Do I need to file an FBAR?

If you are a US person and the combined highest balance of every financial account you hold or can sign on outside the US exceeded $10,000 at any point in the calendar year, yes — FinCEN Form 114, filed online with FinCEN, separately from your tax return. It is owed whether or not the accounts earned anything and whether or not you owe any tax.

What is the FBAR threshold?

$10,000, aggregate: add the highest balance each non-US account reached during the year, whenever that was, and the report is due once the total exceeds the figure. It is not per account and not the year-end balance, so three accounts of $4,000 each cross it together, and money moved between two of your own accounts can count at its peak in both.

Does a joint account or an account I can only sign on count?

Yes to both. A joint account is reported in full by each US-person owner, not split. An account you have signature or other authority over — an employer's, a parent's, a company's — is reported even though the money is not yours, with narrow exceptions for officers and employees of certain regulated or publicly traded entities.

Is a foreign pension reportable on the FBAR?

It depends on the plan's form. A personal or self-directed retirement account you control — an RRSP, a SIPP, a Pillar 3a, a superannuation account — is generally a financial account and reportable. An employer defined-benefit scheme with no account in your name generally is not. The pension checker takes the plan's legal form and names the forms in play.

Do crypto exchange accounts go on the FBAR?

An account holding only virtual currency is not currently within the regulation's definition of a reportable account; FinCEN has announced it intends to amend the rule to include it. An exchange account that also holds cash or other reportable assets can already count. Treat it as a review item, and report it if in doubt — there is no penalty for reporting an account that did not need to be reported.

I filed my returns but never filed FBARs. What now?

That is its own route — the late FBARs are filed directly with FinCEN with the reason selected on the form and a reasonable-cause statement kept with your records. The IRS withdrew its published Delinquent FBAR Submission Procedures, and their printed no-penalty assurance, on July 1, 2026; penalties remain discretionary and IRM 4.26.16 still directs examiners not to assert one where the failure was non-willful, due to reasonable cause, and properly reported. Missed returns alongside missed FBARs is a different route: the Streamlined Foreign Offshore Procedures.

How is the FBAR different from Form 8938?

Two reports, two agencies, two thresholds. The FBAR goes to FinCEN with a $10,000 aggregate trigger and covers accounts. Form 8938 goes to the IRS with your return, has much higher thresholds that rise again if you live abroad, and covers a broader set of assets — including some that are not accounts at all. Most people who file one file both; neither substitutes for the other.

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Do you need to file an FBAR?

The FBAR question has three parts people conflate: which accounts count, whether their combined peak crossed $10,000, and whether an earlier year was missed. Five questions, no balances typed, and each part answered with the rule behind it.

1 · Are you a US person?

A citizen, a green-card holder, or a US resident for the year — wherever you live.

2 · What do you hold outside the US?

Everything that applies. Each kind has its own rule, printed in the result.

Bank, savings or deposit accountsBrokerage or investment accountsIncluding accounts that only hold funds or ETFs.Revolut, Wise, N26 or a similar appCounts when a non-US entity holds the balance.A pension or retirement accountA personal or self-directed one, or an employer scheme.Life insurance or an annuity with a cash valueA crypto exchange accountAn account held jointly with someone elseAn account I can sign on but do not ownAn employer's, a parent's, a company's.None of these

3 · Their combined peak during the year

Add each account's highest balance during the year, whenever that was — not the year-end figures, and not one account at a time.

4 · Are your US returns up to date?

5 · Were FBARs filed for earlier years they were due?

Asked apart from the returns: filed returns with missed FBARs is its own route.

What you get

Four findings — US-person status, which of your accounts count, whether the combined peak crosses the $10,000 line, and whether an earlier year is open — each with the reason and the fact that would settle it. Then the route that covers it: the annual return, the delinquent-FBAR procedure, or the Streamlined catch-up.

The FBAR, explained

The three things the FBAR question actually asks

Who. The FBAR binds United States persons — citizens, green-card holders, anyone resident in the US for the year under the substantial-presence test, and US entities. Where you live is irrelevant to whether it applies; it is only relevant to which accounts you are likely to have.

Which accounts. A financial account at an institution outside the US: bank and deposit accounts, brokerage and securities accounts, a foreign-issued life insurance policy or annuity with a cash value, a personal retirement account you control, and any account you hold jointly or can sign on for someone else. An app account counts when the entity holding the balance is outside the US — which is why the same app is a foreign account for one person and not for another.

How much, and when. The test is aggregate and momentary: the sum of every account's highest balance during the year, at whatever point each peaked. Once the total exceeds $10,000, every account is listed — including the one that never held more than a few dollars. The report is due in April and automatically extended to October 15 with nothing to request. It is filed with FinCEN, not on the tax return, which is why it is the report people who file on time still miss.

This checker settles the first two parts and screens the third from a band. When the balances are close to the line, the FBAR & Form 8938 threshold checker takes the exact figures and runs the second report's test beside it; for a Revolut, Wise or N26 balance the fintech account checker settles the entity question first.

