Knowledge Center Financial Accounts & Investing Abroad

FBAR Explained: Filing Requirements, Deadlines, and Penalties for U.S. Expats

You must file an FBAR (FinCEN Form 114) if the combined balance of all your foreign financial accounts exceeded $10,000 at any point during the calendar year. This applies to all U.S. citizens, Green Card holders, and resident aliens, regardless of where they live. The FBAR is filed electronically through FinCEN’s BSA E-Filing System (not with your tax return) by April 15, with an automatic extension to October 15. It is purely informational and does not create additional tax.

According to FinCEN, the $10,000 threshold applies to the aggregate maximum value of all foreign accounts, not to each account individually. If you had three accounts that briefly held $4,000 each on the same day, you’ve crossed the threshold. Common accounts that trigger FBAR requirements include:

Foreign bank accounts: checking, savings, and fixed deposits
Foreign investment accounts: brokerage, mutual funds, securities
Foreign retirement accounts: pensions, provident funds, tax-deferred savings
Foreign accounts with signature authority: accounts you can control even if you don’t own them

Non-willful penalties for failing to file are $16,536 per form (not per account, following the Supreme Court’s Bittner ruling). Filing correctly and on time is straightforward once you know the rules.

Ensure Your FBAR is Filed Correctly — Get Expert Help!

FBAR filing can be complex, but Greenback makes it simple. Our team ensures you’re compliant and file on time to avoid hefty penalties.

Here’s exactly who needs to file, what counts toward the $10,000 threshold, and what to do if you’re behind.

What Is the FBAR?

The FBAR (Foreign Bank Account Report) is an annual form that U.S. expats, Green Card holders, and U.S. citizens (who have foreign bank accounts) must file if their combined foreign account balances exceed $10,000 at any point during the year. It’s submitted to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) and is separate from your tax return, helping you stay compliant and avoid penalties for unreported foreign accounts.

Created under the Bank Secrecy Act, the FBAR helps prevent tax evasion by requiring transparency about offshore assets. But here’s what matters most: filing an FBAR doesn’t mean you owe taxes. It’s purely informational.

The form itself, officially known as FinCEN Form 114, requests basic information about your foreign accounts, including where they’re held, account numbers, and the maximum balance during the year, expressed in U.S. dollars.

Since 2012, all FBARs have been required to be filed electronically through the BSA E-Filing System. Many of our CPAs and Enrolled Agents are expats themselves, living in 14 time zones, and they’ve filed this form thousands of times. They have the knowledge and patience to guide you through the process.

What Counts Toward the $10,000 Threshold?

If you’re a U.S. citizen, Green Card holder, or resident alien with foreign financial accounts, and their combined value exceeded $10,000 at any point during the year, you must file. The threshold is based on the combined maximum value of all accounts, not each account individually. If you had three accounts that briefly held $4,000 each on the same day, you’ve crossed the threshold.

Reportable accounts include:

Foreign bank accounts (checking, savings, certificates of deposit)
Investment and brokerage accounts held at foreign institutions
Mutual funds and unit trusts
Foreign retirement and pension accounts (with some exceptions)
Life insurance policies with cash surrender value
Accounts where you have signature authority, even if you don’t own the funds

Not reportable:

Accounts held at U.S. military banking facilities
IRA or 401(k) accounts at U.S. institutions that invest in foreign assets
Social Security payments deposited in foreign accounts (the account itself is reportable, but Social Security isn’t “income” for FBAR)

FBAR Real-World Examples

Example 1: Digital Nomad with Multiple Accounts

Sarah works remotely and lives in Portugal. She has:

€3,500 in a Portuguese checking account
£4,200 in her old UK savings account
$3,800 in a Mexican investment account

Her combined total is approximately $11,800. Even though no single account exceeds $10,000, Sarah must file an FBAR because her aggregate total crosses the threshold.

Example 2: Retiree with Foreign Pension

James retired to Spain and continues to receive a UK pension. He has €15,000 in a Spanish bank account. James needs to file an FBAR because his account exceeds $10,000. His UK pension account may also be reportable depending on whether he has access to the funds.

Example 3: Corporate Expat with Signature Authority

Michelle works for a U.S. company in Singapore and has signing authority on her employer’s Singapore bank account, which holds $500,000. Even though Michelle doesn’t own these funds, she must report the account on her FBAR because she can direct transactions.

