FATCA for Americans in Europe: What to Report (FBAR vs 8938)

If you are an American with a bank account in Europe, you may owe two reports. The FBAR (a Bank Secrecy Act form filed with FinCEN) is due once your foreign accounts' highest balances, added together, top $10,000 for the year. FATCA's Form 8938, filed with your tax return, applies only above much higher thresholds, such as $200,000 at year-end for a single filer living abroad.

FATCA also explains why European banks hand you a W-9, ask whether you are a US person, or turn you away. This guide covers both sides: what you report to the US government, and which banks and fintechs in Spain, Portugal and France still open accounts for Americans as of October 2026.

FATCA: what to report if you bank in Europe

Under FATCA, you report your specified foreign financial assets on Form 8938 if they pass the IRS thresholds. Separately, under the Bank Secrecy Act, you report your foreign accounts on the FBAR (FinCEN Form 114) if their highest balances add up to more than $10,000. These are two different laws, two different forms and two different agencies.

The IRS says the Form 8938 requirement "does not replace or change" your duty to file the FBAR, and that you need to check each form's rules to see whether you owe one, both or neither (IRS: Comparison of Form 8938 and FBAR requirements). The overlap is confusing enough that the IRS Taxpayer Advocate has recommended harmonizing the two (IRS Taxpayer Advocate Service). Until that happens, you deal with both.

In practice, most Americans with ordinary European bank accounts either owe nothing or owe an FBAR only. Form 8938 tends to apply to people with larger savings, investments or directly held foreign shares. These rules depend on your filing status and residence, so confirm your own case with the IRS website or a qualified US tax adviser.

Form 8938 thresholds: living abroad vs in the US

The FATCA requirements for individuals depend on your filing status and whether you count as living abroad. Americans who qualify as living abroad get Form 8938 thresholds four times higher than those living in the US.

The IRS states that a single filer living abroad must file Form 8938 if specified foreign financial assets exceed $200,000 at year-end, while a single filer living in the US hits the trigger at $50,000. Each threshold also has an "at any time during the year" figure (IRS: Summary of FATCA reporting for U.S. taxpayers; see also Hiltzik CPA):

Who counts as "living abroad"?

You count as living abroad only if your tax home is outside the US and you were either a bona fide resident of a foreign country for the full tax year or present abroad for at least 330 full days in 12 months. In the year you move, you may still fall under the US thresholds of $50,000 and $75,000. The IRS Form 8938 instructions set out this test in full.

How the FBAR $10,000 test works

The FBAR applies when your foreign accounts' maximum values, added together, exceed $10,000 for the calendar year (FinCEN: Report Foreign Bank and Financial Accounts; Arc & Ledger). Take each account's highest balance during the year and add them up, even if the peaks came in different months. The threshold is the same wherever you live.

To convert euros to dollars, find each account's highest balance in euros, then convert it using the US Treasury Reporting Rate of Exchange for December 31 of that year, even if the peak came earlier. Form 8938 also uses the Treasury year-end rate by default (IRS). Your bank's rate or the rate on the peak day does not count.

Rumors in 2025 and 2026 suggested new thresholds. The One Big Beautiful Bill Act, signed July 4, 2025, did not change the Form 8938 or FBAR dollar thresholds. The 2026 threshold changes that circulated online concern Forms 1099-K and 1099-MISC/NEC, not FATCA (Verni Tax Law).

Worked example: adding up your peaks

Say you are a single American, in your first full year abroad in Lisbon on a D7 visa. You keep a checking account and a savings account at a Portuguese bank. The figures below are already converted at the Treasury December 31 rate.

1. Your checking account peaks at $6,000 in January, when your US transfer lands.
2. Your savings account peaks at $5,000 in November.
3. Add the two peaks: $6,000 + $5,000 = $11,000. You must file an FBAR, even though no single day's combined total ever went over $10,000.
4. For Form 8938, your total is far below the $300,000 "any time" and $200,000 year-end thresholds for a single filer living abroad. No Form 8938.

