FBAR filing: why Washington wants to know about your European bank account

For most Americans in Europe, the FBAR is the moment they first realize how long the arm of US tax obligations really is. It costs you nothing in tax. All it asks is that every year you tell the US Treasury about every account you hold outside the US or have authority over: your checking account, your savings account, your brokerage account, your life insurance policy with a cash surrender value, your parents' account you hold a power of attorney for. This page explains who files, from what point, which accounts are included, how to handle joint accounts and pensions, which exchange rate to use and how filing works. If you have missed years, see Catching up on FBARs and penalties.

1What the FBAR is and who files it

FBAR stands for Report of Foreign Bank and Financial Accounts. The form is FinCEN Form 114, and it is based not on the tax code but on the Bank Secrecy Act. It goes to the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Treasury; the IRS enforces the requirement. That is why the FBAR is not part of your tax return but is filed separately.

Every US person must file it. The regulation names three groups: US citizens, individuals who are tax residents of the US under the income tax rules, and companies, trusts and other entities formed under US law. For readers of this page, that means: if you hold US citizenship, with or without a passport, you file. If you hold a green card, you are a resident under the green card test and you file too, even if you have lived in Europe for years, as long as you have not given up the green card. How to give it up cleanly for tax purposes is covered under Giving up your green card and taxes.

One point matters most, and the IRS puts it right at the top: whether an account produces taxable income has no bearing on whether it belongs on the FBAR. A checking account with no interest counts just as much as a brokerage account. And even if you owe no US tax because the tax you pay in your home country is credited, you still have to file. How that credit works is explained in FEIE or Foreign Tax Credit.

2The threshold: $10,000 across all accounts combined

The requirement kicks in if the combined value of your accounts outside the US exceeded $10,000 at any time during the calendar year. Three words in that sentence decide almost every case.

Combined value. The threshold applies not per account but to all accounts together. The IRS says so explicitly: if two accounts together hold more than $10,000, both must be reported. So three accounts of $4,000 each trigger the requirement, and then the fourth account with 300 euros goes on the list as well.

At any time. What counts is not the balance at year end but the maximum value. If your December salary briefly sat in the account together with your Christmas bonus, or the proceeds from selling your car came in during March, that peak is what counts. FinCEN's filing instructions require a reasonable approximation of the highest value of the year; you may rely on periodic account statements as long as they fairly reflect the maximum value.

Calendar year. The FBAR follows the calendar year, regardless of your tax year.

2.1How to convert

The instructions set out two steps. First, determine the maximum value of each account in its own currency, such as euros or francs. Then convert that value into dollars using the US Treasury rate for the last day of the calendar year, even if the peak was in the spring. If the Treasury publishes no rate for a currency, use another verifiable rate and state the source. Round amounts up to the next whole dollar. If the result is negative, for example on an overdrawn account, enter zero.

The table shows what this means for readers holding euros and francs. Because the dollar was weaker at the end of 2025 than a year earlier, the threshold for 2025 worked out to 8,510 euros or 7,920 francs, well below 10,000. If you only roughly estimate your accounts, you can easily end up on the wrong side.

3Which accounts count

The regulation (31 CFR 1010.350) recognizes three types of accounts held outside the US:

• Bank accounts: checking, savings, instant-access, fixed-term deposits and any other account with an institution engaged in banking.
• Securities accounts: brokerage accounts with banks and brokers that trade or hold stocks or other securities. You report the account with its maximum value, not each individual security.
• Other financial accounts: insurance and annuity policies with a cash surrender value, accounts with futures brokers, and holdings in investment funds that are publicly offered and have a regular net asset value and redemptions.

According to the IRS overview, an account at a European branch of a US bank goes on the FBAR; an account at the US branch of a European bank does not. Assets that are not accounts do not belong on the FBAR: the home you live in or rent out, cash in a safe, gold in your own drawer, jewelry, your car.

3.1Ownership or signature authority

Signature authority means you can control the money in the account, alone or together with others, by giving the bank an instruction. The classic example is a power of attorney over your parents' account. It goes on the FBAR too, even though not a cent in the account belongs to you. The regulation exempts certain employees of regulated banks and listed companies; that exemption does not apply to a power of attorney over a private family account.

4Joint accounts and spouses

For a joint account, every owner who is a US person reports the full value of the account, not their share. That is what the filing instructions say. You also state the number of joint owners and the details of the principal joint owner; if your spouse is a joint owner, your spouse is that principal joint owner.

Married couples get some relief if both spouses are US persons. Your spouse does not have to file a separate FBAR if all of their reportable accounts are held jointly with you, you report them on a timely FBAR, and you have both signed FinCEN Report 114a, which you keep with your records. According to the IRS, it makes no difference whether you file your income tax return jointly or separately. As soon as one of you holds an account alone, each of you files your own FBAR.

If your spouse is neither a US citizen nor a green card holder, they are not a US person and do not file an FBAR. You still report the joint account at its full value. This surprises many families in Europe where only one partner is American: the family account that both salaries go into appears in full on the American partner's FBAR. What the partner without a US passport should also know, for example about filing a joint tax return, is covered under Child benefits and the Child Tax Credit.

