Broker · Europe
Revolut, the FBAR, and the hidden fund inside 'Flexible' accounts
Your Revolut balance counts toward the $10,000 FBAR aggregate — and the interest-bearing 'flexible' products are money-market funds, which are PFICs for a US taxpayer.
By Danilson Ramos · Founder, Atamatax
Published July 2026 · Updated October 2026
Direct answer
Does a Revolut account go on the FBAR?
Yes, when a non-US Revolut entity holds it — Revolut Bank UAB (Lithuania) for EEA customers, Revolut Bank UK Ltd or Revolut Ltd (UK) for UK customers.
The app and the currency do not decide it; the entity on your statement does. A foreign Revolut account counts toward the $10,000 aggregate at its highest balance of the year, and toward Form 8938. An account with Revolut Technologies Inc. (the US entity) is not a foreign account.
- Last verified
- Primary source
- Report of Foreign Bank and Financial Accounts (FBAR)
What changes the answer
- Your statement names Revolut Technologies Inc.: not a foreign account (your other non-US accounts still aggregate).
- Your combined non-US accounts never exceeded $10,000 at any point in the year: no FBAR is due for that year.
- Money sits in a Flexible or Savings product: the fund behind it may be a PFIC — a Form 8621 question the FBAR does not settle.
- The account changed entity during the year (a move between regions): the two are separate accounts, each reported at its own highest balance.
- You are a UK customer moved to Revolut Bank UK Ltd in 2026: the account is foreign before and after; how to name the institution for that year is one to confirm with your preparer, since the account number did not change.
Next step: Check my Revolut account (free, no account)
Revolut feels like an app, not a bank — which is exactly why it's one of the most under-reported accounts on FBARs. For a US person there are three separate questions: whether the account counts at all, whose account it is, and what the yield products actually are.
Does your Revolut account count? The entity decides
"Is Revolut a foreign account?" has no answer as asked, because Revolut is not one institution. A customer who onboarded in the US is held by Revolut Technologies Inc., a US entity — not a foreign financial account, and outside the FBAR. A customer in the EEA is typically held by Revolut Bank UAB in Lithuania. A UK customer was held by Revolut Ltd, the e-money company, until Revolut's UK bank, Revolut Bank UK Ltd, launched on 11 March 2026; Revolut has been moving UK accounts across in batches since then, so a UK statement may name either, and a 2026 statement may name both. Those are foreign financial institutions, and an account with them is a foreign financial account whatever currency it holds and wherever you live now. Your account statement names the entity; the IBAN prefix and the app's language are not the test.
| You onboarded… | Entity on the statement | FBAR / Form 8938 |
|---|---|---|
| In the EEA | Revolut Bank UAB (Lithuania) | Foreign financial account — counts |
| In the UK | Revolut Bank UK Ltd, or Revolut Ltd if not yet moved | Foreign financial account — counts |
| In the US | Revolut Technologies Inc. (US) | Not a foreign account; your other non-US accounts still aggregate |
| Moved country mid-year | Possibly two entities in one year | Both regimes can apply in the same year — check each statement |
Whose account is it? Joint accounts and signature authority
The FBAR reaches accounts you own, accounts you own jointly, and accounts you do not own but can sign for. A joint Revolut account with a non-US spouse is reportable by the US person at its full maximum value, not half. A business account you can move money out of is reportable as signature authority even though the money is the company's. And a child's Revolut <18 account funded and controlled by you is, on the ordinary reading, yours to report. For Form 8938 the ownership test is narrower — it reaches only accounts with an interest in the asset — which is one reason the two forms disagree more often than people expect.
The balance counts toward the FBAR
A Revolut account held with a non-US Revolut entity (Lithuania for the EEA, the UK for the UK — the e-money company or the bank) is a foreign financial account. Every currency balance and pocket counts toward the $10,000 FBAR aggregate at its maximum value during the year — even if it only crossed for a day, even if it's just your salary passing through. It also counts toward Form 8938. (US-resident customers of Revolut's US entity are a different case — the FBAR is about non-US accounts.)
Issue 2 — 'Flexible' accounts are funds, and funds are PFICs
Revolut's interest-style products in Europe (marketed as Flexible Cash Funds / savings-like features) generally work by placing your money in money-market funds domiciled outside the US. In the EEA, Revolut's own product page names them: sub-funds of the Irish-domiciled Fidelity Institutional Liquidity Fund plc, bought through Revolut Securities Europe UAB. For a US taxpayer a non-US money-market fund is generally a PFIC — Form 8621 territory — even though the app presents it as a savings balance. The same look-through applies to UCITS ETFs bought through Revolut's trading tab.
| Revolut feature | What it is | US filing angle |
|---|---|---|
| Currency balances / pockets | E-money balances | FBAR + 8938 aggregates |
| Flexible Cash Funds / savings-style yield | Non-US money-market fund | Likely PFIC → Form 8621 |
| Trading tab: US stocks | Individual shares | Not PFICs; account still reportable |
| Trading tab: European ETFs | UCITS funds | Likely PFIC → Form 8621 |
| Crypto balances | Crypto held via Revolut | FBAR treatment is unsettled — flag it |
What to export
- Every currency's maximum balance during the year (statements per currency).
- The fund name and ISIN behind any Flexible/savings product — it's in the product documents.
- Trading-tab positions with ISINs and year-end values.
If you forgot to report it in an earlier year
Two published routes exist, and they are not interchangeable. If your returns for those years reported the income 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 examiner standard in IRM 4.26.16 (non-willful, reasonable cause, properly reported) is unchanged. If the Revolut balances also produced income that was never reported — interest from a savings product, gains in the trading tab — or no return was filed at all, the question is a Streamlined one: three return years, six FBAR years, a certification you sign. The non-willful FBAR penalty is capped at $16,536 per late report, not per account, and reasonable cause can eliminate it.
Then run every account through the threshold
Revolut is one line of the FBAR aggregate. Enter the highest balance of each non-US account and the free checker runs the FBAR and Form 8938 thresholds for your filing status and residence, line by line. This is general information, not individualised tax advice.
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)
- IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
- IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
- IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
- IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
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.