This matches a common pattern: a single American in Spain with $15,000 in a euro account must file the FBAR but is far below the Form 8938 threshold (SettleGuru). Now change one fact. If you moved in July and do not yet meet the bona fide residence or 330-day test, the US thresholds apply. A $60,000 year-end balance would then trigger Form 8938, because it is over $50,000.

Now take a married couple filing jointly who have lived in Spain for years. They hold $380,000 in Spanish bank accounts and $70,000 in shares of a Spanish company held directly, not through a brokerage account. Year-end total: $450,000, which is over the $400,000 joint threshold abroad. They file Form 8938 and the FBAR. The directly held shares go on Form 8938 only, because the FBAR covers accounts, not assets held outside an account.

Form 8938 vs FBAR: do you need to file both?

You may need to file both, one, or neither. The FBAR has a low threshold and covers accounts. Form 8938 has high thresholds, covers a broader range of assets, and only applies if you file a US tax return.

What is Form 8938?

Form 8938, Statement of Specified Foreign Financial Assets, is the IRS form created under FATCA. It is due with your annual income tax return, including extensions, and you file it with the IRS (IRS). The IRS gives directly held foreign stock and partnership interests as examples of assets that go on Form 8938 but not on the FBAR.

You only file Form 8938 if you have to file a US income tax return for that year. If you don't, you don't file Form 8938, even above the threshold. The FBAR has no such exception. If you earn a salary or remote income while abroad, you can estimate how much of it the foreign earned income exclusion may cover with our FEIE calculator.

Deadlines and penalties

The FBAR is due April 15, with an automatic extension to October 15 (FinCEN). The FBAR for 2025 accounts was due April 15, 2026, extended to October 15, 2026, and that date has now passed. The FBAR for 2026 accounts is due April 15, 2027, with the same automatic extension to October 15, 2027 (Arc & Ledger).

The penalty for failing to file Form 8938 is $10,000. If you still have not filed 90 days after an IRS notice, another $10,000 accrues for each 30 days, capped at an extra $50,000, for $60,000 in total (IRS; Arc & Ledger). FBAR penalties are set separately and adjusted for inflation each year, so check the current figure with FinCEN or the IRS. For the filing screens step by step, see our FBAR guide for Americans in Europe.

Joint accounts, pensions, real estate and fintechs: what counts?

Joint accounts and accounts you can sign on count for the FBAR, foreign pensions generally go on Form 8938, and foreign real estate you own directly does not. Fintech accounts count if a non-US entity holds them.

• Joint account with a non-US spouse: you count the full account value toward your FBAR total and report it. Signature authority over an account, such as a parent's account you can sign on, also counts (IRS).
• Foreign real estate: a Spanish or Portuguese apartment you own directly does not go on Form 8938. Rental income still goes on your tax return. Our guide to buying property in Portugal as an American covers the purchase side.
• Foreign pensions: these generally go on Form 8938 if you are over the threshold. Confirm with the IRS Form 8938 instructions.
• Wise and Revolut: these count for the FBAR when a non-US entity holds the account (see the FAQ on Wise and Revolut below).

Why do European banks refuse Americans?

European banks refuse Americans mainly because of FATCA's reporting burden. Every US client means extra paperwork, extra reporting and extra risk, and some banks decide it is not worth it.

Under FATCA, foreign banks must identify accounts held by US persons and report them to their local tax authority, which passes the data to the IRS. Banks that do not comply face 30% withholding on US-source income (Easy France Now). That is why a European bank asks you for a W-9 or a self-certification form. Signing it confirms your US status so the bank can report your account. It does not file anything for you.

The result is uneven. One branch may welcome you while another branch of the same bank says no, and online banks are often stricter than traditional ones. Our guide to foreigner banking restrictions in Europe covers the broader rules for non-EU customers.

Which banks accept US citizens in Europe?