Common questions

Do I need to file an FBAR?: If you are a US person and the combined highest balance of every financial account you hold or can sign on outside the US exceeded $10,000 at any point in the calendar year, yes — FinCEN Form 114, filed online with FinCEN, separately from your tax return. It is owed whether or not the accounts earned anything and whether or not you owe any tax.
What is the FBAR threshold?: $10,000, aggregate: add the highest balance each non-US account reached during the year, whenever that was, and the report is due once the total exceeds the figure. It is not per account and not the year-end balance, so three accounts of $4,000 each cross it together, and money moved between two of your own accounts can count at its peak in both.
Does a joint account or an account I can only sign on count?: Yes to both. A joint account is reported in full by each US-person owner, not split. An account you have signature or other authority over — an employer's, a parent's, a company's — is reported even though the money is not yours, with narrow exceptions for officers and employees of certain regulated or publicly traded entities.
Is a foreign pension reportable on the FBAR?: It depends on the plan's form. A personal or self-directed retirement account you control — an RRSP, a SIPP, a Pillar 3a, a superannuation account — is generally a financial account and reportable. An employer defined-benefit scheme with no account in your name generally is not. The pension checker takes the plan's legal form and names the forms in play.
Do crypto exchange accounts go on the FBAR?: An account holding only virtual currency is not currently within the regulation's definition of a reportable account; FinCEN has announced it intends to amend the rule to include it. An exchange account that also holds cash or other reportable assets can already count. Treat it as a review item, and report it if in doubt — there is no penalty for reporting an account that did not need to be reported.
I filed my returns but never filed FBARs. What now?: That is its own route — the late FBARs are filed directly with FinCEN with the reason selected on the form and a reasonable-cause statement kept with your records. The IRS withdrew its published Delinquent FBAR Submission Procedures, and their printed no-penalty assurance, on July 1, 2026; penalties remain discretionary and IRM 4.26.16 still directs examiners not to assert one where the failure was non-willful, due to reasonable cause, and properly reported. Missed returns alongside missed FBARs is a different route: the Streamlined Foreign Offshore Procedures.
How is the FBAR different from Form 8938?: Two reports, two agencies, two thresholds. The FBAR goes to FinCEN with a $10,000 aggregate trigger and covers accounts. Form 8938 goes to the IRS with your return, has much higher thresholds that rise again if you live abroad, and covers a broader set of assets — including some that are not accounts at all. Most people who file one file both; neither substitutes for the other.

Before you rely on this result

What would settle it, and what covers it

Documents or facts needed

• The highest balance of every non-US account during the year, from its statements
• For an app account, the statement naming the entity that holds the balance
• For a pension, whether the account is in your name and under your control
• Which of the last six years had reports filed

Where this leads

Simple · $299 — prepares the FBAR worksheet and the return the accounts belong to.

Also possible: CPA Export ($199) · Complex ($799). The cheapest route that covers your facts is the right one; a package never covers more than one tax year.

How to read a status

Likely:: The facts entered meet the published test; confirm the inputs before acting.
Possible:: Some facts point this way and others are missing; more information decides it.
Needs review:: These inputs leave it open; a person should look before filing.
Not currently indicated:: Nothing entered triggers it this year; a changed fact can change the answer.
Outside supported scope:: This item is routed to a professional for preparation.

Scope. A scope-and-threshold screen on the answers given; the account's own terms and the year's statements decide the filing. The FBAR is filed by you at FinCEN. This is a computation on the answers you gave, not individualized tax advice.

What changes the result

This answer changes if…

Whether an FBAR is due for a year

…all your non-U.S. accounts together exceeded $10,000 at any single moment in the year — even for a day — the test is the aggregate peak, not a year-end balance and not per account. Check it
…you can sign on an account you do not own — an employer's, a parent's, a company's — signature authority is reportable even with no financial interest.
…an account is joint with a spouse, or held through a company you control — joint and indirectly held accounts count toward your aggregate.
…a product you did not think of as an account holds cash — a fintech wallet, a pension with a cash element, a cash-value insurance policy — the definition of a financial account is wider than a bank account. Check it
…the currency moved during the year — the maximum is converted at the Treasury year-end rate; a peak in a strong-currency month can cross the line.

Whether Form 8938 is due

…you file jointly with a spouse — the joint thresholds are double the single ones.
…you lived in the United States for part of the year — the abroad thresholds are four times the domestic ones; residence for the year decides which set applies.
…you hold a specified asset outside any account — shares in a foreign company, a foreign pension, an interest in a foreign trust — those count toward the threshold even with no account balance.
…the value at year-end differs from the peak — Form 8938 has two lines — a year-end test and an any-time test — and either one triggers it.

Each line names a fact that moves the result; what it moves to depends on the rest of your facts. Nothing here is a determination.

How Atamatax calculations are produced — the tests applied, statutory sources and review cadence — is documented in the methodology, and how the engine is validated in accuracy & review. Calculation fixes are recorded in the changelog.

Authorities cited

31 U.S.C. §5314 — 31 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
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 — Report of Foreign Bank and Financial Accounts (FBAR), "Filing delinquent FBARs" — IRS FBAR page, "Filing delinquent FBARs": file late FBARs as soon as possible with the reason for filing late (page reviewed 30 Jul 2026)
IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (FBAR) — IRM 4.26.16.3.11 Delinquent FBAR Filing Procedures and 4.26.16.5 FBAR Penalties — the examiner standard: no penalty asserted where non-willful, reasonable cause, and the account is properly reported on the late FBAR

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.

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