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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.

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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 statementFBAR / Form 8938
In the EEARevolut Bank UAB (Lithuania)Foreign financial account — counts
In the UKRevolut Bank UK Ltd, or Revolut Ltd if not yet movedForeign financial account — counts
In the USRevolut Technologies Inc. (US)Not a foreign account; your other non-US accounts still aggregate
Moved country mid-yearPossibly two entities in one yearBoth 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.

The pattern to remember: on European neobanks, anything that pays 'interest' by investing your balance is usually a fund. The app's label doesn't control the IRS treatment — the fund's domicile does.
Revolut featureWhat it isUS filing angle
Currency balances / pocketsE-money balancesFBAR + 8938 aggregates
Flexible Cash Funds / savings-style yieldNon-US money-market fundLikely PFIC → Form 8621
Trading tab: US stocksIndividual sharesNot PFICs; account still reportable
Trading tab: European ETFsUCITS fundsLikely PFIC → Form 8621
Crypto balancesCrypto held via RevolutFBAR 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.

Product structures change — confirm what sits behind your specific Revolut products in their documents. Atamatax provides preparation software and educational estimates, not individualised tax, legal, or investment 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.

Frequently asked questions

My Revolut balance never exceeded $10,000 — am I safe?#
No — the FBAR threshold is the AGGREGATE of all your non-US accounts combined, at each account's maximum during the year, so a $6k Revolut balance plus a $5k local bank account crosses it. Run the numbers across every account.
Is Revolut's savings feature really a PFIC?#
Generally yes — in Europe the yield products place your money in non-US money-market funds, and a non-US pooled fund is generally a PFIC for a US taxpayer. Check the product documents for the fund's name and ISIN, the decisive fact, before filing.
I use Revolut US. Does any of this apply?#
An account with Revolut's US entity isn't a foreign account for FBAR purposes, but an EEA/UK Revolut account (common for people who moved) is — and the two regimes can apply in the same year.
I never reported my Revolut account. What now?#
It depends on whether the income from it was reported. Returns filed and tax paid, FBARs missed: file the late FBARs with a reasonable-cause statement (the IRS withdrew its published delinquent-FBAR procedures on July 1, 2026; the examiner standard is unchanged). Income never reported, or no returns filed: the Streamlined Foreign Offshore Procedures, provided the failure was non-willful. The late-FBAR guide draws the line between the two.

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Your next step · free

Does your Revolut account count?

Which entity holds the money, whether it counts toward the FBAR aggregate, whether Form 8938 applies, and whether anything inside it is a PFIC — four questions, kept apart, each labelled with what your facts can support. Free, no account.

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