FBAR Filing: Do You Need to File FinCEN Form 114? (+ Form 8938 Checker)

Updated · Reviewed by Deepak Middha, Chartered Accountant

The short answer

You must file an FBAR (FinCEN Form 114) if you are a US person and your foreign financial accounts added together exceeded $10,000 at any time during the year. For 2026 it is due April 15, 2027, automatically extended to October 15, 2027, and it is filed online through FinCEN’s BSA E-Filing System — not with your tax return.

Do you need to file? FBAR + Form 8938 checker for individuals

1. Are you a US person? (individuals)
This checker is for individuals. A resident alien is someone who passes the green card test or the substantial presence test.
2. Your foreign accounts
$
$
$
Use each account’s highest balance in US dollars, converted at the Treasury year-end rate. Include accounts you only have signature authority over.
3. For the Form 8938 test
$
Accounts plus foreign stock, partnership interests and similar assets held outside an account.
$
Leave at 0 and we use the sum of your account highs above, which can only overstate it.
FBAR (FinCEN Form 114)
Required
Total of your account highs$10,500
FBAR threshold (aggregate)more than $10,000

Your accounts added together passed $10,000 at some point in the year, so you must file an FBAR reporting every one of them — even the small ones.

What to do next: File online through FinCEN’s BSA E-Filing System by April 15, 2027 (automatic extension to October 15, 2027). Not with your tax return.

Form 8938 (FATCA statement)
Not required
Your threshold setunmarried (single or head of household), living in the US
Last day of the year$9,000 vs more than $50,000
Any time (from account highs)$10,500 vs more than $75,000

You are under both Form 8938 thresholds for your filing status and residence, so it is not required.

What to do next: Recheck at year end — the last-day value is measured on December 31.

Filing both is common: Form 8938 does not replace the FBAR. Not sure which other forms you need? Try the IRS Form Wizard.
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Key takeaways

FBAR vs Form 8938: the differences that matter

Form 8938 is the Statement of Specified Foreign Financial Assets, created by FATCA (the Foreign Account Tax Compliance Act). The FBAR is the Report of Foreign Bank and Financial Accounts. They overlap, but the IRS is clear that one never satisfies the other.

Sources: IRS comparison of Form 8938 and FBAR requirements; 31 CFR 1010.821 for the inflation-adjusted FBAR penalties. Tax year 2026.
FBAR (FinCEN Form 114)Form 8938
Who filesUS persons: citizens, resident aliens, and US entities, trusts and estatesSpecified individuals (citizens, resident aliens, certain nonresidents) and certain domestic entities
ThresholdAggregate maximum value over $10,000 at any time in the calendar yearFrom over $50,000 on the last day or $75,000 at any time (unmarried, in the US) up to $400,000 / $600,000 (joint, abroad)
What countsFinancial accounts at institutions located outside the US, including signature-authority accountsForeign financial accounts plus foreign stock, securities and partnership interests held outside an account
Where filedFinCEN, online through the BSA E-Filing SystemAttached to your income tax return
Deadline (2026)April 15, 2027, automatic extension to October 15, 2027Your return's due date, including extensions
PenaltiesNon-willful up to $16,536; willful up to the greater of $165,353 or 50% of the balance (inflation-adjusted)Up to $10,000, plus $10,000 per 30 days after IRS notice, to a $60,000 maximum
Source: IRS — Do I need to file Form 8938? Tax years 2025 and 2026 (IRS page reviewed 20-Sep-2026). If you do not have to file an income tax return, you do not file Form 8938.
Form 8938 threshold (2026)More than this on the last dayOr more than this at any time
Unmarried, living in the US$50,000$75,000
Married filing jointly, in the US$100,000$150,000
Married filing separately, in the US$50,000$75,000
Unmarried or separate, living abroad$200,000$300,000
Married filing jointly, living abroad$400,000$600,000

Which foreign accounts count for the FBAR?

Generally, any account at a financial institution located outside the United States: bank and savings accounts, brokerage and securities accounts, foreign mutual funds, and foreign-issued life insurance or annuities with a cash value. An account you can sign on but do not own — a parent’s account, or an employer’s — still counts.

