How to report Wise and Revolut accounts on FBAR in 2026
If you are a US person and your aggregate foreign financial account balances exceeded $10,000 at any point during the calendar year, you must file FinCEN Form 114 – the Report of Foreign Bank and Financial Accounts.
Whether your Wise or Revolut account triggers FBAR depends on the legal entity holding your funds, not the currency or routing number.
Both Wise and Revolut operate through multiple legal entities around the world. Some are domiciled in the US; most are not. If the entity maintaining your account is located outside the US, that account is generally foreign for FBAR purposes – even if it holds US dollars, even if it has a US routing number, and even if you use it exactly like a domestic bank account.
The question of whether you need to report Wise and Revolut on FBAR comes down to identifying which entity holds your funds and whether your combined foreign account balances hit the $10,000 threshold.
For a full overview of the FBAR filing process, deadlines, and requirements, see the FBAR filing guide for US expats.
FBAR vs. FATCA: Two separate reporting regimes explained
FBAR and FATCA are independent obligations – meeting one does not satisfy the other. US persons with foreign accounts or assets may need to file both FinCEN Form 114 and Form 8938, depending on their balances and filing status.
The two regimes differ in threshold, filing method, and oversight agency. The following table breaks down the key differences:
| Feature | FBAR – FinCEN Form 114 | FATCA – Form 8938 |
|---|---|---|
| Filing threshold | $10,000 aggregate across all foreign accounts at any point during the year | Varies by filing status and residence – starts at $50,000 for single filers in the US, higher for expats and joint filers |
| Where filed | BSA E-Filing System (FinCEN) – separate from your tax return | Attached to your Form 1040 (filed with the IRS) |
| Who must file | All US persons with qualifying foreign accounts | US persons with specified foreign financial assets above the threshold |
| Deadline | April 15, automatic extension to October 15 | Same as your Form 1040 due date |
Filing FBAR does not excuse you from FATCA, and filing Form 8938 does not excuse you from FBAR. If you meet both thresholds, you file both.
For a detailed comparison of FATCA and CRS reporting rules, see how FATCA and CRS reporting requirements apply to US expats.
What makes a fintech account ‘foreign’ for FBAR purposes?
For FBAR purposes, the key question is whether the account is maintained at a financial institution located outside the United States. Review the account agreement, statement, IBAN or account details, and the entity or banking partner identified for your account.
This matters for Wise and Revolut users because both platforms give US-based account features – USD balances, US routing numbers, ACH transfers – to accounts that are actually held by non-US entities.
Under the Bank Secrecy Act, FinCEN – not the IRS – administers reporting of foreign financial accounts, and the legal domicile of the institution is the determining factor.
To understand when foreign accounts may be exempt from the separate FATCA obligation, see FATCA reporting exemptions.
Wise accounts and FBAR: Which Wise entities are foreign?
Wise FBAR reporting depends entirely on which Wise legal entity holds your account. Wise operates through several entities worldwide, and not all of them are foreign for FBAR purposes.
The following Wise entities are relevant to US account holders:
- Wise US Inc. – domiciled in the United States. An account held under this entity is not a foreign account and does not trigger FBAR.
- Wise Europe SA – incorporated in Belgium, regulated by the National Bank of Belgium. This is a foreign account.
- Wise Payments Ltd – incorporated in the United Kingdom, regulated by the FCA. This is a foreign account.
- Wise Australia Pty Ltd – incorporated in Australia, regulated by ASIC. This is a foreign account.
If your Wise account is held under Wise Europe SA or Wise Payments Ltd, it is a foreign financial account and must be reported on FBAR if the $10,000 threshold is met.
Most Wise users outside the US are assigned to Wise Europe SA or Wise Payments Ltd. Even US-based users who opened accounts before Wise fully transitioned to its US entity may still have an FBAR Wise account held under a non-US entity.
To understand how fund transfers between accounts affect the maximum balance you report, see how to determine the maximum annual account balance for FBAR.
FBAR is generally filed electronically through FinCEN’s BSA E-Filing System. Paper filing is available only in limited circumstances after requesting an exemption from FinCEN’s mandatory electronic filing requirement.
Revolut accounts and FBAR: Does Revolut trigger reporting?
Revolut operates through multiple entities, and the one holding your account determines whether it counts as foreign for FBAR purposes.
The relevant Revolut entities are:
- Revolut Ltd – incorporated in the United Kingdom, authorized by the FCA as an electronic money institution. This is a foreign account.