Several large banks in Spain, Portugal and France still accept US citizens as of October 2026, and Wise accepts Americans with a euro IBAN. Policies change often, so ask the bank directly before you visit.

Spain

In Spain, Santander, CaixaBank, BBVA and Sabadell all open non-resident accounts with a passport, and Sabadell is widely reported as the most willing to work with Americans (Greenback Tax Services). Expect the bank to also ask for a non-resident certificate or NIE. Our guide to retiring in Spain as an American explains where a Spanish account fits into the visa process.

Portugal

Portugal's most reliable options for Americans in 2026 are reported as Millennium BCP, ActivoBank (fully online), Bison Bank and Atlântico Europa (Portugalguru). Portugalguru says Banco BPI is closing American accounts and that Caixa Geral de Depósitos and Novo Banco are hit-or-miss, while other guides describe BPI as American-friendly. Call ahead. Many D7 applicants need a Portuguese account early, which our Portugal D7 visa guide covers.

France

In France, BNP Paribas and Société Générale are described as the most consistently accessible traditional banks for Americans (The Connexion). French law gives anyone legally resident in France a right to an account. If a bank refuses you, it must give a written refusal, and you can ask the Banque de France to designate a bank that must open a basic account.

If you are tax resident in France, you also declare your US accounts each year on form 3916 with your French return. Confirm the details with the French tax authority at impots.gouv.fr.

Fintechs (and what we could not confirm for Germany and the Netherlands)

Wise accepts US citizens and gives a Belgian IBAN for euros. Revolut accepts US citizens through its US entity, which does not issue an EU IBAN, and N26 and bunq are listed as EU/EEA residents only (Statrys). Some guides say Revolut customers living in the EEA get a European IBAN, so check Revolut's own site.

N26 closed its US service on January 18, 2022 and now serves only customers based in mainland Europe, usually with documented EU/EEA residency (Wise). We did not find reliable bank-by-bank data for traditional German or Dutch banks, so ask before you book a branch appointment.

Is Chase closing accounts for Americans in Europe?

Chase has begun telling some customers in France that their accounts will close. Letters started arriving on October 1, 2026, saying checking, savings and attached credit cards will close in December (The Connexion). It is not clear how many customers in Europe are affected.

The Connexion ties the letters to the EU's CRD VI banking directive. CRD VI's new third-country banking rules (Article 21c) apply from January 11, 2027. Contracts entered into before July 11, 2026 are grandfathered, and the directive does not create a general ban on Americans in the EU holding US accounts (Goalseek.pt). A US bank may choose to close accounts, but EU law does not force every US bank to.

If you live in Europe, keep at least one US account and one local account. If you get a closure letter, open a replacement US account that accepts foreign addresses (or keep a valid US mailing address only where that is lawful and honest), and move direct deposits and autopays before the closing date.

How to open a European bank account as an American

You can often open a European account before you move, especially in Spain or with Wise. You will be asked about your US tax status either way.

1. Pick two or three banks from the lists above and confirm by email or phone that they currently open accounts for US citizens.
2. Gather your passport, proof of address, your US Social Security number for FATCA reporting, and in Spain your NIE or non-resident certificate if you have one.
3. Expect to sign a W-9 or a FATCA self-certification. Answer truthfully that you are a US person.
4. If you are resident in France and get refused, ask for the refusal in writing and take it to the Banque de France.
5. Open a Wise account as a backup so you can receive euros while a traditional account is pending.
6. Record each account's bank name, address and account number the day you open it. You will need them for your FBAR.

Common mistakes

Most problems come from misreading the thresholds or assuming one form covers the other.

