. It asks you to list your foreign accounts once a year.
Who has to file an FBAR?
A US person who has a financial interest in, or signature or other authority over, at least one account outside the US, if those accounts together were worth more than $10,000 at any time during the calendar year.
The IRS lists who counts as a US person:
- US citizens. Wherever they live. FinCEN's filing instructions add that this includes children.
- US residents. FinCEN's instructions use the US tax residency tests to decide who is a resident.
- US entities. Corporations, partnerships, limited liability companies, trusts and estates formed in the US or under its laws.
Moving abroad does not change this. A US citizen in Lisbon with foreign accounts over the limit files, just like one in Ohio. The FBAR test looks only at your accounts, not your income. So the foreign earned income exclusion, which lowers your US income tax, is a separate question.
Two terms decide whose accounts they are. You have a financial interest if you are the owner of record or hold legal title, even if the account is for someone else. You also have one if an agent or nominee holds it for you, or a company you own more than 50% of. You have signature authority if you can control the money by telling the bank directly, alone or with someone else. FinCEN's instructions excuse some employees who only sign on an employer's account, such as some staff of banks and listed companies.
Married couples can share one report in one case. The IRS says one spouse can file for both if every foreign account is jointly owned, the other spouse signs FinCEN Form 114a, and the filing spouse reports the joint accounts on time. Filing your taxes jointly or separately makes no difference to this. Otherwise each spouse files and reports the full value of the joint accounts.
Children generally file their own. If a child cannot, for example because of age, a parent or guardian files it for them.
Which accounts count toward the $10,000?
Accounts at financial institutions outside the US. That covers bank accounts, brokerage and securities accounts, mutual funds and some insurance policies. The $10,000 is a total across all of them, not a limit per account.
FinCEN's filing instructions set out how to count. Take each account's highest value during the year. For an account in another currency, convert that figure to dollars at the Treasury's exchange rate for the last day of the year. Then add the accounts together. If the total is over $10,000, you file and list every account.
Two accounts that peaked at $6,000 and $5,000 make $11,000, so both go on the report. Bank statements are fine for finding the highest value, as long as they fairly show it.
| What you hold | On the FBAR? |
|---|---|
| Bank account at a bank outside the US | Yes |
| Account at a branch of a US bank located abroad | Yes |
| Brokerage account abroad | Yes, as one account |
| Foreign mutual fund | Yes |
| Foreign life insurance or annuity with a cash value | Yes |
| Foreign account you can sign on but do not own | Yes, with some exceptions |
| Account at a US branch of a foreign bank | No |
| Foreign shares held outside any account | No |
| Property, cash, gold or other things you hold yourself | No |
| Social security type benefits from a foreign government | No |
The IRS also lists foreign accounts you do not need to report. These include accounts held in an IRA you own or benefit from, accounts in a retirement plan you take part in, accounts on a US military banking facility, and some trust accounts that the trust already reports.
Some edge cases:
- US territories. For the FBAR, the United States includes Puerto Rico, Guam, the US Virgin Islands and other territories. So an account there is not a foreign account.
- Multi-currency accounts. The test is where the account is held, not what currency it holds. If you use an app like the ones in Wise vs Revolut, the question is which company holds your money, and in which country.
- Crypto. A FinCEN notice from December 2020, still listed on its FBAR page, says a foreign account holding only virtual currency is not reportable for now. It also says FinCEN plans to change the rules to include it. Check FinCEN's page before you rely on this.
When is the FBAR due?
15 April of the year after the calendar year you are reporting. If you miss it, you get an automatic extension to 15 October. You do not need to ask for it.
So accounts held in 2026 go on an FBAR due 15 April 2027, with the extension running to 15 October 2027. FinCEN's instructions say the deadline follows the federal income tax rule. If it falls on a weekend or a legal holiday, filing on the next working day counts as on time.
The government sometimes gives more time to people hit by natural disasters. FinCEN posts these relief notices on its FBAR page.
How do you file an FBAR?
Online, through FinCEN's BSA E-Filing System. You do not file it with your federal tax return. FinCEN says individuals can file their own FBAR there without registering for an account.
For each account, have these details ready. They are also the records the IRS says to keep for five years from the FBAR's due date:
- The name on the account
- The account number
- The name and address of the foreign bank
- The type of account
- Its highest value during the year
The law does not say which documents to keep. The IRS says bank statements or a copy of the filed FBAR can do, if they hold that information. Amounts go in as US dollars, rounded up to the next whole dollar.
A few other rules:
- Someone filing for you. You sign FinCEN Form 114a to authorise them. You keep it with your records. You do not send it in.
- Tax professionals. FinCEN says an attorney, CPA or enrolled agent filing for a client must register as a BSA E-Filer and file as an institution.
- Paper. Only with an exemption. You ask FinCEN's Resource Center, and if it agrees, it sends you a paper form to post to the IRS.
- Mistakes. To fix a filed FBAR, FinCEN's instructions say to file a new one in full and tick the Amend box, with the BSA identifier of the first report.
Is the FBAR the same as Form 8938?
No. Form 8938 is an IRS form you attach to your tax return. The FBAR goes to FinCEN on its own. The IRS says filing Form 8938 does not replace the FBAR, so some people file both.
| Question | FBAR | Form 8938 |
|---|---|---|
| Where it goes | FinCEN, online | With your tax return |
| When it is due | 15 April, or 15 October with the extension | With your tax return and any extension |
| Limit if you live in the US, single | Over $10,000 at any time | Over $50,000 at year end, or $75,000 at any time |
| Limit if you live abroad, single | Over $10,000 at any time | Over $200,000 at year end, or $300,000 at any time |
| Foreign branch of a US bank | Yes | No |
| Foreign shares held outside an account | No | Yes |
| An account you only sign on | Yes | No, unless you have an interest |
For married couples filing jointly, the Form 8938 limits double. That is over $100,000 at year end or $150,000 at any time if you live in the US, and over $400,000 or $600,000 if you live abroad. The FBAR line stays at $10,000.
US territories count as the US for the FBAR, but not for Form 8938. Both forms carry penalties for not filing. The IRS sets them out side by side in its comparison of Form 8938 and FBAR requirements.
What if you filed late?
The IRS says to file the late FBARs as soon as possible, if it has not contacted you about them and you are not under a civil or criminal investigation. Filing soon keeps any penalty to a minimum, it says.
Filing late, or not at all, is a violation and may bring penalties. The IRS says any penalty depends on the facts and circumstances. It also asks you to explain why you are filing late, and links instructions for how to do that.
The IRS also names compliance options, such as the Streamlined filing compliance procedures. Each has its own instructions to follow.
Where can you get help with your own case?
From the IRS, FinCEN or a tax adviser who works with Americans abroad. This page explains the general rules. Your own answer depends on your accounts, your dates and your status.
The IRS runs an FBAR Hotline for general questions on who files and how: 866-270-0733, or 313-234-6146 from outside the US. FinCEN's BSA E-Filing Help Desk takes technical questions about the filing system.
If you are still setting up your money abroad, one simple setup is three accounts with three jobs, which we explain in the bank accounts that work abroad. For what a foreign bank asks for, see how to open a bank account in Mexico.
Thinking about a Swiss account? Read how to open a bank account in Switzerland.