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Topic · Denmark

FBAR for Americans living in Denmark

Which Danish accounts count toward the $10,000 FinCEN 114 threshold, how the aggregate peak is measured in kroner, and what Skattestyrelsen has nothing to do with.

By Danilson Ramos · Founder, Atamatax

Published August 2026 · Updated September 2026

Part of the Denmark desk — every US tax topic for Denmark in one place.

Check it for your own accounts

Do you need to file an FBAR?

Three questions, no balances typed, no email. The read explains the aggregate rule — the part most people get wrong — and what would settle the rest.

Free, no account, nothing you answer leaves this page. Open the full FBAR / Form 8938 checker

Are you a US person?

A US citizen, a green-card holder, or a US resident for the year.

Do you have financial accounts outside the US?

Bank, savings, brokerage, a pension with a cash value, a fintech balance held by a non-US entity.

A threshold screen, not a filing determination. Three answers cannot establish whether a specific account is reportable; the full checker and the account's own terms can.

Denmark is a near-cashless, account-dense country: a NemKonto for public payments, a lønkonto for salary, a budgetkonto, often an Aktiesparekonto and a brokerage account, plus pension arrangements. Each of those is a candidate foreign financial account for U.S. reporting, and the FBAR test adds them together.

When does an American in Denmark have to file an FBAR?

Generally, when the combined maximum value of all your non-U.S. financial accounts exceeded $10,000 at any point during the calendar year. It is the peak, not the year-end balance, and it is measured across every account you own or can sign for — not account by account.

A single kroner account that peaked at DKK 60,000 looks harmless. Three of them at the same time do not: $10,000 is the aggregate.

Which Danish accounts typically count

  • Bank accounts at Danske Bank, Nordea, Jyske Bank, Sydbank, Nykredit, Arbejdernes Landsbank, Lunar or Coop Bank — including a NemKonto and a budgetkonto
  • Brokerage accounts at Saxo Bank, Nordnet or a Danish bank's investment platform
  • An Aktiesparekonto, which is a Danish account holding securities, not a tax wrapper the IRS recognises
  • Many pension arrangements held with a pension company or bank, where you have an account-like interest
  • Accounts you do not own but have signature authority over — a Danish employer account, an association's account, or a parent's account you can sign for

How to convert kroner to dollars for the FBAR

The FBAR uses the Treasury Reporting Rates of Exchange for December 31 of the reported year — not the IRS yearly-average rate your Form 1040 uses for income. Take each account's maximum DKK balance during the year and convert it at that single year-end rate. Using the yearly average here is one of the most common technical errors on a Danish FBAR.

The FBAR is not Form 8938, and neither is Danish

FBAR (FinCEN 114)Form 8938 (FATCA)
Filed withFinCEN, via the BSA E-Filing SystemYour Form 1040
Threshold$10,000 aggregate peak, any filing statusFrom $200,000 year-end / $300,000 peak for a single filer abroad
ScopeFinancial accountsSpecified foreign financial assets, which is broader
Danish equivalentNone — Denmark has no counterpart filingNone

Danish tax reporting runs on its own track. Skattestyrelsen pre-populates your årsopgørelse from information Danish institutions send it; that has no bearing on whether you owe FinCEN a report. Many Americans in Denmark file both the FBAR and Form 8938, and the two overlap without being the same.

What Danish banks already report about you

Denmark and the United States have a FATCA intergovernmental agreement, so Danish financial institutions identify U.S. account holders and report them. If a Danish bank has asked you to confirm U.S. status or complete a W-9, that is the mechanism. It means the account information is already moving, which is worth knowing before deciding what to do about past years.

What to gather

  • Each institution's name and address, and the account number
  • The maximum value in DKK during the year — most Danish banks show this in netbank under årsoversigt
  • Whether the account is owned, jointly owned, or only signature authority
  • The December 31 Treasury rate for DKK for that year

Check your Danish accounts against both thresholds

The free checker takes your balances and filing status and shows whether FinCEN 114, Form 8938, or both are in play. This is general information, not individualised tax advice.

Check FBAR & Form 8938 thresholds

Authorities cited

  • 31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
  • FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
  • 31 U.S.C. §5314 — 31 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
  • IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
  • IRC §6038D — IRC §6038D — Information reporting of specified foreign financial assets (Form 8938)

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.

