FBAR Requirements: What Americans Abroad Need to Know for 2026

If you're an American living abroad, you've probably heard about the FBAR. But what exactly is it, and do you need to file one?

With the 2026 tax season approaching, now is a good time to understand your FBAR obligations for tax year 2025. Let me break it down in plain English.

What is the FBAR?

FBAR stands for Foreign Bank Account Report, officially known as FinCEN Form 114. It's a report you file with the U.S. Treasury's Financial Crimes Enforcement Network (FinCEN) — not the IRS — to disclose your foreign financial accounts.

The FBAR exists to help the U.S. government combat tax evasion and money laundering. For most expats, it's simply an annual reporting requirement to stay compliant.

Do You Need to File an FBAR?

You must file an FBAR if:

1. You are a U.S. person (citizen, resident alien, or entity)
2. You have a financial interest in or signature authority over foreign financial accounts
3. The aggregate value of all your foreign accounts exceeded $10,000 at any point during the calendar year

That last point is crucial — it's not about how much is in your accounts on December 31st. If your combined foreign accounts exceeded $10,000 for even one day during the year, you have a filing requirement.

What Accounts Must Be Reported?

FBAR reporting covers more than just bank accounts. You must report:

• Bank accounts (checking, savings)
• Securities accounts (brokerage accounts)
• Mutual funds
• Pension accounts in some cases
• Life insurance policies with cash value
• Accounts where you have signature authority (even if you don't own them)

Important: If you're a signatory on your employer's foreign account, you may need to report it — even though it's not your money.

What's NOT Reported on the FBAR?

Some accounts are excluded:

• Accounts at U.S. military banking facilities
• Correspondent or nostro accounts
• Individual retirement accounts (IRAs) owned by you
• Accounts with values that didn't exceed $10,000 in aggregate

FBAR Deadlines for 2026

For tax year 2025, here are the key FBAR deadlines:

• April 15, 2026: Initial FBAR deadline
• October 15, 2026: Automatic extended deadline (no form required)

Unlike tax returns, you don't get to request additional extensions beyond October 15. That's your final deadline.

How to File an FBAR

FBARs are filed electronically through the BSA E-Filing System. You cannot mail in a paper FBAR.

The form asks for:

• Account type and number
• Name and address of the foreign bank
• Maximum account value during the year
• Whether you have sole or joint interest

FBAR Penalties

This is where it gets serious. FBAR penalties can be severe:

| Violation Type | Penalty | |----------------|---------| | Non-willful violation | Up to $10,000 per account, per year | | Willful violation | Greater of $100,000 or 50% of account balance | | Criminal penalties | Up to $500,000 and 10 years imprisonment |

The good news? The IRS generally reserves harsh penalties for egregious cases of willful non-compliance. If you've innocently forgotten to file, there are programs to help you catch up without severe consequences.

FBAR vs. FATCA (Form 8938)

Don't confuse the FBAR with FATCA reporting on Form 8938. They're separate requirements with different thresholds and go to different agencies:

| | FBAR | Form 8938 | |---|------|-----------| | Threshold (abroad) | $10,000 | $200,000 (year-end) or $300,000 (any time) | | Filed with | FinCEN | IRS (with tax return) | | Accounts covered | All foreign financial accounts | Specified foreign financial assets |

Many expats need to file both.

What If You Haven't Filed?

If you've missed FBARs in past years, don't panic. The IRS offers the Streamlined Filing Compliance Procedures for taxpayers who can certify their failure to file was non-willful. This program lets you catch up on the past three years of tax returns and six years of FBARs without facing penalties.

The Bottom Line

The FBAR is a straightforward but important filing requirement for Americans abroad. Keep track of your foreign account balances throughout the year, file by October 15, and you'll stay on the right side of compliance.

If you're unsure whether you need to file or have questions about past years, I'm happy to help you figure it out.