- Revolut Bank UAB – incorporated in Lithuania, licensed as a credit institution by the Bank of Lithuania and the European Central Bank. This is a foreign account.
- Revolut Technologies Inc. – domiciled in the United States. Accounts held under this entity may not be foreign accounts for FBAR purposes.
Most Revolut accounts held by non-US residents are maintained under Revolut Ltd or Revolut Bank UAB – both foreign entities that trigger FBAR reporting when the $10,000 threshold is met.
US-based Revolut users should check which legal entity holds their account, as Revolut’s US operations continue to evolve and different customers may be onboarded through different entities.
The Revolut FBAR question is straightforward once you identify the entity: if it is located outside the US, it is generally foreign and reportable.
For context on how corporate entities file FBAR separately from individuals, see how consolidated FBAR filing works for corporate groups – individual account holders file on their own.
Does Wise report to the IRS? Does Revolut report to the IRS?
It depends on the entity and jurisdiction.
Certain Wise and Revolut entities are Foreign Financial Institutions under FATCA and may be required to report information about US account holders either directly to the IRS or through their local tax authority, depending on the applicable FATCA agreement and the entity involved.
Your obligation to self-report on FBAR exists independently of what Wise or Revolut reports. FATCA reporting by the institution covers the institution’s obligations. Your FBAR obligation is separate, personal, and filed through a different system entirely.
Foreign banks and financial institutions have been cooperating with the US government on account disclosure for over a decade.
For background on this trend, see how foreign banks are working with the US government to disclose American accounts.
Revolut CRS reporting: What US expats need to know
CRS – the Common Reporting Standard – is the international equivalent of FATCA, used by over 100 countries to exchange financial account information automatically. Revolut entities in the EU and UK participate in CRS.
CRS does not replace your US FBAR or FATCA obligations. Revolut entities in CRS jurisdictions may report account information to the tax authority in your country of residence under CRS. US tax reporting generally occurs through FATCA rather than CRS.
CRS reporting does not by itself determine whether FATCA or FBAR applies – your US reporting obligations depend on the applicable FATCA rules and whether you meet the FBAR filing requirements.
The broader trend of international tax transparency has made undisclosed foreign accounts increasingly difficult to maintain.
For context on how global information sharing has evolved, see Swiss bank account secrecy and US reporting.
Step-by-step: How to determine if your Wise or Revolut account is foreign
To report Wise and Revolut on FBAR correctly, you first need to determine whether your account is held by a foreign entity. The following five steps will tell you:
- Log in to your Wise or Revolut account and go to Account Details or Settings.
- Identify the legal entity name listed on your account – for example, Wise Europe SA, Revolut Bank UAB, or Wise US Inc.
- Look up where the entity is located. If it is outside the US, the account is generally foreign for FBAR purposes.
- Calculate your aggregate maximum balance across all foreign accounts during the 2025 calendar year. Use the highest balance each account reached at any point – not the year-end balance.
- If the aggregate exceeded $10,000 at any single point during the year, file FinCEN Form 114 by April 15, 2026. The deadline is automatically extended to October 15, 2026 – no request needed.
The single most important step is identifying the legal entity name in your account settings – that name tells you whether FBAR applies.
Wise address for FBAR: What to enter on FinCEN Form 114
FinCEN Form 114 requires the name and registered address of each foreign financial institution where you hold a reportable account. For Wise and Revolut, use the registered legal address of the specific entity holding your account:
- Wise Europe SA – Rue du Trône 100, 1050 Brussels, Belgium
- Wise Payments Ltd – London, United Kingdom (check Wise’s regulatory disclosure page for the current registered office address)
- Revolut Ltd – London, United Kingdom (check Revolut’s legal or regulatory page for the current registered office address)
- Revolut Bank UAB – Konstitucijos ave. 21B, 08130 Vilnius, Lithuania
Use the registered legal address of the Wise or Revolut entity that holds your account – not the address of a local branch or customer service office.
When completing Wise FBAR reporting, enter the entity name exactly as it appears in your account details. Use the institution’s legal name – “Wise Europe SA,” not “Wise” or “TransferWise.”
