Do I Need to Report My RRSP on FBAR?

Yes, in most cases, you do. The IRS considers Canadian Registered Retirement Savings Plans (RRSPs) as foreign financial accounts. If the aggregate value of all your foreign accounts (including RRSPs) exceeds $10,000 USD at any time during the calendar year, you are required to report them on the FBAR (FinCEN Form 114).

Learn more about FBAR reporting requirements

Do I Also Need to Report My RRSP on FATCA (Form 8938)?

Yes—if your total foreign financial assets meet the FATCA reporting thresholds, RRSPs must also be reported on Form 8938 (Statement of Specified Foreign Financial Assets).

For the 2025 tax year, FATCA thresholds for expats are:

• Single: $200,000 on the last day of the year or $300,000 at any point
• Married Filing Jointly: $400,000 on the last day of the year or $600,000 at any point

Read about FATCA filing requirements

Do I Need to File Form 3520 or 3520-A for an RRSP?

No. Thanks to IRS Revenue Procedure 2014-55, RRSPs are no longer treated as foreign trusts. That means you are not required to file Forms 3520 or 3520-A for RRSP accounts, even though they are foreign-based.

What You Should Do

• Include your RRSP on your FBAR if applicable
• Include it on Form 8938 if you meet the FATCA thresholds
• Do not file Form 3520 or 3520-A for RRSPs
• Maintain clear documentation of RRSP values and contributions
• Your Greenback accountant can help determine exactly what needs to be reported, based on your full financial picture

Read more about RRSPs and RESPs for expats in Canada

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