How to File Your FBAR

Filing an FBAR is straightforward once you’ve gathered your account information. Here’s what you need:

Required Information:

Account numbers for all foreign accounts
Names and addresses of the financial institutions
Maximum account value during the year (highest balance at any point)
Type of account (bank, securities, other)

Currency Conversion: Convert all foreign currency balances to U.S. dollars using the U.S. Treasury’s exchange rate for December 31 of the reporting year. You can find these rates at the Treasury’s website.

Filing Process: Submit your FBAR electronically through the BSA E-Filing System. The system walks you through each required field.

FBAR Filing Services: We Handle the Details for You

If you have foreign accounts exceeding $10,000, Greenback’s FBAR filing experts are here to ensure accurate and timely submissions. Don’t risk penalties — let us take care of it.

Explore FBAR Filing Services

Learn more: Complete guide to FinCEN Form 114

FBAR Filing Deadlines for 2026

The FBAR deadline for the 2025 tax year is April 15, 2026, with an automatic extension to October 15, 2026. You don’t need to request this extension; it is automatically applied to all filers.

Important distinctions:

FBAR deadline: April 15, 2026 (automatic extension to October 15, 2026)
Tax return deadline for expats: June 15, 2026 (can extend to October 15, 2026 with Form 4868)

These are separate deadlines because the FBAR is filed with FinCEN, not the IRS. An extension for your tax return doesn’t extend your FBAR deadline, and vice versa.

What If I Haven’t Filed an FBAR?

First, don’t panic. Millions of Americans have past-due FBAR forms. The most important thing is to get compliant now, before the IRS contacts you.

The IRS offers two main programs to help you catch up without paying penalties:

Delinquent FBAR Submission Procedures

This program is exclusively for catching up on FBARs if you’re current on your tax returns. You qualify if:

The IRS hasn’t contacted you about delinquent FBARs
You’ve properly reported all foreign income on your tax returns
Your failure to file was non-willful (you didn’t know about the requirement or received incorrect advice)

The process: File all missing FBARs for up to 6 years back and include a statement explaining why they were not filed. If approved, the IRS waives all penalties.

Learn more: Filing past-due FBAR forms

Streamlined Filing Compliance Procedures

Use this program if you’re behind on both tax returns and FBARs. You’ll file:

Three years of tax returns
Six years of FBARs
A certification that your failure to file was non-willful

If you live outside the U.S. for 330 days or more per year, there are typically no penalties. U.S. residents face a 5% penalty on unreported account balances.

We’ve helped thousands of expats get caught up through these programs. Many were relieved to discover they could become compliant without the penalties they feared.

Learn more: Everything you need to know about Streamlined Filing

FBAR Penalties: What You Need to Know

While we don’t want to create anxiety, understanding potential penalties helps you appreciate the importance of timely filing. The good news is that if you come forward voluntarily before the IRS contacts you, you can usually avoid penalties entirely through the programs mentioned above.

Non-willful violations (honest mistakes):

Up to $16,536 per year for unfiled FBARs
The IRS typically shows leniency for first-time filers with reasonable cause
Recent Supreme Court rulings (Bittner case) clarified that penalties apply per form, not per account

Willful violations (intentional non-compliance):

Greater of $165,353 or 50% of the account balance per violation
Potential criminal charges in extreme cases (rare)

What counts as “reasonable cause”?

You weren’t aware of the FBAR requirement
You received incorrect professional advice
You made a good-faith effort to comply

We’ve served over 23,000 expats, and many came to us worried about penalties after discovering they hadn’t filed FBARs. Through the proper catch-up programs, the vast majority avoided penalties entirely.

Learn more: Complete guide to FBAR penalties.

2026 Enforcement Update: Recklessness Now Triggers Willful Penalties

In January 2026, the U.S. Court of Appeals for the Second Circuit ruled in United States v. Reyes that “reckless disregard” of the FBAR requirement is enough to trigger the maximum willful penalty — you don’t need to have intentionally hidden accounts. This ruling joins six other circuit courts in adopting the same standard, meaning it now applies in almost every U.S. jurisdiction.