Frequently asked questions

Do Danish bank accounts count for the FBAR?#
Generally yes. A Danish bank account is a foreign financial account, and its maximum value during the year counts toward the $10,000 aggregate test. That includes an everyday lønkonto and a NemKonto — the account's purpose does not exempt it.
Does an Aktiesparekonto go on the FBAR?#
An Aktiesparekonto is an account at a Danish bank or broker holding securities, so it is generally reportable as a foreign financial account and its maximum value counts toward the aggregate. Denmark's favourable treatment of the wrapper does not change U.S. reporting; the underlying holdings raise a separate PFIC question.
Are Danish pensions reported on the FBAR?#
It depends on the arrangement. Where you hold an account-like interest with a Danish pension provider, it is commonly treated as reportable; some employment-related arrangements are analysed differently. Because the answer turns on the specific scheme and your interest in it, this is worth confirming rather than assuming either way.
What exchange rate do I use for kroner?#
The Treasury Reporting Rates of Exchange for December 31 of the year being reported, applied to each account's maximum DKK balance. This differs from the IRS yearly-average rate used for income on Form 1040.
What if my Danish accounts never reached $10,000?#
An FBAR is generally not required for a year in which the combined maximum never crossed $10,000. Test the aggregate, not each account, and remember the test is the highest point in the year rather than the balance on 31 December.
I have missed FBARs for years in Denmark — what now?#
Established catch-up pathways exist for taxpayers whose failure to file was non-willful, and the right one depends on your facts. The Streamlined Foreign Offshore Procedures are the common route for Americans living abroad. Atamatax provides preparation support; it is not legal advice, and willfulness is a legal judgement.

Related guides

Preparation · price before you start

If you want the return and the account reporting prepared

Which route fits depends on a few facts, not on the balances. These are the common situations and the route the same rules give each one. Nothing is charged until you generate a package or accept a written quote.

  1. Returns up to date, accounts over the thresholds, no non-US funds

    Simple · $299 · Self-serve preparation

    The threshold is met and no non-US fund is in play: the Simple package prepares the return with the FBAR and Form 8938 logic inside it.

    What arrives, who prepares and checks it, and who files

    A draft filing package for one tax year: Form 1040 and the supported schedules, Form 1116 inputs, FBAR/Form 8938 threshold logic and filing instructions — with every assumption disclosed.

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Start a Simple return

  2. Every return was filed; only the FBARs were missed

    Simple · $299 · Self-serve preparation

    Your returns appear current and only FBARs were missed. Late FBARs are filed with FinCEN directly, with the reason for filing late and a reasonable-cause statement, so the annual package covers the return side. The threshold is met and no non-US fund is in play: the Simple package prepares the return with the FBAR and Form 8938 logic inside it.

    What arrives, who prepares and checks it, and who files

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Start a Simple return

  3. The accounts hold non-US funds or ETFs

    PFIC Portfolio · $499 · Self-serve preparation

    Non-US funds mean Form 8621 wherever a holding is a PFIC. The PFIC package screens each one from its domicile and drafts the form only where it applies.

    What arrives, who prepares and checks it, and who files

    Everything in Simple plus up to 25 supported Forms 8621 with QEF / mark-to-market / §1291 inputs per holding, fund-domicile classification with confidence shown, and the assumption log — for one tax year.

    The Atamatax engine prepares a draft package from the figures you enter and confirm. No person prepares it.

    Nobody at Atamatax reviews it before you download it. A package generated with an open gap is stamped DRAFT — INCOMPLETE and lists what must be resolved, and every assumption is listed for you, or a professional you choose, to check.

    You file — the return with the IRS using the package's instructions, the FBAR on FinCEN's BSA E-Filing System — or a professional you engage files for you. Atamatax transmits nothing to the IRS or FinCEN.

    Prepare my PFIC portfolio

  4. Returns are missing too, not only the FBARs

    Streamlined Essential · $1,590 · Scoped by hand

    Wages, pensions or bank accounts with no non-US funds is the standard catch-up scope: three returns, six FBARs, and the certification package.

    What arrives, who prepares and checks it, and who files

    A Streamlined Foreign Offshore preparation package: up to three delinquent returns and six FBAR years as worksheets mapped to each year's official forms (official PDFs for the current filing year), a document completeness check, the Form 14653 organiser, and filing instructions — one scoped quote, one payment.

    A person at Atamatax prepares the three returns, the six FBAR years and the Form 14653 organiser from your documents, against the written scope, with the engine computing the figures. You write your own statement of facts.

    A person at Atamatax checks the package for completeness before release — an operational check, not a review by a credentialed tax professional. No EA or CPA review is included unless your written scope names one.

    You mail the returns to the IRS as the Streamlined instructions direct, and file the FBARs on FinCEN's BSA E-Filing System. Atamatax transmits nothing to the IRS or FinCEN.

    Get a scoped quote

When a professional's judgment is needed. Missed years beyond the FBARs, a foreign pension whose US treatment is unsettled, or an IRS letter about the accounts are read by a person before a route is chosen — the account reporting is the easy part; what the accounts earned is the part that needs judgment.

In every route the signatures and the filing stay with you or the accountant you choose; nothing is filed on your behalf. Written questions to hello@atamatax.com get a reply within one business day. Who does what in each route.

Free preliminary result · a few questions

See which foreign-account filings may apply to you

The FBAR and Form 8938 have different thresholds, different definitions and different penalties. A few questions show which one — or both — your accounts point at, and what else rides along.

Check my foreign-account filingsNo signup. Answers stay yours.

Your next step · free

Do your accounts cross the threshold?

Enter each account's highest balance as a band. The checker runs the FBAR aggregate and the Form 8938 threshold for your filing status and where you live, and says which form — or both — the numbers point at. Free, no account.

Check my FBAR and Form 8938 thresholdsThe Denmark country desk
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