FBAR reporting threshold: How to stay compliant

You already know that you have to file your tax return every year. But there's another form that catches many US taxpayers off guard: the FBAR, or Foreign Bank and Financial Accounts Report.

If you have foreign financial accounts that exceed the FBAR reporting threshold, you need to file this form with FinCEN. The threshold is 10,000 USD across all your foreign accounts at any point during the year.¹

This is separate from your tax return.

The penalties for missing the FBAR filing are steep, so here's everything you need to know to stay compliant.

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Table of contents
What is FBAR? What is the FBAR reporting threshold? Who is required to file FBAR? Who is exempt from filing FBAR? FBAR threshold for minors How to determine if you meet the FBAR threshold? When is the FBAR deadline?¹ Penalties for non-compliance Common mistakes and how to avoid them

What is FBAR?

FBAR stands for Foreign Bank and Financial Accounts Report. It's a form that you need to file with FinCEN to report your foreign financial accounts to the US government.

The form asks for information such as which foreign banks you use, the types of accounts you have, your account numbers, and the maximum value each account reached during the year.

It's not a part of your regular tax return, and you don't have to pay any taxes on your foreign financial assets. FBAR is purely a disclosure requirement.

Even if you don't owe any US taxes, you still need to file FBAR if you meet the reporting threshold.

What is the FBAR reporting threshold?

You need to file FBAR if the total value of all your foreign financial accounts combined is over 10,000 USD at any point during the calendar year.¹

This means you need to add up the balances across all your foreign accounts.

Let's say you have a checking account in France with 6,000 USD and a savings account in Germany with 5,000 USD. Your total is 11,000 USD, which means you've crossed the threshold and need to file.

Both accounts get reported on your FBAR, even though neither one reaches 10,000 USD.

If your accounts hit 10,001 USD for even a single day during the year, you must file an FBAR. You can’t use averages or pick and choose the days to report.

Who is required to file FBAR?

The filing requirement applies to what the IRS calls **"US persons."**¹

It's a pretty broad category that covers both individuals and business entities.

For individuals, you need to file FBAR if you're:²

• A US citizen, regardless of where you live
• A Green Card holder (permanent resident)
• Someone who spent at least 183 days in the US during the tax year
• Anyone who filed a first-year election on their tax return to be treated as a US resident

Business entities also have FBAR obligations. Any corporation, partnership, LLC, trust, or estate that was formed under US law needs to file if it meets the threshold.

So if you own a business that has foreign accounts totaling more than 10,000 USD, your company needs to submit its own FBAR.

Foreign financial accounts that need to be reported include:

• Checking and savings accounts
• Brokerage accounts
• Mutual funds
• Retirement accounts held abroad
• Certain life insurance policies with cash value

You need to report accounts where you have either a financial interest (meaning you own the account or benefit from it) or signature authority (meaning you can control the account's funds, even if you don't own it).

Who is exempt from filing FBAR?

Even if you have foreign accounts over 10,000 USD, you might not need to file FBAR if:

• Your foreign accounts are held in a US-based IRA or retirement plan, even if those plans invest in foreign assets
• You have accounts at a US military banking facility overseas
• You're a trust beneficiary, and the trust or trustee already files an FBAR for those accounts
• All your foreign accounts are jointly owned with your spouse, your spouse files an FBAR reporting them, and you've signed Form 114a authorizing your spouse to file on your behalf¹
• You have signature authority over your employer's foreign accounts (FinCEN has provided extended relief for certain financial professionals in this situation)

For married couples, the joint filing option only works if every single foreign account you own is jointly held with your spouse. If you have even one account in your name alone, such as a personal savings account from before you got married, you need to file your own FBAR.

FBAR threshold for minors

Children follow the same FBAR rules as adults.

If a minor's foreign accounts total more than 10,000 USD at any point during the year, they need to file—or, typically, their parent or guardian files for them.