FBAR thresholds, deadlines, and filing details for 2025
The FBAR deadline for tax year 2025 is April 15, 2026, with an automatic extension to October 15, 2026 – no extension request is needed.
| Item | Detail |
|---|---|
| Aggregate threshold | $10,000 at any point during the calendar year |
| Form | FinCEN Form 114 |
| Filing deadline | April 15, 2026 – automatically extended to October 15, 2026 |
| Where to file | BSA E-Filing System at bsaefiling.fincen.treas.gov |
| Who must file | US persons with a financial interest in, or signature authority over, foreign financial accounts |
| Non-willful penalty | Up to $16,536 per report per year – per the Supreme Court’s Bittner v. United States ruling |
| Willful penalty | Greater of $165,353 or 50% of the account balance per violation |
Understanding how and when to file an FBAR for Wise accounts starts with this table. The $10,000 threshold is aggregate – it includes every foreign account you hold, not just Wise or Revolut. If you have a Wise Europe SA account, a Revolut Bank UAB account, and a traditional foreign bank account, all three balances count together.
The non-willful penalty figure reflects the inflation-adjusted amount for penalties assessed on or after January 17, 2025.
For the full history of how this per-report rule was established, see the Supreme Court ruling on FBAR penalties.
FATCA reporting for Wise and Revolut: Form 8938 requirements
In addition to FBAR, US persons may need to file Form 8938 with their federal tax return if their specified foreign financial assets exceed the applicable thresholds. The thresholds depend on your filing status and whether you live in the US or abroad:
- Single filers in the US: $50,000 at year-end or $75,000 at any time during the year.
- Single filers living abroad: $200,000 at year-end or $300,000 at any time.
- Married filing jointly, living abroad: $400,000 at year-end or $600,000 at any time.
Form 8938 is filed with your federal tax return – unlike FBAR, which is filed separately through FinCEN – and Wise or Revolut account balances count toward the FATCA threshold.
Worked example: Based on a common TFX client scenario
A US expat living in Germany holds two fintech accounts:
- A Wise Europe SA EUR account with a peak balance of €12,000 during 2025 – approximately $13,200 USD using the Treasury Bureau of the Fiscal Service’s year-end exchange rate for 2025, as instructed for FBAR reporting.
- A Revolut Bank UAB EUR account with a peak balance of €3,000 – approximately $3,300 USD.
The aggregate maximum balance across both accounts is approximately $16,500 – exceeding the $10,000 FBAR threshold. The client must file FinCEN Form 114 reporting both accounts, listing each one separately with its entity name, registered address, account number, and maximum balance. The client may also need to file Form 8938 depending on total foreign asset values and filing status.
Even if each individual account stays below $10,000, the aggregate rule means both accounts count together toward the FBAR threshold.
This is one of the most common mistakes when deciding whether to report Wise and Revolut on FBAR – checking each account in isolation rather than adding them together.
Penalties for failing to report Wise or Revolut on FBAR
The IRS imposes civil and criminal penalties for FBAR violations, scaled by whether the failure was willful:
- Non-willful failure: up to $16,536 per report per year. Following the Supreme Court’s Bittner v. United States decision, this penalty applies per annual FBAR report, not per account.
- Willful failure: the greater of $165,353 or 50% of the highest account balance per violation.
- Criminal penalties for willful failure: up to $250,000 in fines and five years of imprisonment.
- IRS Streamlined Filing Compliance Procedures: available for taxpayers whose failure was non-willful. This program covers three years of tax returns and six years of FBARs, with no penalty under the foreign track.
Failing to report a Wise or Revolut foreign account willfully can result in a penalty equal to 50% of the account balance – far exceeding the balance itself over multiple years.
The penalty figures above reflect inflation-adjusted amounts for assessments on or after January 17, 2025. For a deeper look at how courts have handled FBAR penalty disputes, see what happens when you fight FBAR penalties in court.
How to file FBAR for Wise and Revolut accounts: Step-by-step
If you need to know how to report a Wise account on FBAR – or a Revolut account – the filing process follows the same steps as any other FBAR. The difference is knowing the correct entity names and addresses.
- Gather account details for each foreign Wise or Revolut account – the legal entity name, registered address, account number, and the maximum balance during 2025.
- Convert maximum balances to USD using the Treasury Bureau of the Fiscal Service’s year-end exchange rate for 2025, as instructed for FBAR reporting. Use this rate even if the account peaked at a different time of year.
- Log in to the FinCEN BSA E-Filing System at bsaefiling.fincen.treas.gov. You can file without registering by using the no-registration option.
- Complete FinCEN Form 114 – enter one entry per foreign account. For each FBAR Wise account, enter the entity name exactly as listed in your account settings.
