FATCA W-9: What the FATCA code on Form W-9 means

Form W-9 is not a personal FATCA tax return. Understanding the FATCA code meaning on this form helps clarify why a foreign bank, broker, or online platform may request Form W-9 to document that an account holder is a US person.

Most individual US taxpayers, including expats, leave the FATCA exemption-code field blank because Form W-9 reserves that field for certain entities, not individuals.

Submitting Form W-9 to a foreign financial institution does not determine whether the taxpayer must separately file FinCEN Form 114 or IRS Form 8938.

Expats who receive this request alongside a FATCA letter from a foreign bank should treat the two issues separately: one is account documentation, the other is personal reporting. The current Form W-9 revision is dated March 2024 and remains the applicable version for the 2025 tax year filed in 2026.

Summary box

Below are 5 common questions about what Form W-9 does, why your foreign bank may have requested one, and where personal FATCA reporting comes in.

 

Form W-9 has two separate exemption fields on Line 4. The Exempt payee code relates to backup withholding, while the Exemption from FATCA reporting code relates to FATCA reporting for eligible entities.

What does FATCA mean on Form W-9?

FATCA on Form W-9 refers to a certification and exemption field that applies to certain entities with accounts maintained outside the United States. Form W-9 lists 13 FATCA exemption codes, A through M. A foreign financial institution may request Form W-9 to document that an account holder is a US person.

Under the Foreign Account Tax Compliance Act, participating foreign financial institutions identify and report US reportable accounts in accordance with applicable FATCA rules or intergovernmental agreements. FATCA reporting is separate from an individual’s own US tax filing obligations.

Form W-9 gives the requester your name, TIN, and US tax classification. The requester generally keeps the completed Form W-9 on file rather than sending it to the IRS. The IRS may request it from the requester during an examination or compliance review.

An FFI can request a W-9 as account documentation, but the request does not itself establish a Form 8938 or FBAR filing requirement.

Expats unsure why their bank is asking for paperwork should review what to do when a foreign bank sends a FATCA letter before responding.

The 3 FATCA and W-9 items people confuse

Form W-9 contains two separate exemption fields, while Form 8938 and FBAR are separate individual reporting analyses. A FATCA exemption code on Form W-9 does not determine whether an individual must report foreign assets or foreign accounts to the US government.

The two Line 4 fields on Form W-9, Form 8938, and FBAR each serve a different compliance purpose.

 

On Form W-9, the term FATCA refers to a certification code for eligible entities. For individual taxpayers, FATCA filing usually means a separate Form 8938 analysis. FBAR is a FinCEN filing under the Bank Secrecy Act, not under FATCA itself.

Understanding how FBAR and FATCA reporting differ prevents duplicate or missed filings.

Do individuals need a FATCA exemption code on Form W-9?

Most individual US citizens and resident aliens do not enter a FATCA exemption code on Form W-9. The IRS Form W-9 instructions state that Line 4 exemption codes apply only to certain entities, not individuals. An individual should not select a FATCA code merely because a foreign bank requested a W-9.

The following 4 scenarios cover most account holders:

• US citizen with a personal foreign bank account – leave blank.
• US resident alien with a personal foreign brokerage account – leave blank.
• Corporation, trust, bank, tax-exempt organization, or other entity – determine whether a code applies.
• Foreign individual – use Form W-8 instead of Form W-9.

Do not select a code because it appears to reduce reporting. A FATCA exemption code certifies a specific entity status, and an incorrect certification can create documentation and tax-compliance problems.

How to complete Form W-9 when a foreign bank requests it

A US expat who receives a legitimate Form W-9 request should provide the name and TIN that match US tax records, select the correct federal tax classification, leave inapplicable Line 4 fields blank, and return the completed form to the requester.

The following 6 steps apply to a typical individual account holder.

1. Verify the requester

Confirm the request came through the bank’s official portal or a secure channel. Never send a Social Security number through an unverified email.

2. Enter the taxpayer’s legal name

Use the name shown on your US tax return. Line 1 must match the TIN entered in Part I.

3. Select the correct tax classification

Choose individual/sole proprietor unless an entity legally owns the account.

4. Enter the correct TIN

Most individuals use their Social Security number. A resident alien without one may use an ITIN where applicable.

5. Review Line 4 separately

Most individuals leave both exemption fields blank. Entities should confirm eligibility before entering any code. Individual filers leave the FATCA reporting code field untouched unless their entity status qualifies.

6. Return the form to the requester

Send it through the bank’s official process. Never mail Form W-9 to the IRS – the form belongs with the requester, not with a government agency.

A US citizen living in Spain receives a W-9 request after a Spanish bank identifies US indicia. The taxpayer enters the legal name shown on the US tax return, provides a Social Security number, selects the individual classification, and leaves both Line 4 exemption fields blank. The W-9 documents US status for the bank but does not determine FBAR or Form 8938 obligations.

