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 50% of the account balance per year (wilful). In this guide, we explain exactly who must file, what accounts must be reported, the deadlines, and how to stay compliant.
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:
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- 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 (per account per year)
- 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 offer a zero-penalty pathway to catch up, provided your non-compliance was non-wilful.
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