FBAR Threshold Checker: Do You Need to File?

What Is the FBAR?

The Foreign Bank Account Report (FBAR) — formally FinCEN Form 114 — is a disclosure report that U.S. persons must file whenever they have a financial interest in, or signature authority over, one or more foreign financial accounts with a combined maximum value exceeding $10,000 at any point during the calendar year.

The FBAR is filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury. It is a separate requirement from your IRS tax return, and it is filed electronically through the BSA E-Filing System — not mailed to the IRS.

Who Must File?

You must file an FBAR if you are a U.S. person (citizen, permanent resident, or U.S.-based entity) and you had:

• A financial interest in one or more foreign financial accounts, or
• Signature authority over one or more foreign financial accounts (even if you have no financial interest — for example, an employee with authority over a company account)

...and the aggregate maximum value of those accounts exceeded $10,000 at any point during the calendar year.

What Counts as a Foreign Financial Account?

• Bank accounts (checking, savings, time deposits)
• Brokerage and securities accounts
• Mutual fund accounts held at foreign institutions
• Foreign retirement accounts (e.g., UK ISAs, Australian superannuation in some cases)
• Foreign life insurance policies with cash value
• Accounts at foreign branches of U.S. banks

These generally do not count:

• Accounts at U.S. branches of foreign banks
• U.S.-based brokerage accounts holding foreign stocks
• Real estate held directly (not through a foreign entity)
• Precious metals held directly

FBAR Deadlines

The FBAR deadline is April 15 of the year following the calendar year being reported. However, FinCEN provides an automatic extension to October 15 — no extension request or form is required. The extension is granted automatically to all filers.

If you missed a prior year FBAR, the Streamlined Filing Compliance Procedures may allow you to catch up without the full penalty exposure, provided your failure was non-willful.

How to File the FBAR

The FBAR is filed electronically through the BSA E-Filing System at bsaefiling.fincen.treas.gov. You will need the following information for each account:

• Name and address of the foreign bank or financial institution
• Account number
• Maximum value of the account during the year (converted to USD using the Treasury's year-end exchange rate)
• Account type (bank account, securities account, etc.)

If you have 25 or more accounts, you may file a consolidated FBAR rather than itemizing each one (though itemizing is preferred for accuracy and audit protection).