  • Counts for the FBAR but not Form 8938: an account at a foreign branch of a US bank, and signature-only accounts.
  • Counts for Form 8938 but not the FBAR: foreign stock held directly, foreign partnership interests, and foreign hedge or private equity funds.
  • Counts for neither: foreign real estate held directly, foreign currency or precious metals held directly, and foreign government social-security-type benefits.

Accounts held in an IRA or retirement plan you participate in are excluded from the FBAR, and a spouse can report jointly owned accounts for both of you if you sign FinCEN Form 114a. If you also pay foreign tax on the income these accounts earn, see the foreign tax credit guide. Received a large gift or inheritance into a foreign account? That has its own report — see Form 3520.

Missed past FBARs? The official options

The IRS says that if it has not contacted you about a late FBAR and you are not under civil or criminal investigation, you should file the late FBARs as soon as possible to keep potential penalties to a minimum, and explain why they are late using FinCEN’s late-filing instructions. For broader failures, the IRS lists three programs:

Each has its own eligibility rules, and the IRS encourages taxpayers to consult a professional tax or legal advisor about which fits. This page does not choose one for you. Not sure you are a US person in the first place? Run the substantial presence test calculator, then the IRS Form Wizard for the rest of your forms.

Frequently asked questions

Do I need to file an FBAR if no single account is over $10,000?

Possibly, yes. The test is the aggregate: add up the highest balance each foreign account reached during the year. If that total is more than $10,000, every account must be reported — even an account that never held more than a few hundred dollars. Three accounts that peaked at $4,000, $3,500 and $3,000 add up to $10,500, so an FBAR is required.

What are the FBAR requirements for a US person?

A US person — a citizen, a resident alien, or a US corporation, partnership, LLC, trust or estate — files an FBAR when they have a financial interest in, or signature authority over, foreign financial accounts whose combined maximum value exceeded $10,000 at any time in the calendar year. Whether the accounts earned taxable income does not matter.

Can I file my FBAR online, and is it filed with my tax return?

The FBAR is filed online only, through FinCEN's BSA E-Filing System. It is not part of your tax return and is not sent to the IRS with your Form 1040. A paper FBAR is available only if FinCEN grants an exemption from e-filing. A tax preparer can file it for you if you sign FinCEN Form 114a, which you keep rather than submit.

What is the FBAR deadline for 2026 accounts?

The FBAR for calendar year 2026 is due April 15, 2027, with an automatic extension to October 15, 2027. You do not need to request the extension. The government may extend the date further for people affected by declared natural disasters, so check the current FinCEN relief notices if that applies to you.

What does FATCA reportable mean on Form 8938?

FATCA is the Foreign Account Tax Compliance Act, the law behind Form 8938. A FATCA-reportable asset is a specified foreign financial asset: an account at a foreign financial institution, or foreign stock, securities, partnership interests and contracts held for investment outside an account. Foreign real estate held directly, foreign currency and personal property are not reportable on Form 8938.

Do I file both the FBAR and Form 8938 for the same account?

Often, yes. The IRS says Form 8938 does not replace or otherwise affect the FBAR obligation, so the same foreign bank account can appear on both. They have different thresholds, are filed with different agencies — FinCEN for the FBAR, the IRS for Form 8938 — and carry separate penalties, so check each test on its own.

Sources & verification
Last verified: 2026-10-25. Figures apply to the 2026 calendar and tax year (the same thresholds applied for 2025). No 2027 figures are published separately: the IRS and FinCEN state one set of FBAR and Form 8938 thresholds, used for 2025 and 2026. The inflation-adjusted penalty maximums are the amounts in 31 CFR 1010.821 on that date.
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Treaty rules by country
Educational estimate only. This checker is for individuals and applies the published FBAR and Form 8938 thresholds to the figures you enter; it does not assess companies, partnerships, LLCs, trusts or estates. It does not decide whether a particular account or asset is reportable, whether an exception applies, or how a penalty would be assessed. For missed filings, speak to a qualified tax professional before choosing a compliance option. Full disclaimer.