 

Choosing correctly also matters when the requester is a marketplace rather than a bank. Reviewing which form a US expat or foreign individual needs – W-8 or W-9 can prevent sending the wrong form entirely.

Not sure how a bank’s W-9 request affects your US filing obligations?

Get FATCA reporting help

FATCA exemption codes on Form W-9

Form W-9 lists 13 FATCA exemption codes, A through M. These codes identify certain organizations and other specified persons that are exempt from FATCA reporting under the IRS Chapter 4 rules. The codes do not create a personal FATCA exemption for an individual account holder.

Only specific entity types qualify for a FATCA exemption code – individual account holders do not.

 

A corporation, bank, broker, tax-exempt organization, or trust should confirm its code with the financial institution requesting Form W-9 or with a qualified tax adviser. A personal account holder should not select a code from this table unless an eligible entity owns the account.

The following 4 rules prevent misuse of FATCA exemption codes:

• Do not treat codes A through M as personal exemptions.
• Do not use an exempt payee code in the FATCA field.
• Do not use a FATCA code to decide whether Form 8938 applies.
• Do not select a code simply because a foreign bank requests proof of US tax status.

Exempt payee code vs. FATCA exemption code

An Exempt payee code and a FATCA exemption code are not interchangeable. Form W-9 uses 13-letter codes, A through M, for FATCA exemptions and 13 numeric codes, 1 through 13, for exempt payees. Each code system addresses a different reporting rule.

Numeric codes address backup withholding. Letter codes address FATCA reporting. The two fields answer different questions.

 

Exempt payee code 5 is a backup-withholding exemption for a corporation in applicable circumstances. Code 5 is not a FATCA exemption code. FATCA exemption codes use letters, not numbers.

W-9 vs. W-8 vs. Form 8938 vs. FBAR

Form W-9, Form W-8, Form 8938, and FBAR serve four different compliance purposes. Form W-9 documents US status for a requester, while Form W-8 generally documents foreign status. Form 8938 and FBAR are separate reporting analyses that may apply to US taxpayers with foreign assets or foreign accounts.

Each form answers a different question, goes to a different recipient, and follows a different set of rules.

 

For individual taxpayers, Form 8938 is the FATCA reporting form attached to the federal income tax return when filing is required. FBAR is filed separately with FinCEN under the Bank Secrecy Act, not under FATCA itself.

Together, Form W-9 and Form 8938 are the two FATCA forms most individual expats encounter – but each serves an entirely different purpose. Form W-9 goes to the bank. Form 8938 goes to the IRS with your return.

Certain Forms 1099 include a FATCA filing requirement box. That checkbox is separate from the FATCA exemption field on Form W-9 and does not certify a taxpayer’s FATCA filing obligations.

The following 4 situations clarify which form applies:

• US citizen asked by a foreign bank – start with Form W-9.
• Foreign individual asked by a US payer – review Form W-8BEN.
• US taxpayer with foreign accounts or assets – review FBAR and Form 8938 separately, and comparing FBAR and Form 8938 side by side clarifies which thresholds and deadlines apply.
• A FATCA letter does not confirm that all US reporting is complete – whether you are exempt from FATCA reporting on Form 8938 has no bearing on how you complete Form W-9.

Common FATCA W-9 mistakes

The following 5 mistakes can cause incorrect tax-status documentation or an incomplete foreign-account reporting review. Each results from confusing Form W-9 certification with a taxpayer’s separate FATCA or FBAR compliance analysis.

1. An individual enters a FATCA code when Line 4 codes apply to certain entities. Leave it blank.
2. Code 5 is entered in the FATCA field when Code 5 belongs to the exempt payee system. Use the correct field and confirm entity eligibility first.
3. A W-9 is sent to the IRS when it belongs with the requester. Use the bank’s secure process instead.
4. A US citizen submits Form W-8BEN, when that form documents foreign status. A US person provides Form W-9.
5. A taxpayer assumes the W-9 replaces FBAR or Form 8938, when the purposes differ. Review each obligation separately – understanding how FBAR and FATCA reporting differ prevents this specific mix-up.

Bottom line

Form W-9 helps a foreign financial institution document a customer’s US tax status. Most individual US expats should provide accurate name and TIN information but leave both Line 4 exemption fields blank.

Form W-9 does not satisfy FATCA filing obligations, which are handled separately through Form 8938 or FBAR. US taxpayers should review foreign-account and foreign-asset reporting obligations on their own timeline for the 2025 tax year filed in 2026.

A completed W-9 does not resolve whether FBAR or Form 8938 applies to your accounts.

Speak with a FATCA reporting specialist