The Foreign Bank Account Report (FBAR) — formally FinCEN Form 114 — is one of the most significant compliance obligations for US citizens and green card holders living in the UK. Failure to file can result in penalties of up to $10,000 per violation (non-wilful) or the greater of $100,000 or 50% of the account balance (wilful). In this guide, we explain exactly who must file, what accounts must be reported, the deadlines, and how to stay compliant.
Quick answer — who must file an FBAR? A US person — including a US citizen or green card holder living in the UK — must file an FBAR (FinCEN Form 114) if they had a financial interest in, or signature authority over, foreign financial accounts whose combined highest balances exceeded $10,000 at any time during the calendar year.
- How it is filed: electronically through FinCEN’s BSA E-Filing System — not with your tax return.
- When: due 15 April, with an automatic extension to 15 October.
- Related form: FATCA Form 8938 is filed with your tax return and has much higher thresholds for people living abroad. FATCA guide.
- Need it done for you? We prepare FBARs alongside your US tax return.
Who Must File an FBAR?
You must file an FBAR if you are a US person (citizen, green card holder, or resident) who:
- Had a financial interest in, or signature authority over, one or more foreign financial accounts
- The aggregate maximum value of all foreign accounts exceeded $10,000 at any point during the calendar year
The $10,000 threshold is aggregate — if you have three UK bank accounts each with £4,000 in them, the total ($12,000+ equivalent) exceeds the threshold and all three accounts must be reported.
What Accounts Must Be Reported on the FBAR?
The FBAR covers a wider range of accounts than many people expect:
- UK current accounts and savings accounts
- UK ISAs (including cash ISAs and stocks & shares ISAs)
- UK investment accounts and brokerage accounts
- Joint accounts (where you have either ownership or signatory authority)
- Business accounts of a foreign company if you have signatory authority
- Foreign pension accounts (though an exception may apply to certain UK registered pensions — take advice)
- Life insurance policies with a cash surrender value held with a foreign insurer
Notably, UK workplace pension plans (such as NEST or defined benefit schemes) involve complex reporting questions. The FBAR treatment depends on the structure of the pension and whether an exemption applies under IRS Notice 2020-2 or the US-UK Tax Treaty.
FBAR Filing Deadlines 2026
- April 15, 2026 — Original FBAR due date for 2025 tax year
- October 15, 2026 — Automatic extension (no form required to request the extension)
The FBAR is filed electronically via the FinCEN BSA E-Filing System — it is not attached to your tax return. This is a separate system operated by the Financial Crimes Enforcement Network (FinCEN), not the IRS.
FBAR vs. FATCA Form 8938: What Is the Difference?
Many US expats confuse the FBAR with FATCA Form 8938. Both require disclosure of foreign assets, but they are different filings with different thresholds and scopes:
| Feature | FBAR (FinCEN 114) | FATCA (Form 8938) |
|---|---|---|
| Who files with | FinCEN (separate system) | IRS (with tax return) |
| Threshold (abroad) | $10,000 aggregate | $200,000 on last day / $300,000 at any point (single) |
| What is covered | Financial accounts only | Broader foreign financial assets |
| Penalty for non-filing | Up to $10,000 / year (non-wilful) | $10,000 per form per year |
If you must file one, you typically must file both. They are complementary, not alternatives.
FBAR Penalties: What You Risk by Not Filing
- Non-wilful penalty: Up to $10,000 per violation, as adjusted annually for inflation (per annual report, not per account, following Bittner v. United States (2023))
- Wilful penalty: Greater of $100,000 or 50% of the account balance per violation — and potential criminal prosecution
- Reasonable cause exception: Penalties may be waived if you can demonstrate reasonable cause for non-filing
If you have missed FBAR filings, the IRS Streamlined Foreign Offshore Procedures can allow eligible taxpayers living abroad to catch up without FBAR penalties, provided the non-compliance was non-wilful and the other eligibility conditions are met.
Missed FBARs? Your Options
If the IRS has not contacted you and you are not under examination, there are two main routes:
- Delinquent FBAR Submission Procedures — generally for people who reported all their income and paid all US tax due, but did not file FBARs.
- Streamlined Filing Compliance Procedures — for non-wilful taxpayers who also have unfiled or incorrect tax returns. See our IRS Streamlined Filing service.
Our FBAR Filing Service
We prepare current-year and late FBARs for Americans in the UK, usually together with the US tax return and any Form 8938, so balances, exchange rates and account lists are consistent. Send us an enquiry with the years involved, the number of accounts, and all your sources of income, and we will confirm the work required and a fee before any engagement.
Frequently Asked Questions
Is the $10,000 threshold per account?
No. It is the total of the highest balances of all your foreign accounts during the year. Several small UK accounts can together cross the threshold.
Do UK ISAs and savings accounts count?
UK bank, savings, ISA and investment accounts are generally foreign financial accounts for FBAR purposes. UK pensions need a case-by-case review.
Do I file the FBAR with my tax return?
No. The FBAR is filed separately with FinCEN through the BSA E-Filing System. Form 8938, by contrast, is attached to your tax return.
I hold a joint account with my non-US spouse. What do I report?
Under the FBAR instructions, a US person who jointly owns a foreign account generally reports the full value of the account, not just their share.
Related Services and Resources
- Complete FBAR Filing Guide — in-depth resource on our cornerstone guides page
- FATCA Reporting Guide
- US Expat Tax Services — annual compliance including FBAR preparation
- IRS Streamlined Filing Guide — for those with missed FBAR filings