5Pensions, retirement savings and insurance

This is where most of the uncertainty lies, and the regulation is narrower than many assume. The only explicit exemptions are for participants in and beneficiaries of US retirement plans under sections 401(a), 403(a) and 403(b) of the Internal Revenue Code, and for owners of IRAs and Roth IRAs. Accounts that such US plans hold abroad do not require an FBAR. The regulation contains no equivalent exemption for European retirement savings.

That leaves you with a distinction to make for every contract:

• State pension: the IRS does not list Social Security-type benefits paid by a foreign government as reportable, either on the FBAR or on Form 8938. That includes entitlements under your home country's state pension system. Such an entitlement is not an account within the meaning of the regulation.
• Insurance with a cash surrender value: under the regulation, life insurance and annuity policies with a cash surrender value are other financial accounts and belong on the FBAR, with the cash surrender value as their value.
• Pension savings held in a bank or securities account: If private or occupational pension savings are held as an account at a bank or as a custody account, such as a Pillar 3a account at a bank or a vested benefits account in Switzerland, the wording of the regulation makes it a foreign bank or securities account. The exception for US plans does not apply.

How the income and payouts from such contracts are taxed in the US is a separate question that depends on the tax treaty. It is covered under Pensions across the Atlantic. For the FBAR, all that matters is whether an account exists.

6Filing through BSA E-Filing

The FBAR is filed only electronically, through FinCEN's BSA E-Filing System. The IRS does not accept a printed form; paper filing is only possible with an exemption you request from FinCEN. As an individual, you do not need an account in the system: if you report your own accounts or joint accounts with your spouse, you can file the FBAR without registering. Tax advisors, attorneys and enrolled agents filing for clients, on the other hand, register as an institution and have the filing authorized with FinCEN Report 114a. You do not submit Form 114a; you keep it and produce it on request.

The FBAR is due on April 15 of the following year. If you miss that deadline, you automatically get an extension to October 15, without having to request anything. This applies to reporting years from 2016 onward; the text of the regulation still names the old date of June 30, while the IRS and the Taxpayer Advocate Service name April 15. How the FBAR deadlines fit together with those of your tax return is shown in the deadline calendar for Americans abroad.

For each account, you enter the institution, its address, the account number, the account type and the maximum value in dollars. If you have 25 or more accounts, the number of accounts and some basic details are enough at first; you provide the specifics if the agency asks for them. For every reported account, you must keep records showing the account holder's name, the account number, the institution's name and address, the account type and the year's maximum value, generally for five years from the FBAR deadline. The law does not prescribe which documents these must be; bank statements are enough if they contain this information.

7FBAR and Form 8938 are two separate obligations

Besides the FBAR, there is a second report of foreign assets: Form 8938 under the Foreign Account Tax Compliance Act (FATCA). It is part of your income tax return and goes to the IRS. The IRS states explicitly that Form 8938 neither replaces nor affects the FBAR. If you reach the thresholds for both, you file both.

The Form 8938 thresholds are much higher for Americans living abroad. Single filers and those filing separately must report if their covered foreign assets were worth more than $200,000 on the last day of the year or more than $300,000 at any time; for joint filers, the figures are $400,000 and $600,000. In return, Form 8938 also covers things that do not belong on the FBAR, such as directly held interests in foreign companies. What banks in Europe report about you under FATCA, and why they ask for a Form W-9, is explained in FATCA in Europe. The background on information exchange is covered in The USA and automatic exchange of information.

8What happens if you get it wrong

The FBAR is purely a report, but the penalties for a missing or incorrect filing are steep, and they are not based on any tax owed. For a non-willful violation, the law sets a maximum penalty per violation that is adjusted for inflation every year; for penalties assessed on or after January 17, 2025, it is $16,536. For willful violations, the penalty can reach 50 percent of the account balance. The agency has discretion, and in many non-willful cases an examination ends with a warning letter rather than a penalty.

If years are missing, the order matters: first establish whether only the FBAR is missing or also income and tax returns, then choose the right path. Both are covered in detail under Catching up on FBARs and penalties, and the path for years without any US return is described in Streamlined Procedure: catching up on US taxes without penalties. For an overview of every obligation, from the tax return to the reports, see the guide US tax obligations for Americans in Europe.

The simplest preparation is a list of all your accounts with each one's highest balance of the year, drawn up in January: it doubles as your records, your basis for the FBAR and your check for Form 8938.

In short

• Every US person, meaning US citizens and green card holders, files the FBAR if their accounts outside the US were worth more than $10,000 combined at any time during the year.
• Bank, securities and other financial accounts are reported, including insurance policies with a cash surrender value, funds, and accounts over which you only have signature authority.
• Each account's maximum value is converted at the Treasury rate for December 31; for 2025, the threshold equaled 8,510 euros or 7,920 Swiss francs.
• The FBAR is due on April 15, with an automatic extension to October 15, filed electronically with FinCEN and separately from the tax return.
• Form 8938 does not replace the FBAR; if you reach both thresholds, you file both.

How we help you

• US taxes for US citizens abroadForm 1040, FBAR and Streamlined for US citizens living in Europe.
• Streamlined FilingCatch up on missed US tax returns and FBARs through the Streamlined procedure.
• US Tax ConsultationYour US tax question, answered by people who know both sides.
• IRS letters and penaltiesMail from the IRS? We reply, request penalty relief and put things right.