FBAR explained: the $10,000 rule every American abroad has to know
If the combined balance of your foreign accounts went over $10,000 at any moment last year, you must file an FBAR. Filing is free and takes an evening. Skipping it is one of the costliest mistakes an American abroad can make.
The short version
- The FBAR is FinCEN Form 114. It's filed online with the Treasury's Financial Crimes Enforcement Network, not the IRS, and it doesn't ride along with your tax return [1][2].
- You file if the aggregate maximum value of all your foreign financial accounts exceeded $10,000 at any time during the calendar year [1].
- It covers accounts you own and accounts you only have signature authority over, including joint accounts and many foreign pensions [1][4].
- It's due April 15, with an automatic extension to October 15. The 2026 FBAR is due April 15, 2027, and extended automatically to October 15, 2027 [1][3].
- Penalties are adjusted yearly for inflation. Since a 2023 Supreme Court decision, the non-willful penalty is counted per report, not per account [5][6].
Who has to file
A "United States person" files if they have a financial interest in, or signature or other authority over, at least one foreign financial account, and the combined value exceeded $10,000 at any time in the calendar year [1][2]. US persons include citizens (also dual citizens who have never lived in the US), green card holders, US residents, and US entities such as LLCs, partnerships, trusts and estates [1].
There's no income test. Owing no tax, being retired or earning nothing doesn't get you a pass. Kids aren't exempt either. A child with a foreign savings account above the threshold needs an FBAR. A parent or guardian can file it for them.
The aggregate test, with an example
Here's where people trip up: the $10,000 isn't per account. Add the highest balance each account reached during the year, even if those peaks happened on different days [1][3].
Example for calendar year 2026: your checking account peaked at $6,200 in March and your savings account peaked at $4,500 in November. You never held more than $10,000 on any one day, but the sum of the peaks is $10,700. Congratulations, you're an FBAR filer, and you report both accounts.
Convert each maximum value to dollars using the Treasury's Bureau of the Fiscal Service exchange rate for the last day of the calendar year. If no rate is available for that currency, use another verifiable rate and cite its source [3].
Which accounts count
The FBAR casts a wide net with "financial account." The IRS manual lists these [4]:
| Reportable on the FBAR | Not reportable on the FBAR |
|---|---|
| Checking, savings and time deposit accounts at a foreign bank | Foreign stocks or bonds you hold directly, not in an account |
| Brokerage and securities accounts abroad | Foreign real estate you own directly |
| Foreign mutual funds and similar pooled funds | Physical cash, gold or jewelry you hold yourself |
| Insurance or annuity policies with a cash value | A safe deposit box (unless the institution can access the contents) |
| Foreign pension accounts such as a Canadian RRSP or a Mexican AFORE | Accounts at US military banking facilities |
| Futures or options accounts with a foreign broker | Foreign accounts inside your US IRA or US 401(k) plan |
| Accounts you can sign on but don't own, such as an employer's or a parent's |
The IRS manual singles out foreign retirement accounts such as RRSPs and AFOREs as normally reportable. The exception covers only US plans [4]. Workplace pensions in the UK, Australian superannuation and similar plans raise the same question. They may feel like the local cousin of your 401(k), but the exception above covers only the US originals. A US expat tax preparer can check how yours is treated.
Joint accounts and spouses
Each joint owner reports the full account value. Spouses who own all their foreign accounts jointly can file a single FBAR, with one spouse filing for both and FinCEN Form 114a signed to authorize it. Your tax filing status doesn't affect this [1]. If your spouse isn't a US person, they don't file, but you still report the full value of the joint account.
Signature authority
If you can sign on your employer's account or Mom's account, you report it even if none of the money is yours. Some employees and officers of certain regulated employers who have signature authority but no financial interest get a continuing extension [1]. Read the fine print in the FinCEN notices before relying on it.
How and when to file
- Collect statements for every foreign account for the calendar year and note the highest balance in each.
- Convert each maximum to dollars at the Treasury year-end rate [3].
- Add them up. If the total is over $10,000, you must file.
- Go to the BSA E-Filing System at bsaefiling.fincen.gov and choose the individual FBAR filing option. You don't need an account. Paper filing needs an exemption from FinCEN [1].
- Enter each account: institution name and address, account number, account type and maximum value.
- Submit and save the confirmation and a PDF copy.
- Answer the FBAR question on Schedule B of your Form 1040 consistently. If you have a foreign account above the threshold, say so.
- Keep records for five years from the FBAR due date: account name and number, the bank's name and address, account type and maximum value [1].
| Calendar year reported | Due date | Automatic extension |
|---|---|---|
| 2025 | April 15, 2026 | October 15, 2026 |
| 2026 | April 15, 2027 | October 15, 2027 |
The extension to October 15 is automatic, and you don't need to request it [1][3]. No forms, no phone calls. FinCEN also publishes extra extensions for disaster areas and for certain financial professionals with signature authority, so check its site if either might apply [2].
Penalties, and fixing missed years
Penalties are what give the FBAR its teeth. The statute starts at up to $10,000 per non-willful violation. For willful violations, it's up to the greater of $100,000 or 50% of the account balance at the time of the violation. These figures are adjusted for inflation every year, so the current maximums are higher [4][6]. Criminal penalties can apply in the worst cases [3][6].
In Bittner v. United States (February 28, 2023), the Supreme Court ruled 5–4 that the non-willful penalty applies per report, not per account [5]. Someone with ten accounts who missed one year faces one non-willful penalty, not ten. That's a big deal. The willful penalty still applies per account [5]. Checking "no" to the foreign account question on Schedule B can be used as evidence of willfulness [5]. Answer it honestly.
The IRS says it won't penalize a properly reported late FBAR when it finds reasonable cause [3]. In practice, Americans abroad who missed FBARs usually fall into one of two camps:
- Your tax returns are filed and all income was reported, but you missed FBARs. You may be able to use the IRS Delinquent FBAR Submission Procedures. You file the late FBARs through BSA E-Filing with an explanation of why they're late. Eligibility generally requires that you're not under IRS examination or criminal investigation and haven't been contacted about the missing FBARs.
- You also missed tax returns or left out income. For non-willful filers living abroad, the Streamlined Foreign Offshore Procedures are the usual route. They involve back returns and six years of FBARs. See our separate guide.
To file a late FBAR, use the same BSA E-Filing System. It accepts prior years and lets you pick a reason for late filing [3]. To fix a filed FBAR, file a new one and mark it "Amended" [3].
A US expat tax preparer (or a lawyer, if there's any question of willfulness) can check your situation before you file late.
FBAR vs Form 8938
People mix up the FBAR and Form 8938, the FATCA form, all the time. They overlap, but they're separate filings with different thresholds, filed in different places. The FBAR goes to FinCEN at $10,000 aggregate. Form 8938 goes with your tax return and starts at $200,000 at year-end for a single filer living abroad [6]. Filing one doesn't satisfy the other [7]. Many people with large balances file both, listing the same accounts twice. Yes, really.
Sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR)
- FinCEN: Report Foreign Bank and Financial Accounts
- IRS: Understand how to report foreign bank and financial accounts (FS-2019-7)
- IRS: Internal Revenue Manual 4.26.16, Report of Foreign Bank and Financial Accounts
- EY Global Tax News: US Supreme Court holds the nonwillful FBAR penalty applies per report (March 2023)
- IRS: Comparison of Form 8938 and FBAR requirements
- IRS: Basic questions and answers on Form 8938