Foreign bank account reporting (FBAR FinCEN)

An FBAR (FinCEN Form 114, "Report of Foreign Bank and Financial Accounts") is an annual report of foreign bank, brokerage, and similar accounts held outside the US, required from any US person — citizen, green card holder, resident alien, or US entity — who has a financial interest in or signature authority over at least one foreign account. It's filed with FinCEN, not the IRS, and it's completely separate from your income tax return — you can owe zero US tax and still have an FBAR obligation simply because of where your money is held. See the full FBAR definition and filing requirements for how it differs from the related Form 8938.

$10,000 — but it's an aggregate threshold across every foreign account you hold, not a per-account limit, and it's based on the highest combined balance at any single point during the year, not the year-end total. That means three accounts worth $4,000 each ($12,000 combined) all become reportable, even though no individual account comes close to $10,000 on its own. A balance that briefly spiked above the threshold for even one day and dropped back down still triggers the requirement — see the full FBAR filing guide for how the aggregate calculation works across multiple accounts.

Bank checking and savings accounts, brokerage and securities accounts, mutual funds, foreign pension or retirement accounts, cash-value life insurance policies, and foreign-entity fintech accounts (like Wise or Revolut, depending on which entity holds the funds) are all reportable once your combined foreign accounts cross the $10,000 threshold. One common exception worth knowing: directly held foreign stock certificates, without a custodial brokerage account holding them, generally aren't FBAR-reportable on their own. Since the definition covers accounts you merely control as well as ones you own, the full rules on financial interest versus signature authority are worth checking if you manage an account you don't personally own.

The FBAR covering your 2025 foreign accounts is due April 15, 2026, but every filer automatically receives an extension to October 15, 2026 — no form, no request, and no application to FinCEN required. This automatic extension applies uniformly to everyone, unlike the separate application-based extensions that apply to your income tax return, which makes the FBAR one of the few US filing deadlines expats don't have to actively request more time for. See the full FBAR filing guide for how this deadline interacts with your income tax filing timeline.

You file FinCEN Form 114 electronically through the BSA E-Filing System at bsaefiling.fincen.gov — not through the IRS or as part of your Form 1040 — and filing itself is completely free. You'll need the maximum value each account reached during the year, converted to US dollars, along with each institution's name, address, and your account number for every account you're reporting. See the full FBAR filing guide for the exact information the form requires before you start.

Yes — if you're the US person on the account, you must file and report the full account balance, not just your half, and you can't use the FBAR's spousal joint-filing exception to let your spouse file on your behalf, because that exception only applies when both spouses are US persons. Your non-US spouse has no FBAR obligation of their own on that account, but your obligation isn't reduced by their ownership share — each US person with financial interest in a joint account reports 100% of its maximum value, not a proportional split. See the full rules on filing FBAR jointly for exactly when the spousal exception does and doesn't apply.

It depends heavily on willfulness: a non-willful violation currently costs up to $16,536 per violation (adjusted annually for inflation), while a willful violation costs the greater of $165,353 or 50% of the account balance at the time of the violation — and following the Supreme Court's 2023 ruling in Bittner v. United States, the non-willful penalty is assessed per report, not per unreported account, which meaningfully limits the total exposure for someone with several small accounts. Willful violations can also carry criminal penalties of up to $250,000 and 5 years in prison ($500,000 and 10 years if paired with certain other violations). FBAR penalties are assessed independently of any income tax penalties you might also owe. See the full FBAR penalty breakdown and the Bittner ruling explained for the full picture.

Often, yes — if your non-filing wasn't willful and you come forward before the IRS contacts you first, catching up through the delinquent FBAR procedure or establishing reasonable cause can result in no penalty at all, even though there's no guaranteed outcome once the IRS has already reached out. The dedicated IRS.gov page describing this "no penalty if reasonable cause exists" pathway was removed around mid-2026, but the underlying relief still exists in IRS internal guidance — it's just less publicly documented than before, which makes getting this right the first time more important, not less. See the full delinquent FBAR submission procedures and the reasonable cause standard for how to qualify.

Often, yes — a foreign pension with a cash surrender value held at a non-US bank or insurer, or a self-directed pension holding its own foreign bank or brokerage account (common structures like a UK SIPP or Swiss Pillar 3a), typically counts as a foreign account once the total crosses $10,000, alongside your other foreign accounts. This is a separate question from whether the pension itself is taxable income or requires Form 8938 — filing one of these doesn't satisfy the other, and a pension can trigger all three obligations independently. See the full foreign pension reporting guide for how specific plan structures are treated.