Do Wise, Revolut and other fintech accounts go on the FBAR?

Yes. The FBAR (FinCEN Form 114) reports financial accounts held at institutions located outside the United States. An e-money or payments account is a financial account, and whether the app feels like a bank is beside the point — what matters is where the institution that holds the balance is located.

That is why the same app can produce opposite answers for two people: a Wise or Revolut customer onboarded by the provider's US entity holds a US account, and a customer of the same app onboarded by its Belgian, Lithuanian or UK entity holds a foreign one.

The legal entity named on your account statement, in the app's terms of service or in its legal documents. Not the IBAN prefix (a Belgian entity can issue accounts with non-Belgian details), not the currency of the balance, and not the country you live in now.

Most providers assign the entity from the address you registered with, and several moved whole customer groups between entities in recent years. The table below lists the entities the registry knows; your own statement is the only source that settles it.

If a non-US entity holds it, every balance in it counts toward the $10,000 trigger. The test is the combined highest value of all your non-US accounts at any point in the year — not the year-end balance and not any one account on its own. A salary that sat in a Wise balance for a day counts at that day's value.

Once the aggregate crosses the trigger, every non-US account is listed on the FBAR, including ones whose own balance never got anywhere near it.

The FBAR asks for each account's maximum value during the year in US dollars, converted at the Treasury's year-end exchange rate for each currency. Whether a multi-currency account is one line or several depends on how the provider structures it: a single account with currency pockets is usually one account at its combined peak, while balances that carry their own account numbers or IBANs are usually separate accounts, each with its own peak.

Where the structure is unclear, listing each currency balance as its own account is the cautious reading — the FBAR carries no penalty for reporting an account you might have been allowed to combine, and a real one for leaving one out.

Then you may have held two foreign accounts in one year, or a foreign one and a US one. Providers have migrated customers between entities — for example, moving European customers from a UK entity to an EU one — and a customer who changes country of residence can be moved too. Each period is reported on the terms of the entity that held it, at the highest value reached during that period.

Your statements for the year will name both entities if this happened to you. The change of entity is also the fact to check when the aggregate was close to the trigger: a balance that moved between two foreign entities is still one balance, but it may now be two account lines.

For each account: the name and address of the institution, the account number, the type of account, and the maximum value during the year — with the per-currency statements that show it. Keep the documents that name the holding entity, because that is the fact an examiner would ask you to support.

The FBAR rules require these records to be kept for five years from the report's due date. Apps make this harder than banks do: export statements while you still have access, since a closed app account can take its history with it.

A foreign-entity fintech account is also a specified foreign financial asset for Form 8938, which is filed with your tax return rather than with FinCEN and has much higher thresholds — for a taxpayer living abroad, the year-end and peak values of all specified foreign assets together are tested. The two forms have different ownership tests too: signature authority alone reaches the FBAR but not Form 8938.

An account with a US entity goes on neither. Many people abroad file both forms for the same accounts; the threshold checker runs both tests from one set of balances.

Two published routes exist and they are not interchangeable. If your returns reported the income from the account and paid the tax, you file the missed FBARs late with FinCEN, the reason on the form and a reasonable-cause statement with your records — the IRS withdrew its published Delinquent FBAR Submission Procedures, and their printed no-penalty assurance, on July 1, 2026; the filing and the IRM 4.26.16 examiner standard are unchanged. If the account's income was never reported — or returns for those years were never filed — the question is a Streamlined one, with three return years and six FBAR years.

The non-willful civil penalty is currently capped at $16,536 per late report — per report, not per account — and reasonable cause can eliminate it. Which route applies depends on your facts, and the certification in a Streamlined submission is signed by you.