• Thinking the $10,000 FBAR limit is per account. It is the total of all accounts' peaks. Three accounts that each peaked at $4,000 put you over.
• Looking only at December balances. The FBAR uses each account's highest balance during the year, added together.
• Converting at your bank's rate. Use the Treasury rate for December 31, applied to each account's peak.
• Calling the FBAR a FATCA form. It comes from the Bank Secrecy Act, and Form 8938 does not replace it.
• Using the abroad thresholds in your move year. Until you meet the bona fide residence or 330-day test, the US thresholds apply.
• Leaving out Wise or Revolut. An account held by a provider's non-US entity counts toward your FBAR total (see the FAQ below).
• Believing a new threshold rumor. As of October 2026, the FBAR and Form 8938 thresholds are unchanged.

Once your banking is sorted, look at investing. Many European funds create US tax problems, which our guide to how Americans in Europe should invest explains.

Frequently asked questions

Do I need to file an FBAR if my European account only has a few thousand dollars?

Add up the highest balance each account reached during the year. If that total is over $10,000, you file. One account that peaked at $3,000 with nothing else means no FBAR. But if a checking account peaked at $8,000 and a savings account at $3,000 in other months, your total is $11,000 and you file, even though no single day went over $10,000.

Do I report my Wise or Revolut balance as a foreign account?

Wise, Revolut and similar accounts count toward your FBAR total when the account is held by a non-US entity, for example Wise Europe SA in Belgium or Revolut's Lithuanian entity. What matters is the legal entity holding the account, not the currency. Check the entity shown in your account settings or terms. An account held by a provider's US entity is generally not foreign, even if it holds euros.

What happens if I missed FBAR or Form 8938 in prior years?

The main formal catch-up route is the IRS Streamlined Filing Compliance Procedures, for people whose missed filings were non-willful. In July 2026 the IRS removed the Delinquent FBAR Submission Procedures, which had let people whose income was fully reported file late FBARs without a penalty. You can still file a late FBAR with a reasonable-cause statement, but the IRS no longer promises that no penalty will be charged. Talk to a US tax professional first, and do not simply ignore the gap.

Does the FBAR deadline get extended if I file a tax extension?

The FBAR has its own automatic extension. It is due April 15 and extends automatically to October 15 without any request. For 2026 accounts, that means April 15, 2027, or October 15, 2027 at the latest. Form 8938 follows your tax return, so it moves with whatever extension applies to your return.

What does my bank do with the W-9 or self-certification form it asks me to sign?

The bank uses it to confirm you are a US person. Under FATCA, it then reports your account to its local tax authority, which passes the information to the IRS. Signing it does not replace your own reporting. You still file the FBAR and, if you pass the thresholds and file a tax return, Form 8938 yourself.

Does CRD VI ban Americans in the EU from keeping US bank accounts?

No. CRD VI's new third-country banking rules apply from January 11, 2027, and contracts entered into before July 11, 2026 are grandfathered. The directive does not create a general ban on Americans in the EU holding US accounts. Individual US banks may still choose to close accounts, as Chase has told some customers in France it will do in December 2026.

References

1. IRS: Comparison of Form 8938 and FBAR requirements
2. IRS: Summary of FATCA reporting for U.S. taxpayers
3. IRS: About Form 8938, Statement of Specified Foreign Financial Assets
4. IRS: Streamlined Filing Compliance Procedures
5. FinCEN: Report Foreign Bank and Financial Accounts
6. IRS Taxpayer Advocate Service: Purple Book, harmonize FATCA/FBAR reporting
7. French tax authority: impots.gouv.fr
8. The Connexion: Americans in France face bank closures linked to new EU ruling
9. Arc & Ledger: FBAR Filing 2026, Deadline, $10,000 Threshold and FATCA Rules
10. Hiltzik CPA: FBAR vs 8938
11. Verni Tax Law: OBBBA FATCA Threshold Changes 2026
12. SettleGuru: Form 8938 vs FBAR 2026
13. Easy France Now: French Bank Account for Americans
14. Greenback Tax Services: Banks in Spain for Americans
15. Portugalguru: FATCA-Friendly Portuguese Banks 2026
16. Statrys: How to Open a Bank Account in Europe 2026
17. Wise: N26 alternatives
18. Goalseek.pt: New EU Banking Law in 2027