FBAR for US Citizens Living Abroad: Who Must File (2026)

Reader, before you start: this article assumes you are a US citizen or green-card holder who already has — or is about to open — at least one bank account outside the United States. If you have no foreign account, you have no FBAR to file. This is a US reporting obligation only; it has nothing to do with your host country’s tax office.

What this guide covers

You opened a bank account abroad, someone in an expat forum said the letters “FBAR,” and now you are quietly wondering whether you have already broken a law you never heard of. Take a breath. For most people this is a free online form that takes under an hour, filed once a year, with no tax attached to it.

This guide answers the panicked question competitors dance around — do I have to file this, and how, without paying a firm?

• Whether you must file at all (the $10,000 rule, and the two words inside it that trip everyone up)
• How FBAR differs from your tax return and from Form 8938
• How to file it yourself, free, step by step, and by when
• What to do if you just found out you should have been filing for years

The 60-second answer

You almost certainly must file an FBAR if both of these are true:

1. You are a “US person” — a US citizen, a green-card holder, or a resident alien.
2. The combined value of all your foreign financial accounts topped $10,000 at any single moment during the calendar year — even for one day.

If that is you, you file FinCEN Form 114 electronically, for free, through the Treasury’s BSA E-Filing System. It is not part of your tax return and you do not mail anything to the IRS. The rule and the form are confirmed on the IRS FBAR page.

The rest of this guide is the detail behind those two sentences.

What FBAR actually is (and what it is not)

FBAR stands for the Report of Foreign Bank and Financial Accounts. It is filed on FinCEN Form 114 and goes to the Financial Crimes Enforcement Network — a bureau of the US Treasury, separate from the IRS return system. That separation matters and explains a lot of the confusion below.

FBAR is a disclosure, not a tax. Filing it does not create a tax bill. You are telling the Treasury where your foreign accounts are and how much sat in them; you are not paying anything for the privilege. The form is free.

Who counts as a “US person”

The obligation follows your status, not your address. Per the IRS, a US person includes:

• US citizens — including dual citizens and citizens who have never lived in the US
• Lawful permanent residents (green-card holders)
• Resident aliens who meet the substantial-presence test
• Certain US entities (corporations, partnerships, LLCs, trusts, estates)

Living abroad does not exempt you. A US citizen in Berlin with a German checking account is in exactly the same position as one in Boston who opened an account on a trip to Mexico.

Why this exists even if you owe $0 in US tax

People assume that if they are under the income-tax filing threshold, or if the Foreign Earned Income Exclusion wipes out their US tax, the FBAR goes away too. It does not. FBAR is an informational report run by a different agency for a different purpose — tracking money, not collecting tax. You can owe the IRS nothing and still be required to file an FBAR. The two obligations are decided separately.

Do you have to file? The $10,000 aggregate trap

This is the single most misunderstood point on the whole topic, so it gets its own callout.

The trap, in one example. You have $6,000 in a German savings account and $5,000 in a Wise balance. Neither account alone crossed $10,000. But FBAR looks at the aggregate — all foreign accounts added together. $6,000 + $5,000 = $11,000. You must file, and you report both accounts, even the one with $5,000.

Two words inside the rule do the damage:

• Aggregate — you add up every foreign account you have. The threshold is not per account. It is the total.
• At any time — you use each account’s highest balance during the year, not the year-end balance. If your accounts briefly totaled $10,001 on one day in March because a property deposit was passing through, you crossed the threshold, even if you ended December near zero.

That “at any time” wording is deliberate. It is an anti-structuring design — it stops people from dodging the report by shuffling money between accounts or timing balances around a single reporting date.

You also count accounts you do not own but have signature authority over — for example, a foreign company account you can sign on, or a parent’s overseas account you manage. The IRS FBAR page sets out both the financial-interest and the signature-authority tests.

