FBAR Filing Guide: Report of Foreign Bank Accounts (FinCEN 114)

If you are a US citizen or green card holder living abroad, you have likely heard of the FBAR — or at least been warned about it. The Report of Foreign Bank and Financial Accounts, officially known as FinCEN Form 114, is one of the most important annual compliance obligations for Americans with financial accounts outside the United States. Failing to file can result in severe penalties, even if you owe no tax at all.

This guide covers everything you need to know: who must file, how the $10,000 threshold works, which accounts count, how to file, key deadlines, penalties, and how the FBAR compares to FATCA (Form 8938).

What Is the FBAR?

The FBAR is not a tax form. It is a reporting form required by the Bank Secrecy Act and filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury. It is entirely separate from your federal income tax return filed with the IRS.

The purpose of the FBAR is to help the US government detect and prevent money laundering, tax evasion, and other financial crimes. By requiring US persons to disclose their foreign accounts, the government maintains visibility into assets held outside the US banking system.

FinCEN Form 114 replaced the older TD F 90-22.1 paper form in 2013. Today, the FBAR is filed exclusively online through the BSA E-Filing System.

Who Must File an FBAR?

You must file an FBAR if you are a US person and you had a financial interest in, or signature authority over, one or more foreign financial accounts with an aggregate value exceeding $10,000 at any point during the calendar year.

A "US person" includes:

• US citizens (including those living abroad)
• US residents and green card holders
• Entities organized in the United States (corporations, partnerships, LLCs, trusts, estates)

Importantly, the filing obligation applies regardless of whether the accounts produce any taxable income. Even a dormant savings account with no interest and no activity triggers the requirement if it pushes your aggregate balance over the threshold.

The $10,000 Threshold: How to Calculate It

The $10,000 threshold is an aggregate figure. You do not look at each account individually. Instead, you add up the maximum balance of every foreign account you held during the year and check whether that combined total exceeds $10,000 on any single day.

Here is how to calculate it step by step:

• Identify all foreign accounts you held at any point during the year, even accounts you closed mid-year.
• Determine the maximum balance for each account during the year. This is the highest value the account reached at any point, not the year-end balance.
• Convert to US dollarsusing the Treasury Department's year-end exchange rate (also called the "Treasury Reporting Rate of Exchange"). FinCEN publishes these rates at fiscaldata.treasury.gov.
• Add them up. If the combined total exceeds $10,000 on any single day, you must report all foreign accounts — not just the ones that individually exceeded $10,000.

For example, if you have a French bank account with a maximum balance of EUR 6,000 and a German brokerage account that peaked at EUR 5,000, your aggregate easily exceeds the threshold even though neither account individually reached $10,000.

What Accounts Must Be Reported?

The FBAR covers a broad range of foreign financial accounts. "Foreign" means the account is held at a financial institution located outside the United States. The following account types must be reported:

• Bank accounts — checking, savings, and term deposits at foreign banks
• Brokerage accounts — securities and investment accounts held outside the US
• Mutual funds — shares in foreign mutual funds or pooled investment vehicles
• Foreign retirement accounts — pension plans, provident funds, and retirement savings accounts in other countries (e.g., French PEA, UK ISA, German Riester)
• Foreign life insurance with a cash surrender value — whole life or endowment policies held with a foreign insurance company
• Accounts with signature authority — even if you have no financial interest, you must report accounts over which you have the power to control the disposition of funds (e.g., a corporate account you manage for your employer)

A common question among US expats in Europe is whether everyday accounts count. The answer is yes. Your French Livret A, your German Girokonto, your Dutch savings account — they all count toward the aggregate threshold. For more on managing multi-country finances, see our dedicated guide.

How to File Your FBAR

The FBAR is filed electronically through the BSA E-Filing System at bsaefiling.fincen.treas.gov. There is no paper filing option — electronic submission is mandatory.

The process is straightforward:

• Go to the BSA E-Filing website and select "File FinCEN Report".
• Choose "FinCEN Report 114" (FBAR).
• Fill in your personal information (name, SSN/ITIN, address).
• Enter each foreign account: institution name, account number, country, account type, and maximum balance during the year.
• Submit electronically. You will receive a confirmation number — save it for your records.

Filing is completely free. You do not need to attach any supporting documents, bank statements, or receipts. However, you should keep your records for at least five years from the filing date in case of an audit.

You can also authorize a third party (such as a tax preparer or CPA) to file on your behalf by completing FinCEN Form 114a.

FBAR Deadlines

The FBAR is due on April 15 of the year following the reporting year. So for the 2025 tax year, the FBAR is due April 15, 2026.

If you miss the April deadline, there is an automatic extension to October 15. You do not need to file a request or submit any paperwork — the extension is granted automatically to all filers. There is no penalty for using the automatic extension.