At the same time, a September 2025 ruling in United States v. Sagoo gave taxpayers a new potential defense, with a federal court holding that the IRS may not be able to impose willful FBAR penalties without first providing a jury trial.

The practical takeaway: the window between “I didn’t know about FBAR” and willful penalty exposure has narrowed significantly. If you have unreported accounts, coming forward voluntarily through the proper programs is more important than ever.

Learn more: FBAR Willful Violation: What Reyes and Sagoo Means for Expats

FBAR vs. FATCA (Form 8938): What’s the Difference?

The U.S. government has two separate requirements for reporting foreign assets, which can be confusing for many expats. Here’s how they differ:

Quick Comparison

	FBAR (FinCEN Form 114)	FATCA (Form 8938)
Filing Threshold	$10,000 aggregate	$200,000 (single expats) / $400,000 (married expats)
Who Must File	Individuals and entities	Individuals only
Where to File	FinCEN (separate from tax return)	IRS (attached to tax return)
What’s Reported	Foreign financial accounts	Foreign financial assets (broader category)
Deadline	April 15 (auto-extension to Oct 15)	Same as tax return deadline

Key insight: You can hold an asset inside an account. In this case, it’s reportable on both forms. However, if you hold an asset individually (such as direct ownership in a foreign company), it’s only reported on Form 8938.

Many expats need to file both forms for the same accounts. The reporting thresholds differ, and they are directed to various agencies.

Learn more: FBAR vs. FATCA: Complete comparison

Special FBAR Situations

Joint Accounts with Non-U.S. Spouses

If you have joint accounts with your non-U.S. spouse, both of you must report the account if you both have signing authority. However, spouses can file one joint FBAR if:

All foreign accounts are jointly owned
Neither spouse has separate foreign accounts
Both spouses sign Form 114a (authorization form)

You don’t need to report your non-U.S. spouse’s individual accounts if you have no signing authority over them.

Learn more: FBAR filing rules for joint accounts with non-U.S. citizens

Business Owners and Signature Authority

If you own a business with foreign accounts or have signature authority over employer accounts, special rules apply:

Business accounts count toward your personal $10,000 threshold
You must report accounts where you have signature authority, even if you don’t own the funds
Consolidated FBAR filing may be available for parent companies with subsidiaries

Learn more: Consolidated FBAR filing for businesses

Children with Foreign Accounts

If your child has foreign accounts exceeding $10,000, you must file an FBAR on their behalf. This includes:

Custodial accounts you opened for them
Trust accounts where they’re beneficiaries
Joint accounts you hold with your child

Parents must file using the child’s name and Social Security Number, even if the child doesn’t need to file a tax return.

Common FBAR Mistakes to Avoid

Based on working with expats, here are the most common mistakes we see:

Mistake 1: Thinking the FBAR is only for wealthy people: The $10,000 threshold is low. Many expats hit it simply by maintaining regular checking and savings accounts.
Mistake 2: Assuming your foreign bank reports for you: While some banks share information with the U.S. through FATCA, that doesn’t eliminate your personal FBAR filing requirement.
Mistake 3: Not reporting accounts under $10,000 when the total exceeds the threshold: You must report all foreign accounts if your aggregate total exceeds $10,000, even if individual accounts are below the threshold.
Mistake 4: Forgetting about old accounts: That UK savings account from your previous job? If it still had funds during the year and your total exceeded $10,000, it’s reportable.
Mistake 5: Overlooking retirement and pension accounts: Foreign retirement accounts are generally reportable if you can access the funds. This trips up many retirees.

Next Steps: Getting Your FBAR Right

If you’re current on FBAR filing: Continue filing annually by the April 15 deadline (or use the automatic October 15 extension). Keep records of all foreign accounts for at least 5 years.
If you need to file for the first time, gather your account statements showing the year’s maximum balances. File through the BSA E-Filing System or work with a qualified expat tax professional.
If you’re behind on filing: Don’t wait. The longer you delay, the more complicated it becomes. Use the Delinquent FBAR Submission Procedures or Streamlined Filing Compliance Procedures to get caught up penalty-free.
If you’re unsure what applies to your situation, contact us. One of our Customer Champions can help you understand your obligations and connect you with an experienced CPA or Enrolled Agent who specializes in expat taxes.