What counts as a “foreign financial account”

More than people expect. The category covers:

• Checking and savings accounts at a non-US bank
• Brokerage and securities accounts held abroad
• Many foreign pension and certain insurance accounts with a cash value
• Money held in foreign-based money-service apps and neobanks — a balance held in a non-US e-money institution is generally reportable

The deciding factor is whether the account is held at an institution located outside the United States, not the currency or the app’s branding. A Revolut or Wise balance held through a non-US entity is the kind of account readers most often overlook. If you are unsure whether a specific fintech balance is “foreign” for FBAR purposes, check the current IRS FBAR guidance or ask a cross-border preparer before you decide it does not count.

What is exempt

Not everything foreign is reportable. The IRS lists exceptions, including:

• Accounts held at a US branch of a foreign bank (and foreign branches of a US bank are treated as foreign)
• Certain accounts owned by an IRA, or held by a beneficiary of a tax-qualified retirement plan
• Some accounts held jointly by spouses, where one spouse can report both on a single FBAR using Form 114a to authorize it
• Correspondent or “Nostro” accounts, and accounts owned by a governmental entity

The exceptions are narrower than they look. When in doubt, the safe default is to report the account — there is no penalty for over-reporting, only for leaving one off.

FBAR vs. Form 8938 (FATCA) — they are different forms

Many Americans abroad must file both. Some only need the FBAR. They are not the same form, they go to different places, and they have different thresholds. Confusing them is the most common error in competitor guides.

	FBAR (FinCEN Form 114)	Form 8938 (FATCA)
Who runs it	FinCEN / Treasury	IRS
Where you file it	BSA E-Filing System, separately	With your federal tax return
Threshold (living abroad, single)	$10,000 aggregate, at any time	$200,000 on the last day, or $300,000 at any time
Threshold (living abroad, married filing jointly)	$10,000 aggregate, at any time	$400,000 on the last day, or $600,000 at any time
What it reports	Foreign bank and financial accounts	Foreign financial assets (broader)

Thresholds confirmed on the IRS comparison page. The short version: the FBAR threshold is low and account-based; the Form 8938 threshold is much higher and asset-based. Crossing $10,000 is common. Crossing $200,000 is not. So most filers who must do Form 8938 also owe an FBAR — but plenty of people owe only the FBAR.

How to file FBAR — free, yourself, step by step

This is the part the lead-gen firms bury, because they sell the service. You do not need them for a straightforward case. You file directly on the Treasury’s portal.

What to gather before you start

Have these ready for each account:

• The institution’s name and address
• The account number
• The account type (bank, securities, other)
• The maximum value the account reached during the year, converted to US dollars

For the dollar conversion, the IRS directs filers to use the Treasury’s year-end exchange rate for the relevant currency. Convert each account’s peak balance to USD using that rate, then keep your worksheet — you will not upload it, but you want a record of how you arrived at each figure.

The steps

1. Go to the BSA E-Filing System — the official Treasury portal at bsaefiling.fincen.gov. Individuals can file without registering, using the online FinCEN Form 114.
2. Open the individual FBAR (Form 114). Choose the option to file as an individual.
3. Enter your information and each account. Add every reportable account, with the institution details and the maximum USD value during the year.
4. Sign and submit. You will get a confirmation on screen and a confirmation email with a BSA Identifier. Save both.
5. Keep your records for five years — the supporting account statements and your conversion worksheet, in case the filing is ever reviewed.

Filers consistently report that a simple case — one or two accounts, no signature-authority complications — takes roughly 20 to 60 minutes the first time and less in later years once the format is familiar.

The deadline

The FBAR is due April 15. If you miss it, there is an automatic extension to October 15 — you do not have to request it and you do not file any form to get it. The deadline and automatic extension are stated on the IRS FBAR page. In practice the FBAR rides along with the same mid-April / mid-October rhythm as your tax return, but remember it is filed separately.

What if I never filed? The honest off-ramp

If you just learned this rule applies to you and realized you should have filed for past years, do not panic, and do not let a fear-based sales page rush you into the most expensive option. There are calm, official paths back.

FBAR penalties are real and can be significant, with much steeper amounts possible for willful violations than for non-willful ones. That willful/non-willful line is a legal judgment, and it is exactly where a cross-border CPA or tax attorney earns their fee. This guide does not put a dollar figure on the penalty — the civil amounts are inflation-adjusted and the willfulness analysis is fact-specific. Read the current figures on the IRS site and get advice before assuming the worst.