This is different from your tax return, where you generally need to file Form 4868 to request an extension. For the FBAR, the October 15 extension is built in.

Penalties for Non-Filing

FBAR penalties are among the harshest in the US tax compliance landscape. The government takes foreign account reporting seriously, and the penalty structure reflects that.

Non-Willful Violations

If you failed to file but the IRS determines the failure was not willful (i.e., you did not intentionally disregard the requirement), the penalty is up to $10,000 per violation. Each unreported account in each year can be treated as a separate violation.

Willful Violations

If the failure is found to be willful — meaning you knew about the requirement and chose not to comply — the penalty jumps dramatically: up to $100,000 or 50% of the account balance at the time of the violation, whichever is greater. This penalty applies per account, per year.

Criminal Penalties

In extreme cases, willful failure to file an FBAR can result in criminal prosecution, with fines up to $500,000 and imprisonment of up to 10 years.

Streamlined Filing Compliance Procedures

If you have been living abroad and were not aware of your FBAR obligations, the IRS offers the Streamlined Filing Compliance Procedures. This program allows qualifying taxpayers to file delinquent FBARs (and tax returns) with reduced or eliminated penalties, provided the failure was non-willful. For expats living abroad, the Streamlined Foreign Offshore Procedures require no penalty payment at all — you simply file the missing returns and FBARs.

This program is an important lifeline for the many Americans abroad who only learn about FBAR requirements years after moving overseas. If you are in this situation, consult a tax professional experienced with US expat tax obligations to evaluate whether the Streamlined Procedures are right for you.

FBAR vs. FATCA: Key Differences

The FBAR and FATCA (Form 8938) both deal with foreign financial accounts, but they are separate obligations with different rules. Many expats must file both. Here is how they compare:

Many expats with significant foreign accounts must file both forms. The overlap can be confusing, but the key takeaway is: the FBAR has a much lower threshold ($10,000 vs. $200,000 for expats) and much steeper penalties for willful violations.

Common FBAR Mistakes to Avoid

Even well-intentioned filers make errors. Here are the most frequent mistakes we see among US expats:

• Not including all accounts. You must report every foreign account — checking, savings, brokerage, retirement, insurance. If you have accounts in multiple European countries, each one counts.
• Using the wrong exchange rate. The FBAR requires Treasury year-end rates, not the spot rate on the day of the maximum balance. Using a different source (Google, XE, your bank) can produce incorrect values.
• Forgetting joint accounts. If you hold a joint account with your spouse, both of you must report the full balance of the account on your respective FBARs (unless you file a joint FBAR).
• Not reporting zero-balance accounts. If an account existed during the year, you must report it — even if the balance dropped to zero or the account was closed before year-end.
• Ignoring signature authority accounts. If you can control the funds in a foreign account (e.g., a business account you manage), it is reportable even if you have no personal financial interest.
• Confusing FBAR with FATCA. Filing Form 8938 does not satisfy your FBAR obligation, and vice versa. They are separate filings with different agencies.
• Reporting year-end balances instead of maximum balances. The FBAR asks for the highest balance during the year, which may occur at a completely different time than December 31.

How ExpatFolio Helps with FBAR Compliance

Tracking maximum balances across multiple countries, currencies, and account types is tedious and error-prone when done manually. This is exactly the problem ExpatFolio was built to solve.

• Automatic aggregate balance calculation. ExpatFolio tracks all your foreign accounts in one dashboard and computes your aggregate maximum balance in real time, converting each account to USD using the correct exchange rates.
• Threshold monitoring. The compliance page shows exactly where you stand relative to the $10,000 FBAR threshold (and the FATCA thresholds). You will know immediately whether you need to file.
• Deadline reminders. ExpatFolio sends automated reminders as the FBAR deadline approaches, so you never miss a filing date.
• Multi-currency support. Whether you hold accounts in euros, pounds, Swiss francs, or any other currency, ExpatFolio handles the conversion and aggregation automatically.
• Historical snapshots. Daily balance snapshots give you an accurate record of your maximum balances throughout the year — no more scrambling through bank statements every April.

Combined with our FATCA compliance tracking and country-specific tax guides, ExpatFolio gives US expats a single place to stay on top of all their cross-border financial obligations.

Sources & Methodology

This guide is based on official IRS and FinCEN publications. Key sources include:

• FinCEN — FBAR filing instructions and BSA E-Filing
• IRS Publication 54 — Tax Guide for U.S. Citizens and Resident Aliens Abroad
• 31 USC § 5314 — Records and reports on foreign financial agency transactions
• 31 CFR § 1010.350 — Reports of foreign financial accounts (FBAR regulations)

Last reviewed: March 2026. This guide is for informational purposes only and does not constitute tax or legal advice.