Let Greenback Handle Your FBAR Filing

Many of our CPAs and Enrolled Agents are expats themselves, living in 14 time zones. They experience firsthand the challenges of living abroad and have the knowledge and patience to help you navigate complicated U.S. tax requirements.

FBAR filing services: Starting at $125 for up to 5 accounts. We handle everything from gathering information to electronic filing.

Ready to get started? Click below to be matched with a Greenback accountant, or contact our Customer Champions if you have questions about the process.

FBAR Filing Done Right — Avoid Penalties, Get Expert Help

Avoid the IRS penalties with professional FBAR filing support. Greenback’s expat tax specialists will guide you through the process, ensuring you meet all requirements and deadlines.

The information provided here is for general guidance only and should not be construed as legal or tax advice. FBAR requirements can be complex, and individual situations vary. For specific advice about your situation, please consult with a qualified tax professional.

Frequently Asked Questions

What is the purpose of the FBAR?

The FBAR exists to help the U.S. government detect and prevent tax evasion, money laundering, and other financial crimes involving offshore accounts. Created under the Bank Secrecy Act, it is a reporting requirement only. Filing an FBAR does not mean you owe additional taxes; it simply informs the U.S. Treasury that you hold foreign financial accounts. The form goes to FinCEN (Financial Crimes Enforcement Network), not the IRS, though the IRS enforces penalties on FinCEN’s behalf.

Does the $10,000 threshold apply to each account individually, or to all accounts combined?

The $10,000 threshold is aggregate — meaning all of your foreign accounts are added together. If you have three accounts with $4,000 each, your combined total is $12,000, and you must file an FBAR, even though no single account exceeds the threshold. You must then report all foreign accounts on the FBAR, not just the ones that pushed you over.

Do I need to file an FBAR if I only briefly exceeded $10,000?

Yes. The threshold triggers if your combined foreign account balances exceeded $10,000 at any single point during the year — even for one day. A temporary transfer, a payroll deposit, or a lump-sum payment that briefly pushed your balance over the threshold is enough to create the filing requirement for that entire year.

Is the FBAR the same as FATCA Form 8938?

No, they are two separate requirements. The FBAR is filed with FinCEN and has an aggregate threshold of $10,000. Form 8938 (FATCA) is filed with your tax return and has a much higher threshold — $200,000 for single expats and $400,000 for married expats filing jointly on the last day of the year. Many expats need to file both. The key difference is that Form 8938 covers a broader category of foreign financial assets, while the FBAR is limited to foreign financial accounts. See our FBAR vs. FATCA comparison for a full breakdown.

What happens if I file my FBAR late but haven’t been contacted by the IRS?

If you have properly reported all income from the foreign accounts on your U.S. tax returns, you can use the Delinquent FBAR Submission Procedures to file back FBARs with no penalty. You file the missing FBARs electronically and include a brief statement explaining why they were not filed on time. The key condition is that the IRS must not have already contacted you about the delinquency. If you are also behind on tax returns, the Streamlined Filing Compliance Procedures allow you to catch up on both with no penalty for qualifying expats.

Do I need to report my foreign employer’s bank account if I have signing authority?

Yes. The FBAR requires reporting any account over which you have signature authority, regardless of whether you own the funds. This is one of the most commonly missed FBAR triggers for corporate expats. If you can direct transactions on an employer account — even as part of your job — and the account balance contributed to an aggregate total over $10,000, it must be reported on your personal FBAR.

Does the FBAR apply to cryptocurrency held on foreign exchanges?

This is an evolving area. FinCEN has proposed rules that would explicitly require FBAR reporting for cryptocurrency held in foreign accounts, but as of the 2025 tax year, those rules have not been finalized. The current guidance is that if you hold crypto on a foreign exchange that also holds fiat currency (like USD or another national currency), the entire account may be reportable once it crosses the $10,000 threshold. The safest approach for 2025 is to report foreign exchange accounts that hold both crypto and fiat currency, and to consult a qualified expat tax professional about accounts that hold crypto only.

Can my spouse and I file one FBAR together?

Yes, in limited circumstances. Spouses can file a joint FBAR if all their foreign financial accounts are jointly owned and neither spouse has any separate foreign accounts that require disclosure. Both spouses must sign Form 114a to authorize the joint filing. If either spouse has individual foreign accounts, you must each file a separate FBAR for those accounts.