- Submit electronically by April 15, 2026. The automatic extension to October 15, 2026, applies – no request needed.
- Save your confirmation number and a copy of the filed report. FinCEN provides an electronic acknowledgement with a tracking number.
Wise and Revolut FBAR reporting for joint account holders
If a US person has signature authority over a joint Wise or Revolut account held with a non-US spouse or partner, the account must still be reported on FBAR. The reporting obligation applies to anyone with a financial interest in, or signature authority over, a foreign account – ownership is not required.
Signature authority alone – even without ownership – triggers FBAR reporting for Wise and Revolut accounts held jointly with a non-US person.
A non-US spouse has no FBAR obligation unless they qualify as a US person – for example, as a green card holder or resident alien under the substantial presence test.
For the full rules on joint FBAR filing, see whether your FBAR needs to include your spouse’s bank accounts.
Common misconceptions about Wise and Revolut FBAR reporting
The five most common mistakes US expats make with fintech account reporting:
- “My Wise account is in USD, so it is not foreign.” Wrong. Currency does not determine whether an account is foreign. If the entity maintaining the account is located outside the US, the account is generally foreign regardless of the currency it holds.
- “Wise gave me a US routing number, so it is a US account.” Wrong. Routing numbers are for payment rails – they identify how money moves, not where the institution is legally domiciled. A US routing number on a Wise Europe SA account does not make it domestic.
- “My balance never exceeded $10,000, so I do not need to report.” The $10,000 threshold is aggregated across all foreign accounts – not per account. If your Wise account peaked at $6,000 and your traditional foreign bank account peaked at $5,000, the aggregate is $11,000, and FBAR is required.
- “Revolut is a US company.” Most Revolut FBAR obligations arise because accounts are held under Revolut Ltd in the UK or Revolut Bank UAB in Lithuania – both foreign entities. The US Revolut entity exists but does not hold most accounts used by expats.
- “Wise or Revolut will file FBAR for me.” FBAR is the account holder’s personal obligation. No financial institution files it on your behalf.
The most common FBAR mistake with Wise accounts is assuming a US routing number means the account is domestic.
For the current penalty structure and relief options for missed filings, see the FBAR penalties guide.
Frequently asked questions
Yes, if the entity maintaining your account is located outside the US. Wise accounts need to be reported on an FBAR when held under Wise Europe SA or Wise Payments Ltd – regardless of currency. The entity’s domicile determines foreign status, not whether the account holds dollars, euros, or pounds.
The deadline is April 15, 2026, with an automatic extension to October 15, 2026. No extension request is needed – the extension applies to everyone. FBAR is filed through the FinCEN BSA E-Filing System, not with your tax return.
Certain Revolut entities are Foreign Financial Institutions under FATCA and may report your account information to the IRS or to local tax authorities who then share it with the IRS, depending on the applicable FATCA agreement and the entity involved. Whether Revolut reports to the IRS does not change your personal FBAR obligation – you must still file FinCEN Form 114 if your aggregate foreign account balances exceeded $10,000.
Use the registered legal address of the entity holding your account. For Wise Europe SA, use Rue du Trône 100, 1050 Brussels, Belgium. For Wise Payments Ltd, use the current registered office in London – check the Wise address for FBAR on Wise’s regulatory disclosure page. Do not use a customer service or branch address.
Yes. FBAR – FinCEN Form 114 – is filed separately with FinCEN and has a $10,000 aggregate threshold. FATCA – Form 8938 – is filed with your tax return and has higher thresholds starting at $50,000 for US residents and $200,000 for expats. Filing one does not satisfy the other. If you meet both thresholds, you must file both forms.
If your failure was non-willful, the appropriate compliance option depends on your circumstances. Taxpayers who properly reported all taxable income and are not under IRS civil or criminal examination should generally file delinquent FBARs as soon as possible under the IRS’s delinquent FBAR procedures, if applicable. If foreign income or other reporting was omitted, the IRS Streamlined Filing Compliance Procedures or another IRS compliance option may be more appropriate. Do not file late FBARs as a quiet disclosure – the IRS does not treat that as a formal compliance path.
It depends on your total foreign accounts. The $10,000 threshold is aggregate – it includes every foreign account you hold, not just your Wise account. If your Wise Europe SA account peaked at $4,000 but you also had $7,000 in a foreign bank account, the aggregate is $11,000 and you must report Wise and Revolut on FBAR along with every other foreign account that year.
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