FBAR Filing Requirements: Foreign Accounts, $10,000 Threshold, and Deadlines

An FBAR may be required when the total value of your foreign financial accounts is more than $10,000 at any point during the year. It is filed electronically as FinCEN Form 114, and it is separate from your income tax return. The deadline is April 15, with an automatic extension to October 15, so you do not have to request that extension. The FBAR is a reporting obligation, not a tax payment and not a penalty. If you hold money abroad above the threshold, you file. This guide explains the threshold, who has to file, and how the FBAR differs from IRS Form 8938.

How the $10,000 Aggregate Threshold Works

The number that trips the requirement is the aggregate, meaning the combined high value of all your foreign accounts, not the balance in any single one. This catches a lot of people off guard.

Say you have three foreign accounts: $4,000, $4,000, and $3,000 at their respective peaks during the year. None of them crosses $10,000 on its own. Together they hit $11,000. That aggregate is over the threshold, so an FBAR is required for all of them. The test is also “at any time during the year,” so a brief spike counts. If an account touched $10,500 for one week and sat at $2,000 the rest of the year, you use the $10,500 high.

This is why several smaller accounts can quietly create an obligation that no single account would.

Financial Interest Versus Signature Authority

You can have an FBAR duty in two distinct ways, and both count toward the threshold:

Financial interest: you own the account or are the beneficial owner. This is the obvious case.
Signature authority: you can control the disposition of the money by signature or other means, even if the account is not yours. Think a business account you can sign on, or a relative’s account where you are authorized.

People miss the signature-authority case constantly. If you can move the money, you may have to report the account even when none of it belongs to you.

FBAR Versus Form 8938

These two get confused because they overlap, but they are separate filings with separate homes.

FBAR (FinCEN Form 114) is a FinCEN filing, submitted through the BSA E-Filing System. It is not part of your tax return.
Form 8938 (Statement of Specified Foreign Financial Assets) is an IRS form that you attach to your income tax return. It has its own thresholds, which are generally higher than the FBAR’s and vary by filing status and whether you live in the US or abroad.

The key point: both can apply to the same person at the same time. Filing one does not satisfy the other. They ask overlapping questions but answer to different agencies, so if you meet both sets of thresholds, you file both.

The Filing Process and Deadlines

The FBAR is filed electronically through FinCEN’s BSA E-Filing System. You report each account: the institution, the account number, the type, and the maximum value during the year. There is no tax due on the FBAR itself; it is informational.

The deadline is April 15. If you miss it, there is an automatic extension to October 15. You do not file anything to get that extension; it applies on its own. That said, do not treat October as the real date and drift, because the obligation is firm and the filing is not hard once your records are in order.

Records to Keep for Foreign Accounts

The FBAR rules expect you to be able to support what you reported. Keep these:

The name on each account and the account number
The name and address of the foreign financial institution
The type of account (checking, savings, brokerage, and so on)
The maximum value of each account during the year, with the source you used to determine it
Year-end and periodic statements showing balances
The exchange rate you used to convert foreign currency to US dollars, and the date
Records of any account where you hold signature authority but not ownership

Hold these for several years. The point is to be able to reproduce, calmly, every figure you put on the form.

Run the Tax Return Documentation Checkup to review your own records before you file.

A Quick Worked Example

You moved to Lisbon for a contract gig and opened a local checking account that peaked at $7,500. You also kept an old brokerage account back in Canada that hit $6,000 during the year. Neither alone clears $10,000. Combined, the aggregate high is $13,500, which is over the threshold, so you file an FBAR listing both accounts at their maximum values. Separately, you check the Form 8938 thresholds for your filing status to see whether that form is also required. It might not be, since 8938 thresholds run higher, but you check rather than assume.

Before you file, run the Tax Return Documentation Checkup and confirm your foreign-account records are complete.

Frequently Asked Questions

Do I owe tax when I file an FBAR?

No. The FBAR is purely informational. It reports the existence and value of foreign accounts to FinCEN. Any tax on income those accounts generated is handled on your regular income tax return, separately. The FBAR itself carries no tax.

I closed the foreign account mid-year. Do I still report it?

Yes. The test is whether the aggregate exceeded $10,000 at any time during the year. If a now-closed account contributed to crossing that threshold, you report it using its maximum value before it closed.

What if I have an account with signature authority but no ownership?

You may still need to report it and include it in the aggregate. Signature authority alone can create an FBAR obligation. Keep documentation of the authority and the account details just as you would for an account you own.

Sources

IRS, Report of Foreign Bank and Financial Accounts (FBAR)
IRS, About Form 8938

Last reviewed: June 21, 2026.