Two official procedures exist for people who simply did not know:

• Delinquent FBAR Submission Procedures — for filers who missed FBARs but properly reported and paid tax on the account income, and who are not under examination. You e-file the late FBARs through the BSA system, select a reason for late filing on the cover page, and the IRS will not impose a penalty where the income was correctly reported.
• Streamlined Filing Compliance Procedures — for non-willful filers who also missed tax returns or under-reported foreign income, not just FBARs. These require certifying that the failure was non-willful — “negligence, inadvertence, or mistake,” or a good-faith misunderstanding of the law.

The honest rule of thumb: if you owed no extra US tax and just missed the form, the Delinquent FBAR path is usually the right, low-drama fix. If you also have unfiled or wrong returns, that is Streamlined territory, and it is worth paying a professional to do once and do right.

Frequently asked questions

Who has to file an FBAR?

Any US person — citizen, green-card holder, resident alien, or certain US entities — whose foreign financial accounts had a combined value over $10,000 at any time during the calendar year. The obligation depends on your status and your account balances, not on where you live or whether you owe US tax.

Is the $10,000 threshold per account or total?

Total. You add up the highest balance of every foreign account during the year. If the combined peak crossed $10,000 — even on a single day, even if no individual account did — you must file, and you report every account, not just the ones over $10,000.

What is the difference between FBAR and Form 8938?

They are separate forms run by different agencies. The FBAR (FinCEN Form 114) goes to the Treasury through the BSA E-Filing System, separate from your tax return, with a $10,000 account threshold. Form 8938 goes to the IRS with your tax return and has far higher thresholds ($200,000+ for a single filer abroad). Many Americans abroad file both; some file only the FBAR.

When is the FBAR due in 2026?

April 15, with an automatic extension to October 15 if you miss it. You do not need to request the extension or file anything to get it — it is granted automatically.

Do I have to file if I am under the income-tax filing threshold?

Yes. FBAR is decided independently of your tax return. You can owe the IRS nothing, or be below the income-tax filing threshold, and still be required to file the FBAR if your foreign accounts crossed $10,000.

Does a Wise or Revolut balance count?

Often, yes. A balance held through a non-US entity is generally a foreign financial account for FBAR purposes, regardless of the app’s branding. If you are unsure how a specific fintech balance is structured, confirm against current IRS FBAR guidance or ask a cross-border preparer before deciding it is exempt.

How do I file an FBAR for past years I missed?

Through the Delinquent FBAR Submission Procedures if you reported and paid tax on the account income and are not under audit. If you also missed returns or under-reported foreign income, the Streamlined Filing Compliance Procedures are the non-willful path. Talk to a cross-border CPA before choosing.

Next steps

If you have a foreign account and your combined balances crossed $10,000 at any point last year, your next move is simple: open the BSA E-Filing System, file the individual Form 114, and save the confirmation. For most people that closes the loop for the year. If you are behind, start with the Delinquent FBAR procedure and bring in a professional only if returns are involved.

The accounts that trigger this are the ones you opened while settling in abroad. If you are setting up in Mexico, the CURP, RFC, and bank-account guide walks through the local account that lands you here. New Zealand migrants hit it through the IRD number and bank account process. The classic FBAR scenario is a Swiss account opened during a first-week move to Switzerland. And if you run a US-side tax ID alongside this, the ITIN application guide is the sibling piece on the IRS side of your paperwork.

This guide is general information, not individualized tax or legal advice. Confirm current figures on IRS.gov, and see a cross-border CPA before filing if you are behind or your situation is complex.

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Sources

• IRS — Report of Foreign Bank and Financial Accounts (FBAR) — accessed 2026-06-19
• IRS — Comparison of Form 8938 and FBAR Requirements — accessed 2026-06-19
• FinCEN — BSA E-Filing System — accessed 2026-06-19
• IRS — Delinquent FBAR Submission Procedures — accessed 2026-06-19
• IRS — Streamlined Filing Compliance Procedures — accessed 2026-06-19