Most of the people who come to us about an FBAR are not hiding anything. They moved to the United States years ago and kept a savings account in Mumbai, a fixed deposit their parents opened for them, a pension from a first job in Manchester, or a checking account in Toronto they still use when they visit. Nobody told them that once they became US taxpayers, those accounts had to be reported to the Treasury every year. This guide sets out who has to file, which accounts count, and how the filing actually works.
Who has to file an FBAR
The FBAR, formally FinCEN Form 114, the Report of Foreign Bank and Financial Accounts, is required from a US person who has a financial interest in, or signature authority over, at least one financial account outside the United States, when the combined value of those foreign accounts was more than $10,000 at any time during the calendar year. A US person includes citizens and residents, which covers green card holders and many visa holders who are treated as residents for tax purposes, as well as US companies, partnerships, trusts and estates.
Financial interest means you are the owner of record or hold legal title, which includes an account you hold jointly with a parent or sibling abroad. Signature authority means you can move money in the account by instructing the bank directly, even if none of the money is yours. Whether the account earned any taxable income has no bearing on whether it has to be reported.
The $10,000 test is about all of your accounts together
This is the rule people get wrong most often. The threshold is not $10,000 per account. It is the aggregate of all your foreign financial accounts at their highest point during the year. If you have two accounts and their combined balance was above $10,000 at any one time, both accounts go on the FBAR, even if each one on its own never came close. If the combined total never passed $10,000 during the year, no FBAR is due for that year.
Accounts that are easy to forget
Bank savings and current accounts are the obvious ones. Less obvious, and just as reportable: fixed or term deposits, brokerage and investment accounts, foreign mutual funds, an account you can sign on for an elderly parent, a foreign-issued life insurance or annuity policy with a cash value, and foreign retirement accounts held with a financial institution, which the IRS's FBAR reference guide treats as reportable. A joint account with family back home counts as your account. On the other side, foreign currency or precious metals you hold directly, and foreign real estate you own directly, are not FBAR accounts.
Who does not need to file
Some accounts are excluded even when the threshold is met. You do not report foreign accounts held inside a US individual retirement account or a US retirement plan in which you participate. Married couples whose foreign accounts are all held jointly can have one spouse report them on a single timely FBAR, provided both sign FinCEN Form 114a authorizing it and keep it on file. Income tax filing status does not decide this: a couple filing a joint return still needs the Form 114a arrangement, or two separate FBARs.
When the FBAR is due and how to file it
The FBAR is due April 15 following the year being reported, with an automatic extension to October 15. You do not need to request the extension. The FBAR is not part of your tax return and is not filed with it. It goes electronically to the Financial Crimes Enforcement Network through FinCEN's BSA E-Filing System. If someone files it for you, you sign FinCEN Form 114a to authorize them and keep that form in your records.
For each account you report the maximum value during the year, which you can take from periodic statements, converted to US dollars at the Treasury's exchange rate for the last day of the year. Keep a record of each account's name, number, bank name and address, account type and maximum value for five years from the FBAR due date.
Do I have to file every year?
Yes. The FBAR is an annual report, and the test runs fresh each calendar year. A year in which your combined balance stays at or below $10,000 needs no FBAR. A year in which it passes $10,000, even for one day after a large transfer, does.
The other form that often applies: Form 8938
The FBAR is a Treasury filing under the Bank Secrecy Act. Separately, the Foreign Account Tax Compliance Act added Form 8938, which is attached to your income tax return and has much higher thresholds. Many people with foreign accounts owe one form, some owe both. Our side-by-side guide on FBAR vs Form 8938 shows how to tell. The same law also requires foreign financial institutions to report information on accounts held by US taxpayers, which is one reason foreign accounts that went unreported for years now come to light.
If you have missed FBARs in past years
You are far from alone, and there is a sensible way back. The IRS's guidance is to file late FBARs as soon as possible if it has not contacted you and you are not under investigation. How you file them matters more than it did, because in July 2026 the IRS took down the web page that promised no penalty to many late filers. Our guide to late FBAR filing explains the routes that remain, and our guide to FBAR penalties explains what is actually at stake. If you would rather have it handled, our FBAR and FATCA compliance service covers current-year filings and catch-up years alike, and a No-Obligation Tax Resolution Case Evaluation is the place to start.