For example, maybe you have relatives in another country who opened a savings account or set up a trust fund for your child. If those accounts add up to more than 10,000 USD, you need to file an FBAR.

It doesn't matter that your child has no income or doesn't file a tax return. The FBAR reporting threshold still applies.

How to determine if you meet the FBAR threshold?

You'll need to look at every foreign financial account you had during the year, and see if their total adds up to more than 10,000 USD.

Here's what the process looks like in practice:

1. Make a list of all your foreign financial accounts, including accounts you own, jointly own, or have signature authority over
2. Find the highest balance that each account reached during the year
3. Convert all foreign currency amounts to USD using the Treasury's exchange rate from December 31st³
4. Add up all the maximum balances
5. If the total exceeds 10,000 USD, you need to file an FBAR

Keep your account statements showing the peak balances because you'll need them when filling out the form.

When is the FBAR deadline?¹

The FBAR deadline is April 15th.

That said, if you miss it, you automatically get an extension until October 15th.

You file the FinCEN Form 114 online through FinCEN's BSA E-Filing System, and it's important to remember that FBAR is separate from your tax return. You don't attach it to your Form 1040.

Penalties for non-compliance

Missing the FBAR deadline or not filing at all can lead to serious consequences, even if you didn't know about the requirement.

For non-willful violations, meaning you didn't intentionally ignore the filing requirement but just didn't know about it, the penalty is up to 16,536 USD per year for unfiled FBARs.⁴

The government considers each year you don't file as a separate violation, so these penalties can add up quickly if you've missed multiple years.

Willful violations have much higher penalties.

If the government believes that you knew about the FBAR requirement and didn't file on purpose, penalties can reach 165,353 USD or 50% of the account balance per violation, whichever is greater.⁴

Keep in mind that these numbers are adjusted for inflation.¹

Sometimes, willful violations can also result in criminal charges and prison time.

Overall, it's very important to file FBAR on time.

💡 If you realize you've missed filing in previous years, there are procedures that allow you to catch up with minimal penalties or no penalties at all, such as the Delinquent FBAR Submission Procedures and Streamlined Filing Compliance Procedures.⁴

Common mistakes and how to avoid them

FBAR filing requirements can be confusing for many people, so watch out for these common errors:

• Thinking you don't need to file because you don't owe taxes: FBAR is a reporting requirement that applies even if you have zero tax liability
• Not filing because each account is under 10,000 USD: The threshold is aggregate—you add up all your foreign accounts to see if the total exceeds 10,000 USD
• Forgetting to include all account types: Foreign retirement accounts, brokerage accounts, and life insurance policies with cash value all count toward the threshold
• Confusing FBAR with FATCA: These are separate forms with different thresholds and filing instructions, and many Americans with foreign assets need to file both
• Missing accounts where you have signature authority: If you can control an employer's foreign account or have signing authority on a family member's account, you might need to report it, although there are exemptions

Overall, if you're unsure about your FBAR filing obligations, it can be a good idea to consult with a tax professional. They can clarify any questions you may have and help you stay compliant with the law.

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If your foreign financial accounts total more than 10,000 USD at any point during the year, you need to file FinCEN Form 114 by April 15th (with an automatic extension to October 15th).¹

It's a relatively straightforward form that you'll need to file online with FinCEN, but make sure to do it on time to avoid steep penalties. You don’t have to pay any taxes on FBAR.

If you're a US expat or someone who splits their life between different countries, FBAR compliance is just one piece of a puzzle in your financial life.

You also likely manage bank accounts in different countries and feel frustrated when you lose a lot of money in international transfer fees and currency exchange rate markups.

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Sources

1. IRS - Report of Foreign Bank and Financial Accounts (FBAR)
2. Gordon Law - FBAR Filing Requirements (2025)
3. Financial Crimes Enforcement Network - Reporting Maximum Account Value
4. Greenback Expat Tax Services - FBAR

Sources checked 12/08/2025